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LAW OFFICES OF CHARLES R. PERRY
`Charles R. Perry (SBN 124828)
`100 Pine Street, Suite 1250
`San Francisco, CA 94111
`Telephone: (415) 800-3937
`Telecopier: (415) 869-2822
`E-Mail: rick@crperrylaw.com
`
`Attorneys for Plaintiff
`Sherrie L. Corder
`
`4/5/2021
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`IN AND FOR THE COUNTY OF SAN MATEO
`
` Case No:
`21-CIV-01800
`COMPLAINT FOR DAMAGES
`
`)))))))))))
`
`SHERRIE CORDER, an individual,
`
` Plaintiff,
`
`vs.
`
`HEIR CASH NOW, LLC, a California limited
`liability company, and Does 1 through 50,
`inclusive,
`
` Defendant.
`
`Plaintiff, Sherrie Corder (“Sherrie”), hereby complains and alleges as follows:
`Sherrie is an individual currently residing in Stanislaus County, State of
`1.
`California. Sherrie also lived in San Mateo County during many of the events that led to this
`action.
`
`Defendant Heir Cash Now, LLC (“Heir Cash”) is, and at all times relevant was, a
`2.
`California limited liability company with its principal place of business in Marin County,
`California.
`The true names and capacities of the defendants sued herein as Does 1 through
`3.
`50, inclusive, are unknown to Corder, and Corder accordingly sues these defendants by their
`
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` Case No. Complaint for Damages and
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`fictitious names. Corder will amend this complaint in accordance with Section 474 of the
`California Code of Civil Procedure once the true names and capacities of these defendants have
`been ascertained.
`Beginning in May 2010 and continuously to January 2020, Corder had a one-
`4.
`third interest in a piece of property located at 1325 Cloud Avenue, Menlo Park, California (the
`“Property”).
`As of May 2010, Corder’s siblings Donald White (“Donald”) and Sonja White
`5.
`(“Sonja”) also each had a one-third interest in the Property.
`Donald passed away in June 2013, and Corder eventually became the
`6.
`administrator of Donald’s estate.
`Sonja and Corder agreed to sell the Property while Donald’s interest was still in
`7.
`probate. Corder made this agreement on behalf of herself as an individual and as the
`administrator of Donald’s estate.
`Corder wanted and needed cash before the Property sold, and saw on the Internet
`8.
`that Heir Cash advertised loans as “Inheritance Loan Specialists.” Indeed, Heir Cash’s website
`is full of material talking about “Inheritance Loans.” Attached hereto as Exhibit 1 are true and
`correct copies of screenshots from Heir Cash’s website.
`On August 13, 2018 Corder obtained a $50,000 loan from Heir Cash; however,
`9.
`the loan documents that Corder received from Heir Cash were structured as an “option” on the
`Property. A true and correct copy of the loan agreement is attached hereto as Exhibit 2. This
`agreement was also made in San Mateo County, and was where Corder would make any
`repayment to Heir Cash.
`Corder and Heir Cash knew that Heir Cash would never exercise the “option,”
`10.
`and understand that the $50,000 was a loan with interest expressed as an Early Termination Fee.
`See Ex. 2, ¶13. Indeed, Heir Cash expressly told Sheri on July 17, 2018 that it had no intention
`of exercising the option. A true and correct copy of this message is attached hereto as Exhibit 3.
`
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` Case No. Complaint for Damages and
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`As such, structuring the transaction as an “option” was simply an attempt by Heir Cash to make
`a loan at usurious interest rates.
`On January 10, 2019, Corder obtained an additional $25,000 loan from Heir
`11.
`Cash, and Heir Cash provided an amendment to the loan agreement. A true and correct copy of
`the amended loan agreement is attached hereto as Exhibit 4.
`The amendment increased the interest, again called an Early Termination Fee.
`12.
`See Ex. 4, ¶ 5.
` When the Property sold on January 24, 2020 Heir Cash received $150,000 in
`13.
