Preview
1 SCOTT D. LONG (SBN 203505)
Fidelity National Law Group
2 The Law Division of Fidelity National Title Group, Inc.
1550 Parkside Drive, Suite 300
3 Walnut Creek, CA 94596
Telephone: (925) 280-3362
4 Facsimile: (925) 930-9588 3/8/2022
Email: Scott.Long@fnf.com
5
Attorney for Defendants
6 LEONARD W. STONE III and JESSICA L. STONE
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF SAN MATEO
10
11 ADRIANA J. QUINTERO, Case No.: 22-CIV-00190
12 Plaintiff, DEFENDANTS LEONARD W. STONE III AND
JESSICA L. STONE’S VERIFIED ANSWER
13 vs. AND AFFIRMATIVE DEFENSES TO
PLAINTIFF’S VERIFIED COMPLAINT
14 LEONARD W. STONE III; JESSICA L.
STONE; STEVEN A. WEINKAUF, TRUSTEE
15 OF THE STEVEN A WEINKAUF
IRREVOCABLE LIVING TRUST; ALL
16 PERSONS UNKNOWN, CLAIMING ANY
LEGAL OR EQUITABLE RIGHT, TITLE,
17 STAKE, LIEN OR INTEREST IN THE
PROPERTY DESCRIBED IN THE
18 COMPLAINT ADVERSE TO PLAINTIFFS’
TITLE, OR ANY CLOUD ON PLAINTIFFS’ Complaint Filed: 1/24/2022
19 TITLE TO THAT PROPERTY, and DOES 1- Trial Date: TBD
50, inclusive,
20
Defendants.
21
22 Defendants Leonard W. Stone III and Jessica L. Stone (together, “Defendants”) hereby respond
23 to the allegations contained in Plaintiff Adriana J. Quintero’s Verified Complaint filed on or around
24 January 24, 2022, (“Complaint”) as follows:
25 1. In response to the allegations of paragraphs 1, 2, 4, 5, 7, 9, 11, 13, 14, 15, 18, 20, of the
26 Complaint, Defendants do not have sufficient information to admit or deny the allegations set forth in
27 each of those paragraphs. Based on these grounds, Defendants deny each and every allegation as set
28 forth in each of those paragraphs.
1
DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND
AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT
1 2. In response to the allegations of paragraphs 6, 12, 16, 19, 21, 26, 29, 30, 31, 33, 35, 36,
2 and the Prayer of the Complaint, Defendants deny each and every allegation set forth in each of those
3 paragraphs.
4 3. In response to the allegations of paragraph 3, 8, 23, 28, Defendants admit the allegations.
5 4. In response to the allegations of paragraph 24 of the Complaint, Defendants admit that by
6 this action Plaintiff is seeking to quiet title to her claimed interest in the Property. As to any of the other
7 allegations of this paragraph, Defendants deny each and every of those other allegations.
8 5. In response to the allegations of paragraph 25 of the Complaint, Defendants admit that
9 they assert their ownership interest in the Property. As to any of the other allegations of this paragraph,
10 Defendants deny each and every of those other allegations
11 6. In response to the allegations of paragraphs 10, 17, 22, 27, 32, and 34 of the Complaint,
12 Defendants admit, deny, and/or respond that they do not have sufficient information to admit or deny the
13 allegations of each of the incorporated paragraphs as described in its responses above as to each
14 paragraph.
15 AFFIRMATIVE DEFENSES
16 Defendants additionally assert the following affirmative defenses against the claims made by
17 Plaintiff in the Complaint:
18 FIRST AFFIRMATIVE DEFENSE
19 The Complaint fails to state a claim against Defendants upon which any of the relief sought by
20 Plaintiff can be granted in law or equity, including, without limitation, compensatory or punitive
21 damages, attorneys’ fees or costs.
22 SECOND AFFIRMATIVE DEFENSE
23 Defendants are informed and believe and thereupon allege that Plaintiff had knowledge of and
24 assumed the risks incident to the matters set forth in the Complaint. The damages alleged by Plaintiff, if
25 any, were caused by or arose out of such risks.
26 THIRD AFFIRMATIVE DEFENSE
27 Defendants are informed and believe and thereupon allege that Plaintiff is guilty of negligence
28 which contributed to the alleged damages, if any.
