Digitally signed

Human Rights Alert by Joseph Zernik

DN: cn=Joseph
PO Box 526, La Verne, CA 91750 Zernik, o, ou,
email=jz12345@
Fax: 323.488.9697; Email: jz12345@earthlink.net earthlink.net,
Blog: http://human-rights-alert.blogspot.com/ c=US
Date: 2011.04.12
Scribd: http://www.scribd.com/Human_Rights_Alert 17:40:17 +03'00'

11-04-08 Ex Parte Applications for Due Process and Statement by California Judge Peter J
Meeka RE: Financial Benefits to Him by Bank of America

Attached:
# Date Record Page #
1. April 8, 2011 Minutes, as received from the Clerk 3
2. April 8, 2011 Receipt for payment for the Minutes 4
3. April 8, 2011 Ex Parte Application for a Statement on the Record by Judge 5
Meeka regarding Financial Benefits, if any, to him, from Bank
of America
4. April 8, 2011 Ex Parte Application for Due Process: Notice and Service of 12
Minutes, certified by the Clerk, and for access to the Register of
Actions (California civil docket) to inspect and to copy
In Lomas v Bank of America (KC059379) in the Superior Court of California, County of Los
Angeles, Plaintiff Susan Lomas is trying to protect her rights through a Quiet Title action against
alleged fraud by Bank of America and others in foreclosure procedures.
The case is opined as Fraud on the Court through collusion of BANK OF AMERICA
CORPORATION, California Judge PETER MEEKA, Clerk of the Court JOHN A CLARKE,
and Attorney MARK ASDOURIAN aimed to dispossess Plaintiff Susan Lomas, while denying
her due process and access to an honest court.
A pattern of false and deliberately misleading court records is found in the case: [ i ]
• None of the minutes were certified by the Deputy Clerk of the Court;
• None of the minutes were noticed and served by the Court;
z Page 2/2 April 12, 2011

• Multiple proceedings were secretly listed in the minutes as "off of the record";
• No Initial Case Management Conference was ever held;
• Plaintiff has been repeatedly denied access to the Register of Actions (California civil
docket), where the true registration of the proceedings (or lack thereof) would be discerned;
• An invalid online "Case Summary" is published by the Court, which would lead a naive
reader to conclude that valid and effectual proceedings have been held and rulings have been
entered by the court.
• Attorney Mark Asdourian appears in the case for BofA, while refusing to provide certificate
of Attorney of Record. Attorney Asdourian has filed false and deliberately misleading
banking records as "Request for Judicial Notice", which was granted by Judge Peter Meeka.
• No declaration or any other record signed by Bank of America authorized person was ever
filed in the case.
Such conduct is inconsistent with the Bank of America Code of Ethics and the Bank of America
Outside Counsel Procedures, which prohibit appearances by unauthorized attorneys and
obstructionist conduct in litigation. [ii ]
Such conduct should also be deemed deprivation of Human, Constitutional, and Civil Rights of
Susan Lomas, through collusion by Judge Peter J Meeka, Clerk John A Clarke, and Bank of
America Corporation.
i
11-03-20 PRESS RELEASE Lomas v Bank of America (KC059379) Bank of America Continues Racketeering in
the Los Angeles Superior Court
Hhttp://www.scribd.com/doc/51160102/H
11-03-20 Lomas v Bank of America (KC059379) in the Superior Court of California County of Los Angeles online
“Case Summary” and Minutes
Hhttp://www.scribd.com/doc/51157264/H
11-04-05 Lomas v Bank of America (KC059379) in the Superior Court of California, County of Los Angeles –
Fraud on the Court in a Quiet Title Action
Hhttp://www.scribd.com/doc/52336989/H
11-04-06 Lomas v Bank of America (KC059379) “Request[s] for Judicial Notice”- Additional Evidence of Fraud on
the Court in Foreclosure Procedure s
Hhttp://www.scribd.com/doc/52420585/H
11-04-07 Press Release: Lomas v BofA (KC059379) – Judge Meeka is Requested to Restore Due Process,
Declare Any Benefits from BofA
Hhttp://www.scribd.com/doc/52494342/H
11-03-31 Lomas v Bank of America (KC059379) Request and Response for Certification of Authority as Attorney
of Record s
Hhttp://www.scribd.com/doc/52516705/H
ii
09-01-27 Bank of America Code of Ethics
Hhttp://www.scribd.com/doc/32173783/H
08-12-11 Bank of America - Outside Counsel Procedures
Hhttp://www.scribd.com/doc/27932516/
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

