Defendants Cross Complaint

SUMMONSCross-Complaint

(CITACION JUDICIAL-CONTRADEMANDA)NOTICE TO CROSS-DEFENDANT:(A VISO AL CONTRA-DEMANDADO):

MELODY GILLESPIE

YOU ARE BEING SUED BY CROSS-COMPLAINANT:(LO ESTA DEMANDANDO EL CONTRADEMANDANTE):

THE H.M. WYSOCKI TRUST BY AND THROUGH ITS ETC.ET.AL

SUM-110FOR COURT USE ONt y

(SOLO PARA US~ DE LA CORTE)

, Deputy(Adjunto)

You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have acopy served on the cross-complainant. A letter or phone call will not protect you. Your written response must be in proper legal form if youwant the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and moreInformation at the California Courts Online Self-Help Center (www.courtinfo.r;a.gov/selfhelp), your county law library, or the courthousenearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you maylose the case by default, and your wages, money, and property may be taken without further warning from the court.

There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call anattorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal servicesprogram. You can locate these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the CaliforniaCourts Online Self-Help Center (www.eourtinfo.ea.govlselfhe/p), or by contacting your local court or county bar association. NOTE: Thecourt has a statutory lien for waived fees and costs on any settlement or arbitration aWard of $10,000 or more in a civil case. The court'slien must be paid before the court will dismiss the case.

Tiene 30 DlA5 DE CALENDARIO despues de que Ie entreguen esta eitseion y papeles legales para presentar una respuesta par esqritoen esta corte y hacer que se entregue una copia al eontrademandante. Una carta 0 una lIamada te/efonica no 10 protegen. Su respuestapor escrito tlene que estsr en formato legal correcto si desea que procesen su caso en la corte. Es posible que hays un formulario queusted pueda usar para su respuesta. Puede eneontrar estos formularios de la corte y mas informaci6n en el Centro de Ayuda de lasCortes de California (www.sucorte.ca.gov). en la biblioteca de leyes de su condacJo 0 en Is corte que Ie quede mas cerea. 5i no puedepagar la cuota de presentacion, piela al secretarlo de la corte que Ie de un formulario de exenci6n de pago de cuotas. 5i no presenta surespuesta a tiempo, puede perder el easo por ineumpl/miento y la corte Ie podrfl qultsr su sueldo, dinero y bienes sin mas advertenc/a.

Hay otros requisitos legales. Es recomendable que lIame a un abogado inmedlatamente. 51 no conoce a un abogado, puede lIamar a unservicio de remisi6n a sbogados. 51no puede psgar a un abogsdo, es poslble que eumpla can 105 requisltos para obtener servicios legalesgratuitos de un programs de servicios legales sin fines de luero. Puede encontrar estos grupos sin fines de lucro en el sitl0 web deCalifornia Legal Services, (www.lawhelpcallfornia.org), en el Centro de Ayuda de las Cortes de California (www.sucorte.ca.gov), 0oniendose en contacto con 18corte 0 el colegio de abogados locales. A VISO: Por ley, la corte tiene derecho a reclamar las cuotas y loscostos exentos por imponer un gravamen sobre cualquler recuperac/6n de $10,000 6 mas de valor raeibida mediante un acuerdo 0 unaconeesi6n de arbitraje en un caso de derecho civil. Tiene que pagar el gravamen de la corte antes de que la corte pueda desechar el caso.

The name and address of the court is: SHORT NAME OF CASE (from Complaint): (Nombre de caso):

(EI nombre y direcci6n de la corte es): SUPERIOR COURT OF THE GILLESPIE VS. HOFFMANSTATE OF CALIFORNIA, COUNTY OF TULARE CASE NUMBER: (NLimerodeICaso)'

221 S. MOONEY BLVD, VISALIA, CA 93291 10-238961

The name, address, and telephone number of cross-complalnant's attorney, or cross-GomplalOant Without an attorney, IS:

(EI nombre, la direcci6n y el numero de telefono del abogado del contrademandante, 0 del eontrademandante que no tieneabogado, es):Robert J. Fletcher, Attorney at Law, P.O. Box 824, Tulare, CA 93275 (559) 684-1795

DATE: _ NOV 1 9 20~O Clerk, by . ~ -, ,., G'_ _op ="(Fecha) ••• l'r ~ tV (Secretario) Lal.;.ayne Clee ..k(For proof of seNiee of this summons, use Proof of Service of Summons (form POS-010).) .(Para prueba de entrega de esta citation use el formulario Proof of Service of Summons (POS-010).)

