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WILLIAM A. BRUCE, ESQ. - SBN 91633
CLIFFORD & BROWN
A Professional Corporation
Attorneys at Law
Bank of America Building
1430 Truxtun Avenue, Suite 900
Bakersfield, CA 93301-5230 {Filing fee exempt
Email: bbruce@clifford-brownlaw.com Gov. Code § 6103)
Tel: (661) 322-6023 Fax: (661) 322-3508
Attorneys for Defendant,
CITY OF BAKERSFIELD
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
10 METRO JUSTICE BUILDING
ll ROK
12 IRENE HELEN CURTIS, an individual, CASE NO. BCV-23-102343-TSC
Complaint filed: 07/20/23
13 Plaintiff, Trial Date: n/a
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VS.
15 CITY OF BAKERSFIELD’S ANSWER TO
COMPLAINT
16 CITY OF BAKERSFIELD;
COUNTY OF KERN;
17 M-STREET NAVIGATION CENTER dba
CAPK COMMUNICATION ACTION
18 PARTNERSHIP OF KERN;
STATE OF CALIFORNIA; and
19 DOES 1 through 100, Inclusive
20 Defendants.
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24 COMES NOW Defendant, CITY OF BAKERSFIELD, appearing for itself alone and no other,
25 and in answer to Plaintiff’s Complaint on file herein, admits, denies, and alleges as follows:
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CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT
I
Answering each and every allegation contained in Plaintiff's Complaint, this answering
Defendant denies each and every, all and singular, generally and specifically, the allegations therein
contained and further denies that Plaintiffs were damaged in the sums therein alleged or in any sum
whatsoever or at all.
Il.
FOR A FIRST, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE to each and every
cause of action herein, this answering Defendant alleges that Plaintiff’s Complaint and each alleged
cause of action therein fails to state facts sufficient to constitute a cause of action against this
10 answering Defendant so as to bar recovery herein.
ll il.
12 FOR A FURTHER, SEPARATE AND SECOND AFFIRMATIVE DEFENSE to each and
13 every cause of action herein, this answering Defendant alleges that Plaintiff was careless, reckless and
14 negligent in and about the matters and things alleged in the Complaint which caused or contributed to
15 Plaintiff's damages, if any, so as to bar or reduce recovery herein.
16 IV.
17 FOR A FURTHER, SEPARATE AND THIRD AFFIRMATIVE DEFENSE to each and every
18 cause of action herein, this answering Defendant alleges that the Court may be called upon to
19 apportion liability, if any, for the subject accident on a comparative fault basis and this Defendant may
20 seek contribution and/or indemnity from such other persons as may have been contributive to the
21 matters herein.
22 Vv
23 FOR A FURTHER, SEPARATE AND FOURTH AFFIRMATIVE DEFENSE to each and
24 every cause of action herein, this answering Defendant alleges that the claims asserted herein are
25 subject to off-set and/or set-off, and the damages, if any, claimed by Plaintiff should be barred or
26 reduced accordingly.
27 VI.
28 FOR A FURTHER, SEPARATE AND FIFTH AFFIRMATIVE DEFENSE to each and every
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CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT
cause of action herein, this answering Defendant alleges that Plaintiff's Complaint, and each alleged
cause of action therein, is barred or reduced by the provisions of Civil Code §§ 1431 and 1431.2, and
each of them.
VII.
FOR A FURTHER SEPARATE AND SIXTH AFFIRMATIVE DEFENSE to each and every
cause of action herein, this answering Defendant alleges that the Complaint was not timely filed as
required by the Government Code and/or Code of Civil Procedure Sections 340, et seq., and is,
therefore, barred.
VII.
