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[Claimant] [Claimant Street Address] [Claimant City State Zip] [Phone] [Fax] Fax

IN THE SUPERIOR COURT OF CALIFORNIA IN AND FOR SAN JOAQUIN COUNTY [Claimant] Claimant, v. WASHINGTON MUTUAL BANK, F.A.; JPMORGAN CHASE BANK N.A.; CALIFORNIA RECONVEYANCE COMPANY; WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 Trust; and all persons known and unknown claiming any legal or equitable right, title, estate, lien, or interest in Property adverse to Claimants title to the Property, Does 1 through 50 inclusive. Respondents.

CASE NO.:_________________________

CLAIM TO ENFORCE ADMINISTRATIVE RECORD SUMMARY OF ADMINISTRATIVE RECORD REQUEST FOR JUDICIAL NOTICE OF ADMINISTRATIVE RECORD AFFIDAVIT OF TRUTH

ENFORCEMENT OF CIVIL CLAIM

1. Claimants [Claimant] are people of San Joaquin County, California and bring this action as the owner of the
real property commonly known as 6344 Antler Ct., Stockton CA 95219. Legal Description: LOT 46 AS SHOWN ON THE MAP OF TRACT NO. 3138 SPANOS PARK WEST UNIT NO. 21 FILED FOR RECORD JULY 2, 2003 IN BOOK OF MAPS AND PLATS, BOOK 38, PAGE 35, SAN JOAQUIN COUNTY RECORDS. EXCEPTING THEREFROM AN UNDIVIDED 49% OF ALL OIL, GAS, MINERALS AND OTHER HYDROCARBON SUBSTANCES IN AND TO THE ABOVE DESCRIBED REAL PROPERTY WITHOUT THE RIGHT TO EXPLORE AND EXTRACT OIL GAS MINERALS ON AND FROM SAID PROPERTY AS RESERVED IN DEED EXECUTED BY ADRIENNE M. PROVO, ET AL RECORDED MAY 11, 1984 RECORDER'S INSTRUMENT NO. 84033222, SAN JOAQUIN COUNTY RECORDS. ALSO EXCEPTING THEREFROM ALL [REMAINING] OIL, GAS,

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MINERALS AND OTHER HYDROCARBON SUBSTANCES LYING BELOW A DEPTH OF 500 FEET BENEATH THE SURFACE OF SPECIALTY CAPITAL INC., A CALIFORNIA CORPORATION BY DEED RECORDED NOVEMBER 20, 1990 RECORDER'S INSTRUMENT NO. 90113634, SAN JOAQUIN COUNTY RECORDS. JURISDICTION AND VENUE

2. This Court has jurisdiction over the matters related to the emergency, injunctive, provisional, and equitable
relief sought herein, pursuant to the agreements of the parties referenced below.

3. The property is within San Joaquin County, California, and the transaction was originated within San Joaquin
County, California. PURPOSE OF THIS CLAIM

4. The parties herein are subject to certain contractual obligations that are the subject of this claim. 5. This action is brought, for among other purposes, to;
a) Restrain and enjoin the Respondents, their agents, employees, representatives, lawyers, directors and officers, from taking any action to improperly transfer, dispose of, or use the property of Claimant from the foreclosure action and gain possession of Claimants Property. b) Enforce a Private Administrative Judgment. (Abstract of Judgment) THE PARTIES

6. Claimant Ramin Yavrom, and Catherine Yavrom are individuals, hereinafter collectively referred to as
Claimants, living in the State of California at all times relevant to the Complaint and property commonly known as 6344 Antler Ct., Stockton CA 95219, identified by Parcel Number 066-290-33 (Property).

7. WASHINGTON MUTUAL BANK, F.A., hereinafter collectively referred to as Respondent, is shown as the
lender as indicated on page one of a Deed of Trust recorded against the property in San Joaquin County, California, Instrument # 2004-224957, and the beneficiary on the Notice of Trustee Sale document number 2012-170155.

8. JPMORGAN CHASE BANK N.A., also hereinafter collectively referred to as Respondent, is shown to be
the Assignor of a Corporation Assignment of Deed of Trust Recorded Instrument # 2011-111554.

9. WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1
Trust, also hereinafter collectively referred to as Respondent, is purported to be the Assignee of a Corporation Assignment of Deed of Trust Recorded Instrument # 2011-111554.

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10. CALIFORNIA RECONVEYANCE COMPANY, also hereinafter collectively referred to as Respondent is a

California corporation engaged in the business of title insurance, banking services, including foreclosure, and acting as trustee for banks, mortgage holders and lien holders in California.

11. Claimant is informed and believes that Doe 1 through Doe 50 are the employees or agents of named
Respondents and liable to Claimant. Claimant will amend this complaint to allege their true names and capacities when ascertained. The named Respondent acted in concert with Doe 1 through 50 in the subject transactions described in the Complaint or claim legal or equitable right, title, estate, lien, or interest in Property adverse to Claimants title to the Property, Does 1 through 50 inclusive.