NOTICE TO THE PERSON SERVED: You are served

[SEAL] 1. 0 as an individual cross-defendant.

2. 0 as the person sued under the fictitious name of (specify):

COURT SEAL

Form Adopted for Mandatory UMJudicial Council of CaUfomla

SUM·110 rR~v, Jllly 1. 2009]

3. 0 on behalf of (specify):

under: 0 CCP 416.10 (corporation)o CCP 416.20 (defunct corporation)o CCP 416.40 (association or partnership)o other (specify):4. 0 by personal delivery on (date):

$UMMONS-CROSS·COMPLAINT

oooCCP 416.60 (minor)

CCP 416.70 (conservatee)

CCP 416.90 (authorized person)

of 1

Coda of Civil Procedure. §§ 412.20.428.60,465www.courlinfo.c8.goV

Amencan LegaINe!. Inc.www.FormsWorkffow.com

1 Robert J. Fletcher No. 119770

Attorney at Law2 P.O. Box 824

Tulare, CA 932743 (559) 684-1795

4 Attorney [or Nicklas Hoffman andthe Wysocki Irrevocable Trust

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FILED'TUlARE COUNlY SUPERIOR COURT

VISALIA DIVISION

NOV 1 9 2010

LAAAYNE CLEEK, CLERK

BV:------6

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF TULARE

8)Case No.: 10-238961

)9

Courtney and Melody Gillespie,)

Plaintiffs,

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)VS.

)11 Nicklas Hoffman; et. al.

))12

Defendants)13

)

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THE H.M. WYSOCKI IRREVOCABLE)TRUST BY AND THROUGH ITS

)15

CO-TRUSTEES, NICKOL D. )GERRITSMA AND NICKLAS

)16

HOFFMAN, ))17

Cross-complainant,)

)18VS.

)

)19COURTNEY GILLESPIE, MELODY

))20

GILLESPIE AND ALL PERSONS)

CROSS-COMPLAINT FORUNKNOWN CLAIMING ANY LEGAL )EJECTMENT, DECLARATORY RELIEF,

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OR EQillTABLE RIGHT, TITLE,)QIDET TITLE AND DAMAGES

ESTATE, LIEN, OR INTEREST IN THE )22

PROPERTY ADVERSE TO CROSS- )COMPLAINANT'S TITLE, OR ANY

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CLOUD ON CROSS-COMPLAINANT'S)TITLE TO THE PROPERTY, AND

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DOES 1 THROUGH 100 inclusive, ))25

Cross-defendants)1-

Cross-Complaint to Quiet Title, For Ejectment, For Declaratory Relief and For Damages

Wysocki Irrevocable Trust vs. Gillespie et.al.

(~)

1 COMES NOW cross-complainant, the H.M. Wysocki Trust by and through its

2 Co-Trustees, Nickol D. Gerritsma and Nicklas Hoffman and by way of cross-complaint alleges

3as follows:

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FIRST CAUSE OF ACTION

EJECTMENT

Cross-complainant is, and at all times mentioned was, the owner in fee pursuant

to that Grant Deed recorded with the office of the Tulare County Recorder on

May 17, 2004 as document number 2004-0046807, a copy of which is attached

hereto as Exhibit A and incorporated herein by this reference as though fully set

forth at length, and is entitled to possession of all that real property and

improvements thereon located in the County of Tulare, State of California

commonly known as 1831 North Lime Street, Porterville, California, consisting

of approximately ten (l0) acres, more or less, hereinafter referred to as the

"Property" artd is more particularly described as:

Lot 10 of Hermosa Orange Colony, County of Tulare,State of California, according to the Map thereofRecorded in Book 2, Page 131 of Maps, TulareCounty Records

A.P.N. 255-230-004

Cross-complainant is ignorant of the true names and capacities of the

cross-defendants sued herein as Does I through 100, inclusive, and therefore sues

these cross-defendants by such fictitious names and will amend this

cross-complaint when that information is discovered. Cross-complainant is

informed and believes and based lJ..1ereon alleges that each of the cross-defendants-~-

Cross-Complaint to Quiet Title, For E;jectment, For Declaratory Relief and FOl"Damages

Wysocki Irrevocable Trust vs. Gillespie et.aI. Case No. 10-238961

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Courtney Gillespie) Melody Gillespie and all those cross-defendants designated

herein as a Doe is legally responsible for each of the acts, failures to act,

circumstances, events and happenings alleged in this cross-complaint.

