On June 02, 2021 a
Answer
was filed
involving a dispute between
Doe, Jane Bns,
and
Barstow Unified School District,
Doe 1,
Does 2 To 100,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
V ORIGINAL
L
SUPERIOR COURT 0F CALIFORNIA
\
COUNTY 0F SAN BERNARDINO
RYAN D. MILLER (SBN 256799) SAN BERNARDINO DISTRICT
CUMMINGS, MCCLOREY, DAVIS, ACHo & ASSOCIATES, P.C.
3801 University Avenue, Suite 560 DEC 1 6 2021
Riverside, CA 92501
(951) 276-4420
(95 1) 276—4405 fax
By 6k Ig’éE
‘ SI (“a
ANGEL ARCIA. Deputy
©00\l0\Ul#WNi—I EXEMPT PER GOV. CODE § 6103
Attorneys for Defendant
Barstow Unified School District
FAX SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
BY
JANE BNs DOE, AN INDIVIDUAL, ) Case No.: C1V332115713
)
Plaintiff, )
) DEFENDANT BARSTOW UNIFIED
v. SCHOOL DISTRICTS ANSWER T0
g
)
PLAINTIFF’S COMPLAINT; DEMAND
DOE 1, A California local public entity and )
FOR JURY TRIAL
DOES 2 to 100.
g
)
Defendants. )
NNNNNNNNp—dr—I—‘p—It—Ib—tt‘p—tt—dw )
)
)
\IQMLWNr—IOOOOVONUI#WNr—Io
)
COMES NOW, Defendant BARSTOW UNIFIED SCHOOL_pISTRICT (hereinafter
“Defendant”) and answers Plaintiff s Complaint as follows:
1. Pursuant to Sections 43 l .30 and 446(a) ofthe California Codelof Civil Procedure,
defendant denies each and every material allegation contained in the complaint, and further
specifically deny that plaintiffhas been damaged in the sum or sums alleged, or in any other sum
0r sums or at all, by any action or omission on the part of defendant.
AFFIRMATIVE DEFENSES
2. FOR AND AS A FIRST, SEPARATE, AND AFFIRMATIVE DEFENSE,
Defendant alleges at all times mentioned in the complaint, any injury, damages, 0r loss, if any,
28
allegedly suffered by plaintiff was directly an? proximately caused and contributed to by the
Cummings. McClorey,
Davis, Acho
& Associates, P.C.
380| Universi‘y Avenue, DEFENDANT BARSTOW UNIFIED SCHOOL DISTRICT’S ANSWER TO PLAINTIFF’S
Suile 560
Riverside, CA 92501 COMPLAINT; DEMAND FOR JURY TRIAL
Telephone (95 1) 276-4420
Facsimile (95 1) 2764405
Document Filed Date
December 16, 2021
Case Filing Date
June 02, 2021
Category
Other PI/PD/WD Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
V ORIGINAL L SUPERIOR COURT 0F CALIFORNIA \ COUNTY 0F SAN BERNARDINO RYAN D. MILLER (SBN 256799) SAN BERNARDINO DISTRICT CUMMINGS, MCCLOREY, DAVIS, ACHo & ASSOCIATES, P.C. 3801 University Avenue, Suite 560 DEC 1 6 2021 Riverside, CA 92501 (951) 276-4420 (95 1) 276—4405 fax By 6k Ig’éE ‘ SI (“a ANGEL ARCIA. Deputy ©00\l0\Ul#WNi—I EXEMPT PER GOV. CODE § 6103 Attorneys for Defendant Barstow Unified School District FAX SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO BY JANE BNs DOE, AN INDIVIDUAL, ) Case No.: C1V332115713 ) Plaintiff, ) ) DEFENDANT BARSTOW UNIFIED v. SCHOOL DISTRICTS ANSWER T0 g ) PLAINTIFF’S COMPLAINT; DEMAND DOE 1, A California local public entity and ) FOR JURY TRIAL DOES 2 to 100. g ) Defendants. ) NNNNNNNNp—dr—I—‘p—It—Ib—tt‘p—tt—dw ) ) ) \IQMLWNr—IOOOOVONUI#WNr—Io ) COMES NOW, Defendant BARSTOW UNIFIED SCHOOL_pISTRICT (hereinafter “Defendant”) and answers Plaintiff s Complaint as follows: 1. Pursuant to Sections 43 l .30 and 446(a) ofthe California Codelof Civil Procedure, defendant denies each and every material allegation contained in the complaint, and further specifically deny that plaintiffhas been damaged in the sum or sums alleged, or in any other sum 0r sums or at all, by any action or omission on the part of defendant. AFFIRMATIVE DEFENSES 2. FOR AND AS A FIRST, SEPARATE, AND AFFIRMATIVE DEFENSE, Defendant alleges at all times mentioned in the complaint, any injury, damages, 0r loss, if any, 28 allegedly suffered by plaintiff was directly an? proximately caused and contributed to by the Cummings. McClorey, Davis, Acho & Associates, P.C. 380| Universi‘y Avenue, DEFENDANT BARSTOW UNIFIED SCHOOL DISTRICT’S ANSWER TO PLAINTIFF’S Suile 560 Riverside, CA 92501 COMPLAINT; DEMAND FOR JURY TRIAL Telephone (95 1) 276-4420 Facsimile (95 1) 2764405