VERIFIED STATEMENTS IN SUPPORT OF CLAIM

12. Claimant is facing the pending loss of his home through foreclosure initiated and advanced by Respondents
without any verified proof of standing that would be provided by a verified Corporate Assignment of Deed of Trust.

13. On or about September 28, 2004, Claimant executed and delivered to Washington Mutual Bank, FA a written
promissory note in the amount of $325.000.00 along with a deed of trust securing Washington Mutual Bank's interests.

14. Claimant is informed, and after completing a search of the www.secinfo.com website, and the www.edgr.com
( Edgar Online), he that his promissory note was sold by Washington Mutual Bank, FA, to WaMu Mortgage Pass-Through Certificates Series 2005-AR1 Trust. And as of January 1, 2005, WaMu Mortgage Pass-Through Certificates Series 2005-AR1 Trust was the owner of the note and the only beneficiary under the deed of trust.

15. An Assignment of Deed of Trust dated September 14, 2011., showing JPMorgan Chase Bank N.A., as
successor in interest to Washington Mutual Bank, FA, purports to assigns its beneficial interests in the deed of trust to WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 Trust. The assignment is void and improper. JPMorgan has no right or interest in the promissory note as of September 28, 2004, and such purported assignment is void due to the following; a) There is no recorded assignment of the trust deed from Washington Mutual Bank, FA, to WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1, the holder of the note, as required under California Civil Code 2932.5. Section 2932.5 provides that where a power of sale for real property is given to a mortgagee or other encumbrances to secure an obligation,

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such power of sale may be exercised by an assignee only if the assignment is duly acknowledged and recorded. There is no proper assignment of the deed of trust to the holder-in-due-course of the note. b) Claimant is informed, and after completing a search of the www.secinfo.com website, and the www.edgr.com (Edgar Online), the WAMU Mortgage Pass-Through Certificates Series 2005-PR1 Trust cannot be found in the Edgar Online database, nor can it be found in the SEC Info database. c) JPMorgan has no legal authority to draft trust-deed assignments relating to the loan. JPMorgan is presently bound by a Consent Order, #AA-EC-1 1-15, with the United States of America Department of the Treasury, Comptroller of the Currency related to its initiation and handling of foreclosure proceedings. The Consent Order is based in part on foreclosure affidavits that have been found to be false. JPMorgan presently manages approximately 6.3 million residential mortgage loans in which it has litigated numerous wrongful foreclosure proceedings and initiated non-judicial foreclosure proceedings without proper standing.

16. On information and belief, neither WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage PassThrough Certificates Series 2005-PR1, nor JPMorgan Chase Bank N.A. had any interest in the foregoing notes, Deed of Trust, or Property.

17. On or about September 16, 2011, California Reconveyance recorded a Notice of Default and of Election to
Sell, document number 2011-111555, in the Official Records of San Joaquin County, California alleging that a breach of the obligation secured by the deed of trust had occurred, consisting of Claimant's alleged failure to pay certain amounts of principal and interest.

18. The Notice of Trustee's Sale recorded on or about December 12, 2012, is fatally defective on its face.
Washington Mutual Bank, FA, cannot be a beneficiary under the note as of September 25, 2008, the date Washington Mutual Bank, F. A. was seized by the FDIC. Washington Mutual Bank, F. A., ceased to exist in 2005 according to the 2005 10-K filed by Washington Mutual Inc.. The Notice of Trustee's Sale is fatally defective because no valid declaration and demand for sale have been executed and delivered to California Reconveyance, by Washington Mutual Bank, FA, nor attached to the Notice of Trustee's Sale recorded on December 12, 2012. 19. Despite the Claimant's efforts, JPMorgan Chase Bank N. A. and WELLS FARGO BANK, N. A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 Trust has refused to work in any reasonable way to modify the loan or avoid foreclosure proceedings.

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20. On March 2, 2013, Claimant produced multiple instruments for JP Morgan Chase, including TENDER OF
PAYMENT/PROMISSORY NOTE-UNCONDITIONAL PROMISE TO PAY, and a VERIFIED NOTICE OF TENDER OF PAYMENT and a REQUEST REGARDING A STATEMENT OF ACCOUNT. a) Tender of Payment was in the amount of Three Hundred Eighty Six Thousand Five Hundred Dollars ($386,500.00), dated March 2, 2013, with Instrument Number: SO-681116075-2013. b) Claimant stated terms and conditions for the Defendant to return the Tender of Payment as following: If the enclosed instruments contain any defects or are incorrect, incomplete, or inaccurate, please return the same to the Principal at the address shown above within 15 days

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from the date of receipt. and also stated: ..this is a record authenticated by the debtor requesting that the recipient approve or correct a statement indicating what the debtor believes to be the aggregate amount of unpaid obligations secured by collateral as of a specified date and reasonably indentifying the transactions or relationship that is the subject of the request. Recipient has ten (10) days to comply with this request and provide an authenticated record.

