Answer To Ud

KATRINA GJURASHAJ
1
34202 PINEHURST DRIVE,
2 YUCAIPA, CA 92399
Phone (951) 801-9526
3 Defendant In Pro Se
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6 SUPERIOR COURT OF THE STATE OF CALIFORNIA
7 IN AND FOR THE COUNTY OF SAN BERNARDINO
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DEUTSCHE BANK NATIONAL TRUST Case No.: UDSS 802-816
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COMPANY, AS TRUSTEE,
10 ANSWER TO COMPLAINT FOR
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Plaintiff, UNLAWFUL DETAINER
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Vs.
ROBERT GJOLAJ; MINERVA A.
13 TOLOMA; and DOES 1 through 6,
inclusive
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15 Defendant.
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Defendant KATRINA GJURASHAJ answering as one of the doe defendants
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herein denies generally and specifically each of the allegations of the complaint on file
20 herein..
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FIRST AFFIRMATIVE DEFENSE
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Plaintiffs lack Standing as they were not the BENEFICIARY of the note and another
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party has unlawfully foreclosed thereon and this matter is before this court as
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Case Number CIVSS-805619; Judge ALVAREZ
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SECOND AFFIRMATIVE DEFENSE
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Deutsche Bank was not the beneficiary of this Note
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the actual Beneficiary remained in hiding
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during the entire foreclosure process.
ANSWER TO COMPLAINT
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1 And the wrong party has foreclosed.
2 Plaintiffs are not the right party to bring this foreclosure action.
3 “As they lack standing”
4 THIRD AFFIRMATIVE DEFENSE
5 Plaintiffs can not establish that they are in the chain of title
6 FOURTH AFFIRMATIVE DEFENSE
7 Plaintiffs can not establish that
8 they paid consideration for this note and mortgage
9 FIFTH AFFIRMATIVE DEFENSE
10 Plaintiff’s can not establish that they owned
11 this note and mortgage at the time of the default
12 SIXTH AFFIRMATIVE DEFENSE
13 The notices served on defendants were defective under California Law
14 SEVENTH AFFIRMATIVE DEFENSE
15 The real beneficiary is STILLcurrently unknown
16 EIGHTH AFFIRMATIVE DEFENSE
17 The Complaint, fails to state
18 a cause of action against these answering defendants.
19 NINTH AFFIRMATIVE DEFENSE
20 The Complaint is not properly verified
21 IT MUST BE VERIFIED BY A PARTY
22 TENTH AFFIRMATIVE DEFENSE
23 Plaintiff does not have effective title
24 as alleged in the Complaint, nor as required by law.
25 ELEVENTH AFFIRMATIVE DEFENSE
26 The Complaint was filed prematurely
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ANSWER TO COMPLAINT
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1 TWELFTH AFFIRMATIVE DEFENSE
2 The complaint fails to state sufficient facts to warrant the FORECLOSURE of
3 defendants PROPERTY AND AN EVICTION THEREOF
4 THIRTEENTH AFFIRMATIVE DEFENSE
5 Plaintiff is barred by the doctrine of UNCLEAN HANDS.
6 FOURTEENTH AFFIRMATIVE DEFENSE
7 The EVICTION IS BEING conducted by a party who was not properly authorized
8 or appointed by the Beneficiary’, AND WHO IS NOT THE BENEFICIARY
9 FIFTEENTH AFFIRMATIVE DEFENSE
10 Plaintiff does not have clean hands as Plaintiff has committed a FRAUD by double
11 securitizing Plaintiff’s Note. And therefore IS not the proper party to participate in the
12 foreclosure OR THIS EVICTION.
13 SIXTEENTH AFFIRMATIVE DEFENSE
14 Defendants HAVE FILED a claim against Plaintiff for Fraud and will move this court to
15 consolidate both cases for trial.
16 SEVENTEENTH AFFIRMATIVE DEFENSE
17 Defendants attach hereto AND INCORPORATE AS PART OF THEIR AFFIRMATIVE
18 DEFENSES true and correct copies of Ohio Federal Court decisions where as here
19 DEUTSCHE BANK WAS FOUND TO BE THE WRONG PARTY AND THOSE
20 FORECLOSURES WERE DISMISSED.
21 EIGHTEENTH AFFIRMATIVE DEFENSE
22 Defendants attach hereto AND INCORPORATE AS PART OF THEIR AFFIRMATIVE
23 DEFENSES A true and correct copy of their first amended complaint against this
24 Plaintiff for among other claims FRAUD
25 WHEREFORE, Defendants, and each of them pray for judgment as follows:
26 A. That Plaintiff take nothing by way of the complaint; and
27 ///
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ANSWER TO COMPLAINT
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1 B. For costs of suit incurred herein; and
2 C. For such other and further relief that the Court deems just and proper.
3
4 DATE: June __, 2008

5 Respectfully Submitted,
6
___________________
7
KATRINA GJURASHAJ
8 34202 PINEHURST DRIVE,
YUCAIPA, CA 92399
9 Phone (951) 801-9526
Defendant In Pro Se
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ANSWER TO COMPLAINT
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1 VERIFICATION
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3 I, the undersigned, say:

4 I am ONE OF the Defendants in the above-entitled action. I have read the
5 foregoing ANSWER and know the contents thereof, and that the same is true of my own
6 knowledge, except as to the matters which are therein stated upon my information or
7 belief, and as to those matters that I believe them to be true.
8 I declare, under penalty of perjury, under the laws of the State of California, that
9 the foregoing is true and correct.
10 Executed on June __, 2008, at San Bernardino County, California.
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_______________________
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KATRINA GJURASHAJ
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ANSWER TO COMPLAINT
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1 PROOF OF SERVICE by Mail
I am employed in the county and state set forth above. I am over the age of 18
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and not a party to the within action; my address is:
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_______________________________
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On June __, 2008, I served the foregoing document described as Answer to the
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interested parties in this action:
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(X) by placing () the original (X) a true copy thereof enclosed in a sealed
7 envelope addressed as follows:
8
Randall D. Newman
9 4660 La Jolla Village Dr. Suite 500
San Diego, California 92122
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Attorney for Plaintiff
12 (X) (BY MAIL) I deposited with the U.S. postal service on that same day with
postage thereon fully prepaid at the city set forth above.
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(X) (STATE) I declare under penalty of perjury under the laws of the State of
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California that the foregoing is true and correct.
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Executed on June __, 2008, at San Bernardino, California.
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______________________
18 Jennifer GJURASHAJ
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ANSWER TO COMPLAINT
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24 EXHIBIT “A”
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26 Ohio cases Dismissing Deutsche Bank as a claimant

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ANSWER TO COMPLAINT
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21 EXHIBIT “B”
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23 Plaintiff’s first amended complaint against DEUTSCHE BANK ET. AL.

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ANSWER TO COMPLAINT
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KATRINA GJURASHAJ

6 SUPERIOR COURT OF THE STATE OF CALIFORNIA

7 IN AND FOR THE COUNTY OF SAN BERNARDINO

4 DATE: June __, 2008

3 I, the undersigned, say:

26 Ohio cases Dismissing Deutsche Bank as a claimant

23 Plaintiff’s first amended complaint against DEUTSCHE BANK ET. AL.

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