`repayment for its $75,000 loan to Corder. As such, the interest rate on the loan was far more
`than the 10 percent per annum allowed by law.
`
`FIRST CAUSE OF ACTION
`
`
`(Usury Violation)
` Corder incorporates all of the allegations set forth above, as though fully set
`
`14.
`forth herein.
`Heir Cash loaned Corder $50,000 on August 13, 2018, and an additional $25,000
`15.
`on January 10, 2019.
`16.
`Corder repaid Heir Cash the sum of $150,000 on January 24, 2020, which meant
`she paid $75,000.00 in interest.
`17.
`Heir Cash had no risk on the loan, as Corder’s interest in the Property was valued
`in excess of $750,000. Heir Cash also had no intention at any time of exercising the option.
`18.
`Corder paid interest far in excess of the maximum permissible rate authorized by
`Cal. Const. XV, §1, and Usury Law, Stats. 1919, p. lxxxiii, Deering’s Uncod. Initiative
`Measures & Stats. 1919-1, and Corder is entitled to repayment from Heir Cash of treble the
`amount of interest paid.
`
`
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`SECOND CAUSE OF ACTION
`
`(Deceptive Advertising and Unfair Competition, Bus. & Prof. Code §17200 et seq)
`19.
` Corder incorporates all of the allegations set forth above, as though fully set
`forth herein.
`Heir Cash’s transaction involves the assessment of interest expressly prohibited
`20.
`by the maximum rate set forth in Cal. Const. Art. XV, §1. Heir Cash’s business practices also
`include representations on its website that it provides “loans” to people who qualify. Heir Cash
`fails to disclose that its loans are at usurious interest rates, and that it will in fact disguise its
`loan as an “option” that it never intends to exercise. These practices are thus either unlawful or
`unfair, under Section 17200 et seq. of the California Business and Professions Code.
`21.
`Corder has suffered injury in fact and has lost money as a result of Heir Cash’s
`acts of unfair competition.
`22.
`Corder is accordingly entitled to injunctive relief requiring Heir Cash now
`provide truthful advertising on its website regarding its produce, and comply with all usury laws
`in the State of California. Corder is also entitled to restitution of all interest paid to Heir Cash.
`
`THIRD CAUSE OF ACTION
`
`
`
`(Consumers’ Legal Remedies Act, Civil Code §1750 et seq)
`Corder incorporates all of the allegations set forth above, as though fully set forth
`
`23.
`
`herein.
`
`Corder is a consumer as that term is defined in Civil Code §1761.
`24.
`Heir Cash has violated Civil Code § 1770(a)(9) by representing its product as a
`25.
`loan, with no intention of providing that product as advertised.
`Heir Cash has violated Civil Code §1770(a)(14) by representing that the loan
`26.
`transaction requires the payment of interest at a rate above that allowed by law.
`27.
`Heir Cash has violated Civil Code §1770(a)(19) by inserting an unconscionable
`provision in a contract.
`
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`Heir Cash has violated Civil Code §1770(a)(26) by selling a financial product
`28.
`that is illegal under California law, given the interest rate charged for the transaction.
`29.
`Heir Cash’s violations of Civil Code §1770 present a continuing threat to
`members of the public in that Heir Cash continues to engage in these practices and refuses to
`refund the amounts paid by Corder, and will not cease until an injunction is issued by this
`Court.
`
`By way of letter dated December 11, 2020, Corder notified Heir Cash of its
`30.
`violations and demanded that Heir Cash provide remedies to rectify its conduct. A true and
`correct copy of this letter is attached as Exhibit 5.
`By way of letter dated January 19, 2021, Heir Cash failed to give any remedy for
`31.
`the above-mentioned violations. A true and correct copy of this letter is attached hereto as
`Exhibit 6.
`Corder has suffered an injury in an amount subject to proof at trial, but which is
`32.
`no less than $75,000.00.
` Heir Cash’s conduct is and is entitled to recover relief and damages pursuant to
`33.
