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Law Office
Law Ofice Of0f
ELECTRONICALLY
ELECTRONICALLY FILED
FILED
MICHAEL P. RING
MICHAEL RING
Superior Court of California
County Santa Barbara
County of Santa Barbara
AND ASSOCIATES
AND ASSOCIATES
Parker, Executlve
_
Michael P. Ring, State
P, Ring, #95922
state Bar #95922 Darrel E. Parker, Executive Offlcer
Officer
M. Ring,
Iris L. M.Ring, State Bar #298179
State Bar #298179 2:08:31
3/8/2016 2:08:31 PM
PM
1234 Santa
1234 Santa Barbara Street Narzram
By: Narzralli Baksh,
Baksh, Deputy
Deputy
CA 93101
Santa Barbara, CA 93101
(805) 564-2333
ATTORNEYS FOR
ATTORNEYS
\IO‘\Ul-J>~
FOR PATSY
PATSY MOLERMOLER
SUPERIOR COURT
SUPERIOR COURT OF THE STATE
OF THE STATE OF OF CALIFORNIA
CALIFORNIA
FOR THE
FOR COUNTY OF
THE COUNTY OF SANTA BARBARA
SANTA BARBARA
00
ANACAPA DIVISION
ANACAPA DIVISION
Patsy Moler, )) 1417847
Case No. 1417847
10 )
Plaintiff, )) ANSER TO
ANSER TO THIRD AMENDED CROSS-
THIRD AMENDED CROSS-
11 ) COMPLAINT
COMPLAINT
v. ))
12 ) (Assigned to the Hon. James E. Herman) Herman)
Chris Hulme, individually and dba ))
13 Clearview Industries, Inc., and DOES DOES 11 ))
through 10,10, inclusive )
14 )g
Defendants. )
15 )g
And Related Cross-Actions
And ))
16
COMES NOW
COMES NOW Cross-Defendant Patsy Moler, herself alone, responds to the Cross-
who, for herself
17
Complaint as follows:
1s
1.
1. Cross-Defendant
This answering Cross-Defendant denies specifically
denies specifically and generally
and generally that she is liable
liable
19
Cross-Complainant
to Cross-Complainant amount claimed,
in the amount
in claimed, or sums whatsoever,
in any sums whatsoever, denies that
and further denies that
20
finding of
there is any basis for the finding of liability against this answering Cross-Defendant.
21
AFFIRMATIVE DEFENSES
AFFIRMATIVE DEFENSES
22
2.
2. As aa first
As affirmative defense,
first affirmative defense, this
this answering Cross-Defendant
answering Cross-Defendant alleges
alleges follows:
as follows:
23
Cross-Complainant is barred from asserting its claims based upon upon the doctrine of unclean hands.
24
3.
3. As a second affirmative
As affirmative defense, this answering Cross-Defendant alleges as follows:
25
Cross-Complainant’s
Cross-Complainant's claims barred
claims are barred by the applicable
by applicable statutes of limitation,
limitation, including,
including, but not
26
limited to CCP §§338,
t0 CCP §§338, 339, & & 340.
27
4.
4. As aa third
As affirmative defense,
third affirmative defense, this
this answering Cross-Defendant
answering Cross-Defendant follows:
alleges as follows:
28
1
Amended Cross-Complaint
Answer to Third Amended
Answer
Cross-Complainant
Cross-Complainant did not
did suffer any
not suffer any injury
injury from
from alleged
any alleged conduct
conduct of this answering Cross-
this answering Cross-
Defendant.
5.
5. As a fourth affirmative
As affirmative defense, this answering Cross-Defendant alleges as follows:
.5;
the Cross-Complaint, including each purported claim contained therein, fails to state facts sufficient
to constitute a cause of of action.
6.
