Preview
RESNICK & LOUIS, P.C. E-FILED
Dirk E. Silva, Esq., SBN 134135 1/30/2018 2:13 PM
9891 Irvine Center Dr., Suite 200
FRESNO COUNTY SUPERIOR COURT
Irvine, CA 92618 By: I. Herrera, Deputy
Telephone: (714) 709—4919 /Facsimile: (714) 709—4919
Email: dsilva@rlattomeys.com
\ODONQU‘I-bU-‘Nv—d
Attorneys for Defendants Maritza Elisa Rivera, Sonia Bravo, and Florentino Rivera
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
COUNTY 0F FRESNO
FEDERICO SANCHEZ, Case No. 17CECG04204
Plaintiff,
Judge: Hon. Mark Snauffer
V.
DEFENDANTS MARITZA ELISA
RIVERA, SONIA BRAVO AND
FLORENTINO RIVERA’S ANSWER
MARITZA ELISA RIVERA; SONIA BRAVO; T0 PLAINTIFF FREDERICO
FLORENTINO RIVERA; MARIO CEJA; and SANCHEZ’S COMPLAINT
DOES 1 through 30, inclusive,
DEMAND FOR JURY TRIAL
Defendants.
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Case Management Conference:
DATE: April 2, 2018
TIME: 2:30 p.m.
DEPT: 305
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Action Filed: December 6,2017
COMES NOW, Defendants MARITZA ELISA RIVERA, SONIA BRAVOE and
FLORENTINO RIVERA (“Defendants"), and respond t0 the Complaint 0f FEDERICO SANCHEZ
(“Plaintiff'), as follows:
GENERAL DENIAL
Pursuant to the provisions 0f Section 431.30 0f the California Code osz'viZ Procedure, these
answering Defendants deny generally and specifically each, every and all of the allegations in said
Complaint, and the whole thereof, including each and every purported cause 0f action contained
therein. These answering Defendants further deny that Plaintiff has or will sustain damages in the
DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO PLAINTIFF FEDERICO
SANCHEZ’S COMPLAINT
1
amount alleged or in any amount whatsoever. These answering Defendants deny that Plaintiff has
sustained any injuries, damages 0r losses because of any act or omission of these answering
-
Defendants.
AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
\OOOQQLIIAUJNH
(Comparative Negligence)
Defendants are informed and believe and thereon allege, at alltimes and places set forth in the
Complaint, Plaintiff failed to exercise ordinary care on his own behalf, which negligence and
carelessness was a proximate cause of some portion, up t0 and including the whole thereof, of the
injuries and damages complained of in this action. Plaintiffs recovery, therefore, against Defendants
should be barred 0r reduced according to principles of comparative negligence 0f Plaintiff.
SECOND AFFIRMATIVE DEFENSE
(Comparative Fault 0f Others)
Defendants are informed and believe and thereon allege, at all times and places set forth in the
Complaint, other persons, other than Defendants, failed to exercise ordinary care on their own behalf,
which negligence and carelessness was a proximate cause of some portion, up to and including the
Whole thereof, of the inj uries and damages complained of by Plaintiff in this action. The fault, if any,
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of Defendants should be compared with the fault of those other individuals, and damages, if any,
should be apportioned among the others in direct relation to each person’s comparative fault, such
that Defendants should be obliged to pay only such damages, if any, which are
OOQONm-kWNHOWOOQQUIgWNNO
directly attributable to
their percentage of comparative fault.
THIRD AFFIRMATIVE DEFENSE
(Comparative Negligence)
Defendants deny that they were negligent in any fashion with respect to the damages, losses,
injuries, and debts ciaimed by the Plaintiff. However, if Defendants are found to have been negligent
(which supposition is denied and merely stated for the purpose of this affirmative defense), then
Defendants provisionally allege that their negligence is not the sole and proximate cause of the
DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO PLAINTIFF FEDERICO
SANCHEZ’S COMPLAINT
2
resultant damages, losses and injuries alleged by Plaintiff and that the damages awarded t0 Plaintiff,
if any, are to be apportioned according to the respective fault of the parties, persons, and entities, or
their agents, servants, and employees who contributed to and/or caused said resultant damages as
alleged, according to proof presented at the time of trial.