`Civil Code §1780 including attorneys fees pursuant to §1780(d). Heir Cash’s conduct was also
`fraudulent and malicious, in that it was designed to prey upon the desires of people who needed
`cash immediately instead of waiting for their inheritance, and was based on false
`representations to potential clients about their product being a lawful loan.
`WHEREFORE, Corder prays for relief against Heir Cash as follows:
`1.
`Compensatory damages in an amount according to proof, but in no event less
`than Two Hundred Twenty-Five Thousand Dollars ($225,000.00);
`2.
`Exemplary damages in an amount according to proof;
`3.
`Reasonable attorney’s fees in an amount according to proof;
`4.
`An injunction against Heir Cash prohibiting it from engaging in violations of
`California’s usury laws, or advertising its product as “loans” unless the interest rate is at or less
`
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`than the maximum legal rate;
`5.
`Pre-judgment interest and costs of suit; and
`6.
`Such other and further relief that this Court deems just and proper.
`
`Dated: April 4, 2021
`
`LAW OFFICES OF
`CHARLES R. PERRY
`
`Charles R. Perry
`Attorney for Plaintiff
`Sherrie L. Corder
`
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`Option Agreement
`
`This Option Agreement is made between Sherrie L. Corder (Optionor) and Heir Cash Now,
`LLC (Optionee). This Option Agreement is dated August 13, 2018, for reference purposes only.
`
`RECITALS
`
`WHEREAS, Optionor holds an interest in that certain property described hereinbelow, which
`she and her family are in the process of selling;
`
`WHEREAS, Optionor desires to obtain liquid funds by granting an option to Optionee to
`purchase her interest in the event that the aforementioned sale is not consummated in a timely
`manner;
`
`WHEREAS, Optionee desires to advance funds to Optionor to obtain an option to purchase
`Optionor’s interest in that certain property, exercisable at a discounted valuation representing a
`reasonable return as negotiated by the parties;
`
`NOW THEREFORE, Optionor and Optionee agree to the following terms:
`
`1. Grant of Option. Optionor grants to Optionee the option to purchase Optionor’s undivided
`one-third interest as a tenant in common (Interest) in the real property described in the attached
`Exhibit A, commonly known as 1325 Cloud Ave., Menlo Park, CA 94025 (Property). This
`option is on the terms and conditions set forth in this Option Agreement. The purchase and sale
`of the Interest on exercise of this option shall be on the terms and conditions set forth in the
`Purchase and Sale Agreement, attached as Exhibit B (Purchase Agreement).
`
`2. Term of Option. The initial term of the option shall begin on August 13, 2018, and shall
`terminate at 5:00p.m. (California time) on February 12, 2019.
`
`As long as this Option Agreement remains in effect, Optionee may extend the term of the
`option for the periods described in Section 3.2 by timely payment of the extension payment
`amounts described in that section.
`
`3. Consideration.
`
`3.1. Payment of Consideration. On the execution and delivery of this Option Agreement,
`Optionee shall pay to Optionor, in immediately available funds, the sum of Fifty Thousand
`Dollars ($50,000) as consideration for the option. The option consideration set forth in this
`section, as well as any other consideration deemed to have been received by Optionor under this
`Option Agreement, is and shall be deemed consideration solely for the granting of the option by
`Optionor. On expiration of the option term, including any extensions, Optionor shall retain all
`option consideration, except as provided for in Section 13 (Early Termination). If the option is
`exercised, the consideration shall be credited against the purchase price of the Interest if closing
`occurs in accordance with the Purchase Agreement.
`
`3.2. Successive Payments to Extend Option Term. Optionee may extend the term of the option
`from the expiration of the Initial Term until 5:00p.m. (California time) on May 13, 2019 (First
`
`