10 FOR A FURTHER SEPARATE AND SEVENTH AFFIRMATIVE DEFENSE to each and
11 every cause of action herein, pursuant to California Government Code § 815(b), this answering
12 Defendant affirmatively alleges that its liability is subject to immunity provided by statute, including
13 Part 2 of Division 3.6 of Title 1 of the Government Code (commencing with § 814), and is
14 additionally subject to any defenses and immunities that would be available to this answering
15 Defendant if it were a private person.
16 Ix.
17 FOR A FURTHER SEPARATE AND EIGHTH AFFIRMATIVE DEFENSE to each and
18 every cause of action herein, this answering Defendant alleges that it is immune from liability pursuant
19 to the provisions of Government Code § 818.6 for injuries and damages, if any incurred, and is further
20 immune from liability caused by the plan or design of a public improvement per Government Code §
21 830.6.
22 x.
23 FOR A FURTHER SEPARATE AND NINTH AFFIRMATIVE DEFENSE to each and every
24 cause of action herein, this answering Defendant alleges that it is immune from liability pursuant to the
25 provisions of Government Code §§ $15.2, 818.2, 818.6, 820(b), 820.2, 820.8, 821.4, 830.2, 830.4,
26 830.5, 830.6, 830.8, 831.
27 ///
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CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT
XI.
FOR A FURTHER SEPARATE AND TENTH AFFIRMATIVE DEFENSE TO Each and
every cause of action herein, this answering Defendant alleges that it is immune from liability pursuant
to the provisions of Government Code §§ 835 and 835.2, in that it had no actual or constructive notice
of any allegedly dangerous condition, or if any such notice existed, which is specifically denied, it did
not have sufficient time prior to the alleged injury to take measures to protect against the allegedly
dangerous condition.
XII.
FOR A FURTHER SEPARATE AND ELEVENTH AFFIRMATIVE DEFENSE to each and
10 every cause of action herein, this answering Defendant alleges that it is immune from liability pursuant
11 to Government Code §§ 835.4 and 840.6 in that at all times material to the Complaint, the acts and
12 omissions of its employees and agents, if any, were reasonable.
13 XI.
14 FOR A FURTHER SEPARATE AND TWELFTH AFFIRMATIVE DEFENSE to each and
15 every cause of action herein, this answering Defendant alleges the conditions described in the
16 Complaint and/or which are alleged to have existed at the time of the alleged incident, as a matter of
17 law, were of such a minor, trivial or insignificant nature as to preclude any liability for this answering
18 Defendant as provided by Government Code § 830.2.
19 XIV.
20 FOR A FURTHER SEPARATE AND THIRTEENTH AFFIRMATIVE DEFENSE to each
21 and every cause of action herein, this answering Defendant alleges that if, and to the extent that, the
22 allegations of the Complaint attempt to enlarge upon the facts or contentions set forth in the claim, if
23 any, filed by Plaintiff, then said Complaint fails to state a cause of action and violates the provisions of
24 Government Code, Chapter 1, (commencing with § 900), and Chapter 2, (commencing with § 910),
25 and this answering Defendant hereby reserves its right to strike said allegations and to object to any
26 evidence directed to prove said allegations.
27 XV.
28 FOR A FURTHER, SEPARATE AND FOURTEENTH AFFIRMATIVE DEFENSE to each
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CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT
and every cause of action herein, this answering Defendant alleges that the events, injuries, losses and
damages complained of in the Complaint, if any, were the result of an unavoidable accident insofar as
this answering Defendant is concerned, and occurred without any negligence, want of care, default or
other breach of duty on the part of this answering Defendant.
XVI.
FOR A FURTHER, SEPARATE AND FIFTEENTH AFFIRMATIVE DEFENSE to each and
every cause of action herein, this answering Defendant alleges that Plaintiff, with full knowledge of
the matters and things alleged in the Complaint, and the risk incident thereto, did nevertheless
knowingly and willingly expose herself to said risks, and thereby assumed the risk thereof so as to bar
10 or reduce her recovery herein.
ll XVI.
12 FOR A FURTHER, SEPARATE AND SIXTEENTH AFFIRMATIVE DEFENSE to each and
13 every cause of action herein, this answering Defendant alleges that Plaintiff failed to mitigate her
14 damages so as to bar or reduce her recovery herein.
