1 John R.
Casrto
630 East Market Street B
2 Salinas, California 93905
3 (831)525-1002
johnc630.jc@icloud.com
4 appearing in Propia-Persona
as suri-juris pro-se
5
7 UNITED STATES DISTRICT COURT
8 NORTHERN DISTRICT OF CALIFORNIA
9
10 JOHN R. CASTRO Case No.: 20-cv-01090-BLF
Plaintiff,
11 AMENDED VERIFIED
vs.
12 COMPLAINT FOR DAMAGES &
John Pascual
EQUITABLE RELIEF:
13 Conie Legaspi
14 1. WRONGFUL FORECLOSURE;
Ronald Alonzo
2. BREACH OF CONTRACT;
15 QUALITY LOAN SERVICE
3. NEGLIGENCE;
16 CORPORATION;
Mellissa Robbins Coutts,Esq.
17
Jennifer C. Wong Esq.
18 La Vonne M. Phillips Esq.
McCARTHY & HOLTHUS, LLP
19
JPMORGAN CHASE BANK, N.A.
20
La 'Wanda J. Flowers; V..P. Chase
21 LaKesha M. Sellers V.P. Chase
22 CHAMPERY RENTALS REO LLC;
Sam Chandra Esq. AND LEAVE TO AMEND
23
24
Defendants.
25
26
27 COMES NOW Plaintiff JOHN RAYMOND CASTRO aka John R. Castro (hereinafter “Plaint iff”),
28 hereby alleges the following based on his personal knowledge and belief;
1
AMENDED VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
20-cv-01090-BLF
1. Plaintiff is the rightful owner and beneficial Grant Deed title holder of this Property
and since 07/2009 has resided on property in the county of Monterey, State of
California.
1 2. The subject real property is situated in the County of Monterey , State of California
2 and is commonly described as 630 East Market Street, Salinas, CA 93905 (the
3 “Property”).
4
3. WAMU, (not a party to the claim) was the acting Lender which appointed
5
CALIFORNIA RECONVEYANCE COMPANY as trustee, (see exhibit ).
6
7 4. JPMORGAN CHASE BANK, N.A. (hereinafter "CHASE") is conducting business in the
8 county of Monterey, State of California.
9 5. "CHASE" principal place of business is in Dallas, Texas and therefore Diversity of
10
Citizenship is present.
11
12 6. La'Wanda J. Flowers and LaKesha M. Sellers, are believed and known to be agents
13 of "CHASE", and conducting business in Monterey County, State of California.
14 7. Defendant, "CHASE" claims rights to service Plaintiffs’ Loan. A bank entity acting as
15 a servicer, that transmits REMIC payments to investors of mortgaged-backed securities.
16
8. Plaintiff is informed and believes, and herein alleges, that Defendant QUALITY
17
LOAN SERVICE CORPORATION (hereinafter “QLS”), is the acting trustee of
18
Plaintiffs’ Loan.
19
20 9. "QLS" and it's agents herein believed and known to be, John Pascual, Conie Legaspi,
21 Ronald Alonzo are Defendants relevant to this Claim, and conducting business in the
22 County of Monterey, State of California.
23
10. Plaintiff is informed and believes, and herein alleges, that Defendants McCARTHY &
24
HOLTHUS and agents Mellissa Robbins Coutts,Esq., Jennifer C. Wong Esq., La Vonne
25
M. Phillips Esq. are conducting business in Monterey County, State of California.
26
27 11. Plaintiff is informed and believes, and herein alleges, that Defendant CHAMPERY
28 RENTALS REO LLC. is conducting business in Monterey County, State of California.
12.
servants, employees, or employers and with the permission and consent of their Co-
13. 2
DefenAdMaEntNsD. ED VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
14.
YOUR NAME
Street Address
City, State Zip
Phone Number (with area code)
Email Address (If applicable)
Self-Represented
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF
NAME OF PETITIONER/PLAINTIFF, ) Case No.:
Petitioner/Plaintiff, )
v. ) DOCUMENT NAME (e.g. , STIPULATION
NAME OF RESPONDENT/DEFENDANT, ) AND ORDER RE. PROPERTY DIVISION)
Respondent/Defendan )
t )
)
)
)
)
DOCUMENT NAME (e.g., STIPULATION AND ORDER) - 1
1
4 FACTUAL ALLEGATIONS
5
6
10.
8 11. On or about October 28, 2006, Plaintiff executed a negotiable promissory note and a
9 9*security interest in the form of Deed of Trust (“DOT”) in the amount of $150,000.00
10 (Exhibit A)./
11 12. Throughout the life of the loan, Plaintiffs have maintained payments to JPMORGAN.