`

`Extended Term), by payment to Optionor, in immediately available funds, the sum of One Dollar
`($1) on or before the 14th day before the expiration of the Initial Term.
`
`During the First Extended Term and any successive three-month extension term, Optionee
`may extend the term of the option from the expiration of the then-current term for an additional
`period of three (3) months (expiring at 5:00p.m., California time, on the final day of the
`extension term) by payment to Optionor, in immediately available funds, the sum of One Dollar
`($1) on or before the 14th day before the expiration of the current term.
`
`Payments made under this section shall be applied to the purchase price of the Interest.
`
`4. Exercise of Option.
`
`4.1. Conditions for Exercise of Option. If Optionee is not in default under this Option
`Agreement and all conditions to the exercise of the option are satisfied or are waived in writing
`by Optionor, Optionee may exercise the option in accordance with this section and in no other
`manner. The option shall be exercised by delivering written notice from Optionee to Optionor
`before the expiration of the term of this option and in accordance with the notice provisions of
`section 16 (Exercise Notice). The Exercise Notice shall affirmatively state that the Optionee
`exercises the option without condition or qualification. Within 7 business days after exercise of
`the option, the parties shall execute and deliver the Purchase Agreement and shall deposit the
`funds and documents in escrow that the Purchase Agreement requires to be deposited when the
`Purchase Agreement is executed.
`
`5. Covenants and Warranties of Optionor Concerning Property. Optionor covenants, warrants,
`and represents to Optionee that all the covenants, warranties, and representations set forth in
`Section 5 of the Purchase Agreement are true and correct.
`
`6. Condition of Title.
`
`6.1. Preliminary Report. Within 10 days after execution of this Option Agreement, Optionor
`shall deliver to Optionee a current preliminary report on the Property prepared by First American
`Title Company, together with copies of all documents identified as exceptions in the report
`(collectively, Preliminary Report). Optionee shall have 15 days after receipt of the Preliminary
`Report in which to approve or disapprove any or all of the exceptions shown in the Preliminary
`Report.
`
`6.2. Approval of Exceptions in Preliminary Report. Optionee shall disapprove exceptions
`shown in the Preliminary Report only by delivering written notice to Optionor within 15 days. If
`Optionee does not give written notice of disapproval within that time, Optionee shall be deemed
`to have approved all the exceptions shown in the Preliminary Report.
`
`6.3. Clearing of Exceptions in Preliminary Report. If Optionee disapproves any exception to
`title, as provided above, Optionor shall notify Optionee within 10 days after receipt of such
`notice of disapproval if Optionor is unwilling to clear the disapproved exceptions. Optionor
`covenants that, if the option is exercised, Optionor shall, on or before closing under the Purchase
`Agreement, cause all disapproved exceptions to be removed as encumbrances against title to the
`Property except any exceptions that Optionor has notified Optionee that Optionor will not
`
`

`

`remove, in accordance with the notice provisions of this section. Optionee is aware that
`Optionor’s interest in the Property is limited to the Interest, and Optionor shall not be required to
`remove encumbrances or provide clear title relating to the two-thirds interest in the Property that
`Optionor does not hold.
`
`6.4. Failure to Clear Exceptions in Preliminary Report. If Optionor notifies Optionee that
`Optionor will not remove one or more disapproved exceptions, Optionee may elect by delivering
`written notice to Optionor, within 5 days after receipt of Optionor’s notice, to terminate this
`option and receive a refund of the option consideration paid to Optionor or to waive this
`condition, and this option shall then remain in full force and effect. Optionee’s failure to give
`notice shall waive this condition.
`
`7. Preservation of Property.
`
`7.1. Insurance. Optionor shall secure and maintain at all times during the term of this Option
`Agreement a commercial general liability policy of insurance, including bodily injury and
`property damage coverage, written on an “occurrence” basis, with limits of not less than
`$1,000,000 insuring Optionor against injury to persons or damage to property arising from or in
`connection with any action permitted under this Option Agreement, naming Optionee as an
`additional insured under that coverage, and containing coverage for contractual liability for
`Optionor’s obligations under this Option Agreement. Optionor shall deliver to Optionee a copy
`of certificates evidencing such coverage in force, together with copies of the policies of
`insurance, within 15 days of the execution of this agreement. Each policy will contain a
`provision that such policy may not be terminated until 15 days after written notice of the
`proposed termination has been delivered to Optionee.
`
`8. Intentionally Ommitted.
`
`9. Option May Be Assigned. Optionee may assign this option and the rights under it, but such
`assignment shall not relieve Optionee of any liability or obligation under this Option Agreement.
`An assignment shall be effective only if the assignee assumes all the duties and obligations of
`Optionee under this Option Agreement in a writing duly executed and delivered to Optionor.
`
`10. Risk of Loss. If material loss or damage occurs to the Property during the option term but
`before exercise of the option, Optionee may elect to terminate this option by delivering written
`notice to Optionor within 30 days after discovering such loss or damage, and on such election
`Optionor shall immediately refund to Optionee the option consideration paid to Optionor.
`Optionee shall have no other right or remedy in the event of such loss or damage.
`
`11. Condemnation. If at any time during the term but before exercise of the option either
`Optionor or Optionee receives notice of any condemnation or eminent domain proceeding, or
`any proceeding in lieu of condemnation, initiated against the Property, the party receiving notice
`shall promptly notify the other party of that fact. Optionee may elect to terminate this option by
`delivering written notice to Optionor within thirty days after Optionee receives such notice, and
`on such election Optionor shall immediately refund to Optionee the option consideration paid to
`Optionor. Optionee shall have no other right or remedy in such condemnation or eminent domain
`action.
`
`

