Ud Notice of Demurrer and Demurrer Redact

8/2/2019 Ud Notice of Demurrer and Demurrer Redact

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NOTICE OF DEMURRER AND DEMURRER TO UNLAWFUL DETAINER COMPLAINT

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SACRAMENTO

LIMITED JURISDICTION

ELAINE AND STEPHEN WEEKS 2004FAMILY TRUST

Plaintiff,v.

MOHAMMED S, ABRAHIM, SAMIRA M.ABRAHIM;and DOES 1 through 10, inclusive,

Defendants.

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Case No.: 12UD01426(Unlawful Detainer)

NOTICE OF DEMURRER ANDDEMURRER TO UNLAWFUL DETAINERCOMPLAINT; MEMORANDUM OFPOINTS AND AUTHORITIES INSUPPORT THEREOF; ANDDECLARATION OF MOHAMMED S.ABRAHIM

Filed concurrently with Request for JudicialNotice; [Proposed] Order; and Proof ofService

Hearing Date:Time:Dept.:

UD Complaint Filed: 02/15/2012

Related Case: 34-2010-00072095

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that on __________________________ or as soon thereafter as

the matter may be heard in Department 88 of the above-referenced Court, located at 301

Bicentennial Circle, Sacramento California 95826, Defendants

will, and hereby do, demur to Plaintiff ELAINE AND STEPHEN WEEKS 2004

FAMILY TRUST Unlawful Detainer Complaint on the following grounds:

1. Plaintiff ELAINE AND STEPHEN WEEKS 2004 FAMILY TRUST does not

have the legal capacity to sue pursuant to Code of Civil Procedure 430.10(b).


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NOTICE OF DEMURRER AND DEMURRER TO UNLAWFUL DETAINER COMPLAINT

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2. Since Plaintiff lacks standing to commence an unlawful detainer action against

Defendants as it fails the real party in interest requirement, the pleading does not state facts

sufficient to constitute a cause of action on behalf of the proper specific plaintiff pursuant to

Code of Civil Procedure 430.10(e).

This Demurrer is made pursuant to the provisions of Code Civil Procedure 430.10(b)

and 430.10(e), and is based upon this Notice; the attached memorandum of points and authorities;

declaration of Mohammed Abrahim -in support thereof; the concurrently-filed request for judicial

notice of Defendants Complaint court file; the records, files, and pleadings in this action; and

such further evidence and argument the Court may consider at hearing.

Respectfully submitted,

DATED: February 18, 2012

By ______________________________________

Mohammed Abdrahim


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TABLE OF CONTENT

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TABLE OF CONTENT

TABLE OF AUTHORITIES..... ii

MEMORANDUM OF POINTS AND AUTHORITIES... 1

STATEMENT OF FACTS ................................................. 1

SUMMARY OF ARGUMENT... 3

ARGUMENT... 4

I. DEFENDANTS MAY BASE THIS DEMURRER ON THEIRJUDICIALLY-NOTICEABLE WRONGFUL FORECLOSURECOMPLAINT........................................................................... 4

II. THIS GENERAL DEMURRER TO THE COMPLAINT MUST BESUSTAINED BECAUSE THE PLAINTIFF LACKS THE CAPACITY TO SUEPURSUANT TO CODE OF CIVIL PROCEDURE 430.10(b)......................... 4

III. THIS GENERAL DEMURRER TO THE COMPLAINT MUST BESUSTAINED BECAUSE THE UD COMPLAINT FAILS TOSTATE A CAUSE OF ACTION PURSUANT TO CODE OF CIVILPROCEDURE 430.10(e)... 7

CONCLUSION.. 7

DECLARATION OF MOHAMMED ABRAHIM IN SUPPORT OFDEFENDANTS DEMURRER TO UNLAWFUL DETAINER COMPLAINT........................... 9

[PROPOSED] ORDERFiled Separately

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRERFiled Separately

PROOF OF SERVICEFiled Separately


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TABLE OF AUTHORITIES

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TABLE OF AUTHORITIES

CALIFORNIA STATUTES:

Civil Code 2924Civil Code 2932.5Code of Civil Procedure 430.10(b)Code of Civil Procedure 430.10(e)Code of Civil Procedure 430.30Code of Civil Procedure 430.70Evidence Code 452Evidence Code 453

CASES:

Blank v. Kirwan (1985) 39 Cal.3d 311Color-Vue, Inc. v. Abrams (1996) 44 Cal.App.4th 1599County of Fresno v. Shelton (App. 5 Dist. 1998) 66 Cal.App.4th 996Parker v. Bowron, (1953) 40 Cal.2d 344Washington Mutual Bank v. Blechman (2007) 157 Cal.App.4th 662


