Complaint,Petition: KENNETH BARON VS PARDEE HOMES INC

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     LAW OFFICES OF ISAAC
     2600 West      live Avenue 5! Floor   t OVEG                                                  FILED
                                                                                           Sup crior Court of California
       urbank, California        5                                                             ounty of Los Angeles!
     Telephone     No.: 818 333-5202
     Facsimile No.:      818 333-5203                                                             NOV I 4 2016
       mail: isaactoveg     aol.com
     Attorney for: Plaintiff Kenneth Baron                                                       Carter,Executive Offiqer/Clerk
                                                                                     By.   Teal
                                                                                    Sh arti.
                                                                                                            Nr |
                                                                                                   Raul Sanchez
                                                                                                                       | Deputy

                     SUPERIOR COURT OF THE STATE OF CALIFORNIA,
                   _COUNTY OF LOS ANGELES, CENTRAL DISTRICT


     KENNETH BARON
                                                           Case No. BC 568233
                      Plaintiff,
10                                                         PLAINTIFFS RESPONSE IN
            vs.                                            OPPOSITION TO DEFENDANT
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      DOES 1 AND DOES 2-50,                                                                        URRE
                                                           TO PLAINTIFE’S            ND.
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              Defendants.                                     ENDED COMPLAINT FOR THE
                                                           SECOND. THIR D,FOURTH, F
                                                           AND SIXTH C. ‘A uU SES OF
                                                                                         9
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14                                                     )   MEMORANDUM OF POINTS AND
                                                           AUTHORITIES[concurrently filed with
15                                                         declaration of Isaac Toveg, Proposed
                                                             rder,]
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                                                           DATE: NOVEMBER 28, 2016
17                                                         Time
                                                              ept :
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                       Plaintiff Kenneth Baron (‘Plaintiff’) herein submits his opposition to
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     Defendant Pardee Homes (“Defendant”) Demurrer to Plaintiff's Second Amended                     Complaint
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     (“SAC”) namely the Second, Third, Fourth, Fifth and Sixth causes of action on the ground
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23   that Plaintiffs have failed to set forth facts sufficient to set forth a cause of action and that these

oa   causes of actions are uncertain, ambiguous, and unintelligible . To the contrary, for the reasons
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     set forth below, the Second, Third, Fourth, fifth and sixth causes of action set forth in the
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     SAC are properly plead and Defendants’ demurrer should be overruled in its entirety and have

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     Defendant file an answer to the Complaint within ten days.
     rr
     PLAINTIFF BARON'S OPPOSITION TO DEFENDANT PARDEE DEMURRER OF PLAINTIFF'S SAC..                         1