Answer: NICHOLAS GALL VS FAA BEVERLY HILLS, INC., ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/21/2019 01:58 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Yanez,Deputy Clerk



                   1     Timothy D. Robinett, Esq., SBN 166797
                         MANNING, LEAVER, BRUDER & BERBERICH
                   2     801 S. Figueroa Street, Suite 1150
                         Los Angeles, California 9001 7
                   3     Telephone: (323) 937-4730
                         Fax: (323) 937-6727
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                         Attorneys for Defendant, FAA Beverly Hills, Inc.,
                   5     dba Beverly Hills BMW

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                                                    SUPERIOR COURT FOR THE STATE OF CALIFORNIA
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                         COUNTY OF LOS ANGELES-CENTRAL DISTRICT, STANLEY MOSK COURTHOUSE
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                 1 O NICHOLAS GALL, an individual,                                                   CASE NO. 19STCV36412
                 11                 Plaintiff,                                                       DEFENDANT FAA BEYERLY HILLS, INC.,
                                                                                                     DBA BEYERL Y HILLS BMW'S ANSWER
                 12                 v.                                                               TO PLAINTIFF'S UNVERIFIED
                                                                                                     COMPLAINT
                 13      FAA BERVERLY HILLS, INC., dba
                         BEYERL Y HILLS BMW, a corporation; BMW
                 14      OF NORTH AMERICA, LLC, a limited
                         liability company; and DOES 1 through 75,
                 15      inclusive,

                 16                 Defendants.

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                                    Under Code of Civil Procedure § 431.30, Defendant FAA Beverly Hills, Inc., dba Beverly
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                         Hills BMW (herein referred to as "this answering defendant") generally denies all of the allegations                                                     l
                         in the Complaint, and further denies that plaintiff has been harmed by virtue of these answer
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                         defendant's acts or omissions. This answering defendant asserts the following affirmative defenses
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                         to the Complaint, as follows:
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                 24                                                     FIRST AFFIRMATIVE DEFENSE

                 25                                                       (Failure to State a Cause of Action)
                                     1. As a first, separate and affirmative defense to the Complaint on file herein, and to each
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                         alleged cause of action set forth therein, this answering defendant alleges that the Complaint, and
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                         each purported cause of action contained therein, fails to state facts sufficient to constitute a cause of
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                         action against this answering defendant.

                                                                                                 -1.,
00267604.DOC                                DEFENDANT FAA BEVERLY HILLS, INC., DBA BEVERLY HILLS BMW'S ANSWER TO
                                                             PLAINTIFF'S UNVERIFIED COMPLAINT