Answer: 632 N PALM DRIVE, LLC VS ADAN PENA, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/03/2019 04:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Parententeau,Deputy Clerk

                                                                                                                                                                                  PLD-050
        ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slale Bar number       and addreaail                                                        FOR COURT USE ONLY

        Jeffrey D. Horowitz, Esq. SBN 150012
        THE HOROWITZ LAW FIRM
        14156 Magnolia Blvd., Suite 200
        ShetTttan Oaks, CA 91423
        TELEPHONENO: (818) 907-8000        FAXNO(opltonag(818) 784-3406
        EMAIL ADDREss        jetf@jdhnrOWitZlaW COm
                         (oplonasr
                           RAL Design and Management, Inc.
        ATTQRNEY FoR (Namei.
        sUPERIQR coURT QF cALIFQRNIA, coUNTY QF Los Angeles
           sTREETADDREss:   1725 Main Street
           MAILING ADDREss  1725 Main Street
          cITYAND TIP coDE  Santa Monica, CA 90401
              BRANDH NAME'est Judicial District
           PLAINTIFF/PETITIQNER: 632 N. PALM DRIVE, LLC

            DEFENDANT(IEESPDNOENT:           GOLD PACIFIC CONSTRUCTION, INC., et al
                                                                                                                       CASE NUMBER
                                          GENERAL DENIAL                                                                19SMCV00434
        If you want to file a general denial, you MUST use this form if the amount asked for in the complaint or the value of the property
        involved is $ 1,000 or less.

        You MAY use this form for a general denial if:
             1.  The complaint is not verified; or
                2.      The complaint is verified and the case is a limited civil case (the amount in controversy is $ 25,000 or less),
                        BUT NOT if the complaint involves a claim for more than $ 1,000 that has been assigned to a third party for collection.

        (See Code of Civil Procedure sections 85-86, 90-100, 431.30, and 431.40.)
       1.     DEFENDANT (name)( RAL DESIGN AND MANAGEMENT, INC., a California corporation
              generally denies each and every allegation of plaintiffs complaint.
      2.      Q3 DEFENDANT states the following FACTS as separate affirmative defenses to plaintiffs complaint (attach additional
                      pagesifnecessary):

                      1. The allegations of the Cross-Complaint filed herein, do not state facts suAicient to constitute a cause
                      of action against this Anstvering Cross-Defendant, RAL Design and Management, Inc.




       Date:    September 3, 2019
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                                         (TYPE OR PRINT NAME)
                                                                                                                           2
                                                                                                                    ~GNATURE          OF DEFENDANT ORQTTI3sffsvy



        If you have a claim for damages or other relief against the plaintiff, the law may require you to state your claim in a special pleading
        called a cross-complaint or you may lose your right to bring the claim. (See Code of Civil Procedure sections 426.10-426.40.)
        The original of this General Denial must be filed with the clerk of this court with proof that a copy was served on each plaintiffs
        attorney and on each plaintiff not represented by an attorney. There are two main ways to serve this General Denial: by personal
        delivery or by mail. It may be served by anyone at least 18 years of age EXCEPT you or any other party to this legal action. Be sure
        that whoever serves the Genera/ Denial fills out and signs a proof of service. You may use the applicable Judicial Council form (such
        as form POS-020, POS-030, or POS-040) for the proof of service.
                                                                                                                                                                                   Page I of I
                                                                               GENERAL DEN)AL                                                     Code of 0 vd Procedure,   tt   431 30, 431.40


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