DATE: 00/ 00/ 00 DEPT.

HONORABLE JUDGE DEPUTY CLERK

HONORABLE JUDGE PRO TEM ELECTRONIC RECORDING MONITOR

Deputy Sheriff Reporter

Plaintiff
Counsel

Defendant
Counsel

NATURE OF PROCEEDINGS:

PLAINTIFF'S EX PARTE APPLICATION FOR A STATEMENT ON

THE RECORD BY JUDGE PETER J. MEEKA PURSUANT TO
CALIFORNIA CODE OF JUDICIAL ETHICS CANON 3E(2)
REGARDING FINANCIAL BENEFITS, IF ANY, BY BANK OF
AMERICA, AFFILIATES, SUBSIDIARIES, EXECUTIVES, OR
EMPLOYEES TO JUDGE PETER J. MEEKA OR FAMILY MEMBERS
RESIDING WITH HIM;

PLAINTIFF'S EX PARTE APPLICATION FOR DUE PROCESS

NOTICE AND SERVICE OF MINUTES, RULINGS, ORDERS,
JUDGMENT WITH ENTRY CERTIFIED BY THE CLERK, AND
ACCESS TO THE REGISTER OF ACTIONS TO INSPECT AND
COPY;

MINUTES ENTERED
Page 1 of 1 DEPT. 00/00/00
COUNTY CLERK
 CIT/CASE~ LEA/DEF# ~

0310

CA~:~H ~ Oc50
CHANGE ~
CAPD~

-- ----------- ----
- -
/

Susan Lomas
ORIGINAL FILED
1 2528 Kendall Street APR X8 2011
La Verne, CA 91750
2
Telephone: (323) 533-5242 ~OS AN'GELES
3 SUPE.RIOR COURT
4

5
SUPERIOR COURT OF THE STATE OF CALIFORNIA

6
IN AND FOR THE COUNTY OF LOS ANGELES, EAST DISTRICT

8
SUSAN LOMAS, an individual; KC 059379 0
9
SUSAN LOMAS, Trustee of the
Michael A. Heredia and Susan Lomas Assigned for all purposes to the
10
Joint Living Trust Dated January 22, Honorable
2008 Peter J. Meeka
11
EX PARTE APPLICATION FOR A
12 Plaintiff, STATEMENT ON THE RECORD BY
JUDGE PETER J. MEEKA PURSUAN
13
Vs. TO THE CALIFORNIA CODE OF
JUDICIAL ETHICS CANON 3E(2)
14 REGARDING FINANCIAL BENEf=IT ,
BANK OF AMERICA, National IF ANY, BY BANK OF AMERICA,
15 Association as successor by merger to AFFILIATES, SUBSIDIARIES,
La Salle Bank National Association, as EXECUTIVES, OR EMPLOYEES TO
16 JUDGE PETER J. MEEKA OR FAMIL
Trustee for the C-BASS Mortgage
Loan Asset-Backed Certificates, MEMBER(S) RESIDING WITH HIM.
17
Series, 2006-CB7; DOES 1-20, DATE: 04- O~· ]..01\
18 inclusive TIME: ~ f3~ ?Oflfi'l
DEPT: 0
19
Defendants.
20

21

22

23 PLAINTIFF SUSAN LOMAS hereby applies ex parte for a Statement on the

24 Record by Judge PETER J. MEEKA pursuant to the California Code of Judicial Ethics

25 3E(2).