Cross-complainant is informed and believes and based thereon alleges that at all

times herein mentioned each of the cross-defendants was an agent, servant,

employee, partner, joint venturer or surety of each of the remaining

cross- defendants, and at all times herein relevant was acting within the scope and

purpose of said servant, employment, agency, partnership, joint venture or surety

relationship with the full knowledge and consent, either express or implied, of

each of the remaining cross-defendants.

On or about February, 2005, cross-defendants, Courtney Gillespie and Melody

Gillespie, entered and took possession of approximately one and three quarters

(1-3/4) acres ofthe subject Property and has since that time withheld possession

of this occupied Property from cross-complainant. This occupancy was initiated

under an orally contemplated sales agreement which was understood by the

parties would be fully set forth in writing at such point as a full and final

agreement would be reached by all the parties wherein the different contingencies,

known or unknown, were satisfied. This negotiation process resulted in only two

written memorandums which are the documents attached hereto as Exhibit B,

entitled "Agreement to Terms" and Exhibit C, entitled "Installment Note Secured

by Deed of Trust" each of which documents are incorporated herein by this

reference as though fully set forth at length.

The document entitled "Agreement to Terms') (Exhibit B) was the only document

actually signed by both cross-defendant Courtney Gillespie and Wysocki Tru~t

co-trustee, Nicklas Hoffinan. N~}?erson associated with Wysocki Trust ever

Cross-Complaint to Quiet Title, fi()f Ejectment, For Declaroltory I{elief and For Damages

Wysocki Irrevocable Trust vs. Gillespie et.al. Case No. 10-238961

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7 8910111213141516171819202122232425

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signed acceptance of the document entitled "Installment Note Secured by Deed of

Trust" (Exhibit C) which was only signed and offered by cross-defendant,

Courtney Gillespie. Cross~defendant, Melody Gillespie, never signed either of

these two documents. Cross-complainant, Nickol D. Gerritsma, likewise never

signed either of these two documents.

On or about January 10, 2006, Wysocki Trust co-trustee, Nicklas Hoffman, after

tendering and delivering a full refund of sums previously paid by

cross-defendants, wrote "VOID LATE 2005" across the face of the document

entitled "Installment Note Secured by Deed of Trust"(Exhibit C) and delivered it

back to cross-defendant Courtney Gillespie and informed said cross-defendant

that the ongoing negotiations for the contemplated sales agreement were

terminated. The terms that existed in the negotiation prior to, and at, this time 0

termination contemplated that the cross-defendants would purchase half of the

approximately ten (l0) acres owned by cross-complainant and that

cross-defendants would not have to pay any cash money as a down payment if the

cross-defendants would apply for and obtain the contemplated subdivision of the

Property in a configuration acceptable to all parties and to the County of Tulare

all at cross-defendants' own personal expense. Under the Installment Note

(Exhibit C), which had been prepared by cross-defendants and presented by

cross-defendants, the cross-defendants had proposed paying $600.00 per month at

seven (7) percent interest, and did pay the sum of $4,800.00, but failed to take any

material action to obtain the requisite sub-division approval by either the

cross-complainant or the County of Tulare which led to the tender and delivery of

a check for fun refund of the said SlUll paid, voidance of the proffered Installment

Note (Exhibit C) and termination of the negotiation for sale.-4·



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At no time mentioned herein has any land sales agreement been accepted by

cross-complainant nor has there been any recording of any land sales document

with the office of the Tulare County Recorder, nor has there been any change in

the real property tax status with the office of the Tulare County Assessor nor has

any "Deed of Trust" as contemplated by the offered "Installment Note Secured by

Deed of Trust" (Exhibit C) ever been prepared or executed or delivered or

accepted or recorded by any of the parties of this action.