FOURTH AFFIRMATIVE DEFENSE
KooofioxmAwNH
(Negligence on the Part 0f Third Parties)
Any injuries or damages which may have been sustained by Plaintiff were the proximate
result of negiigence of third parties. For this reason, if Plaintiff has been damaged, aside from any
reduction of damages attributable t0 Plaintiffs own negligence, the damages must be apportioned
among the pafiies to this action in proportion to their respective degrees of fault.
FIFTH AFFIRMATIVE DEFENSE
(Failure to State a Cause of Action)
The Complaint and every purported cause of action therein fail to set forth facts sufficient to
state a cause of action.
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SIXTH AFFIRMATIVE DEFENSE
(Statute of Limitation -General)
Plaintiff’s actions are barred by the applicable statutes of limitations.
SENVENTH AFFIRMATIVE DEFENSE
(Failure to Mitigate)
The Plaintiff failed to exercise reasonable care and diligence to avoid loss and to minimize
damages and, therefore, Plaintiff may not recover for losses which could have been prevented by
reasonable efforts on her own part, or by expenditures that might reasonably have been made.
Therefore, Plaintiff’s recoveries, if any, should be reduced by the failure of Plaintiff to mitigate his
damages.
///
///
///
DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO ?LAINTIFF FEDERICO
SANCHEZ’S COMPLAINT
3
EIGHTH AFFIRMATIVE DEFENSE
(Superseding Negligence)
The injuries and damages of which the Plaintiff complains of were proximately caused or
contributed to by the acts 0f other defendants, persons and/or entities. Said acts were an intervening,
supervening and superseding cause of the injuries and damages, if any, of which the Plaintiff
\OOOQQUIhWN"
complains thus barring Plaintiff from any recovery against these answering Defendants.
NINTH AFFIRMATIVE DEFENSE
(Estoppel)
The Plaintiff has engaged in conduct with respect to the activities which are the subj ect of the
Complaint, and by reason of said activities and conduct, is estopped from asserting any claim for
damages or seeking any other relief against these answering Defendants.
TENTH AFFIRMATIVE DEFENSE
(Waiver)
The Plaintiff has engaged in conduct and activities sufficient to constitute a waiver of any
alleged negligence or any other conduct, if any, as set forth in the Complaint.
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ELEVENTH AFFIRMATIVE DEFENSE
(Contribution)
Defendants allege that damages suffered by Plaintiff, if any, were the direct and proximate
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result of the negligence of parties, persons, corporations and/or entities other than Defendants, and
that the liability of these answering Defendants, if any, are limited in direct proportion to the
percentage of fault actuaily attributable to these answering Defendants.
TWELFTH AFFIRMATIVE DEFENSE
(Assumption of Risk)
The perils or dangers, if any, existing at the time of Plaintiff’s alleged injuries, if any, were
open and obvious and known to Plaintiff Who nevertheless conducted himself in such a manner so as
to expose him to said perils and dangers, if any, and by so doing, assumed all of the risks attendant
thereto.
DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTYNO RIVERA‘S ANS WER TO PLAINTIFF FEDERICO
SANCHEZ’S COMPLAINT
4
THIRTEENTH AFFIRMATIVE DEFENSE
(Offset)
Defendants allege that the claims, and each of them, are barred by offset.
FOURTEENTH AFFIRMATIVE DEFENSE
(Act of God)
\OOOQONU'IAUJNH
Any and all events, happenings, injuries and damages, if any, as alleged in the Plaintiff’s
Complaint, were a direct result of unforeseeable act of God.
FIFTEENTH AFFIRMATIVE DEFENSE
(Last Clear Chance)
Defendants are informed and believe, and thereon allege, that at all times mentioned herein,
that if the Plaintiff had been observant, and had seen what was to be seen, that said Plaintiff had the
Last Clear Chance for avoiding the accident and any damages or injuries sustained. As a result
thereof, and due to Plaintiff’s failure to avoid the accident, Plaintiff should take nothing from these
answering Defendants, and istherefore barred from recovery for any injuries or damages complained
of in his complaint
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SIXTEENTH AFFIRMATIVE DEFENSE
(Several Liability)
Defendants are informed and believes, and thereon alleges, other Defendants and Plaintiff are
responsible for Plaintiffs economic and non-economic damages, if any, pursuant to the California
Civil Code, Sections 1431, 1431.2, 1431.3, 1431.4, and 1431.5, and that Plaintiff’s recovery against
these answefing Defendants for any non-economic damages are barred except as to those non-
economic damages specifically apportioned to these answering Defendants.