26 This ex parte application is based upon the attached Memorandum of Points and

27 Authorities, the declarations of Lomas filed and served herewith, the pleadings and

28 documents on record in this case, all matters of which the Court mayor must take
 judicial notice, and on such other oral and documentary evidence as may be presented
1
at the hearing.
2

3 DATED: 0 Y-O~ ~1P l\

5 BY:~
6
Susan Lomas
7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28
Ex Parte Application for a Statement on the Record by Judge Meeka pursuant to the California Code of Judicial Ethics
3E(2)
2

------
 MEMORANDUM OF POINTS AND AUTHORITIES
1

2
I. SUSAN LOMAS REQUESTS A STATEMENT ON THE RECORD BY
3
JUDGE PETER J. MEEKA PURSUANT TO THE CALIFORNIA CODE
4
OF JUDICIAL ETHICS, CANON 3E(2)
5
The California Code of Judicial Ethics, Canon 3E (1) and (2) states:
6
E. Disqualification.
7 (1) Ajudge shall disqualify himself or herself in any proceeding in which
disqualification is required by law.
8 (2) In all trial court proceedings, a judge shall disclose on the record
information that is reasonably relevant to the question of disqualification
under Code of Civil Procedure section 170.1, even if the judge believes there is
9
no actual basis for disqualification.
10 II. BANK OF AMERICA IS PARTY TO INSTANT LITIGATION
11 BANK OF AMERICA, National Association as successor by merger to La Salle
12 Bank National Association, as Trustee for the C-BASS Mortgage Loan Asset-
13 Backed Certificates, Series, 2006-CB7 is named Defendant in instant litigation.
14 III. CONCLUSION
15 For the foregoing reasons, Plaintiff Susan Lomas respectfully asks the Judge
16 PETER J. MEEKA to file a Statement on the Record regarding financial benefits, if any,
17 to Judge PETER J. MEEKA or any family members residing with him, by Bank of
18 America Corporation, or by any of its subsidiaries, affiliates, executives, or employees.
19

20 Respectfully submitted,
21
DATED: 0 ~ --0 lJ '-1O~l
22

23
By:
24
Susan Lomas
25

26

27

28
Ex Parte Application for a Statement on the Record by Judge Meeka pursuant to the California Code of Judicial Ethics
3E(2)
3
 DECLARAliON OF SUSAN LOMAS
1

2 I, Susan Lomas declare as follows:

3
1. I am the named Plaintiff in litigation of SUSAN LOMAS, an individual;
4
SUSAN LOMAS, Trustee of the Michael A. Heredia and Susan Lomas
5

6 Joint Living Trust Dated January 22, 2008 vs. BANK OF AMERICA,

7 National Association as successor by merger to La Salle Bank National

8
Association, as Trustee for the C-BASS Mortgage Loan Asset-Backed
9
Certificates, Series, 2006-CB7; DOES 1-20, inclusive. The case number is
10

11 KC 059379 0, in the Superior Court of California, County of Los Angeles.

12 2. Bank of America Corporation is named Defendant in the same litigation titled:

13
BANK OF AMERICA, National Association as successor by merger to La
14
Salle Bank National Association, as Trustee for the C-BASS Mortgage
15

16
Loan Asset-Backed Certificates, Series, 2006-CB7; DOES 1-20, inclusive

17

18 I declare under the penalty of perjury under the law of the State of California
19
that the foregoing is true and correct. Executed this 5th day of April 2011 in, La
20
Verne, California.
21

22

23

24
Signature: ~
25

26

27

28
Ex Parte Application for a Statement on the Record by Judge Meeka pursuant to the California Code of Judicial Ethics
3E(2)
4
 PROOF OF SERVICE

1 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

2 I am employed in the County of Los Angeles, State of California. I am over

the age of 18 and not a party to the within action; my address is 422 W. Route 66,
3 Glendora, CA