Following the above referenced termination of negotiations for sale,

cross-defendants remained in possession of the approximately one and three

quarters (1-3/4) acres living in their travel trailer they had parked on this Property

and paying for Nicklas Hoffman's own personal electrical services direct to the

electrical service company, all in lieu of any other cash rental payments to

cross-complainant, all of which was with the oral permission by

cross-complainant until on or about December, 2009 at which time

cross-defendants breached this oral tenancy by installing an electrical sub-panel

on the electrical service panel over the objections by cross-complainant's

co-trustee, Nicklas Hoffman, and by refusing to relinquish possession of the

occupied property to cross-complainant or enter into a formal written rental

agreement for the occupied property all as requested by cross-complainant by and

through its co-trustee, Nicklas Hoffman, who fIrst made the request to

cross-defendants in August, 2009 and continued periodically to make this request

through the time of cross-defendants' fInal breach in December, 2009 by virtue of

the installation of the above referenced electrical sub-panel. At all times

mentioned herein cross-complainant has performed all obligations required to be

perfo1'lut:d or is excused from further perfonnance by cross-defendants' breach.-5-

Cruss-Complainllo Quiet Title, For Ejectment, For Declaratory Reliefand For Damages

Wysocki Irrevocable Trust vs. Gillespie et.al. Case No. ] 0-238961

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Because cross-defendants continue to withhold possession of the Property,

cross-complainant has been denied the use and occupation of the Property to

cross-complainant's damage in the approximate sum of$1,200.00 per month

according to proof and will continue to sustain damages in the sum of

approximately $1,200.00 per month as long as cross-defendants withhold

possession of the property from cross-complainant.

II.

SECOND CAUSE OF ACTION

DECLARATORY RELIEF

Cross-complainant hereby incorporates by this reference each allegation in

Paragraphs 1 - 8 of the first caus€(of action above as though fully set forth at

length.

An actual and justiciable controversy now exists between the parties as to their

respective rights and duties under the above described oral tenancy and proposed

sale agreements. Cross-complainant contends, and cross-defendants deny, that

cross-defendants have no right to require cross-complainant to transfer any title

interest to any portion of the subject Property to themselves because a full and

complete land sale agreement was never finalized between the parties and ,because

the cross-defendants failed to make any material progress towards obtaining, and

did not obtain, either agreement to, or authority for, a sub-division lot split

acceptable by both cross-complainant and by the County of Tulare.

Cross-defendants contend, an~tcross-complainant denies, that a full and complete

land sale agreement was entered into by all relevant parties and that

cross-defendants are entitled to require specific performance of this contended-6-

Cross-Complaint to Quiet Title, For Ejectment, For Declaratory Relief and For D;:Images


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agreement. Possession, or return of possession, of the approximately one and

three quarters (1-3/4) acres actually occupied by the cross-defendants is urged by

each of the contending paJties in accordance with this stated controversy.

Cross-complainant desires ajudicial determination of cross-complainant's rights

and duties under the proposed land sale agreement and a declaration of its

non-existence or invalidity or its enforceability or non-enforceability or both.

A judicial determination and declaration is appropriate and necessary at this time

in order that the parties may ascertain their respective rights and duties there

under.

III.

TIDRD CAUSE OF ACTION

QUIET TITLE

Cross-complainant hereby incorporates by this reference each allegation in

Paragraphs 1 - 8 of the first cause of action and Paragraph 11 of the second cause

of action above as though fully set forth at length.

Cross-complainant seeks to quiet title against the claims of cross-defendants and

each of them as aforesaid. Cross-defendants claims are without any right and

cross-defendants have no right, title, estate, lien or interest in the above described

Property all without exception.

Cross-complainant does not know the exact names, capacities or interests in the

Property of certain of the cross-defendants which cross-complainant designates

for this action as "all persons unknown, claiming any legal or equitable right, title,

estate, lien or interest in the Property adverse to cross-complainant's title, or any

cloud on cross-complainant's title to the Property." Cross·complainant seeks to

4ui~t title in the Property against the claims of each such cross-defendant and-7-

Cross-Complaint to Quiet Title, For Ejectment, For Declaratory Relief and For Damuges


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each such cross-defendant has no right, title, estate, lien or interest in the Property

or any part of it. Cross-complainant will serve this class of cross-defendants by

publication as the Court allows.