`

`12. Memorandum of Option to be Recorded. On execution of this Option Agreement, Optionor
`and Optionee shall execute and record in the official records of the county in which the Property
`is located a memorandum of option in the form of the attached Exhibit C. Optionee shall pay the
`recording cost. Optionee covenants to execute and deliver to Optionor immediately on the
`expiration or earlier termination of the term of this Option Agreement a quitclaim deed in
`recordable form releasing and reconveying to Optionor all right, title, and interest of Optionee in
`the Property.
`
`13. Early Termination. Optionor may elect to sell its Interest while this Option Agreement is
`still in effect, which sale shall constitute an early termination (Early Termination) of this Option
`Agreement. In the event of an Early Termination, the parties agree to the following conditions:
`
`13.1. Notice of Intent to Sell. Optionor shall deliver a notice (Notice of Sale) to Optionee
`stating (i) its good faith intention to sell the Interest, and (ii) the price, terms, and conditions on
`which it proposes to sell the Interest. In the event that the sale of the Interest is part of a sale of
`the entire Property by its interest holders, Optionor’s Notice of Sale shall include the price,
`terms, and conditions of the proposed sale of the Property.
`
`13.2. Early Termination Fee. The parties agree that upon consummation of Optionor’s sale of
`the Interest, Optionee shall receive an Early Termination Fee, which shall be calculated
`according to the following schedule:
`
`
`Months Since Execution of
`Option Agreement
`
`Early Termination Fee Owed
`By Optionor
`
`<6
`
`≥6 and <9
`
`≥9 and <12
`
`≥12 and <15
`
`≥15
`
`$80,000
`
`$85,000
`
`$90,000
`
`$95,000
`
`$100,000
`
`
`13.3. Payment Details. In the event that Early Termination is triggered by the sale of the entire
`Property, the Early Termination Fee shall be paid out of escrow upon closing of said sale.
`Optionor covenants to take steps to ensure that Optionee submits a payment demand to escrow in
`the amount of the Early Termination Fee, which payment shall be a condition to the closing of
`escrow. In the event that Early Termination is triggered by the sale of the Interest without the
`sale of the Property, Optionor agrees to condition the sale on the buyer’s payment to Optionee by
`cashier’s check of the appropriate Early Termination Fee.
`
`13.4. Releasing the Option. Upon receipt of the Early Termination Fee (or as a simultaneous
`condition of the execution of the sale of the Property or Interest in which Optionee shall receive
`the Early Termination Fee, as outlined in section 13.3), Optionee covenants to immediately
`execute and deliver to Optionor a quitclaim deed in recordable form releasing and reconveying to
`Optionor all right, title, and interest of Optionee in the Property.
`
`

`

`14. Time of Essence; Failure to Exercise. Time is of the essence of this Option Agreement and
`is a material term of this Option Agreement. If the option is not exercised as required by this
`Option Agreement before expiration of the term of the option that is set forth here, the option and
`all rights of Optionee shall automatically and immediately terminate without notice, and
`Optionee shall have no interest whatever in the Property. Once it has terminated, the option may
`not be revived by any subsequent payment or further action by Optionee.
`
`15. Attorney Fees. In the event of any action at law or in equity between the parties arising
`from or in connection with this Option Agreement, the prevailing party shall recover attorney
`fees and other costs incurred in that action in addition to any other relief, and such attorney fees
`and costs shall be included in and as a part of any judgment in such action.
`
`16. Notices. All notices and other communications authorized or required under this Option
`Agreement shall be in writing and shall be given by (1) personal delivery, (2) mailing by
`certified mail or registered mail, return receipt requested, postage prepaid, or United States
`express mail, (3) delivery by commercially recognized courier service, or (4) email. Any such
`notice or other communication shall be deemed to have been given on the date of delivery or
`refusal to accept delivery if addressed as follows:
`
`Optionor:
`Sherrie L. Corder
`1325 Cloud Ave.
`Menlo Park, CA 94025
`Email: shericorder@gmail.com
`
`Optionee:
`Heir Cash Now, LLC
`c/o Matthew Lakenbach, Its Managing
`Director
`41 Crossroads Plaza, Suite 225
`West Hartford, CT 06117
`Email: matt@heircashnow.com
`
`
`
`17. Entire Agreement. This Agreement and all exhibits referred to in this Agreement constitute
`the complete, exclusive, and final statement of the terms of the agreement with respect to the
`option and may not be contradicted by evidence of any prior or contemporaneous agreement.
`This Option Agreement specifically supersedes any prior written or oral agreements between the
`parties. The language in all parts of this Option Agreement shall be construed as a whole in
`accordance with its fair meaning and without regard to California Civil Code §1654 or similar
`statutes. Neither party has been induced to enter into this Option Agreement by, and neither party
`is relying on, any representation or warranty outside those expressly set forth in this Option
`Agreement and the Purchase Agreement. No supplement, modification, or amendment of this
`Option Agreement shall be binding unless executed in writing by all parties.
`
`18. Waiver. No waiver of any provision of this Option Agreement shall constitute or be
`deemed a waiver of any other provision, whether or not similar, nor shall any waiver constitute a
`continuing waiver. No waiver shall be binding unless it is executed in writing by the party
`making the waiver.
`
`19. Captions. The captions to the paragraphs of this Option Agreement are inserted for
`convenience only and shall not affect the intent of this Option Agreement.
`
`

