Document for The Lyman Group, Inc. dba Grow West vs Viridi Farms, Inc., a California Corporation, et al

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                                PLD-C-010
         ATTORNEY OR PARTY YITHOUT ATTORNEY (NAME AND ADDRESS): TELEPMONE:     408 206-6318                       FOR COVRT VSE ONLY
         Dean Trinh
         17043 Pistache Dr.
         Morgan Hill, CA  95037

         ATTQRNEY FQR (NAME):   in propria persona
         Insert name of court, judicial district or branch court,
                                                              ifany, and post office and street
         address:
          Superior Court of California, Santa Cruz County
          701 Ocean St.
          Santa Cruz, CA   95060



             PLAINTIFF:  The Lyman Group dba Grow West
          DEFENDANT:     Viridi Farms et al
                mHvbW                     ANSWER—Contract                                            CASE NUMBER:
           x   10&COMPLAINT OF (name):        The Lyman Group dba Grow West                          22CV02329
               TO CROSS-COMPLAINT         (name):

         1.  This pleading, including attachments and exhibits, consists of the following number of pages: 2
         2.   DEFENDANT (name):       Dean Trinh
             answers the complaint or cross-complaint as follows:
         3.
             a.   ~
             Check ONLY ONE of the next two boxes:
                        Defendant generally denies each statement of the complaint or cross-complaint. (Do not check this box if the
                        verified complaint or cross-complaint demands more than $ 1,000.)
              b.  ~x    Defendant admits that all of the statements of the complaint or cross-complaint are true EXCEPT:
                        (1)   Defendant claims the following statements are false (use paragraph numbers or explain):
                              BC-4.  Plaintiff amended the Complaint to include a disputed amount due.    Defendant Trinh disputes the amount
                              due stated as $ 140,225.81.




                        (2)
                                  ~     Continued on Attachment 3.b.(1).
                              Defendant has no information or belief that the following statements are true, so defendant denies them (use
                              paragraph numbers or explain):




                                  ~     Continued on Attachment 3.b.(2).



                                             used to answer a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant.
                                    If this form is

                                                                                                                                         Page 1 of 2
          Form Approved for Optional Use                                                                                  Code of Civil Procedure,
                                                                                                                                            425.12
           Judicial Council of California                      ANSWER—Contract                                                             []
                                                                                                                                    www.courts. ca.gov
         PLD-C-010 [Rev. January 1, 2007]
                                                                                                                                      PLD-C-010
           SHORT TITLE:                                                                              CASE NUMBER:
          The Lyman Group v Viridi Farms et al                                                       22CV02329

                                                                ANSWER—Contract
         4.  ~x    AFFIRMATIVE DEFENSES Defendant alleges the following additional reasons that plaintiff is not entitled to recover
                   anything:
                   Duress: The Answering Defendant was forced to enter into a contract that he would not have otherwise entered into.
                   Unconscionable:   The Answering Defendant entered into an unfair contract to benefit his company when Plaintiff, a company
                   in a stronger bargaining position required his personal guarantees for company accounts.
                   Economic Duress:    The Answering Defendant, a reasonably prudent person, when faced with no reasonable alternative but
                   to succumb when the only other alternative was bankruptcy or financial ruin of the company he helped found, agreed to the
                   personal guarantee.
                   Impossibility of performance: Answering Defendant has no means of paying the company's overdue account.




         5.  ~     ~
                   Other
                         Continued on Attachment 4.




         6.   DEFENDANT PRAYS
              a.
              b.
              c.
                  ~
                  that plaintiff take nothing.

                  ~x
                        for costs of suit.
                        other  (specify):
                        The Court order Plaintiff to accept the payment plan offered by Viridi Farms and rejected by Plaintiff prior to filing suit.




         Dean Trinh
                                (Type or print name)                                                          (Signature of party or attorney)

         PLD-C - 010 [Rev. January 1, 2007)
                                                                  ANSWER—Contract                                                        Page 2 of 2