Case 5:16-cv-01518-JGB-DTB Document 29-1 Filed 09/08/16 Page 1 of 3 Page ID #:232

1 McCARTHY & HOLTHUS, LLP

Melissa Robbins Coutts, Esq. (SBN: 246723)
2 Leticia “Tia” Butler, Esq. (SBN: 253345)
1770 Fourth Avenue
3 San Diego, CA 92101
Quality Loan Service Corporation
4 Telephone: (619) 685-4800
Facsimile: (619) 685-4811
5
Attorneys for Defendant,
6 QUALITY LOAN SERVICE CORPORATION, erroneously sued as QUALITY
LOAN SERVICING
7

8
UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA - RIVERSIDE
10

11
McCARTHY & HOLTHUS, LLP

TELEPHONE (619) 685-4800 FACSIMILE (619) 685-4810

12 SOCORRO DIAZ & FRANCISCO Case No. 5:16-cv-01518-JGB-DTB

DIAZ,
ATTORNEYS AT LAW
SAN DIEGO, CALIFORNIA 92101

13
Plaintiffs, DECLARATION OF LETICIA
1770 FOURTH AVENUE

BUTLER RE: L.R. 7-3 IN SUPPORT

14 OF QUALITY LOAN SERVICE
vs. CORPORATION’S NOTICE OF
15 JOINDER AND JOINDER IN GB
GB INLAND PROPERTIES, LLC
16 and/or its successors and/or assignees in INLAND
MOTION
PROPERTIES, LLC’S
TO DISMISS
intrest; THE BANK OF NEW YORK
17 MELLON AS TRUSTEE FOR
STRUCTURED ASSET MORTGAGE Date: Time:
September 26, 2016
9:00 a.m.
18 INVESTMENTS II, INC., Courtroom: 1
MORTGAGE PASS THROUGH
19 CERTIFICATES SERIES 2005-AR8;
NATION STAR MORTGAGE; Complaint Filed: July 12, 2016
20 CONTINENTAL HL-011 TRUST; Trial Date: Not Set
RAFAEL PEREZ; QUALITY LOAN
21 SERVICING; PLATINUM CAPITAL
GROUP and DOES 1 through 100,
22 inclusive ,

23 Defendants.

24

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28 ///
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DECL. OF COUNSEL RE: L.R. 7-3 IN SUPPORT OF JOINDER TO MOTION TO DISMISS
 Case 5:16-cv-01518-JGB-DTB Document 29-1 Filed 09/08/16 Page 2 of 3 Page ID #:233

1 I, Leticia Butler, declare as follows:

2 1. I am an attorney at law, duly licensed to appear in all courts in the state
3 of California. I am an attorney with the law firm of McCarthy & Holthus, LLP,
4 counsel of record for Defendant Quality Loan Service Corporation, erroneously
5 sued as Quality Loan Servicing (“Quality”).
6 2. On August 24, 2016, I attempted to reach the Plaintiffs in this matter
7 by telephoning them at 951.733.3401 which is the telephone number set forth in the
8 complaint. After ringing several times, I was transferred to a voicemail box where I
9 proceeded to leave a message identifying myself, my client, my telephone number,
10 explained that it was my intent to file a motion to dismiss, explained our obligation
11 to meet and confer in advance of my doing so, and asked for a return call.
McCARTHY & HOLTHUS, LLP

TELEPHONE (619) 685-4800 FACSIMILE (619) 685-4810

12 3. On September 7, 2016, I once again attempted to reach the Plaintiffs at

the above-referenced telephone number. Once again, I reached voicemail and left a
ATTORNEYS AT LAW
SAN DIEGO, CALIFORNIA 92101

13
1770 FOURTH AVENUE

14 message for the Plaintiffs.

15 4. Thereafter, also on September 7, 2016, I reviewed the court docket,
16 more specifically, the declaration of counsel for GB Inland Properties, LLC (Docket
17 No. 28) wherein counsel details her unsuccessful efforts to meet and confer with
18 Plaintiffs.
19 5. Having received no return call from the Plaintiffs, and together with
20 seeing GB Inland Properties, LLC was similarly unable to connect with Plaintiffs
21 for the purpose of a pre-motion conference, I concluded that continued efforts in
22 this regard would likely be futile and elected to join in the motion to dismiss that is
23 pending before this Court.
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28 ///
2
DECL. OF COUNSEL RE: L.R. 7-3 IN SUPPORT OF JOINDER TO MOTION TO DISMISS
 Case 5:16-cv-01518-JGB-DTB Document 29-1 Filed 09/08/16 Page 3 of 3 Page ID #:234

1 I declare under the penalty of perjury under the laws of the State of California
2 that the foregoing is true and correct. This declaration is executed on this 8 Day of
3 September, 2016, at San Diego, California.
4 Dated: September 8, 2016 Respectfully submitted,
McCARTHY & HOLTHUS, LLP
5

6 By: /s/ Leticia C. Butler

Leticia C. Butler, Esq.
7
Attorney for Defendant,
8 Quality Loan Service Corporation,
erroneously sued as Qualtiy Loan
9
Servicing
10

11
McCARTHY & HOLTHUS, LLP

TELEPHONE (619) 685-4800 FACSIMILE (619) 685-4810

12
ATTORNEYS AT LAW
SAN DIEGO, CALIFORNIA 92101

13
1770 FOURTH AVENUE

14

15

16

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18

19

20

21

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24

25

26

27

28
3
DECL. OF COUNSEL RE: L.R. 7-3 IN SUPPORT OF JOINDER TO MOTION TO DISMISS