Preview
aay ti mu —
FILED
ALAMEDA COUNTY
\ZIN BEDWAN JAN2.1 2021
CLE! RK OF os. SUPERIOR COURT
By
THE STATE OF CALIFORNIA
"OF ALAMEDA
Case No.: RG20069958
ANSWER OF DEFENDANTS V5 .
SYSTEMS, INC., STEVEN YUNG, AND
MAZIN BEDWAN TO PLAINTIFF’S
COMPLAINT
UNLIMITED CIVIL
after “V5” or “Defendant”), STEVEN YUNG
IN BEDWAN (hereinafter “Bedwan” or “Defendant”),
answer the Complaint of Plaintiff ANDREW HO
RAL DENIAL
‘alifornia Code of Civil Procedure, specifically section
and every allegation of the Complaint, and the whole
nd every cause of action therein.
— —= ——
si]
\NSWER RG20069958
@
ed or will sustain any injury, damage, or loss by reason
‘endants. Defendants also hereby assert the following
[IVE DEFENSES
idants reserve the right to contend that Plaintiff bears
ion of evidence of the matters set forth herein, which
id that said matters are instead encompassed by the
forth any such affirmative defense out of an abundance
MATIVE DEFENSE
te a Cause of Action)
omplaint, Defendants allege that the Complaint, and
ed therein, fails to state facts sufficient to constitute a
RMATIVE DEFENSE
'rivilege)
Somplaint, and to each purported cause of action
:onduct, or statements by and/or attributed to them were
ze.
(MATIVE DEFENSE
‘ault and/or Liability)
Somplaint, and to each purported cause of action
ry, and/or damage suffered by Plaintiff was proximately
It, errors, acts, and/or omissions of persons and entities
uissions of Plaintiff himself:
~—— |
Qe
NSWER RG20069958
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RMATIVE DEFENSE
Mitigate Damages)
‘omplaint, and to each purported cause of action
:rwise recoverable by Plaintiff are barred and/or limited
2nce In attempting to mitigate his alleged damages.
MATIVE DEFENSE
lean Hands)
‘omplaint, and to each purported cause of action
by the doctrine of unclean hands from maintaining this
‘(MATIVE DEFENSE
of Limitations)
Somplaint, and to each purported cause of action
are barred in whole or in part by the applicable statute
of Civil Procedure sections 335.1, 337. 338, 339, 343,
IRMATIVE DEFENSE
toppel, and Laches)
Yomplaint, Defendants allege that Plaintiff is estopped
‘of the claims raised or causes of action contained in
:oppel, and laches by virtue of his acts, failure to act,
e
*MATIVE DEFENSE
Business Reasons)
Somplaint, and to each purported cause of action
n relevant, Defendants acted in good faith and with
: Plaintiff may have had under federal, state, or local
s, or guidelines.
————
33s
.NSWER RG20069958
@
(MATIVE DEFENSE
od Faith)
Somplaint, and to each purported cause of action
th all laws and regulations with regard to the subject _
2ry purported cause of action contained herein, and is
1e may have sustained, if any.
«MATIVE DEFENSE
ative Damages)
Somplaint, Defendants are informed and believe, and
ined by Plaintiff, if any, are too uncertain, wholly
alleged conduct, act, or omission by Defendants.
*IRMATIVE DEFENSE
's Own Conduct)
Yomplaint, Defendants allege that if Plaintiff suffered or
e or in part, resulted from his own conduct, including
dants, and not the result of any conduct by Defendants..
IRMATIVE DEFENSE
ad Faith)
Zomplaint, Defendants allege that each of the purported
a, fail because Plaintiff acted in bad faith or
FFIRMATIVE DEFENSE
and/or Ratification by Plaintiff)
Zomplaint, Defendants allege that Plaintiff consented to,
issions of Defendants.
FFIRMATIVE DEFENSE
——— —_—~—_____--- —~- “+
Ale
.NSWER RG20069958
e
Causation)
‘omplaint, Defendants allege that Plaintiff is not
as not sustained any injuries or damages caused by any
>»ndants.
*7IRMATIVE DEFENSE
ption of Risk)
‘omplaint, Defendants allege that if Plaintiff suffered or
the time and place alleged in the Complaint, although
vas a direct and proximate result of a risk(s) resulting
by Plaintiff.