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c) On March 11, 2013, Claimant delivered the instrument to JPMorgan chase sent by the United States Postal Office, hereinafter Carrier via USPS Registered Mail Return Receipt, Article No. RE979067125US herein enclosed in the VERIFIED ADMINISTRATIVE RECORD. Respondent was given Fifteen (15) days to respond. As of September 5, 2013, Respondent has failed to sufficiently respond. 22. Not knowing if he had made discharge of this obligation to the right party, on April 5, 2013, Claimant

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produced multiple instruments for Wells Fargo Bank, including TENDER OF PAYMENT/PROMISSORY NOTE-UNCONDITIONAL PROMISE TO PAY, and a VERIFIED NOTICE OF TENDER OF PAYMENT and a REQUEST REGARDING A STATEMENT OF ACCOUNT. a) Tender of Payment was in the amount of Three Hundred Ninety Nine Thousand Five Hundred Dollars ($399,500.00), dated April 5, 2013 with Instrument Number: WF-681116075-2013. b) Claimant stated terms and conditions for the Defendant to return the Tender of Payment as

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following: If the enclosed instruments contain any defects or are incorrect, incomplete, or inaccurate, please return the same to the Principal at the address shown above within 20 days from the date of receipt. .. this is a record authenticated by the debtor requesting that the recipient approve or correct a statement indicating what the debtor believes to be the aggregate amount of unpaid obligations

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secured by collateral as of a specified date and reasonably identifying the transactions or

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relationship that is the subject of the request. Recipient has twenty (20) days to comply with this request and provide an authenticated record. c) On April 16, 2013, Claimant delivered the instrument to Wells Fargo sent by the Carrier via USPS Registered Mail Return Receipt, Article No. RE979067187US, proof of mailing and receipt herein enclosed in the VERIFIED ADMINISTRATIVE RECORD. Wells Fargo was given Twenty (20) days to respond. As of September 5, 2013 Wells Fargo has failed to sufficiently respond.

23. Claimant has produced and delivered to CHASE BANK, WELLS FARGO AND CALIFORNIA
RECONVEYANCE COMPANY multiple instruments since February 2013, through United States Postal Service, via Registered, Certified mail, Certificates of mailing with return receipts and Affidavit of Mailings, for the Setoff, discharge and closure of the account No. 681116075. Evidences of mailing for CHASE BANK, WELLS FARGO AND CALIFORNIA RECONVEYANCE COMPANY are herein enclosed in the VERIFIED ADMINISTRATIVE RECORD.

24. Complete verified records of Respondents acquiescence and tacit agreement with all terms, conditions and
stipulations set forth within this Notice of Default in Dishonor, Consent to Judgment, the Presentment, and the Fault Notice, that have been submitted to this court for In camera judicial review. (EXHIBIT A) FIRST CAUSE OF ACTION Wrongful Foreclosure (As to All Respondents and DOES 1- 50)

25. Claimant reaffirms the above paragraphs 1-24, and brings this cause of action against all RESPONDENTS for
wrongful foreclosure.

26. California Civil Code 2924 requires that a non-judicial trustee sale shall not take place unless it is done on
behalf of the beneficiary of the deed of trust securing the note.

27. WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1
was not the beneficiary at the time of the purported assignment or at the time of the scheduled sale. California Reconveyance is not therefore acting on behalf of the legitimate beneficiary.

SECOND CAUSE OF ACTION Injunctive Relief (As to All Respondents and DOES 1- 50)

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I.

Claimant reaffirms and re-alleges the above paragraphs 1-27 and brings this cause of action against all RESPONDENTS. THIRD CAUSE OF ACTION Declatory Judgment (As to All Respondents and DOES 1- 50)

I.

Claimant reaffirms and re-alleges the above paragraphs 1-27 and brings this cause of action against all RESPONDENTS.

II.

California Reconveyance and WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage PassThrough Certificates Series 2005-PR1 intend to sell, unless restrained, the Property to Claimants great and irreparable injury in that if the sale takes place, Claimant will have no opportunity to redeem the Property and will forfeit it. The foreclosure sale is wrongful and should be enjoined by virtue of the facts stated here and in the VERIFIED ADMINISTRATIVE RECORD. Claimant has no other plain, speedy, or adequate remedy for the loss of his home, and a Declatory Judgment is necessary at this time to prevent irreparable loss to Claimants interests in the home. FOURTH CAUSE OF ACTION Slander of Title (As to All Respondents and DOES 1- 50) 29 Claimant reaffirms the above paragraphs 1-27 and brings this cause of action against California Reconveyance. 30 On or about, 09/06/2011, California Reconveyance willfully, maliciously, and without privilege, recorded a notice of default and election to sell, along with a purported assignment of deed of trust, in the official records of San Joaquin County, California. Publication of the false statements impaired the vendibility of the Property and damaged Claimant. 31 The publication is void in that California Reconveyance knew that Washington Mutual Bank, FA, and JPMorgan, had no beneficial interest in the Property as of September 06, 2011. And Claimant is entitled to Quiet Title. 32 Pursuant to Code Civ. Proc. 761.010, Claimant recorded a Notice of Pendency of Action, (Lis Pendens) shortly after obtaining a case number from the court clerk.

