On April 14, 2022 a
Answer
was filed
involving a dispute between
Felipe Francisco,
Leon Vania Felipe,
Poonsopin Tom,
and
Leon Vania Felipe,
for Other Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 06/28/2022 10:11 AM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Yanez,Deputy Clerk
1 LAW OFFICES OF ROBYN S. HOSMER
330 North Brand Blvd., Suite 900
2 Glendale, CA 91203-2340
Electronic Address: LosAngelesLegal@allstate.com
3 Telephone: (310) 965-5111
By: ABIGAIL W. LLOYD
4 State Bar No. 243971
5 Our File No. 0585984768.2-
Attorneys for Defendant(s):
6 VANIA FELIPE LEON
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT - UNLIMITED
10
11 TOM POONSOIN, CASE NO. 22STCV12550
12 Plaintiff, ANSWER TO COMPLAINT
13 vs.
14 VANIA FELIPE LEON, and DOES 1
TO 50 INCLUSIVE,
15
Defendant.
16
17 Defendant, VANIA FELIPE LEON, alleges as follows:
18 1. Defendant, answering all the paragraphs in the unverified Complaint herein and
19 by virtue of the provisions of the California Code of Civil Procedure Section 431.30, now
20 generally denies each and every allegation therein contained and the whole thereof.
21
22 FIRST AFFIRMATIVE DEFENSE
23 2. That the Complaint and each and every cause of action stated therein is barred by
24 California Code of Civil Procedure Section 335.1.
25
26 SECOND AFFIRMATIVE DEFENSE
27 3. That each and every Plaintiff has failed to state facts sufficient to constitute a
28 cause of action against any answering party herein.
1
ANSWER TO COMPLAINT
Document Filed Date
June 28, 2022
Case Filing Date
April 14, 2022
Category
Other Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
Status
Consolidated (Non-lead case) 06/01/2023
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Electronically FILED by Superior Court of California, County of Los Angeles on 06/28/2022 10:11 AM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Yanez,Deputy Clerk 1 LAW OFFICES OF ROBYN S. HOSMER 330 North Brand Blvd., Suite 900 2 Glendale, CA 91203-2340 Electronic Address: LosAngelesLegal@allstate.com 3 Telephone: (310) 965-5111 By: ABIGAIL W. LLOYD 4 State Bar No. 243971 5 Our File No. 0585984768.2- Attorneys for Defendant(s): 6 VANIA FELIPE LEON 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT - UNLIMITED 10 11 TOM POONSOIN, CASE NO. 22STCV12550 12 Plaintiff, ANSWER TO COMPLAINT 13 vs. 14 VANIA FELIPE LEON, and DOES 1 TO 50 INCLUSIVE, 15 Defendant. 16 17 Defendant, VANIA FELIPE LEON, alleges as follows: 18 1. Defendant, answering all the paragraphs in the unverified Complaint herein and 19 by virtue of the provisions of the California Code of Civil Procedure Section 431.30, now 20 generally denies each and every allegation therein contained and the whole thereof. 21 22 FIRST AFFIRMATIVE DEFENSE 23 2. That the Complaint and each and every cause of action stated therein is barred by 24 California Code of Civil Procedure Section 335.1. 25 26 SECOND AFFIRMATIVE DEFENSE 27 3. That each and every Plaintiff has failed to state facts sufficient to constitute a 28 cause of action against any answering party herein. 1 ANSWER TO COMPLAINT