4 On April 6, 2011, I served the foregoing document(s) described as EX

PARTE APPLICATION STATEMENT OF THE RECORD BY JUDGE PETER
5 JOSEPH MEEKA PURSUANT TO THE CALIFORNIA CODE OF JUDICIAL
ETHICS CANON 3E (2) REGARDING FINANCIAL BENEFITS,IF ANY BY BANK
6 OF AMERICA, AFFILIATES, SUBSIDIARIES, EXECUTIVES OR EMPLOYEES TO
JUDGE PETER J. MEEKA OR FAMILY MEMBERS(S) RESIDING WITH HIM on
7 interested parties in this action by placing a true copy thereof enclosed in a sealed
envelope addressed as follows:
8

9
_-=--X-=- (BY FAX) I transmitted, via facsimile, said document(s) to the telecopier
10 numbers: 949-644-5301 ~ qt.f!1 (,41.( ~ 530 I
11 Mark Asdourian @
Mark Asdourian Esq.,
12 610 Newport Center Drive, #1250
Newport Beach, CA 92660
13

14 (BY MAIL) I am "readily familiar" with this office's practice of collection and
processing correspondence for mailing. Under that practice it would be
15 deposited with U.S. postal service on that same day with postage thereon
fully prepaid at Los Angeles, California in the ordinary course of business. I
16 am aware that on motion of the party served, service is presumed invalid if
postal cancellation date or postage meter date is more than one day after
17 date of deposit for mailing in affidavit.

18 (BY PERSONAL SERVICE) I caused such envelope to be delivered by hand

to the offices of the addressee.
19
_ _ (BY FEDEX) I caused such envelope to be delivered to the offices of the
20 addressee via Federal Express, with next day delivery.

21 (BY EMAIL) I emailed a .pdf file containing and image of said document(s)
to the addressee at the email address listed above.
22

23 I declare under penalty of perjury under the laws of the State of California
that the above is true and correct.
24
Executed on, April 6, 2011, Glendora, California.
25

26 ~~~
27 Anna Cheek
28 Ex Parte Application Re: Due Process Service And Notice,
Access To Register Of Actions
6

-----~
 1 TO ALL PARTIES AND THEIR ATTORNEY OF RECORD:

3 MARK ASDOURIAN @ MARK ASDOURIAN, ESQ., 610 NEWPORT

CENTER DRIVE., #1250, NEWPORT BEACH, CA 92660 @ FACSIMILE # 949
4
-644-530l FOR BANK OF AMERICA, NATIONAL ASSOCATION, as successor
5
by merger to LaSalle Bank National Association, as Trustee for the Certificate C-
6
BASS Mortgage Loan Asset-Backed Certificates, Series, 2006-CB7.
7

8
Please take notice that on Friday, April 8, 2001 at 9:00 am as soon
9
thereafter this matter - EX PARTE APPLICATION STATEMENT OF THE RECORD
10
BY JUDGE PETER JOSEPH MEEKA PURSUANT TO THE CALIFORNIA CODE
11
OF JUDICIAL ETHICS C~NON 3E (2) REGARDING FINANCIAL BENEFITS,IF
12
ANY BY BANK OF AMERICA, AFFILIATES, SUBSIDIARIES, EXECUTIVES OR
13 EMPLOYEES TO JUDGE PETER J. MEEKA OR FAMILY MEMBERS(S)
14 RESIDING WITH HIM. On case number KC 059379 0, in Department 0 of the
15 Pomona Courthouse located at 400 Civic Center Plaza, Pomona, CA 91766.
16 Plaintiff Susan Lomas will be heard.
17

18

19
20 Dated: () q ~O(P ~ 10 ~,

21 Susan Lomas

22

23

24

25

26

27

28

1
PAGE
 TRANSMISSION VERIFICATION REPORT

TIME 04/05/2011 15:11

NAME WEWJWEGEQ::::::::
FAX 909590470000
TEL 9095904077
SER.1t 000K8J381511

DATE,TIME 04/05 15:09

FAX NO./NAME 919495445301
DURATION 00:01:32
PAGE(S) 05
RESULT OK
MODE STANDARD
ECM
 1 SUSAN LOMAS
ORIGI A FILED
2
APR 'to 8 2011
2528 Kendall Street
3 LOS A"NGELES
4
La Verne, CA 91750 SUPERIOR COlJRT
Telephone: (323) 533-5242
5

