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A le rt,
ROUTH CRABTREE OLSEN, P.S.
L.

4 Ai' 9: 53

Edward T. Weber, Esq., SBN 194963 Shahed Shahandeh, Esq., SBN 249668 Rosemary Nguyen, Esq., SBN 265322 1241 E. Dyer Road, Suite 250 Santa Ana, California 92705 Telephone (714) 277-4888 Facsimile (714) 277-4899 File No.: 24629 Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN DIEGO - EAST COUNTY REGIONAL CENTER FEDERAL NATIONAL MORTGAGE ASSOCIATION, PLAINTIFF,
VS.

) )

) Case No.37-2012-00034472-CL-UD-EC
COMPLAINT FOR UNLAWFUL DETAINER

)\ VERIFIED

) ) Action based on Code of Civil Procedure

DOUGLAS D. BRUNELLE, RENEE C. BRUNELLE and Does 1-50, inclusive, DEFENDANTS.

) Section 1161a ) Limited Civil [Does Not Exceed $10,000] ) )

Plaintiff alleges as follows: 1. Plaintiff, FEDERAL NATIONAL MORTGAGE ASSOCIATION, is a national

association qualified to do business in California and is the owner of the real property commonly described as 8535 PARADISE VALLEY ROAD UNIT 29, SPRING VALLEY, CA 91977, (hereinafter "Property") and is entitled to immediate possession. A copy of the legal description is attached hereto as Exhibit "A" and incorporated herein by reference. 2. This is the proper forum for trial of the within action, in that the Property sued upon herein

is located in the City of SPRING VALLEY, County of SAN DIEGO, California.

COMPLAINT FOR UNLAWFUL DETAINER

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3.
are,

nefendants, DOT Tr-J Ac D PRI TNPT LF IMNPF. C . RR T TNFILE and all other occupants on information and belief, individuals residing in the Property without permission or consent of

Plaintiff. 4. The true names and capacities, whether individual, corporate, associate or otherwise, of

Defendants sued herein as Does 1-50, inclusive, are unknown to Plaintiff at this time. Plaintiff is informed and believes and thereon alleges, that each Defendant sued herein by a fictitious name is in possession of the Property, and/or is in some manner responsible for the acts or omissions herein alleged. Plaintiff will ask leave of this Court to amend this Complaint to insert the true names and capacities of said Defendants when ascertained. 5. On April 20, 2012, Plaintiff acquired the Property at a duly conducted foreclosure sale and

obtained a Trustee's Deed Upon Sale in accordance with California Civil Code 2924 et. seq. and pursuant to the power of sale under the Deed of Trust executed and delivered by borrowers, DOUGLAS D. BRUNELLE, RENEE C. BRUNELLE or their predecessors. The title of the Property pursuant to the foreclosure sale has been duly perfected in Plaintiff's name. A true and correct copy of the recorded Trustee's Deed Upon Sale is attached hereto as Exhibit "B" and is incorporated herein by reference. 6. On May 15, 2012, Plaintiff caused to be served upon Defendant, and each of them, written

notice requiring them to quit and deliver up possession of the Property pursuant to California Code of Civil Procedure 1161a. A true and correct copy of the Notice to Vacate along with copies of the Proof of Service are attached hereto as Exhibit "C" and is incorporated herein by reference. 7. More than three (3) days have elapsed since the service of said notice, but Defendants have

failed and refused to deliver up possession of the Property as required by said notice and Defendants continue in possession without permission or consent of Plaintiff.

COMPLAINT FOR UNLAWFUL DETAINER

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8. Plaintiff is infnrrned and helieves and therenpnn alleges that the reasnnahle rental value of
the Property is $92.44 per day from the expiration of the Notice to Vacate and will continue to

accrue at said rate so long as Defendants continue to remain in possession of the Property. WHEREFORE, Plaintiff prays for judgment against Defendants as follows: 1. Restitution and immediate possession of the Property; 2. An order restoring the Property to Plaintiff;

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COMPLAINT FOR UNLAWFUL DETAINER

3. For damages in the amount of $92.44 per day, from the expiration of the Notice to Vacate, for each day Defendants continue in possession of the Property; 4. For costs of suit herein; and 5. For such other and further relief as the court deems just and equitable. DATED this 7/day of May, 2012 at Santa Ana, California.

Respectfully submitted,
ROUTH CRABTREE OLSEN, P.S.

Attorneys for Plaintiff By:

1-"T'AS A TIT% 'I" rrri 1C,1-1 VV /-1.11.1 1. VV

SHAHED SHAHANDEH, ESQ. ROSEMARY NGUYEN, ESQ.

1 2 3 4 5 6 7 8 9 10 allege that matters stated herein are true. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

VERIFICATION STATE OF CALIFORNIA, COUNTY OF ORANGE I am an attorney at law admitted to practice before all courts of the State of California and am an associate at the law firm of Routh, Crabtree, Olsen, P.S., attorneys for FEDERAL NATIONAL MORTGAGE ASSOCIATION, a party to this action. Such party is unable to make the verification because they are absent from the county aforesaid where such attorneys have their office and for that reason I make this verification for and on behalf of that party. I have read the foregoing document and know its contents. I am informed and believe and on that ground

Executed on May 2../ , 2012 at Santa Ana, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

By: EDWARD T. WEBER, ESQ. SHARED SHAHANDEH, ESQ. ROSEMARY NGUYEN, ESQ.

COMPLAINT FOR UNLAWFUL DETAINER