15 XVII.
16 FOR A FURTHER, SEPARATE AND SEVENTEENTH AFFIRMATIVE DEFENSE to each
17 and every cause of action herein, this answering Defendant alleges that in the event this answering
18 Defendant is found to be liable (which supposition is denied and merely stated for purposes of this
19 affirmative defense), this answering Defendant may elect to have future damages paid, offset or
20 adjusted, in whole or in part, as specified in Government Code § 985.
21 XIX.
22 FOR A FURTHER, SEPARATE AND EIGHTEENTH AFFIRMATIVE DEFENSE to each
23 and every cause of action herein, this answering Defendant presently has insufficient knowledge or
24 information on which to form a belief as to whether additional, as yet unstated affirmative defenses
25 may be appropriate. This answering Defendant reserves herein the right to assert additional
26 affirmative defenses as necessary based upon investigation and discovery.
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CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT
XX.
FOR A FURTHER, SEPARATE AND NINETEENTH AFFIRMATIVE DEFENSE to each
and every cause of action herein, this answering Defendant denies that it owned, controlled, or
maintained the premises described in Plaintiffs Complaint.
PRAYER
WHEREFORE, Defendant prays judgment that Plaintiff take nothing by reason of the
Complaint on file herein, for costs of suit incurred herein and for such other and further relief as the
court deems just and proper.
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12 DATED: September 15, 2023 CLIFFORD & BRO
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14 By Ju A
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WILLIAM A . BRUCE, ESQ.
Attorneys for Defendant,
16 CITY OF BAKERSFIELD
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CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT
PROOF OF SERVICE
STATE OF CALIFORNIA COUNTY OF KERN:
Iam a resident of the County aforesaid; I am over the age of eighteen years and not a party to
the within entitled action; my business address is 1430 Truxtun Avenue, Suite 900, Bakersfield,
California, 93301. My electronic address is: afeltus@clifford-brownlaw.com.
On September 15, 2023, I served the within CITY OF BAKERSFIELD’S
ANSWER TO COMPLAINT on the interested party in said action, as listed below:
[SEE ATTACHED MAILING LIST]
(xx) ELECTRONIC TRANSMISSION [CCP § 1010.6]. Only by e-mailing the document(s) to the
person(s) at the e-mail address(es) listed below, this office will not send physical mail as usual,
and is therefore using only electronic mail. No electronic message or other indication that the
transmission was unsuccessful was received within a reasonable time after the transmission.
10
OVERNIGHT DELIVERY. I enclosed the documents in an envelope or package provided by
11
an overnight delivery carrier and addressed to the person(s) at the address(es) stated below. I
12 placed the envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of the overnight delivery carrier.
13
14
C) U.S. MAIL. I enclosed the documents in a sealed envelope or package addressed to the
person(s) at the address(es) stated below by placing the envelope for collection and mailing,
15 following our ordinary business practices. I am readily familiar with this business's practice for
collecting and processing documents for mailing. On the same day that the document is placed
16 for collection and mailing, it is deposited in the ordinary course of business with the United
States Postal Service, in a sealed envelope with postage fully prepaid.
17
PERSONAL/MESSENGER SERVICE. I served the documents by placing them in an
18 envelope or package addressed to the person(s) at the address(es) listed below and providing
19 them to a professional messenger service for service.
20 I declare, under penalty of perjury under the laws of the State of California, that the foregoing
is true and correct.
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Executed on September 15, 2023, at “OL D-2
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ARIEL FELTUS
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MAILING LIST
Irene Helen Curtis v. City of Bakersfield; et al.
