Answer: SHAUNDRA SLEDGE, ET AL. VS BRENT ALLEN PHIPPS, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/01/2020 12:58 PM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Ramos,Deputy Clerk




                           1     Christopher A. White [SBN 156613]
                                 cwhite@morrow-white.com
                           2     Reza M. Razavi SBN [276864]
                                 mrazavi@morrow-white.com
                           3     MORROW & WHITE
                                 1600 Dove Street, Suite 315
                           4     Newport Beach, CA 92660
                                 Telephone: (714) 979-7999
                           5     Toll-Free: (855) 265-4926
                                 Facsimile: (714) 979-7779
                           6     Attorneys for Defendants,
                                 BRENT ALLEN PHIPPS AND
                           7     ACCO ENGINEERED SYSTEMS, INC.
                           8
                                                               SUPERIOR COURT OF THE STATE OF CALIFORNIA
                           9
                                                      COUNTY OF LOS ANGELES, SPRING STREET COURTHOUSE
                          10

                          11     SHAUNDRA SLEDGE,                                                          Case No.: 19STCV41767
                                 JOSHUA BANKS, a minor by & through his
                          12     guardian ad litem, Shaundra Sledge
                                                                                                           DEFENDANTS BRENT ALLEN PHIPPS
                          13
                                                           Plaintiffs,                                     AND ACCO ENGINEERED SYSTEMS, INC.
                                                                                                           ANSWER TO UNVERIFIED COMPLAINT
                          14
                                              vs.
                          15
                                 BRENT ALLEN PHIPPS AND
                          16     ACCO ENGINEERED SYSTEMS, INC.                                             Judge:                Hon. Jon R. Takasugi
                                 and DOES 1 TO 25, inclusive,                                              Dept.:                31 (formerly 3)
                          17                                                                               Action Filed:         11/20/2019
                                                           Defendants.                                     Trial Date:           05/19/2021
                          18

                          19                  DEFENDANTS BRENT ALLEN PHIPPS AND ACCO ENGINEERED SYSTEMS,
                          20     INC. (hereinafter “Defendants”) hereby answers the unverified Complaint of PLAINTIFFS
                          21     SHAUNDRA SLEDGE, JOSHUA BANKS, a minor by & through his guardian ad litem,
                          22     Shaundra Sledge, (hereinafter “Plaintiffs”) as follows:
                          23                                                              AFFIRMATIVE DEFENSES
                          24                                                                          FIRST DEFENSE
                          25                  1.           Pursuant to the provisions of Section 431.30(d) of the California Code of Civil
                          26     Procedure, answering Defendants generally deny each and every allegation of each cause of
                          27     action alleged therein, and further deny that Plaintiffs suffered injury or damage in the sums
                          28     therein alleged, or in any other sum or sums, or at all.

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                                                                                                 ANSWER TO COMPLAINT
                                 G:\19-062 Sledge v ACCO\Pleading\ACCO ANS to Complaint [Draft].doc