Preview
1 HASSARD BONNINGTON LLP
Robert S. Willoughby, Esq. (#189464) rsw@hassard.com
2 Alexandra C. Seibert, Esq. (#283008) acs@hassard.com
275 Battery St., Suite 1600
3 San Francisco, CA 94111
Telephone: (415) 288-9800
4 Fax: (415) 288-9801
1/5/2022
5 Attorneys for Defendant
SUTTER BAY HOSPITALS dba MILLS
6 PENINSULA HEALTH SERVICES
(erroneously sued herein as MILLS
7 HEALTH CENTER)
8
9 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF SAN MATEO
11 UNLIMITED JURISDICTION
12
13 FRANK SHEE, Case No. 21-CIV-00632
14 Plaintiff, DEFENDANT SUTTER BAY
HOSPITALS DBA MILLS PENINSULA
15 vs. HELATH SERVICES’ ANSWER TO
COMPLAINT
16 ALBERTO BOLANOS, MILLS HEALTH
CENTER and DOES 1 through 100, Complaint Filed: February 8, 2021
17 inclusive Trial Date: not yet set
18 Defendants.
19
20 Defendant SUTTER BAY HOSPITALS dba MILLS PENINSULA
21 HEALTH SERVICES (erroneously sued herein as MILLS HEALTH CENTER)
22 (hereafter, “defendant”) in answer to plaintiff FRANK SHEE’s (hereafter, “plaintiff”)
23 Form Complaint on file herein, and each and every cause of action allegedly set forth
24 therein, and subject to the Stipulated Order regarding Punitive Damages dated
25 September 7, 2021, hereby admits, denies and alleges as follows:
26 Defendant admits that it is, and at all times mentioned in said Complaint
27 was, a corporation organized in accordance with the laws of the State of California.
28 Except as so admitted, this defendant denies each and every, all and singular,
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DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT
C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522
1 generally and specifically, the allegations in said Complaint.
2 Further answering said Complaint, and each and every cause of action
3 allegedly set forth therein, defendant denies that it or its agents and/or employees
4 were negligent and/or careless in any respect whatsoever, as alleged therein, or at
5 all, and deny that by reason of these allegations, or otherwise, plaintiff has been
6 damaged in any sum or sums whatsoever, or at all.
7 AS AND FOR A FIRST, SEPARATE AND DISTINCT AFFIRMATIVE
8 DEFENSE to said Complaint and each and every cause of action allegedly set forth
9 therein, this defendant alleges that plaintiff was negligent in and about the facts and
10 things set forth in said Complaint and that said carelessness and negligence caused
11 or contributed to the injuries, if any, of which plaintiff complains.
12 AS AND FOR A SECOND, SEPARATE AND DISTINCT AFFIRMATIVE
13 DEFENSE to said Complaint, and each and every cause of action allegedly set forth
14 therein, this defendant alleges that the allegations set forth therein do not state facts
15 sufficient to constitute a cause of action against this defendant.
16 AS AND FOR A THIRD, SEPARATE AND DISTINCT AFFIRMATIVE
17 DEFENSE to said Complaint, and each and every cause of action allegedly set forth
18 therein, this defendant alleges that the allegations set forth therein are barred by the
19 provisions of the applicable statutes, including but not limited to the provisions of
20 Sections 335.1, 340(a)-(e), 340.5, 364(a)-(f) and 474 including all subdivisions, of the
21 Code of Civil Procedure.
22 AS AND FOR A FOURTH, SEPARATE AND DISTINCT AFFIRMATIVE
23 DEFENSE to said Complaint, and each and every cause of action allegedly set forth
24 therein, this defendant alleges that the injuries and damages complained of by
25 plaintiff, if any there were, were wholly or in part directly caused by the negligence
26 and/or willful and intentional acts of persons or entities other than this defendant, and
27 said negligence is either imputed to plaintiff by reason of the relationship between
28 plaintiff and said person or entities, and/or comparatively reduces the proportion of
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DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT
C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522
1 alleged negligence and corresponding alleged liability of this defendant.
2 AS AND FOR A FIFTH, SEPARATE AND DISTINCT AFFIRMATIVE
3 DEFENSE to said Complaint, and each and every cause of action allegedly set forth
4 therein, this defendant states that in the event it is found to be negligent (which
5 supposition is denied and merely stated for the purpose of this affirmative defense),
6 this defendant may elect to introduce evidence of any amount paid or payable, if any,
7 as a benefit pursuant to Civil Code section 3333.1.