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MEMORANDUM OF POINTS AND AUTHORITIESIN SUPPORT OF DEFENDANTS DEMURRERTO UNLAWFUL DETAINER COMPLAINT

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MEMORANDUM OF POINTS AND AUTHORITIES

STATEMENT OF FACTS

Plaintiffs Complaint provides that Defendants, as trustors, conveyed the subject property

at 3412 May Fair drive, Sacramento, CA 95864 (the Property or Home) to a Trustee by a

Deed of Trust executed and recorded in the Sacramento County Recorders Office on July 26,

2005 (Deed of Trust) to secure payment of said trustors Promissory Note. See, Plaintiffs

Complaint, 4(A). Thereafter, as alleged by Plaintiff, the Trustee of said Deed of Trust sold and

conveyed title to the Property to Plaintiff, ELAINE AND STEPHEN WEEKS 2004 FAMILY

TRUST, pursuant to the foreclosure and sale of the [Property], under the power of sale contained

in the Deed of Trust and in compliance with Civil Code 2924. Plaintiffs Complaint4(B).

On February 9, 2012, Plaintiff caused to be served a written 3/90-Day Notice stating that

Plaintiff had purchased the Property and demanded that all persons vacate the premises.

On February 22, 2011, Defendants filed an action for wrongful foreclosure in Sacramento

Superior Court, Unlimited Jurisdiction, Case No. 34-2010-00072095, naming California

Reconveyance and CHASE as one of the defendants (Defendants Wrongful Foreclosure

Complaint or Defendants Complaint or Defendants First Complaint); attached to the

concurrently-filed Request for Judicial Notice as Exhibit A). Concurrently with this Demurrer,

and in support thereof, Defendants request this Court to take judicial notice of Defendants

Wrongful Foreclosure Complaint pursuant to Evidence Code 452 and 453 and Code of Civil

Procedure 430.30 and 430.70.

Defendants Complaint includes claims for setting aside the Trustee Sale, canceling the

Trustees Deed, Quiet title, and declaratory and injunctive relief, while alleging, inter alia, the

following:

1) On or about July 26, 2005 Defendants entered into a written agreement withWashington Mutual Bank. for the financing of Defendants loan for the purchase of

their Home. Defendants for valuable consideration, as borrowers, made, executed, and


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delivered to Washington Mutual Bank. a written promissory note in the total amount of

$264,000.00.

2) To secure payment of the principle sum and interest as provided in the Note and as partof the same transaction, Defendants, as trustors, executed and delivered to Mortgage

Electronic Registration Systems, Inc. (MERS) as beneficiary, a Deed of Trust dated

September 14, 2006 (the Deed of Trust), by the terms of which Plaintiffs, as trustors,

conveyed to California Reconvenyance, as trustee, the Property. The Deed of Trust was

recorded on September 19, 2006.

3) On or about January 10, 2010, MERS assigned all beneficial interests under the Deedof Trust to California Reconvenyance Company (CRC) (hereinafter referred to as the

Assignment of Deed of Trust). Although executed in Jan 2010, the Assignment of

Deed of Trust was recorded only later, on August 26, 2010.

4) On or about Jan 12, 2010, Defendants CRC caused to be recorded a Notice of Defaultand Election to Sell on Defendants Property. Although CRC claimed to be either the

duly appointed Trustee, the substitute Trustee or acting as agent for Beneficiary under

[the Deed of Trust], no such indication is to be found in the Official Records in the

Office of the Recorder of Sacramento County, California.

5) On or about June 18, 2010, Defendants received a Notice of Trustee Sale from CRCstating that a Trustee Sale of the Property is set to take place on July 8, 2010.

6) On January 11, 2012, CRC conducted a Trustee Sale of the Property. The Property waspurportedly sold to Elaine and Stephen Weeks 2004 Family Trust., allegedly or

presumably, under the power of sale contained in the aforementioned Deed of Trust.

The Trustees Deed Upon Sale of the Property was recorded on January 26, 2012.

7) In their Wrongful Foreclosure Action, Defendants allege, inter alia, violations ofCalifornia law and Federal executive orders in improperly holding the sale of

Defendants Home and in wrongfully executing, delivering, and recording Trustees

Deed on the Property, as set forth below.


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On January 11, 2012, concurrently with Plaintiffs filing of their Complaint or immediately

thereafter, Elaine and Stephen Weeks 2004 Family Trust, the purported purchaser of the Property

in a Trustee Sale, filed this Unlawful Detainer action (UD Complaint) against Defendants.