Cross-complainant seeks to quiet title against all cross-defendants and each of

them as of January 10, 2006 which is the date on which the document attached

hereto as Exhibit C was delivered back to cross-defendants marked

"VOID LATE 2005" and the sales negotiation was terminated by

cross-complainant.

The claim of cross-defendants is contingent and uncertain in that at no time

mentioned herein has any land sales agreement been accepted by

cross-complainant nor has there been any recording of any land sales document

with the office of the Tulare County Recorder, nor has there been any change in

the real property tax status with the office ofthe Tulare County Assessor nor has

any "Deed of Trust" as contemplated by the "Installment Note Secured by Deed

of Trust" (Exhibit C) ever been prepared or executed or delivered or accepted

or recorded by any of the parties of this action.

17 WHEREFORE CROSS-COMPLAINANT PRAYS as follows,

18 On the :first cause of action:

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That this Court decree that cross-complainant is entitled to have and recover

possession of the Property described in Paragraph I of this cross-complaint,

That this Court issue its Writ of Execution directed to the Sheriff of Tulare

County, California directing the Sheriff to remove cross-defendants and all those

claiming by, through or under cross-defendants and to place cross-complainant in

possession of the Property;

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Cross-Complainl to Quiet Title, For Ejeclment, For Dec1aratl}ry Rcliehnd For Damag~s

Wysocki Irrevocable Tru3t Y3. Gillespie et.a1. Cl:lst: No. 10-238961

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For an award ofdainages for cross-defendants' wrongful withholding of the

premises in the sum of $40.00 per day from and after December, 2009 according

to proof until delivery of possession of the Property,

For costs of suit and prejudgment interest according to proof, and

For such other and further relief as the Court deems just and proper according to

proof.

On the second cause of action:

That this Court decree that the subject land sale agreement is void and of no legal

effect,


For such other and further relief as the Court deems just and proper according to

proof.

On the third cause of action:

That this Court decree that all money or money equivalent paid by

cross-defendant since entering into possession of that portion of the subject

Property occupied by cross-defendants shall be retained by cross-complainant as

payment for the fair rental value of the Property according to proof,

For damages at the rate of $40.00 per day, from and after December, 2009

according to proof, for cross·defendants' wrongful detention of the premises until

such time as the premises are restored to cross-complainant,

For a judgment that cross-complainant is the sole owner of the property and that

cross-defendants have no interest in the Property adverse to cross-complainant or

any other interest,


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Wysocki irrevocable Tmst vs. Gillespie et.aL Case No. 10-238961

1 13. For such other and further relief as the Court deems just and proper according to

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Dated:Jj -l~ - J D6789

Dated: t 1- )~ -' )D

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11Dated: \ \ ......\~. L.t7(O12

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THE H.M. WYSOCKI IRREVOCABLE TRUST

BY:~~ iCkol D. Gerritsma, Co-Trustee """'"

By:~Jj~·Nicklas Hoffinan,~----

VERIFICATION

15 I, Nicklas Hoffman, hereby declare as follows:

161. I am a co-trustee of the H.M. Wysocki Irrevocable Trust and I make this

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declaration of my own personal knowledge. If called I could and would testify competently

hereto.

2. I have read the foregoing cross-complaint and know its contents. The same is true

to the best of my knowledge, information and/or belief.

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

foregoing is true and correct.

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tIv·

1•••95.7'

- RECORDING REO~~D BY..._ .. _, CHICAGO TJ:TLE COMPANY

AND WHEN RECORDED MAD.. TO

f;;;COLE D. GERRIT~, TRUSTEE "1614 N. BRADLEY

VISALiA, CA 93292

11II110111111111_111·2004---004&8.7

Rtt:ordtd I RECFEEOfficial Records J TAX

Coanty Of ITedan I

6REGORY B. ~ IRecorder I

J

INt08:81AM 17-ffay-28fM 'Pas, 2 of 2

Maeuor'! Parcel No:255-230-004.f}P Ai ~.:ss- ()~.9-X-Pi GRANT DEED

nm UNDBRSIGNED ORA.WOR(S) D.:ea.ARE(S)DOCUMENl'AAY TRANSPBR. TAX IS $95.70o Wlincmporaled aRa 00 Otyof PORTERv:ILLR