ELEMENTS OF THE ACTION TO QUIET TITLE, Code Civ. Proc. 761.020

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a. A description of the property as evidenced in Paragraph 1. b. Claimant is seeking a determination of Quiet Title due to adverse claims made by Respondents. c. Respondents claim an adverse interest in the property due to a Notice of Trustees Sale, recorded on 12/20/2012, instrument #2012-170155, and a Corporation Assignment of Deed of Trust recorded on 09/16/2011, instrument #2011-111554. d. The date as of which the determination is sought is 09/16/2011, the recording date of the assignment of deed, Grantors being JPMORGAN CHASE BANK N.A. to purported Grantee, WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 This date reflects when the purported beneficiary first initiated any claim to the property referenced above. e. Prayer, for the determination of the title of the Claimant, against the adverse claims. WHEREFORE, Claimant prays for Injunctive Relief, Declatory Judgment, and the determination of title as follows: 1) That the Respondent be required to set forth the nature of any verified claims to the land or premises, so that all adverse claims of the Respondent may be determined by the judgment of this Court. 2) Execute or cause to be executed a Notice of Rescission pursuant to the Assignment of Deed of Trust, recorded on or about 09/16/2011, in the Office of the San Joaquin County Recorder as Instrument No. 2011-111554; 3) Execute or cause to be executed a Notice of Rescission in accord with the Presentment and pursuant to the Notice of Default, recorded on or about 09/16/2011, in the Office of the San Joaquin County Recorder as Instrument No. 2011-111555; 4) Execute or cause to be executed a Notice of Rescission in accord with the Presentment and pursuant to the Notice of Trustees Sale, recorded on or about 12/20/2012, in the Office of the San Joaquin County Recorder as Instrument No. 2012-170155; 5) That it be declared and adjudged that the Respondent has no estate or interest whatever in or to said land or premises, or in or to any part thereof, and that the title of the Claimant is good and valid; whereby this court granting Quiet Title of the subject property to Claimant. 6) That the Respondent be forever enjoined and barred from asserting any claim whatever in or to the land or premises, or to any part thereof, adverse to Claimant. 7) That Claimant recovers its costs and attorneys fees incurred herein.

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8) For such other relief as the Court deems appropriate.

Respectfully submitted,

Signed: _____________________________________________________ Ramin Yavrom

Signed: _____________________________________________________ Catherine B. Yavrom

VERIFICATION OF CLAIM The undersigned Affiant, Ramin Yavrom Trustor, hereinafter, Affiant, does solemnly swear, declare under penalty of perjury and state as follows: All the facts herein are true, correct of my own personal knowledge. FURTHER THE AFFIANT SAYETH NOT IN WITNESS WHEREOF I hereunto set my hand and seal on this _________________ day of _________________, 2013, and hereby certify all the statements made above are true, correct and complete.

Signed: _____________________________________________________ Ramin Yavrom, Affiant

Signed: _____________________________________________________ Catherine B. Yavrom, Affiant

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JURAT State of California ) ) ss: County of San Joaquin )

Subscribed and sworn to (or affirmed) before me on this ________ day of _________________________, 2013, by ______________________________________ did personally appear before me, is known to be the natural woman or man operating in the requisite capacity for signature described herein, who executed the foregoing, acknowledged the contents thereof; and executed the same as her or him free act and deed. Subscribed and agreed to before the undersigned.

___________________________________ Notary My Commission expires: __________________________ (seal)

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[Claimant] [Claimant Street Address] [Claimant City State Zip] [Phone] [Fax] Fax

IN THE SUPERIOR COURT OF CALIFORNIA IN AND FOR SAN JOAQUIN COUNTY [Claimant] Claimant, v. WASHINGTON MUTUAL BANK, F.A.; JPMORGAN CHASE BANK N.A.; CALIFORNIA RECONVEYANCE COMPANY; WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 Trust; and all persons known and unknown claiming any legal or equitable right, title, estate, lien, or interest in Property adverse to Claimants title to the Property, Does 1 through 50 inclusive. Respondents.

CASE NO.:_________________________

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD IN SUPPORT OF ENFORCEMENT OF CLAIM

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

Claimants Ramin Yavrom and Catherine B Yavrom are people of San Joaquin County, California and submit this Summary of Verified Administrative Record, as the owners of the real property commonly known as 6344 Antler Ct., Stockton CA 95219.

