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STATE OF SOUTH CAROLINA
ISSUED BY THE CIRCUIT COURT IN THE COUNTY OF GREENVILLE
AVELINA BOLTIADOR WILEY, Plaintiff
aKa
v. SUBPOENA IN A CIVIL CASE
Statebridge Company LLC, et al., Defendant Case Number: 2023-CP-23-04 194 Le
eh
piper sanereese Pending in Los Angeles (CA) County
TO: RESURGENT CAPITAL SERVICES L.P.. 55 BEATTIE PLACE, SUITE 110 MS 250, GREENVILLE, SC 29601) S21
{J YOU ARE COMMANDED to appear in the above named court at the place, and time specified below to testify in the
above case.
PLACE OF TESTIMONY | COURTROOM
DATE AND TIME 2 AM
CJ YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a
deposition in the above case.
PLACE OF DEPOSITION DATE AND TIME : AM
— a
EX] YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or abjects in
your possession, custody or control at the place, date and time specified below (list documents of objects:
See Attachment “4”
PLACE DATE AND TIME > AM
[] YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below.
PREMISES DATE AND TIME 5 AM
—_ a
ANY SUBPOENAED ORGANIZATION NOT A PARTY TO THIS [$ HEREBY DIRECFED TO RULE 30(by6). SOUTH CAROLINA RULES OF
CIVIL PROCEDURE. TO FILE A DESKGNATION WETH THE COURT YING ONE OR MORE OFFICERS. DIRECTORS, OR MANAGING
AGENTS, OR OTHER PERSONS WHO CONSENT TO TESTIFY ON {7 § BEHALF, SHALL SET FORTH, FOR EACH PERSON DESIGNATED,
THE MATTERS ON WHICH HE WILL TESTIFY OR PRODUCE DOCUMENTS OR THINGS. ‘THE PERSON SO DESIGNATED TESTIEY AS FO
MATTERS KNOWN OR REASONABLY AVAILABLE TO TIE ORGANIZATION
I CERTIFY THAT THE SUBPOENA IS ISSUED IN COMPLIANCE WITH RULE 45(c\}), AND THAT NOTICE AS REQUIRED BY RULE 45(b)(1) HAS BEEN
GIVEN TO ALL PARTIES.
Sept 14, 2023 Jier Dong. Esq.
Attomey/Issuing Officer's Signature Date Print Name
Indicate 1f Atiomey for Plaintull or Defendant
Attomey's Address and Telephone Number
Jigr Dong, Esq. (atorey for Defendants and Cross-Complainant)
4665 MacArthur Court, Suite 200, Newport Beach, CA 92660
La, q law Jaoa3 Boece Garrett
R suing Office Signature Date Print Name
5 hose Titigant’s Name, Address and Telephone Number
—
SCCA 254 (05/2015) (See Rule 45, South Carolina Rules of Civil Procedure, Parts (¢) & (4) on pages 2 and 3)
PROOF OF SERVICE
SERVED DATE FEES AND MILEAGE TO BE TENDERED TO WITNESS UPON
DAILY ARRIVAL,
PLACE
Oves Ono AMOUNT $
SERVED ON MANNER OF SERVICE
SERVED BY THLE
DECLARATION OF SERVER
| certify that the foregoing information contained in the Proof of Service is true and correct.
Executed on,
SIGNATURE OF SERVER
ADDRESS OF SERVER
Rule 45, South Carolina Rules of Civil Procedures, Parts (c) and (d):
{c) Protection of Persons Subject to Subpoenas.
(1) A party or an attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue burden or
expense on a person subject to that subpoena. The court on behalfof which the subpoena was issued shall enforce this duty and impose upon the party
or attorney in breach of this duty an appropriate sanction, which may include, but is not limited to, lost earnings and a reasonable altorney's fee.
(2)(A) A person commanded to produce and permit inspection and copying of designated electronically stored information, books, papers, documents or
tangible things, oF inspection of premises need not appear in person at the place of production or inspection unless commanded to appear for
deposition, hearing or trial. A party or an attorney responsible for the issuance and service of a subpoena for production of books, papers and
documents without a deposition shall provide to another party copies of documents so produced upon written request. The party requesting copies shall
pay the reasonable costs of reproduction.
(B) Subject to paragraph (d)(2) of this rule, a person commanded to produce and permit inspection and copying may, within 14 days after service of the
subpoena or before the time specified for compliance if such time is less than 14 days after service, serve upon the party or attorney designated in the
subpoena written objection to inspection or copying of any or all of the designated materials or of the premises—or to producing electronically stored
information in the form or forms requested. If objection is made, the party serving the subpoena shall not be entitled to inspect and copy the materials or
inspect the premises except pursuant to an order of the court by which the subpoena was issued. If objection has been made, the pasty serving the
subpoena may, upon notice to the person commanded to produce, move at any time in the court that issued the subpoena for an order to compel the
production. Such an order to compel production shall protect any person who is not a party or an officer of a party from significant expense resulting from
the inspection and copying commanded
(3)(A) On timely motion, the court by which @ subpoena was issued, or regarding a subpoena commanding appearance at a deposition, or production or
inspection directed to a non-party, the court in the county where the non-party resides, is employed or regularly transacts business in person, shail
quash or modify the subpoena if it:
(i) fails to allow reasonable time for compliance; or
(ii) requires a person who is not a party nor an officer, director or managing agent of a party, nor a general partner of a partnership that is a party, to
trave! more than 50 miles from the county where that person resides, is employed or regularly transacts business in person, except that, subject to the
provisions of clause (c}(3)(B)(iii) of this rule, such a person may in order to attend trial be commanded to travel from any such place within the state in
which the trial is held, or
(iii) requires disclosure of privileged or otherwise protected matter and no exception or waiver applies; or
(iv) subjects a person to undue burden
(B) If a subpoena
{i) requires disclosure of a trade secret or other confidential research, development, or commercial information, or
{ii} requires disclosure of an unretained expert's opinion or information not describing specific events or occurrences in dispute and resulting from the
expert's study made not at the request of any party, or
SCCA 254 (05/2015) (See Rule 45, South Carotina Rules of Civil Procedure, Parts (c) & (d) on pages 2 and 3)
requires a person who is not a party nor an officer, director or managing agent of a party, nor a generat partner of a partnership that is a party, to
incur substantial expense to travel from the county where that person resides, is employed or regularly transacts business in person, the court may, to
protect a person subject to or affected by the subpoena, quash or modify the subpoena or, if the party in whose behalf the subpoena is issued shows a
substantial need for the testimony or material that cannot be otherwise met without undue hardship and assures that the person to whom the subpoena
is addressed will be reasonably compensated, the court may order appearance or production only upon specified conditions.
{da} Duties in Responding to Subpoena.
(1){A)A person responding to a subpoena to produce documents shall produce them as they are kept in the usuai course of business or shall organize
and label them to correspond with the categories in the demand.
(B) If a subpoena does not specify the form or forms for producing electronically stored information, a person responding to a subpoena must produce
the information in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.
(C) A person responding to a subpoena need not produce the same electronically stored information in more than one form.
(0) A person responding to a subpoena need not provide discovery of electronically stored information from sources that the person identifies as not
Teasonably accessible because of undue burden or cost. On motion to compel discovery or to quash, the person from whom discovery is sought must
show that the information sought is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless
order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(6)(B). The court may specify
conditions for the discovery
(2)(A) When information subject to a subpoena is withheld on a claim that it is privileged or subject to protection as trial preparation materials, the claim
shall be made expressly and shall be supported by a description of the nature of the documents, communications, or things not produced that is
sufficient to enable the demanding party to contest the claim.