8 AS AND FOR A SIXTH, SEPARATE AND DISTINCT AFFIRMATIVE
9 DEFENSE to said Complaint, and each and every cause of action allegedly set forth
10 therein, this defendant states that in the event it is found to be negligent (which
11 supposition is denied and merely stated for the purpose of this affirmative defense),
12 the damages for non-economic losses, if any, shall not exceed the amount specified
13 in Civil Code section 3333.2.
14 AS AND FOR A SEVENTH, SEPARATE AND DISTINCT
15 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action
16 allegedly set forth therein, this defendant states that in the event it is found to be
17 negligent (which supposition is denied and merely stated for the purpose of this
18 affirmative defense), this defendant may elect to have future damages, if any, in
19 excess of the amount specified in Code of Civil Procedure section 667.7, paid in
20 whole or in part, as specified in Code of Civil Procedure section 667.7.
21 AS AND FOR AN EIGHTH, SEPARATE AND DISTINCT AFFIRMATIVE
22 DEFENSE to said Complaint, and each and every cause of action allegedly set forth
23 therein, this defendant alleges that it is entitled to the benefits, defenses, rights,
24 immunities and provisions set forth and contained in Business & Professions Code
25 section 6146 and Code of Civil Procedure sections 364 and 365.
26 AS AND FOR A NINTH, SEPARATE AND DISTINCT AFFIRMATIVE
27 DEFENSE to said Complaint, and each and every cause of action allegedly set forth
28 therein, this defendant alleges that they, acting in good faith at the times mentioned in
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DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT
C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522
1 said Complaint, rendered emergency care, at the scene of the emergency, as defined
2 by Business & Professions Code section 2395.
3 AS AND FOR A TENTH, SEPARATE AND DISTINCT AFFIRMATIVE
4 DEFENSE to said Complaint and each and every cause of action allegedly set forth
5 therein, this defendant alleges that plaintiff was informed and otherwise had reason to
6 know of the risks and hazards in connection with the matters referred to in the
7 Complaint and that plaintiff assumed the risk of said risks and hazards at the time and
8 place referred to therein.
9 AS AND FOR AN ELEVENTH, SEPARATE AND DISTINCT
10 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action
11 allegedly set forth therein, this defendant alleges that upon information and belief they
12 are of the opinion that a certain sum has been or will be paid to plaintiff as
13 compensation for the same damages it seeks against these defendants and,
14 therefore, said defendants are entitled to a set-off in said amount against any
15 judgment or recovery plaintiff may recover against defendant.
16 AS AND FOR A TWELFTH, SEPARATE AND DISTINCT
17 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action
18 allegedly set forth therein, this defendant alleges on information and belief that
19 plaintiff has failed to minimize or mitigate each of her damages, if any.
20 AS AND FOR A THIRTEENTH, SEPARATE AND DISTINCT
21 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action
22 allegedly set forth therein, this defendant alleges that plaintiff has not complied with
23 the joinder of parties requirements of Code of Civil Procedure sections 377.60, 378
24 and 389.
25 AS AND FOR A FOURTEENTH, SEPARATE AND DISTINCT
26 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action
27 allegedly set forth therein, this defendant is entitled to the full benefits and protections
28 provided under section 1431.1, et seq., of the Civil Code, otherwise entitled The Fair
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DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT
C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522
1 Responsibility Act of 1986.
2 AS AND FOR A FIFTEENTH, SEPARATE AND DISTINCT
3 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action
4 allegedly set forth therein, this defendant alleges that the injuries complained of
5 herein were caused by the natural course of plaintiff’s disease or condition, or were
6 the natural or expected results of reasonable treatment rendered for this disease or
7 condition, and plaintiff’s claims herein are barred by California Civil Code §1714.8.
8 WHEREFORE, these answering defendants pray that plaintiff take
9 nothing by reason of the Complaint on file herein, that these defendants be hence
10 dismissed and have judgment for costs of suit incurred herein, and for such other and
11 further relief as to the Court seems just and proper.