Plain Statement of Facts Regarding, JPMORGAN CHASE N.A. On February 14, 2013, an Offer of Tender With Conditions Precedent, hereinafter Offer, was presented to Marianne Lake, dba as CFO JP Morgan Chase, hereinafter Respondent, for terms of setoff, settlement, and closure of Account No. 681116075, sent via United States Post Office, Registered Mail No. RB847595511US. A verified response in answer to the Offer was requested. No verified response was

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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forthcoming in the time allotted in the Offer. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On March 2, 2013, Claimant tendered a payment, and presented an Unconditional Promissory Note, and a Request Regarding a Statement of Account, to Respondent for setoff, settlement, and closure of the Account, sent USPS Registered Mail No.RE979067125US. Claimant requested that if the tender was defective on its face, or a notice of dishonor was issued, the tender was to be returned to Claimant for corrective measures. A verified response in answer to the Presentment was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

The Request Regarding a Statement of Account was presented along with the Promissory Note. The Statement indicated a Zero ($0.00) balance as reflected by the tender of payment. The Claimant requested that the Respondent approve or correct the statement indicating what the Claimant believes to be the aggregate amount of unpaid obligations. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On March 25, 2013, a Notice of Fault in Dishonor with Opportunity to Cure, hereinafter Notice of Fault, was presented to Respondent, for terms of setoff, settlement, and closure of Account No. 681116075, sent via United States Post Office, Registered Mail, Article No. RB979067173US. A verified response in answer to the Notice of Fault was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On April 5, 2013, a Request To Return Promissory Note, hereinafter, Request to Return, was presented to Respondent, sent via United States Post Office, Registered Mail No.RE979067160US. A verified response in answer to the Notice of Fault was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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On May 30, 2013, a NOTICE OF DEFAULT IN DISHONOR with CONSENT TO JUDGMENT was presented to Respondent, sent via United States Post Office, Registered Mail No. RA101867231US. A verified response in answer to the Notice of Fault was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment including Consent to Judgment.

On June 22, 2013, an arms length Third Party Witness, hereinafter Witness, reviewed and examined the foregoing Presentments, hereinafter Record in their entirety, including all enclosures. After the examination and gaining firsthand knowledge of the Record and all enclosures, the Witness Re-presented the Record with all enclosures previously presented by Claimant, to the Respondent for setoff, settlement, and closure of the Account, The Re-presentment of the Record was sent by USPS via Registered Mail, Article No. RA101867700US. A verified response in answer to the Re-presentment of the Record was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Record, including Consent to Judgment.

Plain Statement of Facts Regarding WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage PassThrough Certificates Series 2005-PR1 Trust On April 5, 2013, an Offer of Tender With Conditions Precedent, hereinafter Offer, was presented to Timothy J. Sloan dba as CFO, Wells Fargo Bank N.A., Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 Trust, hereinafter Respondent, for terms of setoff, settlement, and closure of Account No. 681116075, sent via United States Post Office, Registered Mail No. RB979067187US. A verified response in answer to the Offer was requested. No verified response was forthcoming in the time allotted in the Offer. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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On April 5, 2013, Claimant tendered a payment, and presented an Unconditional Promissory Note, and a Request Regarding a Statement of Account, to Respondent for setoff, settlement, and closure of the Account, sent USPS Registered Mail No.RE979067187US. Claimant requested that if the tender was defective on its face, or a notice of dishonor was issued, the tender was to be returned to Claimant for corrective measures. A verified response in answer to the Presentment was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

The Request Regarding a Statement of Account was presented along with the Promissory Note. The Statement indicated a Zero ($0.00) balance as reflected by the tender of payment. The Claimant requested that the Respondent approve or correct the statement indicating what the Claimant believes to be the aggregate amount of unpaid obligations. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On May 8, 2013, a Notice of Fault in Dishonor with Opportunity to Cure, hereinafter Notice of Fault, was presented to Respondent, for terms of setoff, settlement, and closure of Account No. 681116075, sent via United States Post Office, Registered Mail, Article No. RB847595499US. A verified response in answer to the Notice of Fault was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On May 30, 2013, a NOTICE OF DEFAULT IN DISHONOR with CONSENT TO JUDGMENT was presented to Respondent, sent via United States Post Office, Registered Mail No. RA101867259US. A verified response in answer to the Notice of Fault was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment including Consent to Judgment.

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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On June 22, 2013, an arms length Third Party Witness, hereinafter Witness, reviewed and examined the foregoing Presentments, hereinafter Record in their entirety, including all enclosures. After the examination and gaining firsthand knowledge of the Record and all enclosures, the Witness Re-presented the Record with all enclosures previously presented by Claimant, to the Respondent for setoff, settlement, and closure of the Account, The Re-presentment of the Record was sent by USPS via Registered Mail, Article No. RA101867727US. A verified response in answer to the Re-presentment of the Record was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Record, including Consent to Judgment.