12 13. Plaintiffs made monthly payments until March 2018, when JPMORGAN unilaterally
13 decided to stop accepting payments from Plaintiffs for no valid reason.
14 14. After no longer accepting payments from Plaintiffs, JPMORGAN and QUALITY recorded a
15 “Notice of Default and Election to Sell Under the Deed of Trust” (“NOD”) as document number
16 2018-K600027-00 in the San Francisco County Recorder’s office on April 11, 2018 (Exhibit
17
B).
18 15. Plaintiffs attempted to negotiate with JPMORGAN until December of 2018, to cure
19 JPMORGAN’s wrongdoing and reinstate the loan, which JPMORGAN refused to do.
20 16. Plaintiffs are informed and believe that JPMORGAN realized their wrongdoing and
21 attempted to correct the wrongful recording of the 4.11.18 NOD by recording a “Rescission of
22 Notice of Default and Election to Sell Under Deed of Trust” as document number 2019-
23 K720456-00 in the San Francisco County Recorder’s office on January 11, 2019 (Exhibit C).
24 17. After failing to come to agreement, Defendants JPMORGAN and QUALITY then recorded
25 another “Notice of Default and Election to Sell Under the Deed of Trust” (“NOD”) as document
26 number 2019-k737506-00 on February 27, 2019 (Exhibit D).
27
18. Defendants are attempting to conduct a wrongful non-judicial foreclosure.
28
3
AMENDED VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 4 of 55
1
FIRST CAUSE OF ACTION
2 BREACH OF CONTRACT
3 (Asserted against JPMORGAN)
4 18. Plaintiffs hereby allege and incorporate herein by reference, all paragraphs contained in this
5 complaint as if the same were fully set forth at length herein.
6 19. Plaintiffs entered into a loan contract and Promissory Note with JPMORGAN on January 15,
7 2015.
8 20. Plaintiffs made timely payments throughout the life of the loan until JPMORGAN stopped
9 accepting Plaintiffs payments in March 2018, as evidence by Plaintiffs’ February 2018
10 statement from JPMORGAN (Exhibit E).
11 21. This action by JPMORGAN to refuse accept payment, led Plaintiffs going into default,
12 which goes against the terms of the contract as JPMORGAN is the servicer and loan
13 originator of the loan. JPMORGAN’s duty is to accept payments from Plaintiffs and apply
14 towards the principal.
15 22. JPMORGAN breached this contract by refusing to accept payments from Plaintiffs.
16 23. After refusing to accept payment in March, Defendants quickly recorded a Notice of Default
17 number on April 11, 2018.
18 24. JPMORGAN made no attempt to reach out and/or resolve why the one and/or two payments
19 were not received prior to recording the Notice of Default.
20 25. JPMORGAN frustrated the intent and purpose of the contract by refusing to accept payment
21 and then follow this up by quickly recording the Notice of Default.
22 26. Due to JPMORGAN’s wrongful actions and clear attempt to try and recover the property
23 back from Plaintiffs, Plaintiffs now face the real possibility of losing their property and
24 investment.
25 27. Plaintiffs are having to incur expenses in having to bring this action to protect their rights to
26 their property and their investment.
27 28. For the forgoing reasons, JPMORGAN is violation for Breach of Contract.
28
4
VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 5 of 55
1 SECOND CAUSE OF ACTION
NEGLIGENCE
2 (Asserted against JPMORGAN)
3
29. Duty: At all times relevant herein, Defendants acting as Plaintiffs’ lender and/or loan
4
servicer, had a duty to exercise reasonable care and skill in servicing the Subject Loan and
5
ensuring that Defendants would not be subject to a wrongful judicial-foreclosure sale.
6
JPMORGAN had a duty to collect payments that Plaintiffs made timely.
7
30. Breach: In taking the actions alleged above, Plaintiff breached their duty of care owed to
8
Plaintiff in the servicing of the Subject Loan by, among other things, violation the Business
9
& Professions Code §17200, failing to accept Plaintiffs’ timely payments, and wrongfully
10
moving forward with the non-judicial foreclosure sale process without attempting to resolve
11
the default prior to the April 11, 2018 recording.
12
31. Foreseeability: Based upon Defendants conduct as alleged herein, it was reasonably
13
foreseeable that the Subject Property would be subject to wrongful foreclosure and that
14
Plaintiffs would lose title and eventual possession to the Subject Property as a result thereof.