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 IN AND FOR THE COUNTY OF LOS ANGELES

10 EAST DISTRICT - POMONA COURTHOUSE SOUTH

11

12 SUSAN LOMAS, an individual; SUSAN ~ Case No. KC 059379 0

) Assigned for all purposes to the

13 LOMAS, Trustee of the Michael A.
) Honorable
14 Heredia and Susan Lomas Joint Living ~ Judge Peter J. Meeka

Trust Dated January 22, 2008 ) EX PARTE APPLICATION FOR DUE

15
) PROCESS NOTICE AND SERVICE 0
) MINUTES, RULINGS, ORDERS,
16
Plaintiff, ) JUDGMENT, WITH ENTRY CERTIFIE
) BY THE CLERK, and ACCESS TO
17
vs. ) THE REGISTER OF ACTIONS, TO
18 ) INSPECT AND TO COPY
)
DATE: OL(- og-~(I
19 BANK OF AMERICA, A NATIONAL ~ TIME: 8:30 am
20 ) DEPT: 0
ASSOCIATION, as successor by merger)
21 to LaSalle Bank National Association, ~
22 as Trustee for the Certificate C-BASS ~
23 )
Mortgage Loan Asset-Backed )
)
24 Certificates, Series, 2006-CB7, et al
)
25 Defendants. )
)
26 )

27

28
 PLAINTIFF SUSAN LOMAS hereby applies ex parte for an order for Due Process
1
notice and service of entry of minutes, rulings, orders, judgment, or of any other
2
developments in this case, including signed certificates of entry by the Clerk of the Court,
3
and for an order for Due Process access to the Register of Actions in this case, to inspect
4
and to cqpy. This application is ba?ed upon the fact that Lomas has never been noticed
5
and served so far by the Clerk of the Court of any of the Minutes in this case, and that
6
copies of Minutes in this case, obtained by Lomas from the Office of the Clerk were
7
missing the Certificate of Entry by Clerk. This application is also based upon the fact that
·8
Lomas has been so far denied access to the Register of Actions in this case, to inspect
9
and to copy.
10
This ex parte application is based upon the attached Memorandum of Points and
11
Authorities, the declarations of Lomas filed and served herewith, the pleadings and
12
documents on record in this case, all matters of which the Court mayor must take judicial
13
notice, and on such other oral and documentary evidence as may be presented at the
14
hearing.
15

16 DATED: 04- Old - tD\l

17

18

19
SUSAN LOMAS
20

21

22

23

24

25

26

27

28 Ex Parte Application Re: Due Process Service And Notice,

Access To Register Of Actions
2
 MEMORANDUM OF POINTS AND AUTHORITIES
1
I. LOMAS WAS DENIED SERVICE AND NOTICE OF MINUTES, INCLUDING
2
CERTIFICATES OF ENTRY SIGNED BY THE CLERK OF THE COURT
3
Lomas has not received any seNice and notice of any of the Minutes in this case
4
from either the clerk or any other party. (Lomas Declaration., 11 Exhibit A.) Lomas
5
obtained from the Office of the Clerk copies of Minutes in this case. However, all Minutes,
6
without exception, were missing the Certificate of Entry, signed by the Clerk or Deputy
7
Clerk of the Court. f\~
8 Lomas requested and was/permitted Due Process access to the Register of Actions in
9 SUSAN LOMAS, an individual; SUSAN LOMAS, Trustee of the Michael A. Heredia
10 and Susan Lomas Joint Living Trust Dated January 22, 2008 vs. BANK OF
11 AMERICA, A NATIONAL ASSOCIATION, as successor by merger to LaSalle Bank
12 National Association, as Trustee for the Certificate C-BASS Mortgage Loan Asset-

13 Backed Certificates, Series, 2006-CB7, et al.

14 However, Lomas has been denied repeated requests to access the Register of

15 Actions in instant case, with no explanation at all. (Lomas Declaration., 11 Exhibit A.)

16 Lomas should not have to speculate regarding the nature of court actions in this

17 case, or the validity of entry of minutes, orders, and jUdgments.