SEVENTEENTH AFFIRMATIVE DEFENSE
(Reservation)
Defendants presently have insufficient knowledge or information on which to foxm a belief as
to Whether or not they may have additional, as yet unstated affirmative defenses available.
DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO PLAINTIFF FEDERICO
SANCHEZ’S COMPLAINT
5
Defendants reserve defenses the eV'ent dis‘CoVe‘ry
'
their right to assert additionai in that indicates
-
additional. defenses would be appropriate.
PRAYER
WHEREFORE, Defendants prays that Plaintiff take nothing by way of his Complaint o'nfile
_
herein, that judgment be entered i'n the within action in favor 0f these answering Defendants and
of' award these answering
upon with an
'1
against the Plaintiff the issues the Complaint, together to
Defendants of-costs of suit herein incurred, and. such other and further relief as "theCourt-deems just.
DEMAND FOR JURY TRIAL
DEMAND [S HEREBY MADE by Defendants, MARITZA ELISA RIVERA, SONIA
BRAVO and .FLORENTINO RIVERA, for trialbyjury in.the above-entitkd-action.
m“N
DATED: January :1, 201 8 _&. fiVU-Is, RC.
‘\
/
Defendants Maritza Elisa Rivera, Sonia Bravo
and 'Florenlino Rivera
DEFENDANTS MARITZA ELISA RIVERA,-SONIA BRAVO AND 'FLQREN'I‘INO RWERA’S ANSWER TO PLAINTIFF FEDERICQ
SANCHEZ’S COMPLAINT
6
PROOF 0F SERVICE
I am employed in the County of Maricopa, State of Arizona. I am over the age of 18 and not
a party t0 the within action. My business address is 8111 E. Indian Bend Road, Scottsdale, AZ,
85250.
On January 30, 2018, I served the foregoing document(s) described as: DEFENDANTS
MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO
\DOOQQMAWNr—d
PLAINTIFF FREDERICO SANCHEZ’S COMPLAINT, on interested parties in this action by
sending a true copy of the document to the following parties as follows:
SEE ATTACHED SERVICE LIST
(BY ELECTRONIC MAIL) I caused the document(s) to be successfully transmitted via
electronic mail the offices of the addressees.
(BY FACSIMILE) I transmitted, pursuant to Rule 2.306, the above-dcscribed document
by facsimile machine (which complied with Rule 3003(3)), to the attached listed fax
number(s). The transmission originated from facsimile phone number (602) 456-4056
and was reported as complete and without error.
(BY OVER NIGHT DELIVERY) I caused such envelope(s) thereon fuliy prepaid to be
placed via Federal Express.
(BY ELECTRONIC SERVICE VIA CASE ANYWHERE) (AS INDICATED ON
SERVICE LIST) I caused the above- entitled document(s) to be sewed through Case
Anywhere addressed to
NNNHHer—nr—‘p—An—Ap—Aw
all parties appearing on the electronic service listfor the above-
entitled case. The service transmission was reported as complete.
XXX (BY US MAIL) I caused such sealed envelope(s) with postage thereon fully prepaid to
be placed in the United States mail at Scottsdale, AZ. I am readily famiiiar with this
business' practice for collecting and processing correspondence for mailing. On the
same day that correspondence is placed for collection and maiiing, it is deposited in the
ordinary course of business with the United States Postal Service. SEE SERVICE
LIST BELOW
Jesse R. Fretwell
Law Office of Darryl B. Freedman, Inc.
3705 W. Beechwood Avenue
Fresno, CA 93711
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
I
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’éfiefle :gL//
Louis,P.C.