*IRMATIVE DEFENSE
Capacity to Sue)
‘omplaint, Defendants allege that Plaintiff lacks the
FFIRMATIVE DEFENSE
of Standing)
‘omplaint, Defendants allege that Plaintiff lacks
*FIRMATIVE DEFENSE
to Indemnity)
Somplaint, Defendants allege that if it should be found
ontained in the Complaint, then Defendants are entitled
ilawful, and tortious conduct, if any, was active,
endants, if any, was passive, secondary, and derivative
*‘FIRMATIVE DEFENSE
=i
NSWER RG20069958
e
ince with Laws)
‘omplaint, Defendants allege that they have complied .
ubject matter of Plaintiff's Complaint, and each and
1, and are therefore not liable to Plaintiff for damages
FIRMATIVE DEFENSE
lly-Protected Activity)
Yomplaint, Defendants allege that Plaintiff's Complaint
2d of are constitutionally-protected activity by
.FFIRMATIVE DEFENSE
nmunity)
“omplaint, Defendants contend that they are immune
Plaintiff's Complaint pursuant to the business judgment
AFFIRMATIVE DEFENSE
fied Conduct)
Somplaint, Defendants allege that, with respect to the
‘re justified, and by reason of the foregoing, Plaintiff is
\FFIRMATIVE DEFENSE
| Damages)
Somplaint, Detrastesits allege that Plaintiff has incurred
AFFIRMATIVE DEFENSE
bi
.NSWER RG20069958
¢
images — Due Process)
‘omplaint, Defendants allege that Plaintiff's Complaint,
ges pursuant to section 3294 of the Civil Code,
cess under the Fourteenth Amendment of the United
tate of California, and therefore fails to state a cause of
lamages can be awarded.
FFIRMATIVE DEFENSE
nages — Excessive Fine)
‘omplaint, Defendants allege that Plaintiff's Complaint,
iges pursuant to section 3294 of the Civil Code,
xcessive fines” as provided in the Eighth Amendment
ection 17, of the Constitution of the State of California,
e process as provided in the Fifth and Fourteenth
nd the Constitution of the State of California, and
ig the-punitive or exemplary damages claimed.
.FFIRMATIVE DEFENSE
reasonable Conduct)
omplaint, Defendants allege that Plaintiff should be
‘ause of action thereof, because Plaintiff's conduct was
AFFIRMATIVE DEFENSE
to Compete)
Somplaint, Defendants allege that any actions taken by
dete and to pursue a lawful business.
AFFIRMATIVE DEFENSE
sal Connection)
asf
NSWER RG20069958
#
Somplaint, Defendants allege that Plaintiff is barred
is no causal connection between any conduct of
Plaintiff contents it sustained.
\FFIRMATIVE DEFENSE
tual Cause)
complaint, Defendants allege that their conduct was not
vause of any of the losses alleged by Plaintiff.
FIRMATIVE DEFENSE
itions Performed)
2omplaint, Defendants allege that they have fully and/or
hey may have had to Plaintiff, or his predecessor in
FFIRMATIVE DEFENSE
onable Reliance)
complaint, Defendants allege that Plaintiff did not rely
therefore, any injuries, losses, or damages complained
ly representations made by Defendants.
AFFIRMATIVE DEFENSE
Consideration)
Domplaint, Defendants allege that Plaintiff's claims are
.FFIRMATIVE DEFENSE
ient for Award of Punitive Damages)
Somplaint, Defendants allege that Plaintiff's Complaint
ward of punitive damages.
AFFIRMATIVE DEFENSE
icient for Award of Attorney Fees)
«Qe
iNSWER RG20069958
e
‘omplaint, Defendants allege that Plaintiff's Complaint
vard of attorney fees.
FFIRMATIVE DEFENSE
bandonment)
‘omplaint, Plaintiff abandoned his position with the
FFIRMATIVE DEFENSE
ual Fraud)
Jomplaint, Plaintiff committed fraud in connection with
ment relationship, and is therefore barred from
sent.
