A void deed of trust is without legal effect. It binds no one and is a mere nullity. Such a contract has no existence whatsoever. It has no legal entity for any purpose and neither the inaction (failing to answer request for admission) of a party, nor the actions (answering request admission) of a party can validate it. A void thing is nothing. A void transaction cannot be rectified or validated by the parties to it even if they so desired. A homeowner who has been foreclosed on by one with no right to do so has suffered an injurious invasion of his legal rights at the foreclosing entity's hands (Yuanova v. New Century Morg. Corp., 62 Cal. 4th 919.)

The following questions are presented.

1) Have the Defendants satisfied all three factors of the doctrine of claim preclusion, which demands; (1) the claims in the present action be identical to the claims litigated in a prior proceeding; (2) the prior proceeding resulted in a final judgment on the merits; and (3) the party against whom the doctrine is being asserted was a party or in privity with a party to the prior proceeding?

2) Is a demurrer legally considered a ruling on the merits, which can be used for claim preclusion? Can a demurrer validate a void deed of trust?

3) Were the past causes of action in Case No. B247883 identical to these present causes of action under this review? Can the cause of actions in either case validate a void deed of trust?

4) Can a deed of trust, considered void "ab initio" pass privy to a nonaffiliated third-party? Can a deed of trust, considered void "ab initio" legally pass title?

5) Did petitioner present an "affirmative defense" to the defendants' claim preclusion defense in his opening brief, in his reply brief, and in his motion for reconsideration contrary to the 2nd District Court of Appeal's "2DCA" claim that he did not? Did petitioner's "affirmative defense" recite Judge Linfield's initial August 8th, 2016, ruling that rejected the defendants' initial claim preclusion defense in verbatim? Can the defendants' preclusion defense validate a void deed of trust?

6) Does Judge Michael Linfield's initial ruling on August 8th, 2016, regarding claim preclusion contradict his final ruling on January 7th, 2020, regarding the defendants' same exact recycled claim preclusion defense? Is it the duty of this reviewing court to settle the controversial, contradicting, and outstanding "question of law" regarding claim preclusion in this petition?

7) Does this case not mirror the same exact circumstances presented in Boyd v. Freeman (181 Cal. App. 5th 847, 227 Cal. Rptr. 3d ... - Cal: Court of Appeal, 2nd ..., 2017), a precedent case in which 2DCA determined that a demurrer based on the statute of limitations is a "technicality" ruling and not a ruling "on the merits?" Can a "technicality" ruling validate a void deed of trust?

8) Does the Seventh Amendment state?

In suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise re-examined in any Court of the United States, then according to the rules of the common law?

9) Does a "question of fact" unanimously decided upon by a criminal

Whether the defendants have satisfied all three factors of the doctrine of claim preclusion