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Attorney for Plaintiff(s), John and Jane Doe
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES COURTHOUSE
John Doe, an individual,.
Jane Doe, an Individual.
New Homeowners, and
DOES 1-25, Inclusive.
VERIFIED COMPLAINT FOR
Plaintiffs, JANE AND JOHN DOE (“DOE”), by its designated attorney, petitions this Court
NOTICE OF REPRESENTATION
VIA OVERNIGHT MAIL
New Homeowner’s Attorney
123 Broad st
Los Angeles, CA 00000
Date: Apr 16, 2020 Subject Property, 555 West Los Angeles Blvd, CA 00000
Please be advised that my office represents John Doe in this matter, and you hereby
demanded to send all communications regarding this legal issue to me. Your points are duly
noted, but I am struggling to understand which legal authority that your client sits by to justify
her outrageous demand for Doe to pay senior lienholder after they lost their home to
foreclosure. Let us be mindful that your client purchased the property at a foreclosure auction at
a substantially discounted rate. So, it would be asinine for the Doe to pay the Senior Lienholder
whatever was given to them by the trustee in order to subsidize and increase the profits of a
hard money investor such as your client. Notwithstanding, the law is crystal clear in California
that when a Junior Lienholder purchases a property, like any other successful purchaser, he or
she “takes the property subject to senior lien” Kolodge v. Boyd (2001) 88 Cal. App. 4th
349, 356. This means that the new property owner, not the Doe is legally responsible for
honoring the payments associated with that Deed of Trust that was recorded against the
property. If your client chooses to pursue this matter, the likely outcome would that your case
will fail. If, however, my client is forced to incur unnecessary legal fees and expenses
resulting from your client’s bad faith conduct, my office will pursue any and all legal remedies
against you and your client accordingly.
Attorney for John Doe