(B} If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial preparation material, the person making
the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester,
or destroy the specified information and any copies it has and may not use or disclose the information until the claim is resolved. A receiving party may
promptly present the information to the court under seal for a determination of the claim. If the receiving party disclosed the information before being
Notified, the receiving party must take reasonable steps to retrieve the information. The person who produced the information must preserve the
information until the claim is resolved.
SCCA 254 (05/2015) (See Rule 45, South Carolina Rules of Civil Procedure, Paris (c) & (d) on pages 2 and 3)
MC-025
SHORT TITLE: CASE NUMBER:
{ Avelina Boltiador Wiley v. Statebridge Company LLC et al. 22CMCV00416
ATTACHMENT (Number): 4
(This Attachment may be used with any Judicial Council form.)
The records to be produced as follows:
1. Your entire loan file for the LOAN.
The term “LOAN” is means and refers to the account belonging to Avelina Wiley and assigned loan number
1844313 (or 0537013700), with the real property address 429 E. 212th St., Carson, CA 90745.
2. All documents demonstrating, evidencing, or otherwise relating to all payments made on the LOAN since
origination until December 22, 2020 including, but not limited to, copies of cancelled checks, documents
evidencing any wire transfers or clectronic transfers, etc.
3. All payment coupons for the LOAN.
4. A true and correct copy of the origination file, including, but not limited to, copies of the note, the deed of
trust, assignments of the deed of trust, and of the title policy.
5. A true and correct copy of the loan application for the LOAN.
6, True and correct copies of the preliminary and final HUD-1 statements.
7. All documents that relate to or tend to relate to the origination of the LOAN.
8. All documents demonstrating, evidencing, or otherwise relating to all servicing notes for the LOAN.
9. All documents demonstrating, evidencing, or otherwise relating to all payment histories for the LOAN.
10. All correspondence between YOU, YOUR servicing agent, or any prior servicer of the LOAN and the
borrower(s) related to the LOAN or the PROPERTY.
The term “PROPERTY” is means and refers to the real property address 429 E. 212th St., Carson, CA 90745.
11. All “hello” and “goodbye” letters for the LOAN.
12. All notices of sale, transfer, or assignment of the LOAN.
(if the item that this Attachment concerns is made under penaity of perjury, all statements in this Page of
Aitachment are made under penaity of perjury.)
(Add pages as required)
Form Approved for Optional Use ATTACHMENT ‘wwew.courtinfo.ce gov
Judicial Councit of California
MC-025 [Rev. July 1, 2009] to Judicial Council Form
Listing of the Names, Addresses, and Telephone Numbers of All Counsel of Record in the Proceeding
(No Unrepresented Party)
Peter Paul Mendel, Esq.
Law Offices of Peter Paul Mendel
1900 East Ocean Boulevard, Suite 401
Long Beach, CA 90802
310-745-3664
ppmlawmatters@gmail.com
Attorney for Plaintiff, Avelina Boltiador Wiley
Lukasz I. Wozniak, Esq.
Jier Dong, Esq.
Wright, Finlay & Zak, LLP
4665 MacArthur Court, Suite 200
Newport Beach, CA 92660
949-477-5050
jdong@wrightlegal.net
Attorneys for Defendants and Cross-Complainant, Statebridge Company, LLC and Wilmington Savings
Fund Society, FSB, d/b/a Christiana Trust as Trustee for PNPMS Trust I
SUBP-010
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
LWRIGHT. FINLAY & ZAK. LI
Jier Dong, Esq., N 34 OI
4665 MacArthur Court, Suite 2 80. Newport f Beagh, 4
0 2660
TELEPHONENC: (949) 477-505 8-91.42 &
4 f4
EMalt ADDRESS: idong@wrightlegal.net
arrornevrorer*”’ Defendants Statebridge and Wilminaton et al.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
83
STREET ADDRESS: 200 West Compton Blvd.
MAILING ADDRESS: same as above
CITY AND ZiP CODE:Compton, CA 90220
BRANCH NAME: Compton Courthouse
PLAINTIFF/PETITIONER: Avelina Boltiador Wiley
DEFENDANTIRESPONDENT: [Statebridge Company LLC et al. 2023-CP-23-04
‘CASE NUMBER:
JY
DEPOSITION SUBPOENA
FOR PRODUCTION OF BUSINESS RECORDS 22CMCV00416
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, if known):
Resurgent Capital Services L.P., 55 Beattie Place, Suite 110 MS 250, Greenville, SC 29601
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3, as follows:
To (name of deposition officer): Jier Dong, Esq.
On (date): October 31, 2023 At (time): 10:00 a.m.
Location (address): 4665 MacArthur Court, Suite 200, Newport Beach, CA 92660
Do not release the requested records to the deposition officer prior to the date and time stated above.
a. L__] by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed inner
wrapper with the title and number of the action, name of witness, and date of subpoena clearly written on it. The inner
wrapper shail then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the
address in item 1.
b. [4] by delivering a true, legible, and durable copy of the business records described in item 3 to the deposition officer at the
witness's address, on receipt of payment in cash or by check of the reasonable costs of preparing the copy, as determined
under Evidence Code section 1563(b).
c. [_] by making the original business records described in item 3 available for inspection at your business address by the
attorney's representative and permitting copying at your business address under reasonable conditions during normal
business hours.
2. The records are to be produced by the date and time shown in item 1 (but not sooner than 20 days after the issuance of the
deposition subpoena, or 15 days after service, whichever date is later). Reasonable costs of focating records, making them
available or copying them, and postage, if any, are recoverable as set forth in Evidence Cade section 1563(b). The records shall be
accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561.
The records to be produced are described as follows (if electronically stored information is demanded, the form or
forms in which each type of information is to be produced may be specified):
SEE ATTACHMENT 3
(J Continued on Attachment 3.
4. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER
CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN
SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE
AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE RECORDS.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
ate issued: September 14, 2023
Jier Dong, Esq.
(TYPE OR PRINT NAME)
» )\ ee or
OUSIGNATURE OF PERSON ISSUING SUBPOENA}
Attorneys for Defendants
(Proofof service on reverse) (TLE) Page 1 of 2
Foon Adopted lor Mandatory Use DEPOSITION SUBPOENA FOR PRODUCTION Code of Civil Procecure, §§ 2020.410-2020 449;
‘Judicial Council ef California Govemment Code, § 68087 1
‘SUBP.010 [Rev. January 1, 2012] OF BUSINESS RECORDS wnw.caurts.ca.gov
SUBP-010
PLAINTIFF/PETITIONER: Avelina Boltiador Wiley ‘CASE NUMBER:
22CMCV00416
DEFENDANTIRESPONDENT.[Statebridge Company LLC et al.
PROOF OF SERVICE OF DEPOSITION SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
. | served this Deposition Subpoena for Production of Business Records by personally delivering a copy to the person served
as follows:
a. Person served (name):
b. Address where served:
c. Date of delivery:
d. Time of delivery:
e. (1) [_] Witness fees were paid.
Amount:
(2) 7} Copying fees were paid.
Amount:
f. Fee for service:
2 | received this subpoena for service on (date);
3. Person serving:
(J Nota registered California process server.
