On September 25, 2018 a
Answer
was filed
involving a dispute between
American Contractors Indemnity Company,
Home Construction Solutions Corp A California Corporation,
Ramos Antonio,
Ramos Petra,
and
American Contractors Indemnity Company,
Beloskty Vitaly,
Home Construction Solutions Corp,
Kenney Daniel,
Tuffnell Design Group Inc.,
Tuffnell Robert,
Western Surety Company,
Zetz Joseph Robert Sr,
for Contractual Fraud (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
1 Robert H. Dewberry, State Bar No. 89354
theDewberryfirm
2 34 Executive Park Suite 210 F
Irvine, CA 92614 »-
3 (949) 955-2940 Superior Court aflcjam-omia
Fax (949) 209-3883 County of Los Ange,“
4 robert.dewberry@dew|aw.net
5 Att orneys for D een
f d an t sh H3’ J. _
DANIEL KENNEY 3:" C“ W‘ L‘ f",° Officer/Clerk
6 Vauessala aricio .DepuIy
7
8 SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF LOS ANGELES, NORTHWEST DISTRICT
10
11 ANTONIO RAMOS and PETRA RAMOS, Case No. LC107846
Plaintiffs, ‘PROPOSED ANSWER TO UNVERIFIED
12 COMPLAINT
13 vs.
HOME CONSTRUCTION SOLUTIONS Complaint Filed: 9/25/2018
14 CORP., et. al.; Trial: Not Set
15 Defendants.
16
17 Defendant, DANIEL KENNEY, answers the unverified Complaint (”Comp|aint”) as
13 follows:
19 1. The Complaint being unverified, Defendant generally and specifically
20 denies every material allegation, and denies that Plaintiff is entitled to any recovery.
21 FIRST AFFIRMATIVE DEFENSE
22
2. Defendant alleges that throughout the Complaint, Plaintiff has failed to
23
24 allege facts sufficient to constitute a cause of action.
25 SECOND AFFIRMATIVE DEFENSE
26 3. Defendant is informed and believes and thereon alleges that the
27 Complaint, as well as each of its purported causes of action, is barred by the applicable
xiii‘
28 California Statutes of Limitations, including without limitation Code of Civil Procedure
‘J1; ‘1'
l"i'i‘ F ANSWER TO UNVERIFIED COMPLAINT
Document Filed Date
August 28, 2019
Case Filing Date
September 25, 2018
Category
Contractual Fraud (General Jurisdiction)
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