2
DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND
AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT
1 FOURTH AFFIRMATIVE DEFENSE
2 Defendants are informed and believe and thereupon allege that the damages suffered by Plaintiff,
3 if any, were proximately caused or contributed to by the acts or omissions of others and third parties and
4 not by any wrongful conduct of Defendants.
5 FIFTH AFFIRMATIVE DEFENSE
6 Defendants are informed and believe and thereupon allege that if any wrongful conduct was
7 engaged in by others or third parties, that Plaintiffs directly or indirectly acted in concert with others or
8 third parties or knowingly ratified or approved such conduct and is therefore precluded from any
9 recovery under the doctrine of in pari delicto.
10 SIXTH AFFIRMATIVE DEFENSE
11 Defendants are informed and believe and thereupon allege that Plaintiff is guilty of unclean
12 hands with regard to the matters set forth in the Complaint.
13 SEVENTH AFFIRMATIVE DEFENSE
14 Defendants are informed and believe and thereupon allege that Plaintiff did not rely on any act or
15 omission of Defendants.
16 EIGHTH AFFIRMATIVE DEFENSE
17 Defendants are informed and believe and thereupon allege that Plaintiff failed to mitigate the
18 alleged damages, if any.
19 NINTH AFFIRMATIVE DEFENSE
20 Defendants are informed and believe and thereupon allege that Plaintiff is barred from recovery
21 because Plaintiff ratified, in whole or in parts, Defendants’ alleged wrongful acts.
22 TENTH AFFIRMATIVE DEFENSE
23 Defendants are informed and believe and thereupon allege that Plaintiff has released, waived and
24 is estopped from asserting the claims set forth in the Complaint.
25 ELEVENTH AFFIRMATIVE DEFENSE
26 Defendants are informed and believe and thereupon allege that Plaintiff was negligent, legally
27 responsible, comparatively at fault, or otherwise at fault or responsible for the loss and damages
28 complained of, if any there were. Defendants hereby request that, in the event of a finding of any
3
DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND
AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT
1 liability in favor of Complaint and against Defendants, an apportionment of fault be made among all the
2 parties by the Court as permitted by Li v. Yellow Cab Co. and American Motorcycle Assn. v. Superior
3 Court. Defendants further request a judgment and declaration of partial indemnification for fault.
4 TWELFTH AFFIRMATIVE DEFENSE
5 Defendants are informed and believe and thereupon allege that they are entitled to an
6 apportionment of damages, if any, in accordance with the Fair Responsibility Act of 1986, California
7 Civil Code Section 1431 et seq.
8 THIRTEENTH AFFIRMATIVE DEFENSE
9 Defendants are informed and believe and thereupon allege that the Complaint is barred in whole
10 or in part because Plaintiff failed to exercise the quantity and quality of care and caution which a
11 reasonable individual in similar circumstances would have exercised which proximately caused and
12 contributed to the alleged damages, if any, and Plaintiff’s recovery, if any, is thereby diminished or
13 barred.
14 FOURTEENTH AFFIRMATIVE DEFENSE
15 Defendants are informed and believe and thereupon allege that some or all of Plaintiff’s causes
16 of action are barred by the applicable statutes of limitation including but not limited to Code of Civil
17 Procedure Sections 335.1, 337, 338, 339, 340 and 343.
18 FIFTEENTH AFFIRMATIVE DEFENSE
19 Defendants are informed and believe and thereupon alleges that some or all of Plaintiff’s causes
20 of action are barred by the doctrine of laches.
21 SIXTEENTH AFFIRMATIVE DEFENSE
22 Defendants are informed and believe and thereupon allege that some or all of Plaintiff’s causes
23 of action are barred by the equitable doctrine of changed circumstances.
24 SEVENTEENTH AFFIRMATIVE DEFENSE
25 Defendants acted at all relevant times as bona fide purchasers for value.
26 ///
27 ///
28 ///
4
DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND
AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT
1 EIGHTEENTH AFFIRMATIVE DEFENSE
2 Defendants are informed and believe and thereupon allege that some or all of the claims set forth
3 in the Complaint are barred by the privileges set forth in California Civil Code Section 47 and or
4 California Civil Code Section 2924.
5 NINETEENTH AFFIRMATIVE DEFENSE
6 Defendants are informed and believe and thereupon allege that Plaintiff consented to the matters
7 alleged in the Complaint.