Plain Statement of Facts Regarding, CALIFORNIA RECONVEYANCE COMPANY On February 14, 2013, a COPY of the Offer of Tender With Conditions Precedent, hereinafter Offer, was presented to Deborah Brignac, dba as Vice President California Reconveyance Company, hereinafter Respondent, as confirmation of the terms of setoff, settlement, and closure of Account No. 681116075, and sent via United States Post Office, Registered Mail No. RB847595508US. A verified response to confirm and acknowledge receipt was requested. No verified response was forthcoming in the time allotted in the Offer. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On March 15, 2013, Claimant presented to Respondent a COPY of Unconditional Promissory Note, including Notice of Non-Response and Opportunity to Cure, and a COPY of the presentment made to JPMORGAN CHASE BANK N.A. for setoff, settlement, and closure of the Account, sent via USPS Registered Mail No.RE979067195US. A verified response in answer to the Presentment was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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On April 5, 2013, a NOTICE OF TENDER OF PAYMENT IN FULL AND CEASE AND DESIST, hereinafter Notice to Cease and Desist, was presented to Respondent, requesting to cease and desist any and all foreclosure activity concerning the real property commonly known as 6344 Antler Ct., Stockton CA 95219, Account No. 681116075, sent via United States Post Office, Registered Mail, Article No. RE979067142US. A verified response in answer to the Notice to Cease and Desist was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On May 8, 2013, a NOTICE OF FAULT IN DISHONOR and OPPORTUNITY to CURE, hereinafter, Notice of Fault, was presented to Respondent, sent via United States Post Office, Registered Mail No.RB847595471US. A verified response in answer to the Notice of Fault was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment.

On May 30, 2013, a NOTICE OF DEFAULT IN DISHONOR with CONSENT TO JUDGMENT was presented to Respondent, sent via United States Post Office, Registered Mail No. RA101867245US. A verified response in answer to the Notice of Fault was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Presentment including Consent to Judgment.

On June 22, 2013, an arms length Third Party Witness, hereinafter Witness, reviewed and examined the foregoing Presentments, hereinafter Record in their entirety, including all enclosures. After the examination and gaining firsthand knowledge of the Record and all enclosures, the Witness Re-presented the Record with all enclosures previously presented by Claimant, to the Respondent for setoff, settlement, and closure of the Account, The Re-presentment of the Record was sent by USPS via Registered Mail, Article No. RA101867713US. A verified response in answer to the Re-presentment of the Record was requested. No verified response was forthcoming in the time allotted. Respondents failure to perform in good faith and the

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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Respondents acquiescence and tacit agreement with all terms, conditions and stipulations set forth within the Record, including Consent to Judgment.

Respectfully submitted,

Signed: _____________________________________________________ Ramin Yavrom

Signed: _____________________________________________________ Catherine B. Yavrom

VERIFICATION OF SUMMARY The undersigned Affiant, Ramin Yavrom Trustor, hereinafter, Affiant, does solemnly swear, declare under penalty of perjury and state as follows: All the facts herein are true, correct of my own personal knowledge. FURTHER THE AFFIANT SAYETH NOT IN WITNESS WHEREOF I hereunto set my hand and seal on this _________________ day of _________________, 2013, and hereby certify all the statements made above are true, correct and complete.

Signed: _____________________________________________________ Ramin Yavrom, Affiant

Signed: _____________________________________________________ Catherine B. Yavrom, Affiant

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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JURAT State of California ) ) ss: County of San Joaquin )

Subscribed and sworn to (or affirmed) before me on this ________ day of _________________________, 2013, by ______________________________________ did personally appear before me, is known to be the natural woman or man operating in the requisite capacity for signature described herein, who executed the foregoing, acknowledged the contents thereof; and executed the same as her or him free act and deed. Subscribed and agreed to before the undersigned.

___________________________________ Notary My Commission expires: __________________________ (seal)

SUMMARY OF VERIFIED ADMINISTRATIVE RECORD

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[Claimant] [Claimant Street Address] [Claimant City State Zip] [Phone] [Fax] Fax

IN THE SUPERIOR COURT OF CALIFORNIA IN AND FOR SAN JOAQUIN COUNTY [Claimant]

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Claimant, v. WASHINGTON MUTUAL BANK, F.A.; JPMORGAN CHASE BANK N.A.; CALIFORNIA RECONVEYANCE COMPANY; WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 Trust; and all persons known and unknown claiming any legal or equitable right, title, estate, lien, or interest in Property adverse to Claimants title to the Property, Does 1 through 50 inclusive. Respondents.

CASE NO.:

REQUEST FOR JUDICIAL NOTICE AND REVIEW OF VERIFIED ADMINISTRATIVE RECORD,

Ramin Yavrom, hereinafter "Claimant" is one of the people of San Joaquin County, and the State of California, and in this court of record: Hereby requests that the Court take judicial notice and review of the following documents attached as Exhibits A through E, inclusive. This request is made pursuant to Rule 201 of the Federal Rules of Evidence and the authorities cited below. This request is made in connection with the Complaint for Action to Quiet Title.