On or about February 15, 2012, Defendants were served with Plaintiffs UD Complaint.

SUMMARY OF ARGUMENT

In their UD Complaint, Plaintiff explicitly held itself as an entity qualified to commence

this Unlawful Detainer action against Defendants. Plaintiffs Complaint 1. However,it appears

on the face of the UD Complaint and Defendants Complaint, which is judicially-noticeable

by this Court, that:

Plaintiff Elaine and Stephen Weeks 2004 Family Trust is not a real party in interest; Title

has not been perfected in Plaintiff since the title to the Property was not conveyed to Plaintiff

under the power of sale contained in the Deed of Trust and/or was not conveyed in compliance

with Civil Code 2924; Plaintiff Elaine and Stephen Weeks 2004 Family Trust lacks capacity and

standing to sue; and, Plaintiffs Complaint fails to state facts sufficient to constitute cause of

action on behalf of the proper specific plaintiff, pursuant to Code of Civil Procedure1 430.10(b)

and 430.10(e).

Therefore, Defendants Demurrer must be sustained without leave to amend and Plaintiffs

Complaint dismissed.

ARGUMENT

I

DEFENDANTS MAY BASE THIS DEMURRER ON THEIR JUDICIALLY-

NOTICEABLE WRONGFUL FORECLOSURE COMPLAINT

CCP 430.10 provides in pertinent part:


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The party against whom a complaint or cross-complaint has been filedmay object, by demurrer as provided in Section 430.30, to the pleadingon any one or more of the following grounds: (b) The person who

filed the pleading does not have the legal capacity to sue (emphasisadded).

In turn, CCP 430.30(a) states:

When any ground for objection to a complaint, cross-complaint, or answerappears on the face thereof, or from any matter of which the court isrequired to or may take judicial notice, the objection on that ground maybe taken by a demurrer to the pleading (emphasis added).

A demurrer may challenge the legal sufficiency of an opponent's pleading based on

defects that appear on the face of the pleading under attack and/or from matters outside the

pleading that are judicially noticeable. See, Blank v. Kirwan (1985) 39 Cal.3d 311, 318; County

of Fresno v. Shelton (App. 5 Dist. 1998) 66 Cal.App.4th 996, 1008-1009, as modified.

Concurrently with their Demurrer, Defendants are filing a Request for Judicial Notice of

said Wrongful Foreclosure Complaint pursuant to Evidence Code 452 and 453. Under CCP

430.30, Defendants may base their Demurrer on the judicially-noticed Wrongful Foreclosure

Complaint court file.

II

THIS GENERAL DEMURRER TO THE COMPLAINT MUST BE SUSTAINED

BECAUSE THE PLAINTIFF LACKS THE CAPACITY TO SUE

PURSUANT TO CODE OF CIVIL PROCEDURE 430.10(b)

Plaintiff Elaine and Stephen Weeks 2004 Family Trust filed this UD Complaint on or

about Feb 15, 2012, concurrently with or immediately after Defendants filed their Wrongful

Foreclosure Complaint naming CRC as defendant. Defendants Complaint alleges the following:

CRC had no legal capacity to commence, execute, or cause to be executed a Trustee Sale.

As a result of the Office of Thrift Supervisions March 19, 2009 Order, which appointed the FDICas the receiver for MERS, MERS became an inactive institution and no longer in existence on

January 26, 2012. MERS, a defunct corporation, had no authority and legal capacity to initiate a

trustee sale as of January 26, 2012. The only one who had such authority was the receiver, FDIC;


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Since MERS was unauthorized to conduct a trustee sale, its purported agents, CRC were

unauthorized to do so as well;

Also, CRC issued an unauthorized Notice of Default and Election to Sell as CRC did so

before the Assignment of Deed was duly acknowledged and recorded, as required by Civil Code

2932.5;

CRC was never dully appointed as a substitute Trustee and nonetheless acted as such;

CRC thus failed to comply with or misrepresented their compliance with the requirements

under Civil Code 2924 as they were not authorized to conduct a Trustee Sale and unlawfully

issued a Notice of Default and Election to Sell, a prerequisite thereto;

Since the underlying sale was unlawful, the Trustees Deed Upon Sale delivered to Elaine

and Stephen Weeks 2004 Family Trust is invalid and void. Further, Elaine and Stephen Weeks

2004 Family Trust is still subject to any deficiencies in the underlying Trustee Sale because Elaine

and Stephen Weeks 2004 Family Trust is not a bona fide purchaser, as it was already the

beneficial owner of the underlying obligation, whatever that might be and as such, did not

exchange any consideration for the so called Trustees Deed; Elaine and Stephen Weeks 2004