12
13 Dated: January 5, 2022 HASSARD BONNINGTON LLP
14
15 By: ___________________________
Robert S. Willoughby
16 Alexandra C. Seibert
Attorneys for Defendant
17 SUTTER BAY HOSPITALS dba MILLS
PENINSULA HEALTH SERVICES
18 (erroneously sued herein as MILLS HEALTH
19 CENTER)
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DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT
C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522
1 PROOF OF SERVICE
Shee v. Mills Health Center
2 San Mateo County Superior Court Case No. 21-CIV-00632
3 I am a citizen of the United States. My business address is 275 Battery Street,
Suite 1600, San Francisco, CA 94111. My email address is mab@hassard.com. I
4 am employed in the County of San Francisco where this service occurs. I am over
the age of 18 years and not a party to the within cause. I served the foregoing
5 document(s) described as: DEFENDANT SUTTER BAY HOSPITALS DBA MILLS
PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT on the interested
6 parties in said action addressed as follows:
7 Plaintiff in Pro Per Frank Shee Tel: (650) 438-5897
105 Lucca Drive frankshee03@yahoo.com
8 San Francisco CA 9408
COUNSEL FOR James J. Zenere, Esq. Tel: (408) 430-3551
9 Defendant ALBERTO Zenere Cowden & Stoddard APC jzenere@zcslawfirm.com
BOLANOS, MD 2005 De La Cruz Blvd., Suite dpoint@zcslawfirm.com
10 240 ogarcia@zcslawfirm.com
Santa Clara, CA 95050
11
[XX] ONLY BY ELECTRONIC TRANSMISSION. E-mailing the document(s) to the persons at the e-
12 mail address(es) listed. During the Coronavirus (COVID-19) pandemic, this office will be
primarily working remotely, unable to send physical mail as usual, and is therefore using only
13 electronic mail. No electronic message or other indication that the transmission was
unsuccessful was received within a reasonable time after the transmission.
14
I declare under penalty of perjury that the foregoing is true and correct.
15 Executed on January 5, 2022 at San Francisco, California.
16
17 ______________________________________
Morgan Boodoosingh
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DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT
C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522
Preview
1 HASSARD BONNINGTON LLP Robert S. Willoughby, Esq. (#189464) rsw@hassard.com 2 Alexandra C. Seibert, Esq. (#283008) acs@hassard.com 275 Battery St., Suite 1600 3 San Francisco, CA 94111 Telephone: (415) 288-9800 4 Fax: (415) 288-9801 1/5/2022 5 Attorneys for Defendant SUTTER BAY HOSPITALS dba MILLS 6 PENINSULA HEALTH SERVICES (erroneously sued herein as MILLS 7 HEALTH CENTER) 8 9 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF SAN MATEO 11 UNLIMITED JURISDICTION 12 13 FRANK SHEE, Case No. 21-CIV-00632 14 Plaintiff, DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA 15 vs. HELATH SERVICES’ ANSWER TO COMPLAINT 16 ALBERTO BOLANOS, MILLS HEALTH CENTER and DOES 1 through 100, Complaint Filed: February 8, 2021 17 inclusive Trial Date: not yet set 18 Defendants. 19 20 Defendant SUTTER BAY HOSPITALS dba MILLS PENINSULA 21 HEALTH SERVICES (erroneously sued herein as MILLS HEALTH CENTER) 22 (hereafter, “defendant”) in answer to plaintiff FRANK SHEE’s (hereafter, “plaintiff”) 23 Form Complaint on file herein, and each and every cause of action allegedly set forth 24 therein, and subject to the Stipulated Order regarding Punitive Damages dated 25 September 7, 2021, hereby admits, denies and alleges as follows: 26 Defendant admits that it is, and at all times mentioned in said Complaint 27 was, a corporation organized in accordance with the laws of the State of California. 28 Except as so admitted, this defendant denies each and every, all and singular, -1- DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522 1 generally and specifically, the allegations in said Complaint. 2 Further answering said Complaint, and each and every cause of action 3 allegedly set forth therein, defendant denies that it or its agents and/or employees 4 were negligent and/or careless in any respect whatsoever, as alleged therein, or at 5 all, and deny that by reason of these allegations, or otherwise, plaintiff has been 6 damaged in any sum or sums whatsoever, or at all. 7 AS AND FOR A FIRST, SEPARATE AND DISTINCT AFFIRMATIVE 8 DEFENSE to said Complaint and each and every cause of action allegedly set forth 9 therein, this defendant alleges that plaintiff was negligent in and about the facts and 10 things set forth in said Complaint and that said carelessness and negligence caused 11 or contributed to the injuries, if any, of which plaintiff complains. 