18 Lomas's entitlement to notice of the entry of Minutes, Rulings, Orders, and

19 Judgments, as certified by the Clerk of the Court, is clear and arises from the Fourteenth

20 Amendment to the United States Constitution.

21
II. DESPITE MULTIPLE ATTEMPTS, LOMAS WAS DENIED ACCESS TO THE
22 REGISTER OF ACTIONS IN THE CASE, TO INSPECT AND TO COPY

23 Not only was Lomas given no notice and seNice of Minutes, certified as entered by

24 the Clerk of the Court, she was also denied the opportunity to learn on her own the

25 specifics of Court actions in instant case, through review of the Register of Actions.

26 (Lomas Decl., 11 Exhibit A)

27 Lomas attempted on March PI, 4 th , 7th , and April 4 th _ 2011 to access the Register of

28 Ex Parte Application Re: Due Process Service And Notice,

Access To Register Of Actions
3
 Actions in instant case. However, her requests were repeatedly denied, with no
1
explanation at al.
2
The right to access court records, to inspect and to copy, was re-affirmed by the
3
Supreme Court of the United States in Nixon v Warner Communications, Inc (1978), as
4
inherent to Due Process and First Amendment rights.
5

6
III. CONCLUSION
7
For the foregoing reasons, Plaintiff Susan Lomas respectfully asks the Court to rule
8
that the Clerk of the Court immediately provide Lomas copies of any Minutes, Orders,
9
Rulings, Judgments in this case, including Certificates of Entry by the Clerk, if any exist.
10
Moreover, Plaintiff Lomas respectfully asks the Court to rule that that Clerk of the
11
Court immediately provide Lomas access to the Register of Actions in the case, to inspect
12
and to copy.
13

14
Respectfully submitted,
15
DATED: 0 L( ~O~· "'UJ t\
16

17
By:
18
Susan Lomas
19

20

21

22

23

24

25

26

27

28 Ex Parte Application Re: Due Process Service And Notice,

Access To Register Of Actions
4
 1

10

11

12

13

14

15

16

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21

22

23

24

25

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28 Eyh,-b,"+ A
5
-
 DECLARATION OF SUSAN LOMAS

I, Susan Lomas, declare as follows:

1) I am Plaintiff in pro per in the case of SUSAN LOMAS, an

individual; SUSAN LOMAS, Trustee of the Michael A. Heredia
and Susan Lomas Joint Living Trust Dated January 22, 2008
vs. BANK OF AMERICA, National Association as successor by
merger to La Salle Bank National Association, as Trustee
for the C-BASS Mortgage Loan Asset-Backed Certificates,
Series, 2006-CB7; DOES 1-20, inclusive. In the Superior
Court of California, County of Los Angeles, Pomona
Courthouse South, East District. Case Number KC 059379 0

2) This declaration was written as memorandum of events

surrounding my attempts to gain access to the Register of
Actions and regarding failure of the Clerk of the Court to
serve me any minutes, orders, or judgments case KC 059379
O.

3) On dates March 1 st , 4 th , 7 th , and April 4th, 2011. I

contacted the Pomona courthouse (located at 400 Civic
Center, Pomona, CA), Public Counter & Certification
Department in an effort to gain access to the Register of
Actions in case KC 059379 0, to inspect and to copy.

4) On March 1 st , 2011 I met with a Deputy Clerk named Amy and

requested the Register of Actions for case KC 059379 O.
Amy explained that the "all the computer system prints out
is a case summary aka case history report H • I explained to
her that I had just received the Register of Actions from
the unlimited courthouse - Pomona Court - North. Amy
nonetheless refused my request by explaining she had "never
heard of such a report H • I then asked to speak with the
head Supervising Deputy Clerk, Nancy Guerra. Amy informed
me she was out for the day.

