On March 15, 2022 a Answer was filed involving a dispute between Arntsen Family Partnership, Lp, Arntsen, Robert, Brian Christopher Dunn Custodianship, Ho, John, Huang, Quanyu, Lee, Mary, and Black Horse Holdings, Llc, Bragg, David M, Caproc Iii, Llc, Davis, Gregory J, Huang, Quanyu, Huish, Dale, Justesen, Jason, Kludt, Kurtis Stuart, Mclan Trust, Monks Family Trust, Oneil, Scott, Paramont Capital, Llc, Paramont Woodside, Llc, Silicon Valley Real Ventures, Llc, Stoker, Diane, Stoker, Phil, Svrv 385 Moore, Llc, Svrv 387 Moore, Llc, Teh Capital, Llc, Wild Rose Irrevocable Trust, Wolfe, Kevin, Wz Partners Llc, for (16) Unlimited Fraud in the District Court of San Mateo County.
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PLD-050 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Mark Poe, No. 223714 Gaw | Poe LLP Embarcadero 4, Suite 1400 San Francisco, CA 94111 TELEPHONE NO.:415-766-7451 FAX NO. (Optional): mpoe@gawpoe.com E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): Kurtis Stuart Kludt SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo 6/9/2022 STREET ADDRESS: 400 County Center MAILING ADDRESS: 400 County Center CITY AND ZIP CODE: Redwood City 94063 BRANCH NAME: Civil PLAINTIFF/PETITIONER: Robert Arntsen, et al. DEFENDANT/RESPONDENT: David M. Bragg, et al. CASE NUMBER:: GENERAL DENIAL 22-CIV-01148 If you want to file a general denial, you MUST use this form if the amount asked for in the complaint or the value of the property involved is $1,000 or less. You MAY use this form for a general denial if: 1. The complaint is not verified; or 2. The complaint is verified and the case is a limited civil case (the amount in controversy is $25,000 or less), BUT NOT if the complaint involves a claim for more than $1,000 that has been assigned to a third party for collection. (See Code of Civil Procedure sections 85–86, 90–100, 431.30, and 431.40.) 1. DEFENDANT (name): Kurtis Stuart Kludt generally denies each and every allegation of plaintiff's complaint. 2. ✔ DEFENDANT states the following FACTS as separate affirmative defenses to plaintiff's complaint (attach additional pages if necessary): 1. Plaintiffs acquiesced to the conduct described in the Complaint. 2. Defendant Kludt was not in privity with any of the plaintiffs respecting the transactions at issue. 3. Plaintiffs knew the risks inherent in real estate speculation, acknowledged their awareness of those risks, and declined to sign any documents related to the investments at issue, and are thereby equitably estopped from complaining about any conduct by Kludt. 4. All of Plaintiffs' claims against Kludt based in contract are barred by the statute of frauds, especially Civil Code section 1624(a)(1), (2), (4), (6), and (7). Date: June 9, 2022 Mark Poe (TYPE OR PRINT NAME) (SIGNATURE OF DEFENDANT OR ATTORNEY) If you have a claim for damages or other relief against the plaintiff, the law may require you to state your claim in a special pleading called a cross-complaint or you may lose your right to bring the claim. (See Code of Civil Procedure sections 426.10–426.40.) The original of this General Denial must be filed with the clerk of this court with proof that a copy was served on each plaintiff's attorney and on each plaintiff not represented by an attorney. There are two main ways to serve this General Denial: by personal delivery or by mail. It may be served by anyone at least 18 years of age EXCEPT you or any other party to this legal action. Be sure that whoever serves the General Denial fills out and signs a proof of service. You may use the applicable Judicial Council form (such as form POS-020, POS-030, or POS-040) for the proof of service. Page 1 of 1 Form Adopted for Mandatory Use Code of Civil Procedure, §§ 431.30, 431.40 Judicial Council of California GENERAL DENIAL www.courtinfo.ca.gov PLD-050 [Rev. January 1, 2009]