AFFIRMATIVE DEFENSES
iowledge or information on which to form belief as to
fenses. Defendants reserve the right to assert additional
yuld be appropriate.
i FOR RELIEF
: Plaintiff is entitled to the relief sought, or any relief,
his Complaint;
itirety, with prejudice;
orney fees and costs of suit herein incurred; and
is Court deems just and proper.
ipectfully Submitted,
drew G, Watters, Esq.
omey for Defendants,
SYSTEMS, INC., STEVEN YUNG,
.MAZIN BEDWAN
EQ
‘NSWER RG20069958
Preview
aay ti mu — FILED ALAMEDA COUNTY \ZIN BEDWAN JAN2.1 2021 CLE! RK OF os. SUPERIOR COURT By THE STATE OF CALIFORNIA "OF ALAMEDA Case No.: RG20069958 ANSWER OF DEFENDANTS V5 . SYSTEMS, INC., STEVEN YUNG, AND MAZIN BEDWAN TO PLAINTIFF’S COMPLAINT UNLIMITED CIVIL after “V5” or “Defendant”), STEVEN YUNG IN BEDWAN (hereinafter “Bedwan” or “Defendant”), answer the Complaint of Plaintiff ANDREW HO RAL DENIAL ‘alifornia Code of Civil Procedure, specifically section and every allegation of the Complaint, and the whole nd every cause of action therein. — —= —— si] \NSWER RG20069958 @ ed or will sustain any injury, damage, or loss by reason ‘endants. Defendants also hereby assert the following [IVE DEFENSES idants reserve the right to contend that Plaintiff bears ion of evidence of the matters set forth herein, which id that said matters are instead encompassed by the forth any such affirmative defense out of an abundance MATIVE DEFENSE te a Cause of Action) omplaint, Defendants allege that the Complaint, and ed therein, fails to state facts sufficient to constitute a RMATIVE DEFENSE 'rivilege) Somplaint, and to each purported cause of action :onduct, or statements by and/or attributed to them were ze. (MATIVE DEFENSE ‘ault and/or Liability) Somplaint, and to each purported cause of action ry, and/or damage suffered by Plaintiff was proximately It, errors, acts, and/or omissions of persons and entities uissions of Plaintiff himself: ~—— | Qe NSWER RG20069958 @ RMATIVE DEFENSE Mitigate Damages) ‘omplaint, and to each purported cause of action :rwise recoverable by Plaintiff are barred and/or limited 2nce In attempting to mitigate his alleged damages. MATIVE DEFENSE lean Hands) ‘omplaint, and to each purported cause of action by the doctrine of unclean hands from maintaining this ‘(MATIVE DEFENSE of Limitations) Somplaint, and to each purported cause of action are barred in whole or in part by the applicable statute of Civil Procedure sections 335.1, 337. 338, 339, 343, IRMATIVE DEFENSE toppel, and Laches) Yomplaint, Defendants allege that Plaintiff is estopped ‘of the claims raised or causes of action contained in :oppel, and laches by virtue of his acts, failure to act, e *MATIVE DEFENSE Business Reasons) Somplaint, and to each purported cause of action n relevant, Defendants acted in good faith and with : Plaintiff may have had under federal, state, or local s, or guidelines. ———— 33s .NSWER RG20069958 @ (MATIVE DEFENSE od Faith) Somplaint, and to each purported cause of action th all laws and regulations with regard to the subject _ 2ry purported cause of action contained herein, and is 1e may have sustained, if any. «MATIVE DEFENSE ative Damages) Somplaint, Defendants are informed and believe, and ined by Plaintiff, if any, are too uncertain, wholly alleged conduct, act, or omission by Defendants. *IRMATIVE DEFENSE 's Own Conduct) Yomplaint, Defendants allege that if Plaintiff suffered or e or in part, resulted from his own conduct, including dants, and not the result of any conduct by Defendants.. IRMATIVE DEFENSE ad Faith) Zomplaint, Defendants allege that each of the purported a, fail because Plaintiff acted in bad faith or FFIRMATIVE DEFENSE and/or Ratification by Plaintiff) Zomplaint, Defendants allege that Plaintiff consented to, issions of Defendants. FFIRMATIVE DEFENSE ——— —_—~—_____--- —~- “+ Ale .NSWER RG20069958 e Causation) ‘omplaint, Defendants allege that Plaintiff is not as not sustained any injuries or damages caused by any >»ndants. *7IRMATIVE DEFENSE ption of Risk) ‘omplaint, Defendants allege that