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Mayen v. Countrywide Home Loans, Inc. CA4/1
, and The Bank of New York Mellon. I. INTRODUCTION Plaintiff Julio Mayen sued to quiet title as against various entities associated with a loan he and his wife (Wife) took out to acquire a residence.1 The defendants demurred on the grounds that Mayen (1) failed to state a cause of action to quiet title because he did not allege that he tendered full repayment of the underlying debt (the tender rule); (2) failed to name Wife,

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