{_] California sheriff or marshal.
[JJ Registered California process server.
[__] Employee or independent contractor of a registered California process server.
[—_] Exempt from registration under Business and Professions Code section 22350(b).
[} Registered professional photocopier.
{__] Exempt from registration under Business and Professions Code section 22451.
Name, address, telephone number, and, if applicable, county of registration and number:
\ declare under penalty of perjury under the jaws of the State of (For California sheriff or marshal use only)
California that the foregaing is true and correct. \ certify that the foregoing is true and correct.
Date: Date:
> »
(SIGNATURE) (SIGNATURE}
SUBP.010 [Rev. January 1, 2012] DEPOSITION SUBPOENA FOR PRODUCTION Page 20f2
OF BUSINESS RECORDS
MC-025
SHORT TITLE CASE NUMBER:
[~ Avelina Boltiador Wiley v. Statebridge Company LLC et al. 22CMCV00416
ATTACHMENT (Number). 3
(This Attachment may be used with any Judicial Council form.)
The records to be produced as follows:
1. Your entire loan file for the LOAN,
The term “LOAN” is means and refers to the account belonging to Avelina Wiley and assigned loan number
1844313 (or 0537013700), with the real property address 429 E, 212th St.. Carson, CA 90745.
2. All documents demonstrating, evidencing, or otherwise relating to all payments made on the LOAN since
origination until December 22, 2020 including, but not limited to, copies of cancelled checks, documents
evidencing any wire transfers or electronic transfers, etc.
3. All payment coupons for the LOAN.
4. A true and correct copy of the origination file, including, but not limited to, copies of the note, the deed of
trust, assignments of the deed of trust, and of the title policy.
5. A true and correct copy of the loan application for the LOAN.
6. True and correct copies of the preliminary and final HUD-1 statements.
7, All documents that relate to or tend to relate to the origination of the LOAN
§. All documents demonstrating, evidencing, or otherwise relating to all servicing notes for the LOAN.
9. All documents demonstrating, evidencing, or otherwise relating to all payment histories for the LOAN.
10, Ail correspondence between YOU, YOUR servicing agent, or any prior servicer of the LOAN and the
berrower(s) related to the LOAN or the PROPERTY,
The term “PROPERTY” is means and refers to the real property address 429 E, 212th St., Carson, CA 90745.
11. All “hello” and “goodbye” letters for the LOAN.
12. All notices of sale, transfer, or assignment of the LOAN.
{lf the item that this Attachment concerns is made under penalty of perjury, all statements in this Page
Attachment are made under penalty of perjury.)
(Aad pages as required)
Form Approved for Optional Use ATTACHMENT www COuRID.ca.gaV
ductcia’ Council of Calfarnia
MMC-025 [Rev July 1, 2009) to Judicial Council Form
DISC-030
[ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 246329 FOR GOURT USE ONLY
Name: Lukasz |. Wozniak, Esq.
FIRMNAME: Wright, Finlay & Zak, LLP
STREET ADDRESS: 4665 MacArthur Court, Suite 200 FILED het
e
city: Newport Beach state: CA ZIP COvE: 92660 Superior Court of California
untyof Los Angeles: cae
TELEPHONE NO: (949) 477-5050 FAXNO. (949) 608-9142 “i
EMAIL ADDRESS: |wozniak@wrightlegal.net 08/30/2023
ATTORNEY FOR (name): Defendants Statebridge and Wilmington et ai. Oud W. Siaytan, Exacutwe Officer { Ctert af Counts
C. Warren
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES. By. Deputy iD
Pe
STREET ADDRESS: 200 West Compton Blvd. Lr
ea
MAILING ADDRESS: same as above a
CITY AND ZIP CODE: Compton, CA 90220
BRANCH NAME, Compton Courthouse
SHORT TITLE:
Avelina Boltiador Wiley v. Statebridge Company LLC et al.
2023-CP-23- oury
COMMISSION TO TAKE DEPOSITION OUTSIDE CALIFORNIA CASE NUMBER,
(J ORDERED BY COURT [X JISSUED BY THE CLERK OF THE COURT 22CMCV00416
The Superior Court of Catifornia hereby authorizes the deposition, upon oral examination, of (identity of deponent):
RESURGENT CAPITAL SERVICES L.P., 55 BEATTIE PLACE, SUITE 110 MS 250, GREENVILLE, SC 29601
The deposition is to be taken in (state of the United States, territory, or insular possession subject to its jurisdiction):
SOUTH CAROLINA
The deposition will be conducted (check one):
a. [4¢] Under the supervision of a person who is authorized to administer oaths by the laws of the United States or those of the
place where the examination is to be held, and who is not otherwise disqualified under California Cade of Civil Procedure
sections 2025.320 and 2025.340(b)-{f); or
b. [] Before (name of appointee):
who is appointed to administer oaths and to take testimony.
The documents or things to be produced at the time and place of the deposition are
{543 described in Attachment 4 [[j none.
Additional terms required by the foreign jurisdiction to initiate the process are contained in Attachment 5, Number of pages
attached:
Under California Code of Civil Procedure section 2026.010, California authorizes that a commission to take an out-of-state
deposition may be issued by the clerk of the court or, if the foreign jurisdiction requires it, by order of the court.
The Superior Court of the State of California hereby requests that process issue in the above-referenced place where the
examination is to be held, requiring the attendance and enforcing the obligations of the deponent to produce documents and
answer questions,
\2G
ee i
4oo
Date: OBf30/2023
Michael Shultz f Judge
I Judge
OR
[[] Clerk, by , Deputy
Court Seal
Page 1 of t
Ferm Approved for Optional Use COMMISSION TO TAKE DEPOSITION Code Giv. Proc. § 2026.010(f}
Judicial Council of Califomia wonw.courts.ca.gov
DISC-090 [New January 1, 2008] OUTSIDE CALIFORNIA
MC-025
SHORT TITLE: CASE NUMBER:
| Avelina Boltiador Wiley v. Statebridge Company LLC et al. 22CMCV00416
ATTACHMENT (Number): 4
(This Attachment may be used with any Judicial Councit form.)
The records to be produced as follows:
1. Your entire loan file for the LOAN,
The term “LOAN” is means and refers to the account belonging to Avelina Wiley and assigned loan number
1844313 (or 0537013700), with the real property address 429 E. 212th St., Carson, CA 90745.
2. All documents demonstrating, evidencing, or otherwise relating to all payments made on the LOAN since
origination until December 22, 2020 including, but not limited to, copies of cancelled checks, documents
evidencing any wire transfers or electronic transfers, etc.
3. All payment coupons for the LOAN.
4. A true and correct copy of the origination file, including, but not limited to, copies of the note, the deed of
trust, assignments of the deed of trust, and of the title policy.
5. A true and correct copy of the loan application for the LOAN.
6, True and correct copies of the preliminary and final HUD-1 statements.
7. All documents that relate to or tend to relate to the origination of the LOAN.
8. All documents demonstrating, evidencing, or otherwise relating to all servicing notes for the LOAN.
9. All documents demonstrating, evidencing, or otherwise relating to all payment histories for the LOAN.
10. All correspondence between YOU, YOUR servicing agent, or any prior servicer of the LOAN and the
borrower(s) related to the LOAN or the PROPERTY.
The term “PROPERTY” is means and refers to the real property address 429 E. 212th St., Carson, CA 90745.
