We represented lender Washington Federal in a declaratory relief action to determine ownership to valuable land use entitlements following the lender's non-judicial foreclosure of land held for development. The borrower and its assignee contested Washington Federal's ownership of the land use entitlements. We obtained declaratory relief in favor of Washington Federal that its deed of trust encumbered the land use entitlements, and that it acquired those entitlements through foreclosure, an outcome that could be valued in the millions of dollars (the difference between the value of the REO property with and without entitlements).