8 TWENTIETH AFFIRMATIVE DEFENSE
9 Defendants aver that to the extent that both they and Plaintiff were innocent of any wrongdoing
10 in connection with the transaction that is the subject of the Complaint, the loss, if any, should be
11 suffered by Plaintiff, since it was by Plaintiff’s negligence that the loss occurred, and Plaintiff should be
12 estopped from shifting that loss to Defendants.
13 TWENTY-FIRST AFFIRMATIVE DEFENSE
14 Plaintiff has stated the Complaint in conclusory terms and therefore Defendants cannot fully
15 anticipate all affirmative defenses that may be applicable to this action. Accordingly, Defendants
16 reserve the right to add additional affirmative defenses, if and to the extent such affirmative defenses are
17 applicable in this action.
18 WHEREFORE, Defendants Leonard W. Stone III and Jessica L. Stone pray for judgment as
19 follows:
20 1. That Plaintiff take nothing;
21 2. For costs of suit;
22 3. For such other and further relief as the Court shall deem just and proper.
23
24 Dated: March 4, 2022 FIDELITY NATIONAL LAW GROUP
THE LAW DIVISION OF FIDELITY NATIONAL TITLE GROUP, INC.
25
26
________________________________________
27 SCOTT D. LONG,
ATTORNEYS FOR DEFENDANTS LEONARD W. STONE
28 III AND JESSICA L. STONE
5
DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND
AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT
VERIFICATION
L Lennard W. Shane III, am a party to this action. l have rand the foregmg
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DATED: March 2021
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DEPENDANTS LEONARD STONE AND JESSICA STONES VERIFIED ANSWER AND
AFFLRMATWE DEFENSES TO PLAINTIFF‘S VERLFLED COMPLAINT
VERIFICATION
I, Jessica L. Stone . am a party to this action . I have read the fare gmng
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DEFENDANTS LEONARD STUNE AND JESSICA STUNE‘S VERIFlE
""
ANSWE‘FFIHH
AFFIRMATWE UEFENSES To PLAINTIFF‘S wean-"loo CUMFLAINI'
1 Quintero v. Stone, et al
San Mateo County Superior Court Case No. 22-CIV-00190
2
PROOF OF SERVICE
3
I am employed in the County of Contra Costa, State of California. I am over the age of
4 18 years and not a party to the within action. My business address is 1550 Parkside Drive, Suite
5 300, Walnut Creek, California 94596.
6 On the date entered below, I served the within:
7 DEFENDANTS LEONARD W. STONE III AND JESSICA L. STONE’S VERIFIED
ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED
8 COMPLAINT
on the parties in said action by placing a true copy thereof as indicated below, addressed as
9 follows:
10 Counsel for Plaintiff Adriana J. Quintero
11 Bart I. Ring, Esq.
The Ring Law Firm APLC
12 5550 Topanga Canyon Blvd, Suite 200
Woodland Hills, CA 91367
13 Tel.: (818) 587-9299
Email: bart@bartringlaw.com
14
15 BY MAIL: I caused such envelope(s) with postage thereon fully prepaid to be placed
for collection and mailing at my place of business. Following ordinary business
16 practices, said correspondence will be deposited with the United States Postal Service
at Walnut Creek, California, on the referenced date in the ordinary course of business.
17 There is delivery service by United States mail at the place so addressed in the City of
Walnut Creek, County of Contra Costa, State of California.
18
BY OVERNIGHT MAIL: I caused such copies to be placed in envelopes designated
19 by the express carrier, Federal Express, with delivery fees provided for and deposited
those envelopes in a pickup box regularly maintained by Federal Express.
20
BY EMAIL: I caused a PDF document to transmit via electronic mail to the email
21 addresses listed above.
22 BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the
offices of the addressee(s)..
23
I declare under the penalty of perjury under the laws of the State of California, that the
24 foregoing is true and correct.
