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Electronically FILED by Superior Court of California, County of Los Angeles on 09/16/2021 07:09 PM Sherri R. Carter, Executive Officer/Clerk of Court, by X. Soto,Deputy Clerk
L|THE LAW FIRM OF FOX AND FOX
Frank O. Fox - State Bar No. 117780
214262 Wilshire Boulevard, Third Floor
Los Angeles, California 90010-3505
3
{323} 937-4422 FAX (323}937-0282
4
57Attorneys For Defendant,
HARRY STOVALL
6
7
8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
9
10 /DION MIAL, }) Case No. 29 STCV 43317
)
11 Plaintiff, ) [Related Case: In re the
) Stovall Community Trust,
12 Vv. ) L.A.S.C. Case No. 17 STPB
} 09478]
13 |HARRY STOVALL, JR., an individual;}
and DOES 1 through 20; ) ANSWER TO COMPLAINT
14 )
Defendants. ) Dept: 67
15 }
)
16 }
17 TO PLAINTIFF, DION MIAL, AND HIS ATTORNEYS OF RECORD,
18 ALBERTSON & DAVIDSON, LLP:
13
20 Defendant, HARRY STOVALL, JR., an individual (hereinafter
21)"Harry") hereby answers the Complaint, filed by Plaintiff, DION MIAL
22|\ (hereinafter "Dion"), therein and admits, denies and alleges as
23 follows:
24
25 N.B. Harry's Demurrer to the Complaint was overruled
26 |through an Order, issued February 23, 2021, after being taken under
27 submission on February 8, 2021. The Order, required Harry to answer
28
THE LAW FIRM OF FOX AND FOX "ANSWER TO COMPLAINT
MIAL V. STOVALL L.A.S.C. CASE NO. 139 STCV 43317; PAGE 1
stovall-civilipleadings202
1 fanswer-17
Lithe Complaint, but did not order him to do so within a certain time.
24s of the date of this Answer, no request to enter defauit on the
3/Complaint has been submitted by Dion.
4}
5 JURISDICTION AND VENUE
6
7 1. Answering Paragraph One of the Complaint, Harry
8jdenies, generally and specifically, each and every allegation
9iicontained therein.
LO
12 2. Answering Paragraph Two of the Complaint, Harry
12fdenies, generally and specifically, each and every allegation
i3 contained therein.
14
15 PARTIES
16
17 3. Answering Paragraph Three of the Complaint, Harry
1sjadmits the allegations contained therein.
19
20 4. Answering Paragraph Four of the Complaint, Harry
21lidenies that "in accordance with Welfare and Institutions Code
22|)section 15657.3, [Dion] has standing and is authorized to pursue a
23 cause of action for financial elder abuse", and admits the balance
24jof the allegations contained therein.
25
26 5. Answering Paragraph Five of the Complaint, Harry
27 admits the allegations contained therein.
28
THE LAW FIRM OF FOX AND FOX ~~~”
ANSWER TO COMPLAINT
MIAL V. STOVALL L.A.S.C, CASE NO. 19 STCV 43317; PAGE 2
stovall-civilipleadings/202 Vanswer-1/?
1 6. Answering Paragraph Six of the Complaint, Harry
z2jStates that he lacks sufficient information to admit or deny the
3}allegations contained therein, and, on that basis, denies.
4
5 7. Answering Paragraph Seven of the Complaint, Harry
gistates that he lacks sufficient information to admit or deny the
7fallegations contained therein, and, on that basis, denies.
8
9 8. Answering Paragraph Eight of the Complaint, Harry
1o0]/denies, generally and specifically, each and every allegation
lifcontained therein.
12
13 2. Answering Paragraph Nine of the Complaint, Harry
14|denies, generally and specifically, each and every allegation
15 jcontained therein.
16
17 10. Answering Paragraph Ten of the Complaint, Harry
lg/denies, generally and specifically, each and every allegation
ag ycontained therein.
20
21 FACTUAL BACKGROUND
22
23 11. Answering Paragraph Eleven of the Complaint, Harry
24ladmits the allegations contained therein.
25
26 12. Answering Paragraph Twelve of the Complaint, Harry
27 )}denies that Dion's entitlement to receive the real property, located
28
THE LAW FIRM OF FOX AND FOX ~=~—~—~—~—~—~—~””—”—”””C
TO OANSWER
COMPLAINT
MIAL V. STOVALL L.A.S.C. CASH NO. 19 STCV 43317; PAGE 3
stovall-clviipleadings/202 answer?
1yat 4710 Don Miguel Drive, Los Angeles, California, 30008 (the
i is unconditional, and admits the balance of the
3 allegations contained therein.
5| 13. Answering Paragraph Thirteen of the Complaint, Harry
6jadmits the allegations contained therein.
7
8 14. Answering Paragraph Fourteen of the Complaint, Harry
gladmits the allegations contained therein.
19
11 15. Answering Paragraph Fifteen of the Complaint, Harry
12jadmits the allegations contained therein.
13 |
14| 16. Answering Paragraph Sixteen of the Complaint, Harry
iSidenies, generally and specifically, each and every allegation
16 |contained therein.
17
18 17. Answering Paragraph Seventeen of the Complaint, Harry
19fadmits the allegations contained therein.
20
21 18. Answering Paragraph Highteen of the Complaint, Harry
22|admits the allegations contained therein.
23
24 19. Answering Paragraph Nineteen of the Complaint, Harry
25ladmits the allegations contained therein.
