On April 27, 2022 a
Answer
was filed
involving a dispute between
Gutierrez, Elsa Eloisa,
and
Does 1 To 50,
Food 4 Less Of California, Inc,
Food 4 Less Of Southern California, Inc.,
The Kroger Co.,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
\I
I .
V
F E." ,7”
SUPERIOR CO. R -'C‘.".'
‘
JAMES J. RIJ ESQ. (SBN: 94347) COU'STY 3F gAg gégmgfiggm
“A“ “ERNARWO “'STR'CT
LIEBMAN, QUIGLEY & SHEPPARD
A Professional Law Corporation SEP 1 5 2022
401 West A Street, Suite 1150
Sail Diego, CA 92101-7920 ~
Te: 619 ) 232-0777/F ax ( 619 ) 238—5442 - .
( :
BY \hlwn ‘
EQJM
DAisvazLON. DEPUW
Attorneys for Defendants, FOOD 4 LESS OF CALIFORNIA, INC. d.b.a. FOOD 4 LESS, erroneously
\DOOQQUIAUJNt—n
sued and served as “FOOD 4 LESS OF SOUTHERN CALIFORNIA, INC.;” and THE KROGER CO.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
ELSA ELOISA GUTIERREZ, Case No.: CIVSB 2209748
I/c Judge: JANET M. FRANGLE
Plaintiff, Dept: 529
v. ANSWER BY FOOD 4 LESS 0F
CALIFORNIA, INC. d.b.a. FOOD 4
FOOD 4 LESS OF SOUTHERN LESS T0 PLAINTIFF’S
CALIFORNIA, INC.,; THE KROGER CO. and COMPLAINT
DOES 1 THROUGH 50, Inclusive, _
”
“1M4 GED FIL
Defendants.
[TRIAL.- NOTS fificfié
CE
COMES NOW defendant F999 f1 LEss—gfwggggfomm, INC. d.b.a. FOOD 4 LESS,
mqmmgmwwo$5335355:3
erroneously sued and served as “FOOD 4 LESS OF SOUTHERN CALIFORNIA, INC.” (hereinafter
"defendant") for itsélf,” in answering plaintiff s unverified Complaint on file herein, deniwes, and alleges
as follows:
Under the provisions of §43 1 .30(d) ofthe California Code of Civil Procedure, defendant herein
denies generally, specifically, conjunctively, and disjunctively, each and every allegation of each and
every paragaph of each and every cause of action of said Complaint and the Complaint in its entirety,
NNNNNNNMN
and denies that plaintiff has been damaged in any sum or amount whatsoever, or at all.
AFFIRMA TM DEFENSES
AS A FIRST, SEPARA TE AND AFFIRAIA TIVE DEFENSE, this answering defendant is
informed and believes, and thereon alleges:
That the events, injuries, losses, and damages complained ofin plaintiffs Complaint, ifany there
ANSWER BY FOOD 4 LESS OF CALIFORNIA, INC. TO PLAINTIFF’S COMPLAINT
1
RECEWE
SEP 1 5 2022
SUPERIOR COURT
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Document Filed Date
September 15, 2022
Case Filing Date
April 27, 2022
Category
Other PI/PD/WD Unlimited
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\I I . V F E." ,7” SUPERIOR CO. R -'C‘.".' ‘ JAMES J. RIJ ESQ. (SBN: 94347) COU'STY 3F gAg gégmgfiggm “A“ “ERNARWO “'STR'CT LIEBMAN, QUIGLEY & SHEPPARD A Professional Law Corporation SEP 1 5 2022 401 West A Street, Suite 1150 Sail Diego, CA 92101-7920 ~ Te: 619 ) 232-0777/F ax ( 619 ) 238—5442 - . ( : BY \hlwn ‘ EQJM DAisvazLON. DEPUW Attorneys for Defendants, FOOD 4 LESS OF CALIFORNIA, INC. d.b.a. FOOD 4 LESS, erroneously \DOOQQUIAUJNt—n sued and served as “FOOD 4 LESS OF SOUTHERN CALIFORNIA, INC.;” and THE KROGER CO. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO ELSA ELOISA GUTIERREZ, Case No.: CIVSB 2209748 I/c Judge: JANET M. FRANGLE Plaintiff, Dept: 529 v. ANSWER BY FOOD 4 LESS 0F CALIFORNIA, INC. d.b.a. FOOD 4 FOOD 4 LESS OF SOUTHERN LESS T0 PLAINTIFF’S CALIFORNIA, INC.,; THE KROGER CO. and COMPLAINT DOES 1 THROUGH 50, Inclusive, _ ” “1M4 GED FIL Defendants. [TRIAL.- NOTS fificfié CE COMES NOW defendant F999 f1 LEss—gfwggggfomm, INC. d.b.a. FOOD 4 LESS, mqmmgmwwo$5335355:3 erroneously sued and served as “FOOD 4 LESS OF SOUTHERN CALIFORNIA, INC.” (hereinafter "defendant") for itsélf,” in answering plaintiff s unverified Complaint on file herein, deniwes, and alleges as follows: Under the provisions of §43 1 .30(d) ofthe California Code of Civil Procedure, defendant herein denies generally, specifically, conjunctively, and disjunctively, each and every allegation of each and every paragaph of each and every cause of action of said Complaint and the Complaint in its entirety, NNNNNNNMN and denies that plaintiff has been damaged in any sum or amount whatsoever, or at all. AFFIRMA TM DEFENSES AS A FIRST, SEPARA TE AND AFFIRAIA TIVE DEFENSE, this answering defendant is informed and believes, and thereon alleges: That the events, injuries, losses, and damages complained ofin plaintiffs Complaint, ifany there ANSWER BY FOOD 4 LESS OF CALIFORNIA, INC. TO PLAINTIFF’S COMPLAINT 1 RECEWE SEP 1 5 2022 SUPERIOR COURT COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT