1 ROBERT KANE (CSB No. 71407
LAW OFFICES OF ROBERT KANE
2 870 Market Street
San Francisco California. 94102
3 Tel: 415 982-1510
Fax: 415 982-5821 F \ L E D
4 ru
BROOKE THATCHER (CSB No 148371) PACHARD WIEFKSEISRT
6 LEGAL AID OF ,;LEp41<_u.5 T€;§=_I:°‘g°F CAUFQRNIA
‘ 30 Noam SAN Penne ROAD Nost~·=EF°*N 9** `â€
7 SAN RAFAEL, CALIFORNIA
Tel: (415) 982-0230
8 Fax (415)492-0947
9 [email protected]
SHIRLEY HOCHHAUSEN (CSB No. 145619) `,\
10 COMMUNITY LEGAL SERVICES IN EAST PALO ALTO
2117-B University Avenue
I 1 East Palo Alto, CA 94303
Telephone: (650) 326-6440 ‘ *
12 Facsimile: (650) 326»9r22 E-111 1 1'1 Q —.
I 3 s hocb11ausen;@hotmail.com
` Attorneys for Plaintiff,
14 Audrey McNamara Nevis
15
16 UNITED STATES DISTRICT COURT EM
17 NORTHERN DISTRICT OF CALIFORNIA C
18 .. .
19 AUDREY MCNAMARA NEVIS, . ASE 9 7 2 5 6 8 I
Plaintiff, PLAINTIF F AUDREY MCNAMARA NEVIS’
20 EXPARTE MOTION FOR TEMPORARY
v. RESTRAINING ORDER AND ORDER TO
2] SHOW CAUSE REGARDING PRELIMINARY
WELLS FARGO BANK, EXECUTIVE INJUNCTION
22 FINANCIAL LENDING INC. JOHN B.
SPEAR, SHA1 MOSHE, GATEWAY
23 TITLE COMPANY, QUALITY LOAN
SERVICES CORP. and DOES 1-100,
24 inclusive U
25 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
26 Pursuant to FED. R. CW. P-. 65 and Civil Local Rule 65-1, Plaintiff Audrey McNamara
27 Nevis (Ms. Nevis) hereby moves the Court ex pczrre for a Temporary Restraining Order and Order
28
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_ Case 3:07-cv-02568-l\/IHP Document 2 Filed 05/15/2007 Page 2 of 2
1 to Show Cause Regarding Preliminary injunction to enjoin defendant Wells Fargo (Wells Fargo)
2 Quality Loan Service Corp. (Quality") and its ofiicers, agents, servants, employees, and all
3 persons acting in concert with them or acting on their behalf, pending trial of this action from
4 directly or indirectly initiating foreclosure proceedings on a property owned by plaintiff Audrey
5 McNamara Nevis located at 16 Creekside Drive in San Rafael Ca. 94903.
6 This application is made on the grounds that Ms. Nevis will be irreparably harmed without
7 injunctive relief as;Ouality and its principalsare threatening to foreclose on Ms. Nevis’ home, on
8 May 21, 200}*
9 This Application is based on the Complaint on file in this action and the Declarations of
10 Audrey Nevis and the Memorandum of Points and Authorities tiled herewith.
11 As stated in the accompanying Declaration of Shirley Hochhausen and pursuant to Civil
12 Local Rules 7—l 0 and 65-l, defendants were notified of this ex parte motion and served with the U
I3 motion and all supporting papers before they were filed with the Court.
14 ,·~·*
15 Dated; May L, 2007
16 LAW OFFICES OF ROBRERT F. KANE
17 LEGAL AID OF MARIN
18 COMMUNITY LEGAL SERVICES IN EAST PALO ALTO
W mg/Ma
By are v .»¤»c/ t {Kaine
20 » aint-sv ociniaussn
Attorney for Plaintiff
21 Aunasv Mcnamaaa Nevis ,
22
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24
25
26
27
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Case 3:07-cv-02568-MHP
Document 2
Filed 05/15/2007
Page 1 of 2
Case 3:07-cv-02568-MHP
Document 2
Filed 05/15/2007
Page 2 of 2
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