Document for MICHAEL NAGUIB MIKHAIL VS PASADENA UNIFIED SCHOOL DISTRICT E

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. 09/29/2017        15:36 GENERAL                                                         ee”        795 5832                 P,003/018
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                       NANCY P, DOUMANIAN, ESQ., SBN: 168925                                            WDeri       TL
                       DOUMANIAN & ASSOCIATES                                                             Ounty Coury
                       418 North Fair Oaks Avenue, Suite 202
                                                                                                                of       Log 4CMlifonn ia
                       Pasadena, California 91103                                                                                sles
                       Telephone     (626) 795-5802                                                               P29x)
                       Facsimile            (626) 795-5832                                    By "      Carte, &

                       Attorneys for Defendant,                                                         Picardo                 "CO Clery
                                                                                                                   rez            Deputy
                       PASADENA UNIFIED SCHOOL DISTRICT, a public entity




                                              SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                         FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

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               11     MICHAEL NAGUIB MAKHAIL,                                    CASE NO. BC669576
                                                                                 [Assigned to the Honorable Mark Mooney]
               12                             Plaintiff,
               13                Vv,                                             DEFENDANT PASADENA UNIFIED
                                                                                 SCHOOL DISTRICT ANSWER TO
               14     PASADENA UNIFIED SCHOOL                                    COMPLAINT
                      DISTRICT, a public entity, ERIN DREYER,
               15     an individual; JOHN GUNDRY, an
                      individual; JOHN PAPPALARDO, an
               16     individual; DARREN HUGHES, an
                      individual; DOES 1-25, inclusive,
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                                              Defendants.
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                                 COMES NOW Defendant PASADENA UNIFIED SCHOOL DISTRICT, a public entity
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                      and answering the Plaintiffs unverified Complaint on file herein admits, denies and alleges as
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                      follows:

                                  1         Under the provisions of California Code of Civil Procedure § 431.30, the
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                      defendant denies each and every allegation of plaintiff's Complaint on file herein, and further
                      denies that plaintiff was damaged in the manner or sums ‘alleged, or in any sums, or at all.
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                                 2        This answering defendant denies that because of any act, omission, recklessness,
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                      carelessness, or negligence on the part of this defendant that the incident/accident described in
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                      the Complaint on file herein occurred, or that the plaintiff was injured or damaged, and denies
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      on

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                                       ANSWER TO COMPLAINT|BY
                                                      DEF ENDANTPASADENA UNIFIED SCHOOL DISTRICT