11. All “hello” and “goodbye” letters for the LOAN.
12. All notices of sale, transfer, or assignment of the LOAN.
(ff the item that this Attachment concerns is made under penalty of perjury, ail statements in this Page of
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use: ATTACHMENT wow courtinfo.ca gov
Judicial Council of Caltomia
MC-025 jRev. July 1, 2009) to Judicial Council Form
PROOF OF SERVICE
I, Jovete Elguira, declare as follows:
1am employed in the County of Orange, State of California. I am over the age of eighteen (18)
and not a party to the within action. My business address is 4665 MacArthur Court, Suite 200, Newport
Beach, California 92660. J am readily familiar with the practices of Wright, Finlay & Zak, LLP, for
collection and processing of correspondence for mailing with the United States Postal Service. Such
correspondence is deposited with the United States Postal Service the same day in the ordinary course of
business. I am aware that on motion of party served, service is presumed invalid if postal cancellation
date or postage meter date is more than one day after date of deposit for mailing in affidavit.
On August 1, 2023, I served the within COMMISSION TO TAKE DEPOSITION OUTSIDE
CALIFORNIA on all interested parties in this action as follows:
Peter Paul Mendel, Esq.
10
Law Offices of Peter Paul Mendel
Il 1900 East Ocean Boulevard, Suite 401
Long Beach, CA 90802
12 T: 310-745-3664 / F: 310-388-0809
Email: ppmlawmatters@gmail.com
13 Attorney for Plaintiff Avelina Boltiador Wiley
14
{] (BY MAIL SERVICE) I placed such envelope(s) for collection to be mailed on this date
15 following ordinary business practices.
16 {] (BY ELECTRONIC SERVICE) I caused electronic service of the documents to be made in
accordance with Local Rules, California Rules of Court 2.251 and Code of Civil Procedure
17 Section 1010.6, by transmittal to the email addresses of the parties listed above.
18
[x] (BY ONE LEGAL FILE AND SERVE) I caused the document(s) to be e-served through One
19 Legal File and Serve,
20 C] (BY FEDERAL EXPRESS OVERNIGHT- NEXT DAY DELIVERY) I placed true and correct
copies thereof enclosed in a package designated by Federal Express Overnight with the delivery
21 fees provided for.
22 [x] (State) I declare under penalty of perjury under the law of the State of California that the
foregoing is true and correct.
23
Executed on August 1, 2023, at Newport Beach, California.
24
25
26
J ove Elguira CY
27
28
PROOF OF SERVICE
“o~ >
STATE OF SOUTH CAROuNA
IN THE COURT OF COMMON PLEAS
COUNTY OF GREENVILLE
AVELINA BOLTIADOR WILEY CIVIL ACTION COVERSHEET =
Plaintiff(s)
2023 -CP- 23 _- O4TFY
vs.
)
STATEBRIDGE COMPANY LLC, ET AL. )
Defendant(s) } ce
ry
Submitted By: Jier Dong, Esq. (Defendants/Cross-Complainant) SC Bar #:CA 349490
Address: 4665 MacArthur Ct, #200, Newport Beach, CA 92660 Telephone #:949-477-5 143
Fax #: 149-608-9142
Other:
E-mail dong@wrightlegal.net
NOTE: The coversheet and information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by
jaw. This form is required for the use of the Clerk of Court for the purpose of docketing cases that are NOT E-Filed. [t must be filled out completely,
signed, and dated. A copy of this coversheet must be served on the defendant(s) along with the Summons and Complaini. This form is NOT required to
be filed in E-Filed Cases.
DOCKETING INFORMATION (Cheek all that apply)
“Uf Action is Judgmenv/Settlement do not complete
£] JURY TRIAL demanded in complaint. (0 NON-JURY TRIAL demanded in complaint.
C1 This case is subject to ARBITRATION pursuant to the Court Annexed Alternative Dispute Resolution Rules.
(} This case is subject to MEDIATION pursuant to the Court Annexed Alternative Dispute Resolution Rules.
(4 this case is exempt from ADR. (Certificate Attached)
NATURE OF ACTION (Check Qne Box Below)
Contracts Torts - Professional Malpractice Torts - Personal Injury Real Property
Constructions (100) C1 Dental Malpractive (200) Conversion (310) Claim & Delivery (400)
Debt Collection (110) Q Legal Malpractice (210) Motor Vehicle Accident (320} Condemnation (410)
General (130) a Medical Malpractice (220) Premises Liability (330) Foreclosure (420)
Breach of Contract (140) Previous Notice of Intent Case # Products Liability (340} Mechanic's Lien (430)
Fraud/Bad Faith (150) 20, -NI- > Personal Injury (350) Partition (440)
Failure to Deliver! go Notice/ File Med Mal (230) Wrongful Death (360) Possession (450)
Warranty (160) AssaulBattery (370)
O other (299) Building Code Violation (460)
Emptoyment Diserim (170) Slander/Libel (380) Other (499)
Empioyment (180) Other (399)
Other (199)
Inmate Petitions Administrative Law/Relict Judgments/Settlements Appeals
PCR (300) Reinstate Drv. License (800) Death Settlement (700) Arbitration (900)
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Submitting Party Signature: Date: Legit 14 Zor%
SCCA / 234 (04/2021) Page | of 2
o~
Note: Frivolous civil proceedings may be subject to sanctions pursuant to SCRCP, Ku..c 11, and the South Carolina Frivolous Civil
Proceedings Sanctions Act, $.C. Code Ann, §15-36-10 et. seq.
Effective January £, 2016, Alternative Dispute Resolution (ADR) is mandatory in all counties, pursuant
to Supreme Court Order dated November 12, 2015.
SUPREME COURT RULES REQUIRE THE SUBMISSION OF ALL CIVIL CASES TO AN ALTERNATIVE
DISPUTE RESOLUTION PROCESS, UNLESS OTHERWISE EXEMPT,
Pursuant to the ADR Rules, you are required to take the following action(s):
1 The parties shall select a neutral and fite a “Proof
of ADR” form on or by the 210" day of the filing ofthis
action. If the parties have not selected a neutral within 210 days, the Clerk of Court shall then appoint a
primary and secondary mediator from the current roster on a rotating basis from among those mediators
agreeing to accept cases in the county in which the action has been filed.
The initial ADR conference must be held within 300 days after the filing of the action.
Pre-suit medical malpractice mediations required by S.C. Code §15-79-125 shall be held not later than 120
days after all defendants are served with the “Notice of Intent to File Suit” or as the court directs,
Cases are exempt from ADR under ADR Rule 3() upon the following grounds:
a. Special proceeding, or actions seeking extraordinary relief such as mandamus, habeas corpus, or
prohibition;
Requests for temporary relief;
Appeals;
Post Conviction relief matters;
Contempt of Court proceedings:
Forfeiture proceedings brought by governmental entities;
Mortgage foreclosures; and
Cases that have been previously subjected to an ADR conference, unless otherwise required by
Rule 3 or by statute.
Cases may also be exempt from ADR under ADR Rule 3(c) upon motion to and approval by the court.
In cases not subject to ADR, the Chief Judge for Administrative Purposes, upon the motion of the court or
of any party, may order a case to mediation.
Application of a party to be exempt from payment of neutral fees due to indigency should be filed with the
Clerk of Court prior to the scheduling of the ADR conference.
Please Note: You must comply with the Supreme Court Rules regarding ADR.
Failure to do so may affect your case or may result in sanctions.