BASIS FOR REQUESTING JUDICIAL NOTICE

When a court takes judicial notice of a certain fact, it obviates the need for parties to prove the fact in court. Ordinarily, facts that relate to a case must be presented to the judge or jury through testimony or tangible evidence. However, if each fact in a case had to be proved through such presentation, the simplest case

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would take weeks to complete. To avoid burdening the judicial system, all legislatures have approved court rules that allow a court to recognize facts that constitute common knowledge without requiring proof from the parties. On the federal trial court level, judicial notice is recognized in rule 201 of the Federal Rules of Evidence for U.S. District Courts and Magistrates. Rule 201 provides, in part, that "[a] judicially noticed fact must be one not subject to reasonable dispute in that it is either (1) generally known within the territorial jurisdiction of the trial court or (2) capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned." For the foregoing reasons, the Court may properly consider the exhibits.

EXHIBIT A B C D E

DESCRIPTION Verified Administrative Record, Submitted In camera for Judicial Review Assignment of Deed of Trust, document number 2011-111554, recorded 09/16/2011 Notice of Default, document number 2011-111555, recorded 09/16/2011 Notice of Trustees, Sale document number 2012-170155, recorded 12/20/2012 Consent Order, #AA-EC-1 1-15, Amendment to Consent Order, #AA-EC-1 1-15 Amends #2011-050

Ramin Yavrom, hereinafter Claimant, request that this Court take judicial notice of the exhibits A through E, inclusive, to demonstrate that the Enforcement of the Civil Claim has merit and sets forth positions consistent with the enforcement of said claim.

Respectfully submitted, Signed: _____________________________________________________ Ramin Yavrom

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EXHIBIT A

Verified Administrative Record, Submitted In camera for Judicial Review

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EXHIBIT B

Assignment of Deed of Trust, document number 2011-111554, recorded 09/16/2011

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EXHIBIT C

Notice of Default, document number 2011-111555, recorded 09/16/2011

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EXHIBIT D

Notice of Trustees, Sale document number 2012-170155, recorded 12/20/2012

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EXHIBIT E

Consent Order, #AA-EC-1 1-15

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[Claimant] [Claimant Street Address] [Claimant City State Zip] [Phone] [Fax] Fax IN THE SUPERIOR COURT OF CALIFORNIA IN AND FOR SAN JOAQUIN COUNTY [Claimant] Claimant, v. WASHINGTON MUTUAL BANK, F.A.; JPMORGAN CHASE BANK N.A.; CALIFORNIA RECONVEYANCE COMPANY; WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST; and all persons known and unknown claiming any legal or equitable right, title, estate, lien, or interest in Property adverse to Claimants title to the Property, Does 1 through 50 inclusive. Respondents. AFFIDAVIT OF TRUTH CASE NO.:

AFFIDAVIT OF TRUTH In Reference to:

Property commonly known as; 6344 Antler Ct., Stockton CA 95219 APN Number: 066-290-33 Ramin Yavrom (Trustor) Loan/Account #: 681116075

For The Record

The undersigned Affiant, Ramin Yavrom, Trustor and alleged Borrowers, hereinafter, Affiant, does solemnly swear, declare under penalty of perjury and state as follows: 1. Affiant is competent to state the matters set forth herein.

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2. Affiant has knowledge of the facts stated herein.

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AFFIDAVIT OF TRUTH

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3. All the facts herein are true, correct and complete, admissible as evidence, and if called upon as a witness, Affiant will testify to their veracity. 4. Affiant has submitted for Judicial Review In camera, a verified administrative record, as admissible evidence supporting the Plain Statement of Facts below. There is no verified evidence that JPMORGAN CHASE BANK N.A. has provided a verified response to Affiant regarding Affiants verified requests for a response to Affiants Administrative Record. Affiant believes there is no proof to the contrary. 5. Affiant has submitted for Judicial Review In camera, a verified administrative record, as admissible evidence supporting the Plain Statement of Facts below. There is no verified evidence that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST has provided a verified response to Affiant regarding Affiants verified requests for a response to Affiants Administrative Record. Affiant believes there is no proof to the contrary.

Plain Statement of Facts

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1. There is no verified evidence that WASHINGTON MUTUAL BANK, F.A. had at any time, executed a Corporate Assignment of Deed of Trust to JPMORGAN CHASE BANK N.A. Affiant believes there is no proof to the contrary. 2. There is no verified evidence that JPMORGAN CHASE BANK N.A. had any standing at any time, to execute a Corporate Assignment of Deed of Trust in favor of WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST. Affiant believes there is no proof to the contrary. 3. There is no verified evidence that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST is the Note Holder in Due Course pursuant of U.C.C. - ARTICLE 3 -3-302 despite two Verification of Debt and Proof of Claim Requests demanding the Bank to stipulate and clarify this fact. Affiant believes there is no proof to the contrary. 4. There is no verified evidence that JPMORGAN CHASE BANK N.A. has the authority to enforce the contract through servicing and assignment, they have provided no proof of such authority despite two written requests via registered mail. There is no proof to the contrary. 5. WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST failed to stipulate that they are a Creditor in the contract to have subject matter jurisdiction in this matter, despite two requests demanding that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST stipulate and clarify this fact for the record. There is no verified evidence that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST suffered any loss in extending the alleged and purported debt to RAMIN YAVROM.