if Plaintiff suffered or the time and place alleged in the Complaint, although vas a direct and proximate result of a risk(s) resulting by Plaintiff. *IRMATIVE DEFENSE Capacity to Sue) ‘omplaint, Defendants allege that Plaintiff lacks the FFIRMATIVE DEFENSE of Standing) ‘omplaint, Defendants allege that Plaintiff lacks *FIRMATIVE DEFENSE to Indemnity) Somplaint, Defendants allege that if it should be found ontained in the Complaint, then Defendants are entitled ilawful, and tortious conduct, if any, was active, endants, if any, was passive, secondary, and derivative *‘FIRMATIVE DEFENSE =i NSWER RG20069958 e ince with Laws) ‘omplaint, Defendants allege that they have complied . ubject matter of Plaintiff's Complaint, and each and 1, and are therefore not liable to Plaintiff for damages FIRMATIVE DEFENSE lly-Protected Activity) Yomplaint, Defendants allege that Plaintiff's Complaint 2d of are constitutionally-protected activity by .FFIRMATIVE DEFENSE nmunity) “omplaint, Defendants contend that they are immune Plaintiff's Complaint pursuant to the business judgment AFFIRMATIVE DEFENSE fied Conduct) Somplaint, Defendants allege that, with respect to the ‘re justified, and by reason of the foregoing, Plaintiff is \FFIRMATIVE DEFENSE | Damages) Somplaint, Detrastesits allege that Plaintiff has incurred AFFIRMATIVE DEFENSE bi .NSWER RG20069958 ¢ images — Due Process) ‘omplaint, Defendants allege that Plaintiff's Complaint, ges pursuant to section 3294 of the Civil Code, cess under the Fourteenth Amendment of the United tate of California, and therefore fails to state a cause of lamages can be awarded. FFIRMATIVE DEFENSE nages — Excessive Fine) ‘omplaint, Defendants allege that Plaintiff's Complaint, iges pursuant to section 3294 of the Civil Code, xcessive fines” as provided in the Eighth Amendment ection 17, of the Constitution of the State of California, e process as provided in the Fifth and Fourteenth nd the Constitution of the State of California, and ig the-punitive or exemplary damages claimed. .FFIRMATIVE DEFENSE reasonable Conduct) omplaint, Defendants allege that Plaintiff should be ‘ause of action thereof, because Plaintiff's conduct was AFFIRMATIVE DEFENSE to Compete) Somplaint, Defendants allege that any actions taken by dete and to pursue a lawful business. AFFIRMATIVE DEFENSE sal Connection) asf NSWER RG20069958 # Somplaint, Defendants allege that Plaintiff is barred is no causal connection between any conduct of Plaintiff contents it sustained. \FFIRMATIVE DEFENSE tual Cause) complaint, Defendants allege that their conduct was not vause of any of the losses alleged by Plaintiff. FIRMATIVE DEFENSE itions Performed) 2omplaint, Defendants allege that they have fully and/or hey may have had to Plaintiff, or his predecessor in FFIRMATIVE DEFENSE onable Reliance) complaint, Defendants allege that Plaintiff did not rely therefore, any injuries, losses, or damages complained ly representations made by Defendants. AFFIRMATIVE DEFENSE Consideration) Domplaint, Defendants allege that Plaintiff's claims are .FFIRMATIVE DEFENSE ient for Award of Punitive Damages) Somplaint, Defendants allege that Plaintiff's Complaint ward of punitive damages. AFFIRMATIVE DEFENSE icient for Award of Attorney Fees) «Qe iNSWER RG20069958 e ‘omplaint, Defendants allege that Plaintiff's Complaint vard of attorney fees. FFIRMATIVE DEFENSE bandonment) ‘omplaint, Plaintiff abandoned his position with the FFIRMATIVE DEFENSE ual Fraud) Jomplaint, Plaintiff committed fraud in connection with ment relationship, and is therefore barred from sent. AFFIRMATIVE DEFENSES iowledge or information on which to form belief as to fenses. Defendants reserve the right to assert additional yuld be appropriate. i FOR RELIEF : Plaintiff is entitled to the relief sought, or any relief, his Complaint; itirety, with prejudice; orney fees and costs of suit herein incurred; and is Court deems just and proper. ipectfully Submitted, drew G, Watters, Esq. omey for Defendants, SYSTEMS, INC., STEVEN YUNG, .MAZIN BEDWAN EQ ‘NSWER RG20069958