SCCA / 234 (04/2021) Page 2 of 2
Preview
oo STATE OF SOUTH CAROLINA ISSUED BY THE CIRCUIT COURT IN THE COUNTY OF GREENVILLE AVELINA BOLTIADOR WILEY, Plaintiff aKa v. SUBPOENA IN A CIVIL CASE Statebridge Company LLC, et al., Defendant Case Number: 2023-CP-23-04 194 Le eh piper sanereese Pending in Los Angeles (CA) County TO: RESURGENT CAPITAL SERVICES L.P.. 55 BEATTIE PLACE, SUITE 110 MS 250, GREENVILLE, SC 29601) S21 {J YOU ARE COMMANDED to appear in the above named court at the place, and time specified below to testify in the above case. PLACE OF TESTIMONY | COURTROOM DATE AND TIME 2 AM CJ YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above case. PLACE OF DEPOSITION DATE AND TIME : AM — a EX] YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or abjects in your possession, custody or control at the place, date and time specified below (list documents of objects: See Attachment “4” PLACE DATE AND TIME > AM [] YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below. PREMISES DATE AND TIME 5 AM —_ a ANY SUBPOENAED ORGANIZATION NOT A PARTY TO THIS [$ HEREBY DIRECFED TO RULE 30(by6). SOUTH CAROLINA RULES OF CIVIL PROCEDURE. TO FILE A DESKGNATION WETH THE COURT YING ONE OR MORE OFFICERS. DIRECTORS, OR MANAGING AGENTS, OR OTHER PERSONS WHO CONSENT TO TESTIFY ON {7 § BEHALF, SHALL SET FORTH, FOR EACH PERSON DESIGNATED, THE MATTERS ON WHICH HE WILL TESTIFY OR PRODUCE DOCUMENTS OR THINGS. ‘THE PERSON SO DESIGNATED TESTIEY AS FO MATTERS KNOWN OR REASONABLY AVAILABLE TO TIE ORGANIZATION I CERTIFY THAT THE SUBPOENA IS ISSUED IN COMPLIANCE WITH RULE 45(c\}), AND THAT NOTICE AS REQUIRED BY RULE 45(b)(1) HAS BEEN GIVEN TO ALL PARTIES. Sept 14, 2023 Jier Dong. Esq. Attomey/Issuing Officer's Signature Date Print Name Indicate 1f Atiomey for Plaintull or Defendant Attomey's Address and Telephone Number Jigr Dong, Esq. (atorey for Defendants and Cross-Complainant) 4665 MacArthur Court, Suite 200, Newport Beach, CA 92660 La, q law Jaoa3 Boece Garrett R suing Office Signature Date Print Name 5 hose Titigant’s Name, Address and Telephone Number — SCCA 254 (05/2015) (See Rule 45, South Carolina Rules of Civil Procedure, Parts (¢) & (4) on pages 2 and 3) PROOF OF SERVICE SERVED DATE FEES AND MILEAGE TO BE TENDERED TO WITNESS UPON DAILY ARRIVAL, PLACE Oves Ono AMOUNT $ SERVED ON MANNER OF SERVICE SERVED BY THLE DECLARATION OF SERVER | certify that the foregoing information contained in the Proof of Service is true and correct. Executed on, SIGNATURE OF SERVER ADDRESS OF SERVER Rule 45, South Carolina Rules of Civil Procedures, Parts (c) and (d): {c) Protection of Persons Subject to Subpoenas. (1) A party or an attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person subject to that subpoena. The court on behalfof which the subpoena was issued shall enforce this duty and impose upon the party or attorney in breach of this duty an appropriate sanction, which may include, but is not limited to, lost earnings and a reasonable altorney's fee. (2)(A) A person commanded to produce and permit inspection and copying of designated electronically stored information, books, papers, documents or tangible things, oF inspection of premises need not appear in person at the place of production or inspection unless commanded to appear for deposition, hearing or trial. A party or an attorney responsible for the issuance and service of a subpoena for production of books, papers and documents without a deposition shall provide to another party copies of documents so produced upon written request. The party requesting copies shall pay the reasonable costs of reproduction. (B) Subject to paragraph (d)(2) of this rule, a person commanded to produce and permit inspection and copying may, within 14 days after service of the subpoena or before the time specified for compliance if such time is less than 14 days after service, serve upon the party or attorney designated in the subpoena written objection to inspection or copying of any or all of the designated materials or of the premises—or to producing electronically stored information in the form or forms requested. If objection is made, the party serving the subpoena shall not be entitled to inspect and copy the materials or inspect the premises except pursuant to an order of the court by which the subpoena was issued. If objection has been made, the pasty serving the subpoena may, upon notice to the person commanded to produce, move at any time in the court that issued the subpoena for an order to compel the production. Such an order to compel production shall protect any person who is not a party or an officer of a party from significant expense resulting from the inspection and copying commanded (3)(A) On timely motion, the court by which @ subpoena was issued, or regarding a subpoena commanding appearance at a deposition, or production or inspection directed to a non-party, the court in the county where the non-party resides, is employed or regularly transacts business in person, shail quash or modify the subpoena if it: (i) fails to allow reasonable time for compliance; or (ii) requires a person who is not a party nor an officer, director or managing agent of a party, nor a general partner of a partnership that is a party, to trave! more than 50 miles from the county where that person resides, is employed or regularly transacts business in person, except that, subject to the provisions of clause (c}(3)(B)(iii) of this rule, such a person may in order to attend trial be commanded to travel from any such place within the state in which the trial is held, or (iii) requires disclosure of privileged or otherwise protected matter and no exception or waiver applies; or (iv) subjects a person to undue burden (B) If a subpoena {i) requires disclosure of a trade secret or other confidential research, development, or commercial information, or {ii} requires disclosure of an unretained expert's opinion or information not describing specific events or occurrences in dispute and resulting from the expert's study made not at the request of any party, or SCCA 254 (05/2015) (See Rule 45, South Carotina Rules of Civil Procedure, Parts (c) & (d) on pages 2 and 3) requires a person who is not a party nor an officer, director or managing agent of a party, nor a generat partner of a partnership that is a party, to incur substantial expense to travel from the county where that person resides, is employed or regularly transacts business in person, the court may, to protect a person subject to or affected by the subpoena, quash or modify the subpoena or, if the party in whose behalf the subpoena is issued shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship and assures that the person to whom the subpoena is addressed will be reasonably compensated, the court may order appearance or production only upon specified conditions. {da} Duties in Responding to Subpoena. (1){A)A person responding to a subpoena to produce documents shall produce them as they are kept in the usuai course of business or shall organize and label them to correspond with the categories in the demand. (B) If a subpoena does not specify the form or forms for producing electronically stored information, a person responding to a subpoena must produce the information in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms. (C) A person responding to a subpoena need not produce the same electronically stored information in more than one form. (0) A person responding to a subpoena need not provide discovery of electronically stored information from sources that the person identifies as not Teasonably accessible because of undue burden or cost. On motion to compel discovery or to quash, the person from whom