Family Trust did not acquire any interest in the property through a sale; did not pay fair

consideration or for that matter did not pay any consideration; was not a bona fide purchaser; had,

at all times, notice both actual and constructive of defects in the underlying Note, Deed of Trust

and the defects on the on the face of the documents recorded in the public records;

More specifically, Elaine and Stephen Weeks 2004 Family Trust had constructive notice of

the defects alleged by Defendants because the chain of title of the Property in the Official Records

in the office of the Recorder of San Mateo County, California clearly shows that a Notice of

Default was recorded before Power of Sale ever vested in CRC, i.e. before the Assignment of

Deed of Trust was duly acknowledged and recorded (Civil Code 2932.5). Further, Elaine

and Stephen Weeks 2004 Family Trust cannot be said to qualify as a bona fide purchaser without

notice since CRC serves as a Servicer of CHASE, which may indicate that the transfer of the

Property from CHASE to Elaine and Stephen Weeks 2004 Family Trust was part of a well


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calculated scheme between CRC and Elaine and Stephen Weeks 2004 Family Trust to sanitize the

Note..

In light of the foregoing in Defendants Complaint and attachments thereto, which are

judicially-noticeable, it appears title to the Property was not conveyed to Plaintiff under the power

of sale contained in the Deed of Trust and/or was not conveyed in compliance with Civil Code

2924. Thus, title has not been perfected in Plaintiff and Plaintiff is not a real party in interest.

A plaintiff lacks standing to sue if it not is a real party in interest. See, e.g., Washington

Mutual Bank v. Blechman (2007) 157 Cal.App.4th 662, 669 [citing Color-Vue, Inc. v. Abrams

(1996) 44 Cal.App.4th 1599, 1604]. Plaintiffs lack of legal standing is pertinent to the question

whether Plaintiffs UD Complaint sufficiently states a cause of action, see infra.

There is a difference between the capacity to sue, which is the right to come into court, and

the standing to sue, which is the right to relief in court (see Color-Vue, Inc. v. Abrams, id), in the

instant case Plaintiff Elaine and Stephen Weeks 2004 Family Trust also lacks the capacity to sue

as Elaine and Stephen Weeks 2004 Family Trust is subject to any deficiencies in the underlying

Trustee Sale and its alleged-predecessor in interest, CRC, which similarly lacks such legal

capacity.

Therefore, Plaintiff falls squarely within the objectionable grounds stated in CCP

430.10(b). Accordingly, Plaintiffs Complaint cannot stand and must be dismissed.

III

THIS GENERAL DEMURRER TO THE COMPLAINT MUST BE SUSTAINED

BECAUSE THE UD COMPLAINT ALSO FAILS TO STATE A CAUSE OF ACTION

PURSUANT TO CODE OF CIVIL PROCEDURE 430.10(e)

CCP 430.10 provides in pertinent part:

The party against whom a complaint or cross-complaint has been filedmay object, by demurrer to the pleading on any one or more of thefollowing grounds: (e) The pleading does not state facts sufficient to

constitute a cause of action (emphasis added).

A general demurrer should be sustained if a party is not the proper party to bring suit. See

Parker v. Bowron, (1953) 40 Cal.2d 344, 350-351.


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Here, the pleading does not meet the cause of action requirement because plaintiff lacks

standing to sue, as Plaintiff is not a real party in interest (see, supra). This is also why Plaintiffs

ability to state a claim is stymied.

Therefore, the Court cannot move forward with the merits of the case and Defendants

Demurrer should be sustained without leave to amend.

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CONCLUSION

FOR THE FOREGOING REASONS, Defendants respectfully request that this Court

sustain Defendants Demurrer without leave to amend.

Respectfully submitted,

Dated: February 18, 2012


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PROPOSED ORDER

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DECLARATION OF MOHAMMED ABRAHIM IN SUPPORT OF

DEFENDANTS DEMURRER TO UNLAWFUL DETAINER COMPLAINT

I, Mohammed Abrahim, hereby declare the following:

1. I have personal knowledge of the facts contained in this declaration and if called asa witness, I could and would testify competently to these matters under oath.

2. Defendants filed an action for wrongful foreclosure in Sacramento Superior Court,

Unlimited Jurisdiction, on February 22, 2011 alleging, inter alia, violations of California law and

Federal executive orders in improperly holding the sale of Defendants Home and in wrongfully

executing, delivering, and recording Trustees Deed on Defendants Property.