`

`
`
`IN WITNESS WHEREOF, the parties have executed this Option Agreement on the date set
`forth beside the signature of each.
`
`08/13/2018
`Date: _______________
`
`08/13/2018
`Date: _______________
`
`
`
`
`
`
`
`
`
`Optionor:
`Sherrie L. Corder
`
`___________________________
`
`
`Optionee:
`Heir Cash Now, LLC,
`a California limited liability company
`
`By: ___________________________
`Name: Matthew Lakenbach
`Its: Managing Director
`
`

`

`EXHIBIT A
`
`Property Description
`
`
`
`The following describes and defines “Property” as used in the Option Agreement referencing this
`Exhibit.
`
`
`LEGAL DESCRIPTION
`
`Real property in the unincorporated area of the County of San Mateo, State of California, described as
`follows:
`
`PARCEL ONE:
`
`LOT 14, BLOCK 8, AS DESIGNATED ON THE MAP ENTITLED "UNIVERSITY HEIGHTS SAN MATEO
`COUNTY," WHICH MAP WAS FILED IN THE OFFICE OF THE RECORDER OF THE COUNTY OF SAN
`MATEO, STATE OF CALIFORNIA ON AUGUST 28, 1889 IN BOOK "D" OF MAPS AT PAGE 52, AND A COPY
`ENTERED IN BOOK 1 OF MAPS AT PAGE 96.
`
`PARCEL TWO:
`
`A PORTION OF CLOUD AVENUE ABANDONED, BEING A STRIP OF LAND 4 FEET IN WIDTH, LYING
`BETWEEN THE NORTHEASTERLY LINE OF LOT 14, BLOCK 8 AND A LINE PARALLEL WITH AND
`DISTANCE 4 FEET NORTHEASTERLY THEREFROM, AS SAID AVENUE, LOT AND BLOCK ARE SHOWN ON
`THE MAP ENTITLED "UNIVERSITY HEIGHTS SAN MATEO COUNTY," WHICH MAP WAS FILED IN THE
`OFFICE OF THE RECORDER OF THE COUNTY OF SAN MATEO, STATE OF CALIFORNIA ON AUGUST 28,
`1889 IN BOOK "D" OF MAPS AT PAGE 52, AND A COPY ENTERED IN BOOK 1 OF MAPS AT PAGE 96, AND
`BEING A PORTION OF PARCEL (D) DESCRIBED IN THE RESOLUTION ABANDONING PORTION OF CLOUD
`AVENUE, RECORDED JANUARY 3, 1952 IN BOOK 2180 OF OFFICIAL RECORDS OF SAN MATEO COUNTY
`AT PAGE 674 (80301-J).
`
`JPN: 074-006-063-28A
`
`APN: 074-063-280-7
`
`
`
`
`
`

`

`EXHIBIT B
`
`Purchase Agreement
`
`
`
`
`
`

`

`EXHIBIT C
`
`Memorandum of Option
`
`

`

`
`
`
`
`Recording requested by:
`
`After recording, return to:
`
`
`
`
`MEMORANDUM OF OPTION
`
`This Memorandum of Option is made on August 13, 2018, between Sherrie L. Corder
`(Optionor) and Heir Cash Now, LLC (Optionee), who agree as follows:
`
`1. Optionor grants to Optionee the option to purchase Optionor’s undivided one-third interest
`as a tenant in common (Interest)

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