6. As a fifth
As affirmative defense,
fifth affirmative defense, this
this answering Cross-Defendant
answering Cross-Defendant alleges
alleges follows:
as follows:
Cross-Complainant
Cross-Complainant failed
failed to take such
to take such steps, or took
steps, or took such steps,
steps, such
such that damages,
that the alleged damages, if
if
\OOO\IO\
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Law Office Law Ofice Of0f ELECTRONICALLY ELECTRONICALLY FILED FILED MICHAEL P. RING MICHAEL RING Superior Court of California County Santa Barbara County of Santa Barbara AND ASSOCIATES AND ASSOCIATES Parker, Executlve _ Michael P. Ring, State P, Ring, #95922 state Bar #95922 Darrel E. Parker, Executive Offlcer Officer M. Ring, Iris L. M.Ring, State Bar #298179 State Bar #298179 2:08:31 3/8/2016 2:08:31 PM PM 1234 Santa 1234 Santa Barbara Street Narzram By: Narzralli Baksh, Baksh, Deputy Deputy CA 93101 Santa Barbara, CA 93101 (805) 564-2333 ATTORNEYS FOR ATTORNEYS \IO‘\Ul-J>~ FOR PATSY PATSY MOLERMOLER SUPERIOR COURT SUPERIOR COURT OF THE STATE OF THE STATE OF OF CALIFORNIA CALIFORNIA FOR THE FOR COUNTY OF THE COUNTY OF SANTA BARBARA SANTA BARBARA 00 ANACAPA DIVISION ANACAPA DIVISION Patsy Moler, )) 1417847 Case No. 1417847 10 ) Plaintiff, )) ANSER TO ANSER TO THIRD AMENDED CROSS- THIRD AMENDED CROSS- 11 ) COMPLAINT COMPLAINT v. )) 12 ) (Assigned to the Hon. James E. Herman) Herman) Chris Hulme, individually and dba )) 13 Clearview Industries, Inc., and DOES DOES 11 )) through 10,10, inclusive ) 14 )g Defendants. ) 15 )g And Related Cross-Actions And )) 16 COMES NOW COMES NOW Cross-Defendant Patsy Moler, herself alone, responds to the Cross- who, for herself 17 Complaint as follows: 1s 1. 1. Cross-Defendant This answering Cross-Defendant denies specifically denies specifically and generally and generally that she is liable liable 19 Cross-Complainant to Cross-Complainant amount claimed, in the amount in claimed, or sums whatsoever, in any sums whatsoever, denies that and further denies that 20 finding of there is any basis for the finding of liability against this answering Cross-Defendant. 21 AFFIRMATIVE DEFENSES AFFIRMATIVE DEFENSES 22 2. 2. As aa first As affirmative defense, first affirmative defense, this this answering Cross-Defendant answering Cross-Defendant alleges alleges follows: as follows: 23 Cross-Complainant is barred from asserting its claims based upon upon the doctrine of unclean hands. 24 3. 3. As a second affirmative As affirmative defense, this answering Cross-Defendant alleges as follows: 25 Cross-Complainant’s Cross-Complainant's claims barred claims are barred by the applicable by applicable statutes of limitation, limitation, including, including, but not 26 limited to CCP §§338, t0 CCP §§338, 339, & & 340. 27 4. 4. As aa third As affirmative defense, third affirmative defense, this this answering Cross-Defendant answering Cross-Defendant follows: alleges as follows: 28 1 Amended Cross-Complaint Answer to Third Amended Answer Cross-Complainant Cross-Complainant did not did suffer any not suffer any injury injury from from alleged any alleged conduct conduct of this answering Cross- this answering Cross- Defendant. 5. 5. As a fourth affirmative As affirmative defense, this answering Cross-Defendant alleges as follows: .5; the Cross-Complaint, including each purported claim contained therein, fails to state facts sufficient to constitute a cause of of action. 6. 6. As a fifth As affirmative defense, fifth affirmative defense, this this answering Cross-Defendant answering Cross-Defendant alleges alleges follows: as follows: Cross-Complainant Cross-Complainant failed failed to take such to take such steps, or took steps, or took such steps, steps, such such that damages, that the alleged damages, if if \OOO\IO\