5) On March I, 2011, I was permitted to gain access to a

printout of the Civil Register of Actions from The Superior
Courthouse North - the limited division for the case of

1 I Declaration of Susan Lomas

 Bank of America, National Association, et al vs. Heredia,
Michael (09U01907).

6) On March 4 th , 2011, the Public Counter & Certification

Department's Deputy Clerk named Rhonda at approximately
1:03p.m. and asked for the Registry of Actions in case KC
059379 O. Rhonda explained the Supervising Deputy Clerk,
Nancy Guerra "was not available but that maybe she could
help answer my request". Rhonda also explained "she has
never heard of such a document" and took my number for
Deputy Guerra to call me. I never received a telephone
call.

7) On March 7 th , 2011 I went into the courthouse and requested

the Register of Actions for the case of SUSAN LOMAS, an
individual; SUSAN LOMAS, Trustee of the Michael A. Heredia
and Susan Lomas Joint Living Trust Dated January 22, 2008
vs. BANK OF AMERICA, National Association as successor by
merger to La Salle Bank National Association, as Trustee
for the C-BASS Mortgage Loan Asset-Backed Certificates,
Series, 2006-CB7; DOES 1-20, inclusive. Case number KC
059379 O. I was told Deputy Clerk Nancy Guerra was out and
instead a clerk from the Child & Adolescent Division, who
identified herself as a Supervising Deputy Clerk from the
adjacent division/counter, came over and explained to me
that "a print out of the Register of Actions is not
available from their system because it is an updated, newer
system". She further stated that "a Register of Actions
could be printed out but only for cases that are 30 years
or older". I then showed her the Register of Actions
printout for the Pomona Courthouse North case (09U01907,
she further explained that "the unlimited division - Pomona
Courthouse north was "able to print out a Register of
Actions because they are still using an old computerized
system."

8) On April 4 th 2011, I was again refused the Register of

Actions at approximately 3:20pm. I spoke with Nancy Guerra,
who identified herself as Supervising Deputy Clerk. I
requested a Register of Actions for case number KC 057379 0
for the case titled: SUSAN LOMAS, an individual; SUSAN
LOMAS, Trustee of the Michael A. Heredia and Susan Lomas

2 Declaration of Susan Lomas

 Joint Living Trust Dated January 22, 2008 vs. BANK OF
AMERICA, National Association as successor by merger to La
Salle Bank National Association, as Trustee for the C-BASS
Mortgage Loan Asset-Backed Certificates, Series, 2006-CB7;
DOES 1-20, inclusive. Rene explained "she could print out a
case summary which are the same as case histories, but no
available Register of Actions is available for cases that
are not 30 years or older."

9) To this date I have not been permitted access to the

register of actions in the case of SUSAN LOMAS, an
individual; SUSAN LOMAS, Trustee of the Michael A. Heredia
and Susan Lomas Joint Living Trust Dated January 22, 2008
vs. BANK OF AMERICA, National Association as successor by
merger to La Salle Bank National Association, as Trustee
for the C-BASS Mortgage Loan Asset-Backed Certificates,
Series, 2006-CB7; DOES 1-20, inclusive. Case number KC
057379 0, to inspect and to copy.

10)1 further declare that for the case of SUSAN LOMAS, an

individual; SUSAN LOMAS, Trustee of the Michael A. Heredia
and Susan Lomas Joint Living Trust Dated January 22, 2008
vs. BANK OF AMERICA, National Association as successor by
merger to La Salle Bank National Association, as Trustee
for the C-BASS Mortgage Loan Asset-Backed Certificates,
Series, 2006-CB7; DOES 1-20, inclusive. Case number
KC057379 0, the Clerk of the Court has never served or
mailed any notice, minute order or any other type of
documentation in relation to this case.

I declare under the penalty of perjury under the law of the

State of California that the foregoing is true and correct.
Executed this 5 th day of April 2011 in La Verne, California.