IX] computed Ofttfl~fulhalue of(he iltt=uorproperty~ or iso ccmpukd 011tbeMJ whae Jess the value oflieDI or enaambraDccs rauiniog at time of sale, and

FOR A VALUABLE CONSIDERATION. ~ ofwbich is herebYaclalow1cdacd.ANNE M. M:INTER, TRUSTEe ONDER -TIm ANNE M. MINTER LIVDlG '!'RUS'!"- BSTABL:ISHBI> NOVEMBER2, 1998

LEscrow No. 1057379 - SRSQIder No! 1057372 - ED

hereby GRANT(S) to.NICKOL D. GERR:ITSMA, TRtfSTBB OF THB H. M. WYSOCKI IRREVOCABLE TROST

the foll~ describedreal property in the City of PORTERVILLE'Countyof TOLARB , State of California:

LO'l' 1.0 OF HERMOSA OlUWGB COLONY, COUNTY OF TULARE, S'l'ATE OF CALlPOllNXA, ACCORDmG TOTHE MAP THEREOF RBCORD2D m BOOK 2, PAGE 131 OF MAPS, '1'tJIlARB COON'l'Y RECORDS.

APN NO. 255-230-004

Dated May 4, 2004 ANNE M. MIN'1'BR, TROSTlE UNPElt 'l'BEANNE H. MiN'1')m x,IVING TROST

per1lClnally known to me (of' proved 10 me on the b8Iia Of IItiaftC:ft)ry8v1det1ce) to be 1he Per8On(8) wtloee narne(a) 'sf.re aubecrlbed to thewithin instnlment and acknowledged to me ~ heJrstra/they executed thesame in tflsfher/fMlr authorized capacUy(les). and that by hlsjhlr/th8Il8ignature(s) on 111. Instrument 1118pet'BOn(a). 01 tha entity upon behalf Ofwhich the pet1On(.) ectad. execuled the Instrument.

gmvhand and official teal.~~ \J..J~., IJ-/lrntS.... Of &iy Da1e MYcom EiPiia FOR NOTAA'i SEAL OR ~

MAIL TAX STATEMENTS TO PARTY SHOWN ON FOlLOWING UNE: IF NO PARTY SO SHOWN. MAlt. IS OIAECTED ABOVE

City, SUIte &Z1p

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A & f-C C· yvt[l'j \ TO

1?ri·~·.tate cr.-ansier of prcpert::{ rights ;.,it.hin TrtlSt.. Acceptan.ce of first

~~~'m.~~~1~:I~~l~=8~·~~~2~r~~~~~~t~f a;~o~e~~y p~~~~~e~O a~~t~~~~yp~~J. ~~~;~~of Tulare with the oblig~tions incurred thereby. Tulare County APN255238 -004.Property Description: Of the approximately 10 acre parcel the south 120fE2t aithe east half ar.d that part of the west half excluding the north:.20 feet.

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P2.y-ments shall be a minimum of $600/mcnth with a 7%:1-15-2012 (7yrs). Tax obligation (State rent)possession and portion shall be due upon demand per

apr and all due on13 retroacti·..:e t;'\County of Tulare.

Ttis isa private law document, any adjudication shall be assigned onlyby the church 'at Kaweahboard of elders or other body 0:: Christi;:; .."'1 me!~per lCor 6 :1.

I hereby accept: the aboveWj/socki Trust ~

terms and position of trustee of the H. f.'l.

3.:;.a.

1331 ~ LIME S'!

Balance .

5 ACRES AT R~ 245 & AVE ~71b~g~~ h~l.nc.

int.r&Gt ~aer~ed (7%- x_oo5a/~~·)

pill.y;:.~nt

;J.·-10-:llI05

?~aut data3-01.-05

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-r;-o-:t-q--;Y-[-:C-E-·~-<::-T-R-O-_l-" -T-H-I-S-' -.-~-(j-'.I'-E-· -: -\'I-h-e-n-p-a-i-o.-' ,--t-h-i-S-N-~-q-t-e-.-a-n-_-d-t-h-e-D-e-e-d-71Il ~.TtuS~ musi be s~-rendered with a req~est for reconveYfucce_ . ~

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Installment Note Secured by Deed of Trust

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Defendants Cross Complaint

Documents

Transcript of Defendants Cross Complaint