McAdams

I. FACTUAL BACKGROUND

Plaintiff purchased her former home in August 2004. Complaint 4 15. The home was purchased “with a loan obtained from American Wholesale Lender, Inc.” * Id. Defendant was the mortgage servicer to Plaintiff's loan. /d. 17. 26 Plaintiff received her first loan modification from Defendant in October

2010. Id. 4 18. A few years later, in April 2014, Plaintiff defaulted on her loan. /d. { □

|| 19. Plaintiff filed for Chapter 13 bankruptcy relief on April 23, 2015, and the 2 || bankruptcy plan was confirmed on the same day. (/d. at § 20; Plaintiff Req. Judicial |) Notice Ex. at 2 [ECF No. 37-2.]) In December 2016, Plaintiff entered a second loan modification with 5 || Defendant. /d. § 21. Plaintiffs financial difficulties continued over the next several 6 || years. See id. J] 25-28. In November 2018, Plaintiff again defaulted on her loan 7 || and requested a third loan modification from Defendant. /d. 9 27, 29. In December 2018, Defendant sent Plaintiff a Borrower Response Package 9 || (‘Package’), which Defendant uses to assess whether a loan modification is 10 |) necessary. See id. □□…