Superior Court of California, County of Kern, Case No. BCV-23-102343-TSC
Raymond Ghermezian, Esq. Attorneys for Plaintiff, Irene H. Curtis
RAYMOND GHERMEZIAN,
A PROFESSIONAL LAW CORPORATION
8383 Wilshire Boulevard, Suite 1030
Beverly Hills, CA 90211
Telephone: (323) 900-5800
Facsimile: (323) 900-5801
Email: raymond@ghermezianlaw.com
rberry@ghermezianlaw.com
10 Stephanie Virrey Gutcher, Esq. Attorneys for Defendant, County of Kern
Kyle Holmes, Esq.
11 County Counsel, County of Kern
1115 Truxtun Ave. 4th Floor
12 Bakersfield, CA 93301
Direct Line: (661) 868-3813
13 Fax: (661) 868-3805
Email: kholmes@kerncounty.com
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WILLIAM A. BRUCE, ESQ. - SBN 91633 CLIFFORD & BROWN A Professional Corporation Attorneys at Law Bank of America Building 1430 Truxtun Avenue, Suite 900 Bakersfield, CA 93301-5230 {Filing fee exempt Email: bbruce@clifford-brownlaw.com Gov. Code § 6103) Tel: (661) 322-6023 Fax: (661) 322-3508 Attorneys for Defendant, CITY OF BAKERSFIELD SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN 10 METRO JUSTICE BUILDING ll ROK 12 IRENE HELEN CURTIS, an individual, CASE NO. BCV-23-102343-TSC Complaint filed: 07/20/23 13 Plaintiff, Trial Date: n/a 14 VS. 15 CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT 16 CITY OF BAKERSFIELD; COUNTY OF KERN; 17 M-STREET NAVIGATION CENTER dba CAPK COMMUNICATION ACTION 18 PARTNERSHIP OF KERN; STATE OF CALIFORNIA; and 19 DOES 1 through 100, Inclusive 20 Defendants. 21 22 23 24 COMES NOW Defendant, CITY OF BAKERSFIELD, appearing for itself alone and no other, 25 and in answer to Plaintiff’s Complaint on file herein, admits, denies, and alleges as follows: 26 /11 27 /// 28 1 1 CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT I Answering each and every allegation contained in Plaintiff's Complaint, this answering Defendant denies each and every, all and singular, generally and specifically, the allegations therein contained and further denies that Plaintiffs were damaged in the sums therein alleged or in any sum whatsoever or at all. Il. FOR A FIRST, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE to each and every cause of action herein, this answering Defendant alleges that Plaintiff’s Complaint and each alleged cause of action therein fails to state facts sufficient to constitute a cause of action against this 10 answering Defendant so as to bar recovery herein. ll il. 12 FOR A FURTHER, SEPARATE AND SECOND AFFIRMATIVE DEFENSE to each and 13 every cause of action herein, this answering Defendant alleges that Plaintiff was careless, reckless and 14 negligent in and about the matters and things alleged in the Complaint which caused or contributed to 15 Plaintiff's damages, if any, so as to bar or reduce recovery herein. 16 IV. 17 FOR A FURTHER, SEPARATE AND THIRD AFFIRMATIVE DEFENSE to each and every 18 cause of action herein, this answering Defendant alleges that the Court may be called upon to 19 apportion liability, if any, for the subject accident on a comparative fault basis and this Defendant may 20 seek contribution and/or indemnity from such other persons as may have been contributive to the 21 matters herein. 22 Vv 23 FOR A FURTHER, SEPARATE AND FOURTH AFFIRMATIVE DEFENSE to each and 24 every cause of action herein, this answering Defendant alleges that the claims asserted herein are 25 subject to off-set and/or set-off, and the damages, if any, claimed by Plaintiff should be barred or 26 reduced accordingly. 