12 AS AND FOR A SECOND, SEPARATE AND DISTINCT AFFIRMATIVE 13 DEFENSE to said Complaint, and each and every cause of action allegedly set forth 14 therein, this defendant alleges that the allegations set forth therein do not state facts 15 sufficient to constitute a cause of action against this defendant. 16 AS AND FOR A THIRD, SEPARATE AND DISTINCT AFFIRMATIVE 17 DEFENSE to said Complaint, and each and every cause of action allegedly set forth 18 therein, this defendant alleges that the allegations set forth therein are barred by the 19 provisions of the applicable statutes, including but not limited to the provisions of 20 Sections 335.1, 340(a)-(e), 340.5, 364(a)-(f) and 474 including all subdivisions, of the 21 Code of Civil Procedure. 22 AS AND FOR A FOURTH, SEPARATE AND DISTINCT AFFIRMATIVE 23 DEFENSE to said Complaint, and each and every cause of action allegedly set forth 24 therein, this defendant alleges that the injuries and damages complained of by 25 plaintiff, if any there were, were wholly or in part directly caused by the negligence 26 and/or willful and intentional acts of persons or entities other than this defendant, and 27 said negligence is either imputed to plaintiff by reason of the relationship between 28 plaintiff and said person or entities, and/or comparatively reduces the proportion of -2- DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522 1 alleged negligence and corresponding alleged liability of this defendant. 2 AS AND FOR A FIFTH, SEPARATE AND DISTINCT AFFIRMATIVE 3 DEFENSE to said Complaint, and each and every cause of action allegedly set forth 4 therein, this defendant states that in the event it is found to be negligent (which 5 supposition is denied and merely stated for the purpose of this affirmative defense), 6 this defendant may elect to introduce evidence of any amount paid or payable, if any, 7 as a benefit pursuant to Civil Code section 3333.1. 8 AS AND FOR A SIXTH, SEPARATE AND DISTINCT AFFIRMATIVE 9 DEFENSE to said Complaint, and each and every cause of action allegedly set forth 10 therein, this defendant states that in the event it is found to be negligent (which 11 supposition is denied and merely stated for the purpose of this affirmative defense), 12 the damages for non-economic losses, if any, shall not exceed the amount specified 13 in Civil Code section 3333.2. 14 AS AND FOR A SEVENTH, SEPARATE AND DISTINCT 15 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action 16 allegedly set forth therein, this defendant states that in the event it is found to be 17 negligent (which supposition is denied and merely stated for the purpose of this 18 affirmative defense), this defendant may elect to have future damages, if any, in 19 excess of the amount specified in Code of Civil Procedure section 667.7, paid in 20 whole or in part, as specified in Code of Civil Procedure section 667.7. 21 AS AND FOR AN EIGHTH, SEPARATE AND DISTINCT AFFIRMATIVE 22 DEFENSE to said Complaint, and each and every cause of action allegedly set forth 23 therein, this defendant alleges that it is entitled to the benefits, defenses, rights, 24 immunities and provisions set forth and contained in Business & Professions Code 25 section 6146 and Code of Civil Procedure sections 364 and 365. 26 AS AND FOR A NINTH, SEPARATE AND DISTINCT AFFIRMATIVE 27 DEFENSE to said Complaint, and each and every cause of action allegedly set forth 28 therein, this defendant alleges that they, acting in good faith at the times mentioned in -3- DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522 1 said Complaint, rendered emergency care, at the scene of the emergency, as defined 2 by Business & Professions Code section 2395. 3 AS AND FOR A TENTH, SEPARATE AND DISTINCT AFFIRMATIVE 4 DEFENSE to said Complaint and each and every cause of action allegedly set forth 5 therein, this defendant alleges that plaintiff was informed and otherwise had reason to 6 know of the risks and hazards in connection with the matters referred to in the 7 Complaint and that plaintiff assumed the risk of said risks and hazards at the time and 8 place referred to therein. 