On February 08, 2019 a
Response - RESPONSE ANSWER TO COMPLAINT
was filed
involving a dispute between
Rahni Michael,
and
Santa Monica Community College District,
for Other Employment Complaint Case (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 05/24/2019 04:13 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk
LOUIS R. DUMONT - State Bar No. 130198
JOHNNY RUNDELL - State Bar No. 289480
2
CARPENTER, ROTHANS & DUMONT LLP
3 500 South Grand Avenue, 19th Floor
Los Angeles, CA 90071
4 (213) 228-0400 FEE EXEMPT
(213) 228-0401 (Fax) GOV. CODE§ 6103
5
ldumont@crdlaw.comijrundell@crdlaw.com
6 Attorneys for Defendant, SANTA MONICA COMMUNITY COLLEGE DISTRICT, a public
7 entity
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT
IO
II MICHAEL RAHN!, Case No. l 9STCV04338
[Assigned to the Hon. Mel Red Recana, Dept.
12
Plaintiff, 45]
13 V.
ANSWER TO COMPLAINT
14 SANT A MONICA COMMUNITY COLLEGE
DISTRICT, and DOES I to 25, inclusive,
15
16 Defendants.
17
18
19 COMES NOW Defendant, SANTA MONICA COMMUNITY COLLEGE DISTRICT, a public
20 entity, and hereby answers plaintiffs Complaint for Damages on file herein and admits, denies
21 and alleges as follows:
22 l. Under the provisions of Code of Civil Procedure § 431.30, this answering
23 defendant denies each and every allegation of plaintiffs Complaint on file herein, and further
24 denies that the plaintiff was damaged in the manner or sums alleged, or at all.
25 2. This answering defendant denies that plaintiff sustained injury due to any act or
26 discrimination, any omission, recklessness, carelessness, negligence or other breach of duty on
27 the part of this answering defendant, that the incidents and events described in the Complaint on
28 file herein occurred, or that the plaintiff was injured or damaged, and denies that plaintiff has
-I-
ANSWER TO COMPLAINT
Document Filed Date
May 24, 2019
Case Filing Date
February 08, 2019
Category
Other Employment Complaint Case (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 03/08/2021
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Electronically FILED by Superior Court of California, County of Los Angeles on 05/24/2019 04:13 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk LOUIS R. DUMONT - State Bar No. 130198 JOHNNY RUNDELL - State Bar No. 289480 2 CARPENTER, ROTHANS & DUMONT LLP 3 500 South Grand Avenue, 19th Floor Los Angeles, CA 90071 4 (213) 228-0400 FEE EXEMPT (213) 228-0401 (Fax) GOV. CODE§ 6103 5 ldumont@crdlaw.comijrundell@crdlaw.com 6 Attorneys for Defendant, SANTA MONICA COMMUNITY COLLEGE DISTRICT, a public 7 entity 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT IO II MICHAEL RAHN!, Case No. l 9STCV04338 [Assigned to the Hon. Mel Red Recana, Dept. 12 Plaintiff, 45] 13 V. ANSWER TO COMPLAINT 14 SANT A MONICA COMMUNITY COLLEGE DISTRICT, and DOES I to 25, inclusive, 15 16 Defendants. 17 18 19 COMES NOW Defendant, SANTA MONICA COMMUNITY COLLEGE DISTRICT, a public 20 entity, and hereby answers plaintiffs Complaint for Damages on file herein and admits, denies 21 and alleges as follows: 22 l. Under the provisions of Code of Civil Procedure § 431.30, this answering 23 defendant denies each and every allegation of plaintiffs Complaint on file herein, and further 24 denies that the plaintiff was damaged in the manner or sums alleged, or at all. 25 2. This answering defendant denies that plaintiff sustained injury due to any act or 26 discrimination, any omission, recklessness, carelessness, negligence or other breach of duty on 27 the part of this answering defendant, that the incidents and events described in the Complaint on 28 file herein occurred, or that the plaintiff was injured or damaged, and denies that plaintiff has -I- ANSWER TO COMPLAINT