Enfyyee ofReg/fijék’
,/
DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FWO
SANCHEZ’S COMPLAINT
RIVERA’S ANSWER TO PLAINTIFF FEDERICO
7
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RESNICK & LOUIS, P.C. E-FILED Dirk E. Silva, Esq., SBN 134135 1/30/2018 2:13 PM 9891 Irvine Center Dr., Suite 200 FRESNO COUNTY SUPERIOR COURT Irvine, CA 92618 By: I. Herrera, Deputy Telephone: (714) 709—4919 /Facsimile: (714) 709—4919 Email: dsilva@rlattomeys.com \ODONQU‘I-bU-‘Nv—d Attorneys for Defendants Maritza Elisa Rivera, Sonia Bravo, and Florentino Rivera SUPERIOR COURT 0F THE STATE OF CALIFORNIA COUNTY 0F FRESNO FEDERICO SANCHEZ, Case No. 17CECG04204 Plaintiff, Judge: Hon. Mark Snauffer V. DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER MARITZA ELISA RIVERA; SONIA BRAVO; T0 PLAINTIFF FREDERICO FLORENTINO RIVERA; MARIO CEJA; and SANCHEZ’S COMPLAINT DOES 1 through 30, inclusive, DEMAND FOR JURY TRIAL Defendants. NNNHHF—Ar—tp—nu—Ar—Ap—nn—AH Case Management Conference: DATE: April 2, 2018 TIME: 2:30 p.m. DEPT: 305 gflgfififimwocmqo‘mhwwfio Action Filed: December 6,2017 COMES NOW, Defendants MARITZA ELISA RIVERA, SONIA BRAVOE and FLORENTINO RIVERA (“Defendants"), and respond t0 the Complaint 0f FEDERICO SANCHEZ (“Plaintiff'), as follows: GENERAL DENIAL Pursuant to the provisions 0f Section 431.30 0f the California Code osz'viZ Procedure, these answering Defendants deny generally and specifically each, every and all of the allegations in said Complaint, and the whole thereof, including each and every purported cause 0f action contained therein. These answering Defendants further deny that Plaintiff has or will sustain damages in the DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO PLAINTIFF FEDERICO SANCHEZ’S COMPLAINT 1 amount alleged or in any amount whatsoever. These answering Defendants deny that Plaintiff has sustained any injuries, damages 0r losses because of any act or omission of these answering - Defendants. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE \OOOQQLIIAUJNH (Comparative Negligence) Defendants are informed and believe and thereon allege, at alltimes and places set forth in the Complaint, Plaintiff failed to exercise ordinary care on his own behalf, which negligence and carelessness was a proximate cause of some portion, up t0 and including the whole thereof, of the injuries and damages complained of in this action. Plaintiffs recovery, therefore, against Defendants should be barred 0r reduced according to principles of comparative negligence 0f Plaintiff. SECOND AFFIRMATIVE DEFENSE (Comparative Fault 0f Others) Defendants are informed and believe and thereon allege, at all times and places set forth in the Complaint, other persons, other than Defendants, failed to exercise ordinary care on their own behalf, which negligence and carelessness was a proximate cause of some portion, up to and including the Whole thereof, of the inj uries and damages complained of by Plaintiff in this action. The fault, if any, NNNNNNNNNMr—II—IHMr—tb—Ip—‘r—AH of Defendants should be compared with the fault of those other individuals, and damages, if any, should be apportioned among the others in direct relation to each person’s comparative fault, such that Defendants should be obliged to pay only such damages, if any, which are OOQONm-kWNHOWOOQQUIgWNNO directly attributable to their percentage of comparative fault. THIRD AFFIRMATIVE DEFENSE (Comparative Negligence) Defendants deny that they were negligent in any fashion with respect to the damages, losses, injuries, and debts ciaimed by the Plaintiff. However, if Defendants are found to have been negligent (which supposition is denied and merely stated for the purpose of this affirmative defense), then Defendants provisionally allege that their negligence is not the sole and proximate cause of the DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO PLAINTIFF FEDERICO SANCHEZ’S COMPLAINT 2 resultant damages, losses and injuries alleged by Plaintiff and that the damages awarded t0 Plaintiff, if any, are to be apportioned according to the respective fault of the