26
27 20. Answering Paragraph Twenty of the Complaint, Harry
23
THE LAW FIRM OF FOX AND FOX == ~—~—~—~*~C*~
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Electronically FILED by Superior Court of California, County of Los Angeles on 09/16/2021 07:09 PM Sherri R. Carter, Executive Officer/Clerk of Court, by X. Soto,Deputy Clerk L|THE LAW FIRM OF FOX AND FOX Frank O. Fox - State Bar No. 117780 214262 Wilshire Boulevard, Third Floor Los Angeles, California 90010-3505 3 {323} 937-4422 FAX (323}937-0282 4 57Attorneys For Defendant, HARRY STOVALL 6 7 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES 9 10 /DION MIAL, }) Case No. 29 STCV 43317 ) 11 Plaintiff, ) [Related Case: In re the ) Stovall Community Trust, 12 Vv. ) L.A.S.C. Case No. 17 STPB } 09478] 13 |HARRY STOVALL, JR., an individual;} and DOES 1 through 20; ) ANSWER TO COMPLAINT 14 ) Defendants. ) Dept: 67 15 } ) 16 } 17 TO PLAINTIFF, DION MIAL, AND HIS ATTORNEYS OF RECORD, 18 ALBERTSON & DAVIDSON, LLP: 13 20 Defendant, HARRY STOVALL, JR., an individual (hereinafter 21)"Harry") hereby answers the Complaint, filed by Plaintiff, DION MIAL 22|\ (hereinafter "Dion"), therein and admits, denies and alleges as 23 follows: 24 25 N.B. Harry's Demurrer to the Complaint was overruled 26 |through an Order, issued February 23, 2021, after being taken under 27 submission on February 8, 2021. The Order, required Harry to answer 28 THE LAW FIRM OF FOX AND FOX "ANSWER TO COMPLAINT MIAL V. STOVALL L.A.S.C. CASE NO. 139 STCV 43317; PAGE 1 stovall-civilipleadings202 1 fanswer-17 Lithe Complaint, but did not order him to do so within a certain time. 24s of the date of this Answer, no request to enter defauit on the 3/Complaint has been submitted by Dion. 4} 5 JURISDICTION AND VENUE 6 7 1. Answering Paragraph One of the Complaint, Harry 8jdenies, generally and specifically, each and every allegation 9iicontained therein. LO 12 2. Answering Paragraph Two of the Complaint, Harry 12fdenies, generally and specifically, each and every allegation i3 contained therein. 14 15 PARTIES 16 17 3. Answering Paragraph Three of the Complaint, Harry 1sjadmits the allegations contained therein. 19 20 4. Answering Paragraph Four of the Complaint, Harry 21lidenies that "in accordance with Welfare and Institutions Code 22|)section 15657.3, [Dion] has standing and is authorized to pursue a 23 cause of action for financial elder abuse", and admits the balance 24jof the allegations contained therein. 25 26 5. Answering Paragraph Five of the Complaint, Harry 27 admits the allegations contained therein. 28 THE LAW FIRM OF FOX AND FOX ~~~” ANSWER TO COMPLAINT MIAL V. STOVALL L.A.S.C, CASE NO. 19 STCV 43317; PAGE 2 stovall-civilipleadings/202 Vanswer-1/? 1 6. Answering Paragraph Six of the Complaint, Harry z2jStates that he lacks sufficient information to admit or deny the 3}allegations contained therein, and, on that basis, denies. 4 5 7. Answering Paragraph Seven of the Complaint, Harry gistates that he lacks sufficient information to admit or deny the 7fallegations contained therein, and, on that basis, denies. 8 9 8. Answering Paragraph Eight of the Complaint, Harry 1o0]/denies, generally and specifically, each and every allegation lifcontained therein. 12 13 2. Answering Paragraph Nine of the Complaint, Harry 14|denies, generally and specifically, each and every allegation 15 jcontained therein. 16 17 10. Answering Paragraph Ten of the Complaint, Harry lg/denies, generally and specifically, each and every allegation ag ycontained therein. 20 21 FACTUAL BACKGROUND 22 23 11. Answering Paragraph Eleven of the Complaint, Harry 24ladmits the allegations contained therein. 25 26 12. Answering Paragraph Twelve of the Complaint, Harry 27 )}denies that Dion's entitlement to receive the real property, located 28 THE LAW FIRM OF FOX AND FOX ~=~—~—~—~—~—~—~””—”—”””C TO OANSWER COMPLAINT MIAL V. STOVALL L.A.S.C. CASH NO. 19 STCV 43317; PAGE 3 stovall-clviipleadings/202 answer? 1yat 4710 Don Miguel Drive, Los Angeles, California, 30008 (the i is unconditional, and admits the balance of the 3 allegations contained therein. 5| 13. Answering Paragraph Thirteen of the Complaint, Harry 6jadmits the allegations contained therein. 7 8 14. Answering Paragraph Fourteen of the Complaint, Harry gladmits the allegations contained therein. 19 11 15. Answering Paragraph Fifteen of the Complaint, Harry 12jadmits the allegations contained therein. 13 | 14| 16. Answering Paragraph Sixteen of the Complaint, Harry iSidenies, generally and specifically, each and every allegation 16 |contained therein. 17 18 17. Answering Paragraph Seventeen of the Complaint, Harry 19fadmits the allegations contained therein. 20 21 18. Answering Paragraph Highteen of the Complaint, Harry 22|admits the allegations contained therein. 23 24 19. Answering Paragraph Nineteen of the Complaint, Harry 25ladmits the allegations contained therein. 26 27 20. Answering Paragraph Twenty of the Complaint, Harry 23 THE LAW FIRM OF FOX AND FOX == ~—~—~—~*~C*~