25 Executed on March 4, 2022, at Walnut Creek, California.
26
27 ___________________________________
Stacey Ruiz
28
PROOF OF SERVICE
Preview
1 SCOTT D. LONG (SBN 203505) Fidelity National Law Group 2 The Law Division of Fidelity National Title Group, Inc. 1550 Parkside Drive, Suite 300 3 Walnut Creek, CA 94596 Telephone: (925) 280-3362 4 Facsimile: (925) 930-9588 3/8/2022 Email: Scott.Long@fnf.com 5 Attorney for Defendants 6 LEONARD W. STONE III and JESSICA L. STONE 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN MATEO 10 11 ADRIANA J. QUINTERO, Case No.: 22-CIV-00190 12 Plaintiff, DEFENDANTS LEONARD W. STONE III AND JESSICA L. STONE’S VERIFIED ANSWER 13 vs. AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT 14 LEONARD W. STONE III; JESSICA L. STONE; STEVEN A. WEINKAUF, TRUSTEE 15 OF THE STEVEN A WEINKAUF IRREVOCABLE LIVING TRUST; ALL 16 PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, 17 STAKE, LIEN OR INTEREST IN THE PROPERTY DESCRIBED IN THE 18 COMPLAINT ADVERSE TO PLAINTIFFS’ TITLE, OR ANY CLOUD ON PLAINTIFFS’ Complaint Filed: 1/24/2022 19 TITLE TO THAT PROPERTY, and DOES 1- Trial Date: TBD 50, inclusive, 20 Defendants. 21 22 Defendants Leonard W. Stone III and Jessica L. Stone (together, “Defendants”) hereby respond 23 to the allegations contained in Plaintiff Adriana J. Quintero’s Verified Complaint filed on or around 24 January 24, 2022, (“Complaint”) as follows: 25 1. In response to the allegations of paragraphs 1, 2, 4, 5, 7, 9, 11, 13, 14, 15, 18, 20, of the 26 Complaint, Defendants do not have sufficient information to admit or deny the allegations set forth in 27 each of those paragraphs. Based on these grounds, Defendants deny each and every allegation as set 28 forth in each of those paragraphs. 1 DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT 1 2. In response to the allegations of paragraphs 6, 12, 16, 19, 21, 26, 29, 30, 31, 33, 35, 36, 2 and the Prayer of the Complaint, Defendants deny each and every allegation set forth in each of those 3 paragraphs. 4 3. In response to the allegations of paragraph 3, 8, 23, 28, Defendants admit the allegations. 5 4. In response to the allegations of paragraph 24 of the Complaint, Defendants admit that by 6 this action Plaintiff is seeking to quiet title to her claimed interest in the Property. As to any of the other 7 allegations of this paragraph, Defendants deny each and every of those other allegations. 8 5. In response to the allegations of paragraph 25 of the Complaint, Defendants admit that 9 they assert their ownership interest in the Property. As to any of the other allegations of this paragraph, 10 Defendants deny each and every of those other allegations 11 6. In response to the allegations of paragraphs 10, 17, 22, 27, 32, and 34 of the Complaint, 12 Defendants admit, deny, and/or respond that they do not have sufficient information to admit or deny the 13 allegations of each of the incorporated paragraphs as described in its responses above as to each 14 paragraph. 15 AFFIRMATIVE DEFENSES 16 Defendants additionally assert the following affirmative defenses against the claims made by 17 Plaintiff in the Complaint: 18 FIRST AFFIRMATIVE DEFENSE 19 The Complaint fails to state a claim against Defendants upon which any of the relief sought by 20 Plaintiff can be granted in law or equity, including, without limitation, compensatory or punitive 21 damages, attorneys’ fees or costs. 22 SECOND AFFIRMATIVE DEFENSE 23 Defendants are informed and believe and thereupon allege that Plaintiff had knowledge of and 24 assumed the risks incident to the matters set forth in the Complaint. The damages alleged by Plaintiff, if 25 any, were caused by or arose out of such risks. 26 THIRD AFFIRMATIVE DEFENSE 27 Defendants are informed and believe and thereupon allege that Plaintiff is guilty of negligence 28 which contributed to the alleged damages, if any. 2 DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT 1 FOURTH AFFIRMATIVE DEFENSE 2 Defendants are informed and believe and thereupon allege that the damages suffered by Plaintiff, 3 if any, were proximately caused or contributed to by the acts or omissions of others and third parties and 4 not by any wrongful conduct of Defendants. 