Answer: MELINA CAMERON VS ALAIN HIRSCH CONSTRUCTION CORP., A CALIFORNIA CORPORATION

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/30/2021 04:30 PM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,Deputy Clerk




                                  Robin D. Perry, Esq., State Bar No. 181686
                           1      LAW OFFICES OF ROBIN D. PERRY & ASSOCIATES
                           2      400 Oceangate, Suite 700
                                  Long Beach, California 90802
                           3      Tel.: (562) 216-2944
                                  E-Mail: Robin@lordp.net
                           4
                                  Attorneys for Defendant,
                           5      ALAIN HIRSCH CONSTRUCTION CORP.
                           6
                           7
                           8                                SUPERIOR COURT FOR THE STATE OF CALIFORNIA

                           9                                              FOR THE COUNTY OF LOS ANGELES

                         10        MELINA CAMERON, an individual                                          CASE NO.: 20LBCV00501
                         11                                         Plaintiff,                            Assigned for all Purposes to:
                         12                                                                               Department S27
                                               v.
                         13                                                                               ANSWER TO UNVERIFIED FIRST
                                   ALAIN HIRSCH CONSTRUCTION                                              AMENDED COMPLAINT
                         14        CORP., a California corporation; and
                                   DOES 1 through 50 inclusive,
                         15                                                                               Complaint filed:                   November 18, 2020
                         16                                          Defendants.

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                         18                  TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
                         19                  Defendant, ALAIN HIRSCH CONSTRUCTION CORP., (“Defendant”), submits the
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                                  following response to the unverified First Amended Complaint filed by Plaintiff, MELINA
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                                  CAMERON, (“Plaintiff”), as follows:
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                                                                                           GENERAL DENIAL
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                         24                  Pursuant to the provisions of the California Code of Civil Procedure § 431.30(d),

                         25       Defendant denies generally and specifically each allegation contained in Plaintiff’s First

                         26       Amended Complaint. In addition, Defendant denies that Plaintiff has sustained, or will sustain,
                         27       any loss or damage in the manner or amount alleged, or otherwise, by reason of any act or
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                                  omission, or any other conduct or absence thereof on the part of Defendant, or at all.
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                                                                  DEFENDANT’S ANSWER TO UNVERIFIED COMPLAINT