Answer: ALEXANDRA RODRIGUEZ VS ANGEL RASO, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 10/06/2021 02:16 PM Sherri R. Carter, Executive Officer/Clerk of Court, by X. Soto,Deputy Clerk


      1       J. Pat Ferraris, Esq. [SBN: 267223]
              Edward E. Dollar, Esq. [SBN: 153873] (Handling Attorney)
      2       HOMAN, STONE & ROSSI
              1461 Ford Street, Suite 201
      3       Redlands, California 92373
      4       (909) 307-9380 / (909) 793-0210 – Fax
              edollar@homan-stone.com
      5       Attorneys for Defendant, ANGEL RASO

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      8                                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                              FOR THE COUNTY OF LOS ANGELES – SPRING STREET
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    11        ALEXANDRA RODRIGUEZ,                                                               Case No.: 20STCV11185
                                                                                                 Unlimited Civil Jurisdiction
    12                               Plaintiff,
                                                                                                 [Assigned to Honorable Michael E. Whitaker, Dept.
    13                                                                                           32]
                          vs.
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              ANGEL RASO; VARTAN DERBEDROSSIAN;                                                  DEFENDANT, ANGEL RASO’S ANSWER
    15        ERIC JOSEPH FLEMING; ERIC HAGER; AND                                               TO THE UNVERIFIED COMPLAINT OF
              DOES 1-50 INCLUSIVE,                                                               PLAINTIFF, ALEXANDRA RODRIGUEZ
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                                     Defendants.
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    19                    COMES NOW Defendant ANGEL RASO (hereinafter referred to as “Defendant”), and hereby

    20        responds to the Complaint of Plaintiff, ALEXANDRA RODRIGUEZ (hereinafter collectively referred

    21        to as “Plaintiff”), for herself alone and for no other person or entity as follows:

    22        Pursuant to Code of Civil Procedure § 431.30(d), this answering Defendant denies, generally and

    23        specifically, each and every allegation in Plaintiff’s Complaint and each and every cause of action set

    24        forth therein. This answering Defendant further generally and specifically denies that Plaintiff has been

    25        damaged in the sum or sums alleged or in any other sum or sums or at all, by reason of any act or
    26        omission on the part of this answering Defendant or on the part of any of Defendant’s agents, servants
    27        and/or employees.
    28        ///
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                                                                  ANSWER TO UNVERIFIED COMPLAINT