Susan Lomas

3 Declaration of Susan Lomas

---------~ --
 1 TO ALL PARTIES AND THEIR ATTORNEY OF RECORD:

3 MARK ASDOURIAN @ MARK ASDOURIAN, ESQ., 610 NEWPORT

CENTER DRIVE., #1250, NEWPORT BEACH, CA 92660 @ FACSIMILE # 949
4
-644-5301 FOR BANK OF AMERICA, NATIONAL ASSOCATION, as successor
5
by merger to LaSalle Bank National Association, as Trustee for the Certificate C-
6
BASS Mortgage Loan Asset-Backed Certificates, Series, 2006-CB7.
7

8
Please take notice that on Friday, April 8, 2001 at B: 3D, am as soon
9
thereafter this matter - EX PARTE APPLICATION FOR DUE PROCESS NOTICE
10
AND SERVICE OF MINUTES, RULINGS, ORDERS, JUDGMENT, WITH ENTRY
11
CERTIFIED BY THE CLERK, and ACCESS TO THE REGISTER OF ACTIONS,
12
TO INSPECT AND TO COpy on case number KC 059379 0, in Department 0 of
13
the Pomona Courthouse located at 400 Civic Center Plaza, Pomona, CA 91766.
14
Plaintiff Susan Lomas will be heard.
15

16

17

18 Dated:
19 Susan Lomas
20

21

22

23

24

25

26

27

28

1
PAGE

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 PROOF OF SERVICE

1 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

2 I am employed in the County of Los Angeles, State of California. I am over

the age of 18 and not a party to the within action; my address is 422 W. Route 66,
3 Glendora, CA

4 On April 6, 2011, I served the foregoing document(s) described as EX

PARTE APPLICATION FOR DUE PROCESS NOTICE AND SERVICE OF
5 MINUTES, RULINGS, ORDERS, JUDGMENT, WITH ENTRY CERTIFIED BY THE
CLERK, and ACCESS TO THE REGISTER OF ACTIONS, TO INSPECT AND TO
6 COPYon interested parties in this action by placing a true copy thereof enclosed in
a sealed envelope addressed as follows:
7

8
_-,--X-,- (BY FAX) I transmitted, via facsimile, said document(s) to the telecopier
9 numbers: 949-644- 53 of ' qyOJ {'lf4, 5"~o \
10 Mark Asdourian @
Mark Asdourian Esq.,
11 610 Newport Center Drive, #1250
Newport Beach, CA 92660
12

13 (BY MAIL) I am "readily familiar" with this office's practice of collection and
processing correspondence for mailing. Under that practice it would be
14 deposited with U.S. postal service on that same day with postage thereon
fully prepaid at Los Angeles, California in the ordinary course of business. I
15 am aware that on motion of the party served, service is presumed invalid if
postal cancellation date or postage meter date is more than one day after
16 date of deposit for mailing in affidavit.

17 (BY PERSONAL SERVICE) I caused such envelope to be delivered by hand

to the offices of the addressee.
18
_ _ (BY FEDEX) I caused such envelope to be delivered to the offices of the
19 addressee via Federal Express, with next day delivery.
20 (BY EMAIL) I emailed a .pdf file containing and image of said document(s)
to the addressee at the email address Iistep above.
21

22 I declare under penalty of perjury under the laws of the State of California
that the above is true and correct.
23
Executed on, April 6, 2011, Glendora, California.
24

26 Anna Cheek
27

28 Ex Parte Application Re: Due Process Service And Notice,

Access To Register Of Actions
6

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 TRANSMISSION VERIFICATION REPORT

TIME 04/05/2011 15:07

NAME WEWJWEGEQ:::::: ::
FAX 909590470000
TEL 9095904077
SER.# 000K8J381511

DATE, TIME 04/05 15:04

FAX NO./NAME 919495445301
DURATION 00:02:34
PAGE(S) 10
RESULT OK
MODE STANDARD
ECM