discovery is sought must show that the information sought is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(6)(B). The court may specify conditions for the discovery (2)(A) When information subject to a subpoena is withheld on a claim that it is privileged or subject to protection as trial preparation materials, the claim shall be made expressly and shall be supported by a description of the nature of the documents, communications, or things not produced that is sufficient to enable the demanding party to contest the claim. (B} If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has and may not use or disclose the information until the claim is resolved. A receiving party may promptly present the information to the court under seal for a determination of the claim. If the receiving party disclosed the information before being Notified, the receiving party must take reasonable steps to retrieve the information. The person who produced the information must preserve the information until the claim is resolved. SCCA 254 (05/2015) (See Rule 45, South Carolina Rules of Civil Procedure, Paris (c) & (d) on pages 2 and 3) MC-025 SHORT TITLE: CASE NUMBER: { Avelina Boltiador Wiley v. Statebridge Company LLC et al. 22CMCV00416 ATTACHMENT (Number): 4 (This Attachment may be used with any Judicial Council form.) The records to be produced as follows: 1. Your entire loan file for the LOAN. The term “LOAN” is means and refers to the account belonging to Avelina Wiley and assigned loan number 1844313 (or 0537013700), with the real property address 429 E. 212th St., Carson, CA 90745. 2. All documents demonstrating, evidencing, or otherwise relating to all payments made on the LOAN since origination until December 22, 2020 including, but not limited to, copies of cancelled checks, documents evidencing any wire transfers or clectronic transfers, etc. 3. All payment coupons for the LOAN. 4. A true and correct copy of the origination file, including, but not limited to, copies of the note, the deed of trust, assignments of the deed of trust, and of the title policy. 5. A true and correct copy of the loan application for the LOAN. 6, True and correct copies of the preliminary and final HUD-1 statements. 7. All documents that relate to or tend to relate to the origination of the LOAN. 8. All documents demonstrating, evidencing, or otherwise relating to all servicing notes for the LOAN. 9. All documents demonstrating, evidencing, or otherwise relating to all payment histories for the LOAN. 10. All correspondence between YOU, YOUR servicing agent, or any prior servicer of the LOAN and the borrower(s) related to the LOAN or the PROPERTY. The term “PROPERTY” is means and refers to the real property address 429 E. 212th St., Carson, CA 90745. 11. All “hello” and “goodbye” letters for the LOAN. 12. All notices of sale, transfer, or assignment of the LOAN. (if the item that this Attachment concerns is made under penaity of perjury, all statements in this Page of Aitachment are made under penaity of perjury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT ‘wwew.courtinfo.ce gov Judicial Councit of California MC-025 [Rev. July 1, 2009] to Judicial Council Form Listing of the Names, Addresses, and Telephone Numbers of All Counsel of Record in the Proceeding (No Unrepresented Party) Peter Paul Mendel, Esq. Law Offices of Peter Paul Mendel 1900 East Ocean Boulevard, Suite 401 Long Beach, CA 90802 310-745-3664 ppmlawmatters@gmail.com Attorney for Plaintiff, Avelina Boltiador Wiley Lukasz I. Wozniak, Esq. Jier Dong, Esq. Wright, Finlay & Zak, LLP 4665 MacArthur Court, Suite 200 Newport Beach, CA 92660 949-477-5050 jdong@wrightlegal.net Attorneys for Defendants and Cross-Complainant, Statebridge Company, LLC and Wilmington Savings Fund Society, FSB, d/b/a Christiana Trust as Trustee for PNPMS Trust I SUBP-010 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY LWRIGHT. FINLAY & ZAK. LI Jier Dong, Esq., N 34 OI 4665 MacArthur Court, Suite 2 80. Newport f Beagh, 4 0 2660 TELEPHONENC: (949) 477-505 8-91.42 & 4 f4 EMalt ADDRESS: idong@wrightlegal.net arrornevrorer*”’ Defendants Statebridge and Wilminaton et al. SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES 83 STREET ADDRESS: 200 West Compton Blvd. MAILING ADDRESS: same as above CITY AND ZiP CODE:Compton, CA 90220 BRANCH NAME: Compton Courthouse PLAINTIFF/PETITIONER: Avelina Boltiador Wiley DEFENDANTIRESPONDENT: [Statebridge Company LLC et al. 2023-CP-23-04 ‘CASE NUMBER: JY DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS 22CMCV00416 THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, if known): Resurgent Capital Services L.P., 55 Beattie Place, Suite 110 MS 250, Greenville, SC 29601 1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3, as follows: To (name of deposition officer): Jier Dong, Esq. On (date): October 31, 2023 At (time): 10:00 a.m. Location (address): 4665 MacArthur Court, Suite 200, Newport Beach, CA 92660 Do not release the requested records to the deposition officer prior to the date and time stated above. a. L__] by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed inner wrapper with the title and number of the action, name of witness, and date of subpoena clearly written on it. The inner wrapper shail then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the address in item 1. b. [4] by delivering a true, legible, and durable copy of the business records described in item 3 to the deposition officer at the witness's address, on receipt of payment in cash or by check of the reasonable costs of preparing the copy, as determined under Evidence Code section 1563(b). c. [_] by making the original business records described in item 3 available for inspection at your business address by the attorney's representative and permitting copying at your business address under reasonable conditions during normal business hours. 2. The records are to be produced by the date and time shown in item 1 (but not sooner than 20 days after the issuance of the deposition subpoena, or 15 days after service, whichever date is later). Reasonable costs of focating records, making them available or copying them, and postage, if any, are recoverable as set forth in Evidence Cade section 1563(b). The records shall be accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561. The records to be produced are described as follows (if electronically stored information is demanded, the form or forms in which each type of information is to be produced may be specified): SEE ATTACHMENT 3 (J Continued on Attachment 3. 4. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE RECORDS. DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY. ate issued: September 14, 2023 Jier Dong, Esq. (TYPE OR PRINT NAME) » )\ ee or OUSIGNATURE OF PERSON ISSUING SUBPOENA} Attorneys for Defendants (Proofof service on reverse) (TLE) Page 1 of 2 Foon Adopted lor Mandatory Use DEPOSITION SUBPOENA FOR PRODUCTION Code of Civil Procecure, §§ 2020.410-2020 449; ‘Judicial Council ef California Govemment Code, § 68087 1 ‘SUBP.010 [Rev. January 1, 2012] OF BUSINESS RECORDS wnw.caurts.ca.gov SUBP-010 PLAINTIFF/PETITIONER: Avelina Boltiador Wiley ‘CASE NUMBER: 22CMCV00416 DEFENDANTIRESPONDENT.