parties, persons, and entities, or their agents, servants, and employees who contributed to and/or caused said resultant damages as alleged, according to proof presented at the time of trial. FOURTH AFFIRMATIVE DEFENSE KooofioxmAwNH (Negligence on the Part 0f Third Parties) Any injuries or damages which may have been sustained by Plaintiff were the proximate result of negiigence of third parties. For this reason, if Plaintiff has been damaged, aside from any reduction of damages attributable t0 Plaintiffs own negligence, the damages must be apportioned among the pafiies to this action in proportion to their respective degrees of fault. FIFTH AFFIRMATIVE DEFENSE (Failure to State a Cause of Action) The Complaint and every purported cause of action therein fail to set forth facts sufficient to state a cause of action. NNNNHMHr—Ir—nh—Ay—AI—Ip—Am SIXTH AFFIRMATIVE DEFENSE (Statute of Limitation -General) Plaintiff’s actions are barred by the applicable statutes of limitations. SENVENTH AFFIRMATIVE DEFENSE (Failure to Mitigate) The Plaintiff failed to exercise reasonable care and diligence to avoid loss and to minimize damages and, therefore, Plaintiff may not recover for losses which could have been prevented by reasonable efforts on her own part, or by expenditures that might reasonably have been made. Therefore, Plaintiff’s recoveries, if any, should be reduced by the failure of Plaintiff to mitigate his damages. /// /// /// DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO ?LAINTIFF FEDERICO SANCHEZ’S COMPLAINT 3 EIGHTH AFFIRMATIVE DEFENSE (Superseding Negligence) The injuries and damages of which the Plaintiff complains of were proximately caused or contributed to by the acts 0f other defendants, persons and/or entities. Said acts were an intervening, supervening and superseding cause of the injuries and damages, if any, of which the Plaintiff \OOOQQUIhWN" complains thus barring Plaintiff from any recovery against these answering Defendants. NINTH AFFIRMATIVE DEFENSE (Estoppel) The Plaintiff has engaged in conduct with respect to the activities which are the subj ect of the Complaint, and by reason of said activities and conduct, is estopped from asserting any claim for damages or seeking any other relief against these answering Defendants. TENTH AFFIRMATIVE DEFENSE (Waiver) The Plaintiff has engaged in conduct and activities sufficient to constitute a waiver of any alleged negligence or any other conduct, if any, as set forth in the Complaint. NNNNr—It—tr—‘Hr—Ar—tr—dH—IH ELEVENTH AFFIRMATIVE DEFENSE (Contribution) Defendants allege that damages suffered by Plaintiff, if any, were the direct and proximate gfigafimwwoomqamgwwwo result of the negligence of parties, persons, corporations and/or entities other than Defendants, and that the liability of these answering Defendants, if any, are limited in direct proportion to the percentage of fault actuaily attributable to these answering Defendants. TWELFTH AFFIRMATIVE DEFENSE (Assumption of Risk) The perils or dangers, if any, existing at the time of Plaintiff’s alleged injuries, if any, were open and obvious and known to Plaintiff Who nevertheless conducted himself in such a manner so as to expose him to said perils and dangers, if any, and by so doing, assumed all of the risks attendant thereto. DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTYNO RIVERA‘S ANS WER TO PLAINTIFF FEDERICO SANCHEZ’S COMPLAINT 4 THIRTEENTH AFFIRMATIVE DEFENSE (Offset) Defendants allege that the claims, and each of them, are barred by offset. FOURTEENTH AFFIRMATIVE DEFENSE (Act of God) \OOOQONU'IAUJNH Any and all events, happenings, injuries and damages, if any, as alleged in the Plaintiff’s Complaint, were a direct result of unforeseeable act of God. FIFTEENTH AFFIRMATIVE DEFENSE (Last Clear Chance) Defendants are informed and believe, and thereon allege, that at all times mentioned herein, that if the Plaintiff had been observant, and had seen what was to be seen, that said Plaintiff had the Last Clear Chance for avoiding the accident and any damages or injuries sustained. As a result thereof, and due to