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AFFIDAVIT OF TRUTH

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6. There is no verified evidence of a defect in the negotiable instrument tendered for payment, hereinafter TENDER, of Ramin Yavrom account No. 681116075, hereinafter ACCOUNT, on or about September 11, 2013 to Marrianne Lake, CFO dba as JPMORGAN CHASE BANK N.A., and Affiant believes that no such evidence exists. 7. There is no verified evidence that JPMORGAN CHASE BANK N.A.s failure to respond to TENDER does not comprise JPMORGAN CHASE BANK N.A.s acceptance of TENDER and agreement with the terms set forth therein and Affiant believes that no such evidence exists. 8. There is no verified evidence of a defect in the negotiable instrument tendered for payment, hereinafter TENDER, of Ramin Yavrom account No. 681116075, hereinafter ACCOUNT, on or about September 11, 2013 to WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST, and Affiant believes that no such evidence exists. 9. There is no verified evidence that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUSTs failure to respond to TENDER does not comprise WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUSTs acceptance of TENDER and agreement with the terms set forth therein and Affiant believes that no such evidence exists. 10. There is no verified evidence that TENDER does not satisfy the obligations set forth in the Deed of Trust recorded October 4, 2004 with the County of San Joaquin as Instrument No. 2004-224957, and Affiant believes that no such evidence exists. 11. There is no evidence that JPMORGAN CHASE BANK N.A.s interest, set forth in TRUST DEED, in the real property commonly known as 6344 Antler Ct Stockton CA 95219 (County of San Joaquin Assessors Parcel No. 066-290-33), hereinafter PROPERTY, is not released by RECIPIENTs acceptance of TENDER, and Affiant believes that no such evidence exists. 12. There is no evidence that JPMORGAN CHASE BANK N.A.s acceptance of TENDER does not obligate JPMORGAN CHASE BANK N.A. to issue a Statement of Account showing a Zero ($0.00) Dollars balance for ACCOUNT and Affiant believes that no such evidence exists. 13. There is no evidence that JPMORGAN CHASE BANK N.A.s acceptance of TENDER does not obligate JPMORGAN CHASE BANK N.A. to take such steps necessary as to cause the full reconveyance of the deed of PROPERTY, and Affiant believes that no such evidence exists. 14. There is no evidence that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage PassThrough Certificates Series 2005-PR1 TRUSTs interest, set forth in TRUST DEED, in the real property commonly known as 6344 Antler Ct Stockton CA 95219 (County of San Joaquin
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AFFIDAVIT OF TRUTH

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Assessors Parcel No. 066-290-33), hereinafter PROPERTY, is not released by RECIPIENTs acceptance of TENDER, and Affiant believes that no such evidence exists. 15. There is no evidence that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage PassThrough Certificates Series 2005-PR1 TRUSTs acceptance of TENDER does not obligate WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST to issue a Statement of Account showing a Zero ($0.00) Dollars balance for ACCOUNT and Affiant believes that no such evidence exists. 16. There is no evidence that WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage PassThrough Certificates Series 2005-PR1 TRUSTs acceptance of TENDER does not obligate WELLS FARGO BANK, N.A. as Trustee for WAMU Mortgage Pass-Through Certificates Series 2005-PR1 TRUST to take such steps necessary as to cause the full reconveyance of the deed of PROPERTY, and Affiant believes that no such evidence exists.

VERIFICATION The undersigned Affiant, Ramin Yavrom Trustor, hereinafter, Affiant, does solemnly swear, declare under penalty of perjury and state as follows: 1. All the facts herein are true, correct of my own personal knowledge. FURTHER THE AFFIANT SAYETH NOT IN WITNESS WHEREOF I hereunto set my hand and seal on this _________________ day of _________________, 2013, and hereby certify all the statements made above are true, correct and complete.

Signed: _____________________________________________________ Ramin Yavrom, Affiant

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AFFIDAVIT OF TRUTH

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JURAT

State of California County of San Joaquin

) ) ss: )

Subscribed and sworn to (or affirmed) before me on this ________ day of

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_________________________, 2013, by ______________________________________ did personally appear before me, is known to be the natural woman or man operating in the requisite capacity for signature described herein, who executed the foregoing, acknowledged the contents thereof; and executed the same as her or him free act and deed. Subscribed and agreed to before the undersigned. ___________________________________ Notary (seal)

My Commission expires:

__________________________

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AFFIDAVIT OF TRUTH