15
32. Actual Causation: But for Defendants’ conduct, Plaintiffs would not have been
16
unlawfully subjected to the foreclosure process and would not have to fight this matter
17
through litigation.
18
33. Proximate Causation: It was clearly foreseeable to Defendants that the wrongful conduct
19
alleged would result in Plaintiffs being wrongfully forced into the foreclosure process,
20
thereby causing Plaintiffs’ substantial damages.
21
22 34. Degree of Certainty that Plaintiffs’ Suffered Injury: Plaintiffs have suffered injury in that
23 Plaintiffs have had to pay exorbitant fees, and costs and in asserting their rights to
24 Defendants wrongful foreclosure process. Additionally, Plaintiffs are facing the very real risk
25 of losing title to, and risk losing the use and possession of, the Subject Property, as well as
26 the equity in the Subject Property.
27 35. Substantial Harm: Defendants’ negligent conduct was a substantial factor in causing
28 Plaintiffs’ harm.
5
VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 6 of 55
1 36. Damages: As a direct and proximate result of Defendants’ negligence, Plaintiffs have
2 been prejudiced, have suffered, and will continue to suffer, general and special damages in a
3 sum determined according to proof at trial.
4
5 THIRD CAUSE OF ACTION
6 VIOLATION OF CALIFORNIA BUS. & PROF. CODE SECTIONS 17200 ET SEQ
(Asserted against All Defendants)
7
8 37. Plaintiffs hereby allege and incorporate herein by reference, all paragraphs contained in this
9 complaint as if the same were fully set forth at length herein.
10 38. Plaintiffs alleges that JPMORGAN engaged in deceptive business practices as defined in the
11 Code section above, by refusing to accept Plaintiffs’ payments and thus forcing Plaintiffs to
12 go into default.
13 39. In addition, JPMORGAN had an opportunity to cure their breach from March 2018, until
14 December 2018, but failed to do so.
15 40. JPMORGAN’s actions continue to constitute unfair business practices as they have failed to
16 remedy the situation. JPMORGAN continues to move forward with the non-judicial
17 foreclosure process as evidence by their recent Notice of Default recording on February 27,
18 2019.
19 41. Furthermore, JPMORGAN is in violation of Cal. Civ. Code §2923.5(a)(1) which states: “A
20 mortgage servicer, mortgagee, trustee, beneficiary, or authorized agent may not record a
21 notice of default pursuant to Section 2924 until both of the following:
22 (A) Either 30 days after initial contact is made as required by paragraph (2) or 30
days after satisfying the due diligence requirements as described in subdivision (e).
23
(B) The mortgage servicer complies with paragraph (1) of subdivision (a) of Section
24 2924.18, if the borrower has provided a complete application as defined in subdivision
(d) of Section 2924.18.”
25
42. Here, Defendants violated §2923.5 by failing to comply with section (a) of §2923.5.
26
Defendants failed to notify Plaintiffs before recording the Notice of Default.
27
28
6
VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 7 of 55
1 43. §2923.5 clearly states a “servicer…may not record a default pursuant to 2924 until… 30 days
2 after initial contact is made.” Here, Defendants recorded a Notice of Default on April 11,
3 2018 without ever making contact with Plaintiff prior to recording.
4 44. Defendants did not exercise due diligence in trying to reach out to Plaintiffs prior to
5 recording the Notice of Default April 11, 2018 default.
6 45. Rather, Defendants purposely refused to accept payments from Plaintiffs, which set them up
7 for Default and Defendants proceeded forward with recording and failed to reach out to
8 Plaintiffs.
9 46. In California specifically, lenders typically don't file a Notice of Default until the borrower is
10 at least 90 days behind in making mortgage payments. When a borrower has missed two
11 payments and is 60 days behind, at that point many banks may send out a 30-day notice of
12 intent, which they are required by law to do before filing a Notice of Default.
13 47. During that 90-day period, the borrower has the right to make up the back payments and
14 reinstate the loan. Here, Plaintiffs were never afforded this right.
15 48. Plaintiff’s January 2018 Mortgage statement, Exhibit E, shows Plaintiffs making a
16 $15,289.91 payment on January 10, 2018, and Plaintiffs had an autopay payment set for
17
February 10, 2018, set up for the same amount.
18 49. Plaintiffs were not past due on any principal or interest payment (see Exhibit E).
19 50. All Defendants and each of them, failed to comply with the requirements of Cal. Civ. Code
20 sec. 2923.55 by failing to contact Plaintiffs in person or by telephone, prior to executing the
21 NOD, in order to discuss Plaintiffs’ options to avoid foreclosure and advise Plaintiffs as to
22 their right to a meeting within fourteen (14) days.