5 FIFTH AFFIRMATIVE DEFENSE 6 Defendants are informed and believe and thereupon allege that if any wrongful conduct was 7 engaged in by others or third parties, that Plaintiffs directly or indirectly acted in concert with others or 8 third parties or knowingly ratified or approved such conduct and is therefore precluded from any 9 recovery under the doctrine of in pari delicto. 10 SIXTH AFFIRMATIVE DEFENSE 11 Defendants are informed and believe and thereupon allege that Plaintiff is guilty of unclean 12 hands with regard to the matters set forth in the Complaint. 13 SEVENTH AFFIRMATIVE DEFENSE 14 Defendants are informed and believe and thereupon allege that Plaintiff did not rely on any act or 15 omission of Defendants. 16 EIGHTH AFFIRMATIVE DEFENSE 17 Defendants are informed and believe and thereupon allege that Plaintiff failed to mitigate the 18 alleged damages, if any. 19 NINTH AFFIRMATIVE DEFENSE 20 Defendants are informed and believe and thereupon allege that Plaintiff is barred from recovery 21 because Plaintiff ratified, in whole or in parts, Defendants’ alleged wrongful acts. 22 TENTH AFFIRMATIVE DEFENSE 23 Defendants are informed and believe and thereupon allege that Plaintiff has released, waived and 24 is estopped from asserting the claims set forth in the Complaint. 25 ELEVENTH AFFIRMATIVE DEFENSE 26 Defendants are informed and believe and thereupon allege that Plaintiff was negligent, legally 27 responsible, comparatively at fault, or otherwise at fault or responsible for the loss and damages 28 complained of, if any there were. Defendants hereby request that, in the event of a finding of any 3 DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT 1 liability in favor of Complaint and against Defendants, an apportionment of fault be made among all the 2 parties by the Court as permitted by Li v. Yellow Cab Co. and American Motorcycle Assn. v. Superior 3 Court. Defendants further request a judgment and declaration of partial indemnification for fault. 4 TWELFTH AFFIRMATIVE DEFENSE 5 Defendants are informed and believe and thereupon allege that they are entitled to an 6 apportionment of damages, if any, in accordance with the Fair Responsibility Act of 1986, California 7 Civil Code Section 1431 et seq. 8 THIRTEENTH AFFIRMATIVE DEFENSE 9 Defendants are informed and believe and thereupon allege that the Complaint is barred in whole 10 or in part because Plaintiff failed to exercise the quantity and quality of care and caution which a 11 reasonable individual in similar circumstances would have exercised which proximately caused and 12 contributed to the alleged damages, if any, and Plaintiff’s recovery, if any, is thereby diminished or 13 barred. 14 FOURTEENTH AFFIRMATIVE DEFENSE 15 Defendants are informed and believe and thereupon allege that some or all of Plaintiff’s causes 16 of action are barred by the applicable statutes of limitation including but not limited to Code of Civil 17 Procedure Sections 335.1, 337, 338, 339, 340 and 343. 18 FIFTEENTH AFFIRMATIVE DEFENSE 19 Defendants are informed and believe and thereupon alleges that some or all of Plaintiff’s causes 20 of action are barred by the doctrine of laches. 21 SIXTEENTH AFFIRMATIVE DEFENSE 22 Defendants are informed and believe and thereupon allege that some or all of Plaintiff’s causes 23 of action are barred by the equitable doctrine of changed circumstances. 24 SEVENTEENTH AFFIRMATIVE DEFENSE 25 Defendants acted at all relevant times as bona fide purchasers for value. 26 /// 27 /// 28 /// 4 DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT 1 EIGHTEENTH AFFIRMATIVE DEFENSE 2 Defendants are informed and believe and thereupon allege that some or all of the claims set forth 3 in the Complaint are barred by the privileges set forth in California Civil Code Section 47 and or 4 California Civil Code Section 2924. 5 NINETEENTH AFFIRMATIVE DEFENSE 6 Defendants are informed and believe and thereupon allege that Plaintiff consented to the matters 7 alleged in the Complaint. 8 TWENTIETH AFFIRMATIVE DEFENSE 9 Defendants aver that to the extent that both they and Plaintiff were innocent of any wrongdoing 10 in connection with the transaction that is the subject of the Complaint, the loss, if any, should be 11 suffered by Plaintiff, since it was by Plaintiff’s negligence that the loss occurred, and Plaintiff should be 12 estopped from shifting that loss to Defendants. 