On November 05, 2019 a
Answer
was filed
involving a dispute between
3835 Cross Creek Llc A Limited Liability Company Doing Business In The State Of California,
Integrated Water Services Inc. A Corporation Doing Business In The State Of Ca,
Malibu Country Mart A Business Entity Doing Business In The State Of California,
Michael Koss Trustee Of The Michael Koss Trust,
Howell Samuel,
and
3835 Cross Creek Llc A Limited Liability Company Doing Business In The State Of California,
Domicile Design Inc. A Corporation Doing Business In The State Of Ca,
Integrated Water Services Inc. A Corporation Doing Business In The State Of Ca,
Koss Financial Inc. A Corporation Doing Business In The State Of Ca,
Malibu Country Mart A Business Entity Doing Business In The State Of California,
Michael Koss Enterprises Inc. A Corporation Doing Business In The State Of Ca,
Michael Koss Trustee Of The Michael Koss Trust,
for Other Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/25/2019 06:49 PM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Ramos,Deputy Clerk
1 LAW OFFICES OF KIRK & MYERS
Amit Palls, - SBN #276487
2 707 Wilshire Boulevard, Suite 1500
Los Angeles, CA 90017
3
Telephone: 213-228-2466
4 Facsimile: 603-334-7162
5 Attorney for Defendants, MALIBU COUNTRY MART and
3835 CROSS CREEK LLC
6
7
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF LOS ANGELES - SPRING STREET BRANCH
11
SAMUEL HOWELL, an individual, Case No.: 19STCV39910
12 Complaint filed: November 5, 2019
13 Plaintiff Assigned to: Honorable Theresa M. Traber
Dept: 4A
14 V.
ANSWER TO COMPLAINT
15 MALIBU COUNTRY MART, a business entity
doing business in the state of California; 3835
16 CROSS CREEK LLC, a limited liability
17 company doing business in the state of
California; and DOES 1 through 40, Inclusive,
18
Defelidarils
19
Defendants, MALIBU COUNTRY MART and 3835 CROSS CREEK, LLC in answer to the
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unverified Complaint on file herein, and by virtue of the provisions of Code of Civil Procedure section
21
431.30, now files its general denial to said unverified Complaint and to each cause of action thereof and
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, answering all of the allegations thereof; Defendants deny each and all of them. Defendants further
23
specifically deny that Plaintiff has been damaged in any sum or sums whatsoever, or at all.
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Defendants state the following separate affirmative defenses to this action:
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AFFIRMATIVE DEFENSES
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1. As to each and every cause of action alleged in the Complaint herein, Defendants are
27
inforrned and believe(s) and thereon alleges that any and all alleged events, happenings, injuries and
28
damages, if any, were proximately caused or contributed to by the failure of Plaintiff to exercise
-1-
ANSWER TO COMPLAINT Samuel Howell v. Malibu Country Mart, et al.
Document Filed Date
November 25, 2019
Case Filing Date
November 05, 2019
Category
Other Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
Status
Court-Ordered Dismissal - Other (Other) 11/30/2022
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/25/2019 06:49 PM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Ramos,Deputy Clerk 1 LAW OFFICES OF KIRK & MYERS Amit Palls, - SBN #276487 2 707 Wilshire Boulevard, Suite 1500 Los Angeles, CA 90017 3 Telephone: 213-228-2466 4 Facsimile: 603-334-7162 5 Attorney for Defendants, MALIBU COUNTRY MART and 3835 CROSS CREEK LLC 6 7 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF LOS ANGELES - SPRING STREET BRANCH 11 SAMUEL HOWELL, an individual, Case No.: 19STCV39910 12 Complaint filed: November 5, 2019 13 Plaintiff Assigned to: Honorable Theresa M. Traber Dept: 4A 14 V. ANSWER TO COMPLAINT 15 MALIBU COUNTRY MART, a business entity doing business in the state of California; 3835 16 CROSS CREEK LLC, a limited liability 17 company doing business in the state of California; and DOES 1 through 40, Inclusive, 18 Defelidarils 19 Defendants, MALIBU COUNTRY MART and 3835 CROSS CREEK, LLC in answer to the 20 unverified Complaint on file herein, and by virtue of the provisions of Code of Civil Procedure section 21 431.30, now files its general denial to said unverified Complaint and to each cause of action thereof and 22 , answering all of the allegations thereof; Defendants deny each and all of them. Defendants further 23 specifically deny that Plaintiff has been damaged in any sum or sums whatsoever, or at all. 24 Defendants state the following separate affirmative defenses to this action: 25 AFFIRMATIVE DEFENSES 26 1. As to each and every cause of action alleged in the Complaint herein, Defendants are 27 inforrned and believe(s) and thereon alleges that any and all alleged events, happenings, injuries and 28 damages, if any, were proximately caused or contributed to by the failure of Plaintiff to exercise -1- ANSWER TO COMPLAINT Samuel Howell v. Malibu Country Mart, et al.