[Statebridge Company LLC et al. PROOF OF SERVICE OF DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS . | served this Deposition Subpoena for Production of Business Records by personally delivering a copy to the person served as follows: a. Person served (name): b. Address where served: c. Date of delivery: d. Time of delivery: e. (1) [_] Witness fees were paid. Amount: (2) 7} Copying fees were paid. Amount: f. Fee for service: 2 | received this subpoena for service on (date); 3. Person serving: (J Nota registered California process server. {_] California sheriff or marshal. [JJ Registered California process server. [__] Employee or independent contractor of a registered California process server. [—_] Exempt from registration under Business and Professions Code section 22350(b). [} Registered professional photocopier. {__] Exempt from registration under Business and Professions Code section 22451. Name, address, telephone number, and, if applicable, county of registration and number: \ declare under penalty of perjury under the jaws of the State of (For California sheriff or marshal use only) California that the foregaing is true and correct. \ certify that the foregoing is true and correct. Date: Date: > » (SIGNATURE) (SIGNATURE} SUBP.010 [Rev. January 1, 2012] DEPOSITION SUBPOENA FOR PRODUCTION Page 20f2 OF BUSINESS RECORDS MC-025 SHORT TITLE CASE NUMBER: [~ Avelina Boltiador Wiley v. Statebridge Company LLC et al. 22CMCV00416 ATTACHMENT (Number). 3 (This Attachment may be used with any Judicial Council form.) The records to be produced as follows: 1. Your entire loan file for the LOAN, The term “LOAN” is means and refers to the account belonging to Avelina Wiley and assigned loan number 1844313 (or 0537013700), with the real property address 429 E, 212th St.. Carson, CA 90745. 2. All documents demonstrating, evidencing, or otherwise relating to all payments made on the LOAN since origination until December 22, 2020 including, but not limited to, copies of cancelled checks, documents evidencing any wire transfers or electronic transfers, etc. 3. All payment coupons for the LOAN. 4. A true and correct copy of the origination file, including, but not limited to, copies of the note, the deed of trust, assignments of the deed of trust, and of the title policy. 5. A true and correct copy of the loan application for the LOAN. 6. True and correct copies of the preliminary and final HUD-1 statements. 7, All documents that relate to or tend to relate to the origination of the LOAN §. All documents demonstrating, evidencing, or otherwise relating to all servicing notes for the LOAN. 9. All documents demonstrating, evidencing, or otherwise relating to all payment histories for the LOAN. 10, Ail correspondence between YOU, YOUR servicing agent, or any prior servicer of the LOAN and the berrower(s) related to the LOAN or the PROPERTY, The term “PROPERTY” is means and refers to the real property address 429 E, 212th St., Carson, CA 90745. 11. All “hello” and “goodbye” letters for the LOAN. 12. All notices of sale, transfer, or assignment of the LOAN. {lf the item that this Attachment concerns is made under penalty of perjury, all statements in this Page Attachment are made under penalty of perjury.) (Aad pages as required) Form Approved for Optional Use ATTACHMENT www COuRID.ca.gaV ductcia’ Council of Calfarnia MMC-025 [Rev July 1, 2009) to Judicial Council Form DISC-030 [ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 246329 FOR GOURT USE ONLY Name: Lukasz |. Wozniak, Esq. FIRMNAME: Wright, Finlay & Zak, LLP STREET ADDRESS: 4665 MacArthur Court, Suite 200 FILED het e city: Newport Beach state: CA ZIP COvE: 92660 Superior Court of California untyof Los Angeles: cae TELEPHONE NO: (949) 477-5050 FAXNO. (949) 608-9142 “i EMAIL ADDRESS: |wozniak@wrightlegal.net 08/30/2023 ATTORNEY FOR (name): Defendants Statebridge and Wilmington et ai. Oud W. Siaytan, Exacutwe Officer { Ctert af Counts C. Warren SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES. By. Deputy iD Pe STREET ADDRESS: 200 West Compton Blvd. Lr ea MAILING ADDRESS: same as above a CITY AND ZIP CODE: Compton, CA 90220 BRANCH NAME, Compton Courthouse SHORT TITLE: Avelina Boltiador Wiley v. Statebridge Company LLC et al. 2023-CP-23- oury COMMISSION TO TAKE DEPOSITION OUTSIDE CALIFORNIA CASE NUMBER, (J ORDERED BY COURT [X JISSUED BY THE CLERK OF THE COURT 22CMCV00416 The Superior Court of Catifornia hereby authorizes the deposition, upon oral examination, of (identity of deponent): RESURGENT CAPITAL SERVICES L.P., 55 BEATTIE PLACE, SUITE 110 MS 250, GREENVILLE, SC 29601 The deposition is to be taken in (state of the United States, territory, or insular possession subject to its jurisdiction): SOUTH CAROLINA The deposition will be conducted (check one): a. [4¢] Under the supervision of a person who is authorized to administer oaths by the laws of the United States or those of the place where the examination is to be held, and who is not otherwise disqualified under California Cade of Civil Procedure sections 2025.320 and 2025.340(b)-{f); or b. [] Before (name of appointee): who is appointed to administer oaths and to take testimony. The documents or things to be produced at the time and place of the deposition are {543 described in Attachment 4 [[j none. Additional terms required by the foreign jurisdiction to initiate the process are contained in Attachment 5, Number of pages attached: Under California Code of Civil Procedure section 2026.010, California authorizes that a commission to take an out-of-state deposition may be issued by the clerk of the court or, if the foreign jurisdiction requires it, by order of the court. The Superior Court of the State of California hereby requests that process issue in the above-referenced place where the examination is to be held, requiring the attendance and enforcing the obligations of the deponent to produce documents and answer questions, \2G ee i 4oo Date: OBf30/2023 Michael Shultz f Judge I Judge OR [[] Clerk, by , Deputy Court Seal Page 1 of t Ferm Approved for Optional Use COMMISSION TO TAKE DEPOSITION Code Giv. Proc. § 2026.010(f} Judicial Council of Califomia wonw.courts.ca.gov DISC-090 [New January 1, 2008] OUTSIDE CALIFORNIA MC-025 SHORT TITLE: CASE NUMBER: | Avelina Boltiador Wiley v. Statebridge Company LLC et al. 22CMCV00416 ATTACHMENT (Number): 4 (This Attachment may be used with any Judicial Councit form.) The records to be produced as follows: 1. Your entire loan file for the LOAN, The term “LOAN” is means and refers to the account belonging to Avelina Wiley and assigned loan number 1844313 (or 0537013700), with the real property address 429 E. 212th St., Carson, CA 90745. 2. All documents demonstrating, evidencing, or otherwise relating to all payments made on the LOAN since origination until December 22, 2020 including, but not limited to, copies of cancelled checks, documents evidencing any wire transfers or electronic transfers, etc. 3. All payment coupons for the LOAN. 4. A true and correct copy of the origination file, including, but not limited to, copies of the note, the deed of trust, assignments of the deed of trust, and of the title policy. 5. A true and correct copy of the loan application for the LOAN. 6, True and correct copies of the preliminary and final HUD-1 statements. 7. All documents that relate to or tend to relate to the origination of the LOAN. 8. All documents demonstrating, evidencing, or otherwise relating to all servicing notes for the LOAN. 9. All documents demonstrating, evidencing, or otherwise relating to all payment histories for the LOAN. 10. All correspondence between YOU, YOUR servicing agent, or any prior servicer of the LOAN and the borrower(s) related to the LOAN or the PROPERTY. The term “PROPERTY” is means and refers to the real property address 429 E. 212th St., Carson, CA 90745. 