13 TWENTY-FIRST AFFIRMATIVE DEFENSE 14 Plaintiff has stated the Complaint in conclusory terms and therefore Defendants cannot fully 15 anticipate all affirmative defenses that may be applicable to this action. Accordingly, Defendants 16 reserve the right to add additional affirmative defenses, if and to the extent such affirmative defenses are 17 applicable in this action. 18 WHEREFORE, Defendants Leonard W. Stone III and Jessica L. Stone pray for judgment as 19 follows: 20 1. That Plaintiff take nothing; 21 2. For costs of suit; 22 3. For such other and further relief as the Court shall deem just and proper. 23 24 Dated: March 4, 2022 FIDELITY NATIONAL LAW GROUP THE LAW DIVISION OF FIDELITY NATIONAL TITLE GROUP, INC. 25 26 ________________________________________ 27 SCOTT D. LONG, ATTORNEYS FOR DEFENDANTS LEONARD W. STONE 28 III AND JESSICA L. STONE 5 DEFENDANTS LEONARD STONE AND JESSICA STONE’S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED COMPLAINT VERIFICATION L Lennard W. Shane III, am a party to this action. l have rand the foregmg LEONARD W. STONE III AND JESSICA L. STONE’S VERIFIED ANSWER”gmmTs 1...] kn w its contents. AFFIRMATIVE DEFENSES TD PLAINTIFF’S VERIFIED COMPLAINT antiwar“: stated upon as t” muse mamas To my own howlcdge, the mattets stated therein are true, excel“ - _ and as to those matters l behave them to be true. infematien and belief. ' . . is Ideclare under penalty ufpeury under the laws Bf the State 0f Callfumla that the furegolng true and eel-reel. DATED: March 2021 K} <1: Leonard W. Stone IF \~ 10 11 12 13 14 15 16 1T 13 19 2D 21 22 23 24 26 27 28 . 6 DEPENDANTS LEONARD STONE AND JESSICA STONES VERIFIED ANSWER AND AFFLRMATWE DEFENSES TO PLAINTIFF‘S VERLFLED COMPLAINT VERIFICATION I, Jessica L. Stone . am a party to this action . I have read the fare gmng ' DEFENDANTS LEONARD W. STDNE III AND JESSICA L. STONE’S VERIFIED ANSWER AND AFFIRMATWE DEFENSES TD PLAINTIFF’S VERIFIED COMPLAINT and know its mutants. Tu my own lmowlegge, the matters stated therein are truet except as to those matters that are stated ' “pm mfnnatmn and ballet, and as to those mailers I believe them to be true. [declare under penalty of peljury under the lam of the State of California that the foreEDiE i5 true and correct. mmqmm DATED: Mamhiije 21122 l ll': 0‘. __ 1‘ W Jessi. Stone ID U 11 12 13 14 15 16 l1 18 19 20 2] 22 23 24 25 26 27 28 1. DEFENDANTS LEONARD STUNE AND JESSICA STUNE‘S VERIFlE "" ANSWE‘FFIHH AFFIRMATWE UEFENSES To PLAINTIFF‘S wean-"loo CUMFLAINI' 1 Quintero v. Stone, et al San Mateo County Superior Court Case No. 22-CIV-00190 2 PROOF OF SERVICE 3 I am employed in the County of Contra Costa, State of California. I am over the age of 4 18 years and not a party to the within action. My business address is 1550 Parkside Drive, Suite 5 300, Walnut Creek, California 94596. 6 On the date entered below, I served the within: 7 DEFENDANTS LEONARD W. STONE III AND JESSICA L. STONE’S VERIFIED ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S VERIFIED 8 COMPLAINT on the parties in said action by placing a true copy thereof as indicated below, addressed as 9 follows: 10 Counsel for Plaintiff Adriana J. Quintero 11 Bart I. Ring, Esq. The Ring Law Firm APLC 12 5550 Topanga Canyon Blvd, Suite 200 Woodland Hills, CA 91367 13 Tel.: (818) 587-9299 Email: bart@bartringlaw.com 14 15 BY MAIL: I caused such envelope(s) with postage thereon fully prepaid to be placed for collection and mailing at my place of business. Following ordinary business 16 practices, said correspondence will be deposited with the United States Postal Service at Walnut Creek, California, on the referenced date in the ordinary course of business. 17 There is delivery service by United States mail at the place so addressed in the City of Walnut Creek, County of Contra Costa, State of California. 18 BY OVERNIGHT MAIL: I caused such copies to be placed in envelopes designated 19 by the express carrier, Federal Express, with delivery fees provided for and deposited those envelopes in a pickup box regularly maintained by Federal Express. 20 BY EMAIL: I caused a PDF document to transmit via electronic mail to the email 21 addresses listed above. 22 BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the offices of the addressee(s).. 23 I declare under the penalty of perjury under the laws of the State of California, that the 24 foregoing is true and correct. 25 Executed on March 4, 2022, at Walnut Creek, California. 26 27 ___________________________________ Stacey Ruiz 28 PROOF OF SERVICE