Answer: JOHN DOE VS SAN MARINO UNIFIED SCHOOL DISTRICT, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 06/15/2021 09:43 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. So,Deputy Clerk



                  1      Barry R. Schirm (SBN 94553)
                         HAWKINS PARNELL & YOUNG, LLP
                  2      445 South Figueroa Street, Suite 3200
                         Los Angeles, California 90071-1651
                  3      Telephone: (213) 486-8000
                         Fax: (213) 486-8080
                  4      Email: bschirm@hpylaw.com

                  5      Attorneys for Defendant
                         WESTERN CAMPS, INC., DBA RIVER WAY RANCH CAMP
                  6

                  7

                  8                                    SUPERIOR COURT OF THE STATE OF CALIFORNIA

                  9                                                 FOR THE COUNTY OF LOS ANGELES

                10

                11       JOHN DOE, an individual,                                                 Case No.: 21STCV13351

                12                              Plaintiff,                                        For All Purposes to the Honorable Michael E.
                                                                                                  Whitaker in Department 32
                13                  v.
                                                                                                  DEFENDANT WESTERN CAMPS, INC., DBA RIVER
                14       SAN MARINO UNIFIED SCHOOL                                                WAY RANCH CAMP’S ANSWER TO PLAINTIFF’S
                         DISTRICT, a public school district;                                      COMPLAINT FOR PERSONAL INJURIES AND
                15       HOWARD CHEUNG, an individual;                                            DAMAGES
                         RIVER WAY RANCH CAMP, a private
                16       entity; and DOES 1-60, inclusive,
                                                                                                  Complaint Filed:     April 7, 2021
                17                              Defendants.                                       Non-Jury Trial Date: October 5, 2022

                18                                                                   GENERAL DENIAL

                19                  Defendant Western Camps, Inc., dba River Way Ranch Camp (“Western Camps”) answering

                20       solely on its own behalf and for no other party or entity, files this general denial pursuant to Code of

                21       Civil Procedure Section 431.30(d) and denies every allegation in plaintiff’s complaint, and further

                22       specifically denies it is responsible in any way for plaintiff’s claimed damages.

                23                                                       FIRST AFFIRMATIVE DEFENSE

                24                  Western Camps alleges that each purported cause of action fails to state facts sufficient to

                25       constitute a cause of action against Western Camps.

                26                                                     SECOND AFFIRMATIVE DEFENSE

                27                  Western Camps alleges that the injuries and damages, if any, of which plaintiff complain was

                28       legally caused and contributed to by the negligence and/or conduct of other persons or entities, and

                              RIVER WAY RANCH CAMP’S ANSWER TO PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
                         11196520V.1