11. All “hello” and “goodbye” letters for the LOAN. 12. All notices of sale, transfer, or assignment of the LOAN. (ff the item that this Attachment concerns is made under penalty of perjury, ail statements in this Page of Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use: ATTACHMENT wow courtinfo.ca gov Judicial Council of Caltomia MC-025 jRev. July 1, 2009) to Judicial Council Form PROOF OF SERVICE I, Jovete Elguira, declare as follows: 1am employed in the County of Orange, State of California. I am over the age of eighteen (18) and not a party to the within action. My business address is 4665 MacArthur Court, Suite 200, Newport Beach, California 92660. J am readily familiar with the practices of Wright, Finlay & Zak, LLP, for collection and processing of correspondence for mailing with the United States Postal Service. Such correspondence is deposited with the United States Postal Service the same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. On August 1, 2023, I served the within COMMISSION TO TAKE DEPOSITION OUTSIDE CALIFORNIA on all interested parties in this action as follows: Peter Paul Mendel, Esq. 10 Law Offices of Peter Paul Mendel Il 1900 East Ocean Boulevard, Suite 401 Long Beach, CA 90802 12 T: 310-745-3664 / F: 310-388-0809 Email: ppmlawmatters@gmail.com 13 Attorney for Plaintiff Avelina Boltiador Wiley 14 {] (BY MAIL SERVICE) I placed such envelope(s) for collection to be mailed on this date 15 following ordinary business practices. 16 {] (BY ELECTRONIC SERVICE) I caused electronic service of the documents to be made in accordance with Local Rules, California Rules of Court 2.251 and Code of Civil Procedure 17 Section 1010.6, by transmittal to the email addresses of the parties listed above. 18 [x] (BY ONE LEGAL FILE AND SERVE) I caused the document(s) to be e-served through One 19 Legal File and Serve, 20 C] (BY FEDERAL EXPRESS OVERNIGHT- NEXT DAY DELIVERY) I placed true and correct copies thereof enclosed in a package designated by Federal Express Overnight with the delivery 21 fees provided for. 22 [x] (State) I declare under penalty of perjury under the law of the State of California that the foregoing is true and correct. 23 Executed on August 1, 2023, at Newport Beach, California. 24 25 26 J ove Elguira CY 27 28 PROOF OF SERVICE “o~ > STATE OF SOUTH CAROuNA IN THE COURT OF COMMON PLEAS COUNTY OF GREENVILLE AVELINA BOLTIADOR WILEY CIVIL ACTION COVERSHEET = Plaintiff(s) 2023 -CP- 23 _- O4TFY vs. ) STATEBRIDGE COMPANY LLC, ET AL. ) Defendant(s) } ce ry Submitted By: Jier Dong, Esq. (Defendants/Cross-Complainant) SC Bar #:CA 349490 Address: 4665 MacArthur Ct, #200, Newport Beach, CA 92660 Telephone #:949-477-5 143 Fax #: 149-608-9142 Other: E-mail dong@wrightlegal.net NOTE: The coversheet and information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by jaw. This form is required for the use of the Clerk of Court for the purpose of docketing cases that are NOT E-Filed. [t must be filled out completely, signed, and dated. A copy of this coversheet must be served on the defendant(s) along with the Summons and Complaini. This form is NOT required to be filed in E-Filed Cases. DOCKETING INFORMATION (Cheek all that apply) “Uf Action is Judgmenv/Settlement do not complete £] JURY TRIAL demanded in complaint. (0 NON-JURY TRIAL demanded in complaint. C1 This case is subject to ARBITRATION pursuant to the Court Annexed Alternative Dispute Resolution Rules. (} This case is subject to MEDIATION pursuant to the Court Annexed Alternative Dispute Resolution Rules. (4 this case is exempt from ADR. (Certificate Attached) NATURE OF ACTION (Check Qne Box Below) Contracts Torts - Professional Malpractice Torts - Personal Injury Real Property Constructions (100) C1 Dental Malpractive (200) Conversion (310) Claim & Delivery (400) Debt Collection (110) Q Legal Malpractice (210) Motor Vehicle Accident (320} Condemnation (410) General (130) a Medical Malpractice (220) Premises Liability (330) Foreclosure (420) Breach of Contract (140) Previous Notice of Intent Case # Products Liability (340} Mechanic's Lien (430) Fraud/Bad Faith (150) 20, -NI- > Personal Injury (350) Partition (440) Failure to Deliver! go Notice/ File Med Mal (230) Wrongful Death (360) Possession (450) Warranty (160) AssaulBattery (370) O other (299) Building Code Violation (460) Emptoyment Diserim (170) Slander/Libel (380) Other (499) Empioyment (180) Other (399) Other (199) Inmate Petitions Administrative Law/Relict Judgments/Settlements Appeals PCR (300) Reinstate Drv. License (800) Death Settlement (700) Arbitration (900) Mandamus (320) Judicial Review (810) Foreign Judgment (710) Magistrate-Civil (910) Habeas Corpus (530) Relief (820) Magistrate's Judgment (720) Magistrate-Criminal (920) Other (399) Permanent Injunction (830) Minor Settlement (730) Municipal (930) — Forfeiture-Petition (840) Transcript Judgment (740) Probate Court (940) Forfeiture—Consent Order (850) Lis Pendens (730) SCDOT (950) Other (899) Transfer of Structured Worker's Comp (960) Settlement Payment Rights Zoning Board (970) Application (760) Public Service Comm. (990) Special/Complex /Other o Confession of Judgment (770) Employment Security Comm (991) Environmental (600) Oo Pharmaceuticals (630) oO Petiuon for Workers Automobile Arb. (610) Qo Unfair Trade Practices (640) Compensation Settlement Other (999) ‘Approval (780) Medival (620) = Ourof State Depositions (650) TO tncapacitated Adutt Settlement (790), Other (699) See 50. 11 Motion to Quash Subpoena in an CO Other (799) Out-of-County Action (660) oO Sexual Predator (510) o Pre-Suit Discovery (670 Bo Permanent Restraining Order (680) o Interpleader (690} Submitting Party Signature: Date: Legit 14 Zor% SCCA / 234 (04/2021) Page | of 2 o~ Note: Frivolous civil proceedings may be subject to sanctions pursuant to SCRCP, Ku..c 11, and the South Carolina Frivolous Civil Proceedings Sanctions Act, $.C. Code Ann, §15-36-10 et. seq. Effective January £, 2016, Alternative Dispute Resolution (ADR) is mandatory in all counties, pursuant to Supreme Court Order dated November 12, 2015. SUPREME COURT RULES REQUIRE THE SUBMISSION OF ALL CIVIL CASES TO AN ALTERNATIVE DISPUTE RESOLUTION PROCESS, UNLESS OTHERWISE EXEMPT, Pursuant to the ADR Rules, you are required to take the following action(s): 1 The parties shall select a neutral and fite a “Proof of ADR” form on or by the 210" day of the filing ofthis action. If the parties have not selected a neutral within 210 days, the Clerk of Court shall then appoint a primary and secondary mediator from the current roster on a rotating basis from among those mediators agreeing to accept cases in the county in which the action has been filed. The initial ADR conference must be held within 300 days after the filing of the action. Pre-suit medical malpractice mediations required by S.C. Code §15-79-125 shall be held not later than 120 days after all defendants are served with the “Notice of Intent to File Suit” or as the court directs, Cases are exempt from ADR under ADR Rule 3() upon the following grounds: a. Special proceeding, or actions seeking extraordinary relief such as mandamus, habeas corpus, or prohibition; Requests for temporary relief; Appeals; Post Conviction relief matters; Contempt of Court proceedings: Forfeiture proceedings brought by governmental entities; Mortgage foreclosures; and Cases that have been previously subjected to an ADR conference, unless otherwise required by Rule 3 or by statute. Cases may also be exempt from ADR under ADR Rule 3(c) upon motion to and approval by the court. In cases not subject to ADR, the Chief Judge for Administrative Purposes, upon the motion of the court or of any party, may order a case to mediation. Application of a party to be exempt from payment of neutral fees due to indigency should be filed with the Clerk of Court prior to the scheduling of the ADR conference. Please Note: You must comply with the Supreme Court Rules regarding ADR. Failure to do so may affect your case or may result in sanctions. SCCA / 234 (04/2021) Page 2 of 2