Plaintiff’s failure to avoid the accident, Plaintiff should take nothing from these answering Defendants, and istherefore barred from recovery for any injuries or damages complained of in his complaint NNNNHHr—dp—Ir—Ay—AHHp—AH SIXTEENTH AFFIRMATIVE DEFENSE (Several Liability) Defendants are informed and believes, and thereon alleges, other Defendants and Plaintiff are responsible for Plaintiffs economic and non-economic damages, if any, pursuant to the California Civil Code, Sections 1431, 1431.2, 1431.3, 1431.4, and 1431.5, and that Plaintiff’s recovery against these answefing Defendants for any non-economic damages are barred except as to those non- economic damages specifically apportioned to these answering Defendants. SEVENTEENTH AFFIRMATIVE DEFENSE (Reservation) Defendants presently have insufficient knowledge or information on which to foxm a belief as to Whether or not they may have additional, as yet unstated affirmative defenses available. DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO PLAINTIFF FEDERICO SANCHEZ’S COMPLAINT 5 Defendants reserve defenses the eV'ent dis‘CoVe‘ry ' their right to assert additionai in that indicates - additional. defenses would be appropriate. PRAYER WHEREFORE, Defendants prays that Plaintiff take nothing by way of his Complaint o'nfile _ herein, that judgment be entered i'n the within action in favor 0f these answering Defendants and of' award these answering upon with an '1 against the Plaintiff the issues the Complaint, together to Defendants of-costs of suit herein incurred, and. such other and further relief as "theCourt-deems just. DEMAND FOR JURY TRIAL DEMAND [S HEREBY MADE by Defendants, MARITZA ELISA RIVERA, SONIA BRAVO and .FLORENTINO RIVERA, for trialbyjury in.the above-entitkd-action. m“N DATED: January :1, 201 8 _&. fiVU-Is, RC. ‘\ / Defendants Maritza Elisa Rivera, Sonia Bravo and 'Florenlino Rivera DEFENDANTS MARITZA ELISA RIVERA,-SONIA BRAVO AND 'FLQREN'I‘INO RWERA’S ANSWER TO PLAINTIFF FEDERICQ SANCHEZ’S COMPLAINT 6 PROOF 0F SERVICE I am employed in the County of Maricopa, State of Arizona. I am over the age of 18 and not a party t0 the within action. My business address is 8111 E. Indian Bend Road, Scottsdale, AZ, 85250. On January 30, 2018, I served the foregoing document(s) described as: DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FLORENTINO RIVERA’S ANSWER TO \DOOQQMAWNr—d PLAINTIFF FREDERICO SANCHEZ’S COMPLAINT, on interested parties in this action by sending a true copy of the document to the following parties as follows: SEE ATTACHED SERVICE LIST (BY ELECTRONIC MAIL) I caused the document(s) to be successfully transmitted via electronic mail the offices of the addressees. (BY FACSIMILE) I transmitted, pursuant to Rule 2.306, the above-dcscribed document by facsimile machine (which complied with Rule 3003(3)), to the attached listed fax number(s). The transmission originated from facsimile phone number (602) 456-4056 and was reported as complete and without error. (BY OVER NIGHT DELIVERY) I caused such envelope(s) thereon fuliy prepaid to be placed via Federal Express. (BY ELECTRONIC SERVICE VIA CASE ANYWHERE) (AS INDICATED ON SERVICE LIST) I caused the above- entitled document(s) to be sewed through Case Anywhere addressed to NNNHHer—nr—‘p—An—Ap—Aw all parties appearing on the electronic service listfor the above- entitled case. The service transmission was reported as complete. XXX (BY US MAIL) I caused such sealed envelope(s) with postage thereon fully prepaid to be placed in the United States mail at Scottsdale, AZ. I am readily famiiiar with this business' practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and maiiing, it is deposited in the ordinary course of business with the United States Postal Service. SEE SERVICE LIST BELOW Jesse R. Fretwell Law Office of Darryl B. Freedman, Inc. 3705 W. Beechwood Avenue Fresno, CA 93711 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. I gquaf/ ’éfiefle :gL// Louis,P.C. Enfyyee ofReg/fijék’ ,/ DEFENDANTS MARITZA ELISA RIVERA, SONIA BRAVO AND FWO SANCHEZ’S COMPLAINT RIVERA’S ANSWER TO PLAINTIFF FEDERICO 7