Complaint,Petition: Tracy B Page vs Larry Taylor et al.

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WILLOUGHBY, STUART. BENING & COOK

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BRUCE D. MacLEOD - 130860

WILLOUGHBY, STUART, BENING & COOK, INC.
50 W. San Fernando St., Suite 400

San Jose, California 95113

Telephone: (408) 289-1972

Facsimile: (408) 295-6375

 

Attorneys for Defendant
JEFFREY LOEW

Luus2e /408
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
JN AND FOR THE COUNTY OF SAN JOAQUIN
TRACY B. PAGE, an individual, Case No. STK-CV-UF-2020-0010485

DEFENDANT JEFFREY LOEW’S
DEMURRER TO FIRST AMENDED

Plaintiff,

vs. COMPLAINT
LARRY TAYLOR, an individual;

JEFFREY LOEW, an individual; Date: SEP 09 2021
‘AMERICAN GENERAL LIFE Time: 9:00 a.m.

INSURANCE COMPANY AKA AIG, a
Texas corporation, and DOES | through 50,
inclusive,

Complaint Filed: 12/14/2020
Trial Date: None Assigned
Defendants. [Assigned for all purposes to the Honorable
Barbara Kronlund, Department 10D]

Ne ee

TO PLAINTIFF TRACY B. PAGE, AND HER ATTORNEY OF RECORD:

Defendant Jeffrey Loew demurs generally to the Sixth Cause of Action for “Legal
Malpractice” pursuant to Code of Civil Procedure §430.10 that the matter fails to state a cause of
action because it is barred by the statute of limitations.

Defendant Jeffrey Loew demurs generally to the Seventh Cause of Action for Negligence
pursuant to Code of Civil Procedure §430.10 that the matter fails to state a cause of action because it
is barred by the statute of limitations.

Defendant Jeffrey Loew demurs generally to the Eighth Cause of Action for Breach of
Fiduciary Duty pursuant to Code of Civil Procedure §430.10 that the matter fails to state a cause of

action because it is barred by the statute of limitations.

DEFENDANT JEFFREY LOEW'S
DEMURRER TO FIRST AMENDED
COMPLAINT l 1490.14002M

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FleWILLOUGHBY, STUART, BENING & COOK

No - -

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Defendant Jeffrey Loew demurs generally to the Ninth Cause of Action for Unfair Business
Practices pursuant to Code of Civil Procedure §430.10 that the matter fails to state a cause of action
because it is barred by the statute of limitations,

Defendant Jeffrey Loew demurs generally to the Tenth Cause of Action for Breach of the
Implied Covenant of Good Faith and Fair Dealing pursuant to Code of Civil Procedure §430.10 that
the matter fails to state a causc of action becausc it is barred by the statute of limitations; defendant
Jeffrey Loew further demurs generally to the Thirteenth Cause of Action for Breach of the Implied
Covenant of Good Faith and Fair Dealing on the grounds that it fails to state a cause of action.

Defendant Jeffrey Loew demurs generally to the Eleventh Cause of Action for Negligent
Infliction of Emotional Distress pursuant to Code of Civil Procedure §430.10 that the matter fails to
state a cause of action because it is barred by the statute of limitations.’ ,

DATED: July 25, 2021 WILLOUGHBY, STUART, BENING & COOK

Bue D. Waclsed.

BRUCE D. MacLEOD
Attorneys for Defendant
JEFFREY LOEW

, Defendant Jeffrey Loew has not been named as a Defendant in the Ist through 5th Causes of Action.

DEFENDANT JEFFREY LOEW'S
DEMURRER TO FIRST AMENDED
COMPLAINT 2 1490.14002M_