3. On February 16, 2012, the purchaser of the Property in the Trustee Sale, Elaine and

Stephen Weeks 2004 Family Trust, filed an Unlawful Detainer action against Plaintiffs in

Sacramento Superior Court, Limited Jurisdiction.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct. Executed on February 19, 2012 at Sacramento, California.

______________________

Declarant


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PROPOSED ORDER

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FOR THE COUNTY OF SACRAMENTO

LIMITED JURISDICTION


Plaintiff,v.

MOHAMMED S, ABRAHIM, SAMIRA M.ABRAHIM;and DOES 1 through 10, inclusive,

Defendants.

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Case No.: 12UD01426

[PROPOSED] ORDER

Date:Time:Dept:

Complaint Filed: 02/15/2012

Related Case: 34-2010-00072095(Unlimited)

TO ALL PARTIES AND THEIR COUNSELS OF RECORD:

IT IS HEREBY ORDERED THAT:

Defendants Demurrer to the Unlawful Detainer Complaint is hereby sustained without

leave to amend.

IT IS FURTHER ORDERED THAT:

_______________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

DATE: _________________________ __________________________________

Judge of the Superior Court


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PROPOSED ORDER

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FOR THE COUNTY OF SACRAMENTOLIMITED JURISDICTION


Plaintiff,v.

MOHAMMED S, ABRAHIM, SAMIRA M.

ABRAHIM;and DOES 1 through 10, inclusive,

Defendants.

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Case No.: 12UD01426(Unlawful Detainer)

PROOF OF SERVICE OF DEFENDANTSNOTICE OF DEMURRER ANDDEMURRER; MEMORANDUM OFPOINTS AND AUTHORITIES IN

SUPPORT THEREOF; DECLARATIONOF MOHAMMED ABRAHIM ;[PROPOSED] ORDER; REQUEST FORJUDICIAL NOTICE IN SUPPORT OFDEFENDANTS DEMURRER TOUNLAWFUL DETAINER COMPLAINT;AND EXHIBIT A

Hearing Date:Time:.Dept.:

UD Complaint Filed: 2/15/2012

Related Case: 34-2010-00072096


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PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF SACRAMENTO

I am employed in the County of Sacramento, State of California. I am over the age of 18

and not a party to the within action. My business address is9091 Devon Crest, Elk Grove, Sacramento, CA 95624

On Feb 20, 2012, I served the following document described asDEFENDANTSNOTICE OF DEMURRER AND DEMURRER; MEMORANDUM OF POINTS ANDAUTHORITIES IN SUPPORT THEREOF; DECLARATION OF MOHAMMEDABRAHIM ; [PROPOSED] ORDER; REQUEST FOR JUDICIAL NOTICE IN SUPPORTOF DEFENDANTS DEMURRER TO UNLAWFUL DETAINER COMPLAINT; ANDEXHIBIT Aon all interested parties in this action by placing [X] a true copy [ ] the original thereof enclosed

in sealed envelopes addressed as follows:

SEE ATTACHED SERVICE LIST[ ] (BY FACSIMILE) The facsimile machine I used complied with Rule 2003(3) and no error

was reported by the machine. Pursuant to Rule 2008(e)(4), I caused the machine to print arecord of the transaction.

[X] (BY MAIL, 1013a, 2015.5 C.C.P.)

[ ] I deposited such envelope in the mail at Sacramento, California. The envelope wasmailed with postage thereon fully prepaid.

[ ] I am readily familiar with the firms practice for collection and processingcorrespondence for mailing. Under that practice, this document will be deposited with the U.S.

Postal Service on this date with postage thereon fully prepaid at Sacramento, California in theordinary course of business. I am aware that on motion of the party served, service is presumedinvalid if postal cancellation date or postage meter date is more than one day after date of depositfor mailing in affidavit.

[ ] (BY PERSONAL SERVICE) I caused the foregoing envelope to be delivered by hand tothe addressee on the attached Service List.

[ ] (BY FEDERAL EXPRESS ) I caused the foregoing envelope to be delivered by xxxxFEDEX

[X] (STATE) I declare under penalty of perjury under the laws of the State of California thatthe above is true and correct.

[ ] (FEDERAL) I declare that I am employed in the office of a member of the bar of thisCourt at whose direction the service was made.

Executed on Feb 19, 2012, Sacramento California._______________________________


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SERVICE LIST

Attorney(s) for Plaintiff, ELAINE AND STEPHEN WEEKS 2004 FAMILY TRUST

SID M ROSENBERG & LINK

AN ASSOCIATION OF PROFESSIONAL LAW CORPORATION

725 30TH

STREET STE 107

SACRAMENTO, CA 95816

Documents

Ud Notice of Demurrer and Demurrer Redact