9 AS AND FOR AN ELEVENTH, SEPARATE AND DISTINCT 10 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action 11 allegedly set forth therein, this defendant alleges that upon information and belief they 12 are of the opinion that a certain sum has been or will be paid to plaintiff as 13 compensation for the same damages it seeks against these defendants and, 14 therefore, said defendants are entitled to a set-off in said amount against any 15 judgment or recovery plaintiff may recover against defendant. 16 AS AND FOR A TWELFTH, SEPARATE AND DISTINCT 17 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action 18 allegedly set forth therein, this defendant alleges on information and belief that 19 plaintiff has failed to minimize or mitigate each of her damages, if any. 20 AS AND FOR A THIRTEENTH, SEPARATE AND DISTINCT 21 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action 22 allegedly set forth therein, this defendant alleges that plaintiff has not complied with 23 the joinder of parties requirements of Code of Civil Procedure sections 377.60, 378 24 and 389. 25 AS AND FOR A FOURTEENTH, SEPARATE AND DISTINCT 26 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action 27 allegedly set forth therein, this defendant is entitled to the full benefits and protections 28 provided under section 1431.1, et seq., of the Civil Code, otherwise entitled The Fair -4- DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522 1 Responsibility Act of 1986. 2 AS AND FOR A FIFTEENTH, SEPARATE AND DISTINCT 3 AFFIRMATIVE DEFENSE to said Complaint, and each and every cause of action 4 allegedly set forth therein, this defendant alleges that the injuries complained of 5 herein were caused by the natural course of plaintiff’s disease or condition, or were 6 the natural or expected results of reasonable treatment rendered for this disease or 7 condition, and plaintiff’s claims herein are barred by California Civil Code §1714.8. 8 WHEREFORE, these answering defendants pray that plaintiff take 9 nothing by reason of the Complaint on file herein, that these defendants be hence 10 dismissed and have judgment for costs of suit incurred herein, and for such other and 11 further relief as to the Court seems just and proper. 12 13 Dated: January 5, 2022 HASSARD BONNINGTON LLP 14 15 By: ___________________________ Robert S. Willoughby 16 Alexandra C. Seibert Attorneys for Defendant 17 SUTTER BAY HOSPITALS dba MILLS PENINSULA HEALTH SERVICES 18 (erroneously sued herein as MILLS HEALTH 19 CENTER) 20 21 22 23 24 25 26 27 28 -5- DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522 1 PROOF OF SERVICE Shee v. Mills Health Center 2 San Mateo County Superior Court Case No. 21-CIV-00632 3 I am a citizen of the United States. My business address is 275 Battery Street, Suite 1600, San Francisco, CA 94111. My email address is mab@hassard.com. I 4 am employed in the County of San Francisco where this service occurs. I am over the age of 18 years and not a party to the within cause. I served the foregoing 5 document(s) described as: DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT on the interested 6 parties in said action addressed as follows: 7 Plaintiff in Pro Per Frank Shee Tel: (650) 438-5897 105 Lucca Drive frankshee03@yahoo.com 8 San Francisco CA 9408 COUNSEL FOR James J. Zenere, Esq. Tel: (408) 430-3551 9 Defendant ALBERTO Zenere Cowden & Stoddard APC jzenere@zcslawfirm.com BOLANOS, MD 2005 De La Cruz Blvd., Suite dpoint@zcslawfirm.com 10 240 ogarcia@zcslawfirm.com Santa Clara, CA 95050 11 [XX] ONLY BY ELECTRONIC TRANSMISSION. E-mailing the document(s) to the persons at the e- 12 mail address(es) listed. During the Coronavirus (COVID-19) pandemic, this office will be primarily working remotely, unable to send physical mail as usual, and is therefore using only 13 electronic mail. No electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. 14 I declare under penalty of perjury that the foregoing is true and correct. 15 Executed on January 5, 2022 at San Francisco, California. 16 17 ______________________________________ Morgan Boodoosingh 18 19 20 21 22 23 24 25 26 27 28 -6- DEFENDANT SUTTER BAY HOSPITALS DBA MILLS PENINSULA HELATH SERVICES’ ANSWER TO COMPLAINT C:\Users\mab\ND Office Echo\VAULT-W4FTMKAH\Answer to Complaint 4881-5491-6872 v.1.doc-1522