23 51. Although §2923.55 applies “only to first lien mortgages or deeds of trust that are secured by
24 owner-occupied residential real property containing no more than four dwelling units.” This
25 section can be imparted to non-owner-occupied units over 4 units through the Business and
26 Professions Code §17200, and Plaintiffs assert as such.
27
28
7
VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 8 of 55
1 52. Beginning non-judicial foreclosure action on Plaintiffs was a clear violation of business and
2 professions code §17200 as JPMORGAN is obligated to uphold fair business practices.
3 53. The acts of the Defendant above, constitute unfair business practices and/or acts, as defined
4 in California Business and Professions Code §§17200, as the acts were in violation of
5 California statutory law, Civil Code §1708 (as the acts were injurious to the Plaintiff and to
6 the public at large, in that they were designed to cause a certain or likely default).
7 54. Plaintiffs further allege that the acts of the Defendants were intentional and malicious, as
8 they have been made aware of the issue or should have known that they were in violation of
9 established California public policies to promote and preserve home ownership and to
10 prevent foreclosures (Civ. Code §§1695(b), 2923.5 et seq. & 3412).
11 55. Lastly, the Plaintiffs allege that the acts were also oppressive and substantially injurious to
12 consumers, such as the Plaintiffs, in that they were committed with the intent and/or
13 knowledge that the commission of the acts would result in the certain default of the subject
14 loan and likely forfeiture of Plaintiffs’ property and equity.
15 56. The acts of Defendants in furtherance of its fraudulent and deceitful corporate polices, in
16 willfully deceiving the Plaintiffs regarding their right to have their payments accepted, were
17 in violation of California law and public policy, as misleading and injurious to the Plaintiffs.
18 57. As a direct and proximate cause of the acts of the named Defendant, Plaintiffs has suffered
19 by struggling to avoid becoming delinquent on their mortgage. They have also suffered
20 consequential damages in an amount to be fully determined at time of trial, but in an amount
21 exceeding $50,000.00 to date and is entitled to all statutory damages as provided in the above
22 entitled Code section, including attorney’s fees and costs.
23
24 FOURTH CAUSE OF ACTION
25 VIOLATION OF THE COVENANT OF GOOD FAITH AND FAIR DEALING
(Asserted against All Defendants)
26
27 58. Plaintiffs hereby allege and incorporate herein by reference, all paragraphs contained in this
28 complaint as if the same were fully set forth at length herein.
8
VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 9 of 55
1 59. “Every contract includes an implied covenant of good faith and fair dealing that neither
2 party will do anything that will have the effect of impairing, destroying, or injuring the
3 rights of the other party to receive the fruits and benefits of their agreement. A party who
4 has discretionary authority has a duty to exercise that discretion in good faith and within the
5 standards of fair dealing. This covenant is included within any loan agreement between a
6 lender and a borrower (citing to Wyatt v. Union Mortgage Co. 24 Cal.3d 773, 783).” Miller
7 & Starr, California Real Estate 3d. Lenders’ Liability §36:17, pp. 24-25.
8 60. Here, JPMORGAN, breached this covenant of good faith and fair dealing by failing to act
9 in good faith as they frustrated the intent and purpose of the Note.
10 61. JPMORGAN acted in willful disregard of Plaintiffs’ rights and still do as they continue to
11 move along with the non-judicial foreclosure process knowing full-well they were the cause
12 of it as they refused to accept payments from Plaintiffs.
13 62. JPMORGAN failed to uphold their duty by failing to acknowledge the issue and accept
14 payments, as a results JPMORGAN causeds Plaintiffs to go into default, which gave
15 JPMORGAN the false sense of right to commence non-judicial foreclose on Plaintiffs’
16 property.
17 63. As a direct and proximate cause of the breach of the covenant of good faith and fair dealing,
18 the Plaintiffs have and will suffer economic damages in an amount to be determined at time
19 of trial, but is believed to be and exceed, the sum of $100,000.00 to date.
20
21 FIFTH CAUSE OF ACTION:
22 DECLARATORY RELIEF
(Asserted Against All Defendants)
23
24 64. Plaintiffs hereby allege and incorporate herein by reference, each and every other paragraph
25 contained in this Complaint as if the same were fully set forth at length herein.
26 65. Defendants have participated in deceptive activity as complained of herein, in order to
27 facilitate a foreclosure sale of Plaintiffs’ Property.
