1 Valerie A.

Lopez
P.O. Box 291133
2 Phelan, California [92329]
619-343-9729
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4 Self-represented

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SUPERIOR COURT OF CALIFORNIA
7 COUNTY OF ORANGE COURT OF APPEAL
8 CENTRAL JUSTICE CENTER
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The Sunningdale Trust #2328, Vecchio Real ) Court of Appeal Case No.: 30-2018-01034346
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11 Estate Corp., as Trustee
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12 Respondent/Plaintiff ) Superior Court No.
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) 30-2018-00983668
vs. )
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) MOTION OF AUGMENT TO ADD
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Valerie Lopez DESIGNATED RECORDS;
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15 ) MEMORANDUM OF POINTS AND
Appellant/Defendant. ) AUTHORITIES AND DECLARATION OF
16 ) VALERIE LOPEZ
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Pursuant to Rule 8.155(a) of the California Rules of Court, I, VALERIE LOPEZ request
23 augmentation of the record on appeal to include documents in this case that were not included in the
Clerk's Transcript. Those documents are:
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(List the documents you are requesting)

26 #1 ROA # 108 06/19/2018 NOTICE AND MOTION FOR JUDGMENT ON THE

PLEADINGS – Exhibit 2 3-day Notice and Declaration of Service.
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4 The reason I am requesting these items are:

5 ALL RELATED DOCUMENTS PERTAINING TO THIS CASE are related to the current case.

6 I declare under penalty of perjury that the foregoing is true and correct.
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Executed at Fallrook, California on __________________, 2020.
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MEMORANDUM OF POINTS AND AUTHORITIES
2 AUGMENTATION SHOULD BE ORDERED
TO ALLOW APPELLANT TO RECEIVE
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FULL AND FAIR APPELLATE REVIEW
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5 Rule 8.155(a) of California Rules of Court permits the augmentation of the appellate record and
specifically under Rule 8.155(a)(1) allows a certified transcript or document not designated under
6 Rule 8.130 to be augmented and permitted. It is well established that this rule is to be construed
liberally. (People v. Brooks (1980) 26 Cal.3d 471, 484.)
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8 The need for augmentation is compelling. Appellant believes the trial court erred in denying the
Notice and Motion for Judgment on the Pleadings whereby Appellant brought to the court’s attention
9 that the Respondent failed to “duly perfect” title prior to serving the 3-day notice. This motion was
filed on June 19, 2018 [CT 3: 646-653] Exhibit 2 which is the 3-day notice and the declaration of
10 service was filed with the court on June 19, 2018 but was not scanned by the court. The issue can
only be reviewed on appeal if all of the related court's documents and minute orders before ruling is
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part of the appellate record. Appellant hereby augments the court record to include the missing
12 exhibit 2 documents which should have followed page 652 of Vol. 3 which was made apart of the
Notice and Motion for Judgment on the Pleadings on June 18, 2018. The documents attached should
13 have been a part of Volume 3 and following behind page 652 as these pages were Exhibit 2 for the
Notice and Motion for Judgement on the Pleadings.
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Not only is augmentation necessary, it will not prejudice any party. The augmentation request
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concerns documents which were all part of the record.
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CONCLUSION
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For the above reasons, this Court should order the record to be augmented on appeal by including the
18 listed motions, minute orders and document(s) requested in this motion.
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Dated: __________________________, 2020
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21 _________________________________

22 VALERIE LOPEZ

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DECLARATION IN SUPPORT OF MOTION TO AUGMENT
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5 I, Valerie Lopez, declare and state as follows:

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1. I am a self-represented litigant.
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2. June 19, 2018, I filed a Notice and Motion for Judgment on the Pleadings and pointed to
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serious issue that the Respondents failed to meet requirements of 1161a “duly” perfected
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title prior to serving the 3-day notice – a strict requirement of 1161a.
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3. Exhibit 2 of the Motion for Judgment on the Pleadings was proof that the Respondent’s
11 served the 3-day notice prior to the recording of the Trustee’s Deed Upon Sale – Exhibit
12 1.
13 4. I filed the 3-day notice and declaration of service as Exhibit 2 on June 19, 2018. There
14 seems to have been a problem when the court was preparing the court transcripts as the

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documents behind page 652 are missing. Exhibit 2 in its entirety is crucial for an effective
judicial review by the Appellate Panel.
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5. I had the hearing on June 26, 2018 at Department 66 where it was transcribed by Linda
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Ryan.
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6. I know of no prejudice to any party as a result of granting of this motion.
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7. This motion is made in good faith for the reasons set forth above and not for the purposes
20 of delay.
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22 I declare under penalty perjury that the foregoing is true and correct.

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Executed this ______________________, 2020 at Phelan, California.
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26 ____________________________
VALERIE LOPEZ
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