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  • JOSEFINA MEZA VS VENCO POWER SWEEPING, INC., ET AL Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction) document preview
  • JOSEFINA MEZA VS VENCO POWER SWEEPING, INC., ET AL Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction) document preview
						
                                

Preview

e e LAW OFFICES OF WOLF & O'CONNOR FUELED Marjorie Motooka - SBN: 136678 1LOS ANGELES SUPERIOR COURT 21650 Oxnard Street, Suite 550 JUN 2.6 I Woodland Hills, CA 91367 RECEIVED Telephone:818-887-5353 a Sherri R. Ci tive Officer/Clerk Facsimile: 603-334-7153 JUN 26 2017 sy Deputy NORTH DISTRICT Attorneys for Defendants, VENCO POWER SWEEPING, INC, and IGNACIO GALVAN ESCOBAR SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - LOS ANGELES 10 11 JOSEFINA MEZA, Case No.: MC026318 12 Complaint filed: May 18, 2016 Plaintiff, Dept. A-14 13 Vv. 14 DEFENDANT IGNACIO GALVAN VENCO POWER SWEEPING, INC., IGNACIO ESCOBAR’S ANSWER TO COMPLAINT; 15 GALVAN ESCOBAR and DOES | through 45, DEMAND FOR JURY TRIAL 16 Inclusive, 17 Defendants. TRIAL DATE: July 21, 2017 18 Defendant, IGNACIO GALVAN ESCOBAR, in answer to the unverified Complaint on file herein, 19 and by virtue of the provisions of Code of Civil Procedure section 431.30, now files his general denial 20 to said unverified Complaint and to each cause of action thereof and answering all of the allegations 21 thereof, Defendant denies each and al] of them. Defendant further specifically denies that Plaintiff has 22 been damaged in any sum or sums whatsoever, or at all. 23 Defendant states the following separate affirmative defenses to this action: 24 AFFIRMATIVE DEFENSES 25 1 As to each and every cause of action alleged in the Complaint herein, Defendant is 26 informed and believes and thereon alleges that any and all alleged events, happenings, injuries and Ch 27 damages, if any, were proximately caused or contributed to by the failure of Plaintiff to exercise 5 pi 28 ordinary care at the time and place alleged. cr -1- DEFENDANT IGNACIO GLAVAN ESCOBAR’S ANSWER TO COMPLAINT