28
9
VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 10 of 55
1 66. In addition, Defendants, and each of them, have committed violations of the Civil Code and
2 Business & Professions Code §§17200-17500.
3 67. Plaintiffs contend that an actual controversy exists as to the rights of Plaintiffs and the named
4 Defendants regarding Plaintiffs’ DOT/Note and the Defendants’ right to proceed lawfully
5 with the non-judicial foreclosure process.
6 68. Plaintiffs desire a judicial determination of their rights and a declaration as to the duties and
7 obligations of all Defendants in this controversy.
8 69. A judicial declaration is necessary and appropriate at this time under the circumstances in
9 order so Plaintiffs may ascertain their rights under the DOT/Note. This decision would have
10 a very practical effect of informing parties’ future conduct regarding these situations and by
11 lessening the financial and emotional burden by the Defendants by the unsettled state of
12 affairs.
13
14 PRAYER FOR RELIEF
15 WHEREFORE, Plaintiff prays for judgment against the Defendants and each of them as
16 follows:
17 1. For all compensatory damages incurred according to proof;
18 2. For all consequential damages incurred according to proof;
19 3. For all special damages according to proof;
20 4. For all statutory damages applicable to each cause of action;
21 5. For punitive damages sufficient to punish the Defendants and act as a deterrent to others;
22 6. For rescission of the loan contracts and restitution of all principal and interest as well as any
23 and all costs and fees paid on the loan;
24 7. For cancellation or reformation of the contract as the court deems appropriate;
25 8. For a declaratory judgment voiding the subject contract;
26 9. For attorney’s fees and costs of suit;
27 10. For such other relief that the court may deem just and proper.
28
10
VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
TABLE OF CONTENTS
1
Page
2
MEMORANDUM OF POINTS AND AUTHORITIES...............................................................1
3
1. INTRODUCTION.............................................................................................................1
4
2. SUMMARY OF THE COMPLAINT JUDICIALLY NOTICEABLE DOCUMENTS
5 (as follows).........................................................................................................................2
6 A.
....................................................... 2
7
B.
8 ................................................................................................................... 3
9 3. .......................................... 4
10 4. THERE IS NO REQUIREMENT THAT A LENDER OR LOAN
SERVICER “PRODUCE” OR “POSSESS” THE ORIGINAL
11 PROMISSORY NOTE TO CONDUCT A NON-JUDICIAL
FORECLOSURE...............................................................................................................6
12
5. PLAINTIFFS’ CLAIM UNDER THE FAIR DEBT COLLECTION
13 PRACTICES ACT (“FDCPA”) IS
........................................................................................................... 6
14
6. THE CLAIM UNDER THE FAIR CREDIT REPORTING ACT (“FCRA”)
15 IS..................................................................7
16 7. THE FRAUD CLAIM..................................................................8
17 A. Plaintiffs Plead The Elements Of Fraud With Specificity.........................8
18 B. The “Fraud By Concealment” Allegations Fail As A Matter Of Law..................9
19 C..............................................................9
20 D. P................................10
21 8.
............................................................................................................. 10
22
9. ...................................... 11
23
10.
24 ............................................................................................................ 13
25 A.
..................................................................... 13
26
B.......................................................................................................................................14
27
C.
28 ...................... 15
i
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 12 of 55
2 VERIFICATION
3 State of California )
)
4 County of Los Angeles )
5 I, ANNE KIHAGI, am the managing member of the Plaintiff in this action. I have
6 read the foregoing Complaint. I am informed and believe and, on that ground, allege that
7 matters stated therein are true.
8 I declare under penalty of perjury under the laws of the State of California that the
9 foregoing is true and correct.
10
11
Executed on May 17, 20 19, Los Angeles, California.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
12
AMENDED VERIFIED COMPLAINT FOR DAMAGES & EQUITABLE RELIEF
1
10
11
12
13
14
15
16
17 A. Plaintiffs Plead The Elements Of Fraud With Specificity.........................8
18 B. The “Fraud By Concealment” Allegations Fail As A Matter Of Law..................9
19 C..............................................................9
20 D. P................................10
21
22 8. ............................................................................................................. 10
23 9. ...................................... 11
24 10. ............................................................................................................ 13
25 A.......................................................................................................................................13
26
B.......................................................................................................................................14
27
28 C......................................................................................................................................15
i
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 14 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 15 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 16 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 17 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 18 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 19 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 20 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 21 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 22 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 23 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 24 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 25 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 26 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 27 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 28 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 29 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 30 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 31 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 32 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 33 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 34 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 35 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 36 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 37 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 38 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 39 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 40 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 41 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 43 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 44 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 45 of 55
Case 4:19-cv-02786-YGR Document 1 Filed 05/22/19 Page 47 of 55