27 VI. 28 FOR A FURTHER, SEPARATE AND FIFTH AFFIRMATIVE DEFENSE to each and every 2 CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT cause of action herein, this answering Defendant alleges that Plaintiff's Complaint, and each alleged cause of action therein, is barred or reduced by the provisions of Civil Code §§ 1431 and 1431.2, and each of them. VII. FOR A FURTHER SEPARATE AND SIXTH AFFIRMATIVE DEFENSE to each and every cause of action herein, this answering Defendant alleges that the Complaint was not timely filed as required by the Government Code and/or Code of Civil Procedure Sections 340, et seq., and is, therefore, barred. VII. 10 FOR A FURTHER SEPARATE AND SEVENTH AFFIRMATIVE DEFENSE to each and 11 every cause of action herein, pursuant to California Government Code § 815(b), this answering 12 Defendant affirmatively alleges that its liability is subject to immunity provided by statute, including 13 Part 2 of Division 3.6 of Title 1 of the Government Code (commencing with § 814), and is 14 additionally subject to any defenses and immunities that would be available to this answering 15 Defendant if it were a private person. 16 Ix. 17 FOR A FURTHER SEPARATE AND EIGHTH AFFIRMATIVE DEFENSE to each and 18 every cause of action herein, this answering Defendant alleges that it is immune from liability pursuant 19 to the provisions of Government Code § 818.6 for injuries and damages, if any incurred, and is further 20 immune from liability caused by the plan or design of a public improvement per Government Code § 21 830.6. 22 x. 23 FOR A FURTHER SEPARATE AND NINTH AFFIRMATIVE DEFENSE to each and every 24 cause of action herein, this answering Defendant alleges that it is immune from liability pursuant to the 25 provisions of Government Code §§ $15.2, 818.2, 818.6, 820(b), 820.2, 820.8, 821.4, 830.2, 830.4, 26 830.5, 830.6, 830.8, 831. 27 /// 28 //1 3 CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT XI. FOR A FURTHER SEPARATE AND TENTH AFFIRMATIVE DEFENSE TO Each and every cause of action herein, this answering Defendant alleges that it is immune from liability pursuant to the provisions of Government Code §§ 835 and 835.2, in that it had no actual or constructive notice of any allegedly dangerous condition, or if any such notice existed, which is specifically denied, it did not have sufficient time prior to the alleged injury to take measures to protect against the allegedly dangerous condition. XII. FOR A FURTHER SEPARATE AND ELEVENTH AFFIRMATIVE DEFENSE to each and 10 every cause of action herein, this answering Defendant alleges that it is immune from liability pursuant 11 to Government Code §§ 835.4 and 840.6 in that at all times material to the Complaint, the acts and 12 omissions of its employees and agents, if any, were reasonable. 13 XI. 14 FOR A FURTHER SEPARATE AND TWELFTH AFFIRMATIVE DEFENSE to each and 15 every cause of action herein, this answering Defendant alleges the conditions described in the 16 Complaint and/or which are alleged to have existed at the time of the alleged incident, as a matter of 17 law, were of such a minor, trivial or insignificant nature as to preclude any liability for this answering 18 Defendant as provided by Government Code § 830.2. 19 XIV. 20 FOR A FURTHER SEPARATE AND THIRTEENTH AFFIRMATIVE DEFENSE to each 21 and every cause of action herein, this answering Defendant alleges that if, and to the extent that, the 22 allegations of the Complaint attempt to enlarge upon the facts or contentions set forth in the claim, if 23 any, filed by Plaintiff, then said Complaint fails to state a cause of action and violates the provisions of 24 Government Code, Chapter 1, (commencing with § 900), and Chapter 2, (commencing with § 910), 25 and this answering Defendant hereby reserves its right to strike said allegations and to object to any 26 evidence directed to prove said allegations. 27 XV. 28 FOR A FURTHER, SEPARATE AND FOURTEENTH AFFIRMATIVE DEFENSE to each 4 CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT and every cause of action herein, this answering Defendant alleges that the events, injuries, losses and damages complained of in the Complaint, if any, were the result of an unavoidable accident insofar as this answering Defendant is concerned, and occurred without any negligence, want of care, default or other breach of duty on the part of this answering Defendant. XVI. FOR A FURTHER, SEPARATE AND FIFTEENTH AFFIRMATIVE DEFENSE to each and every cause of action herein, this answering Defendant alleges that Plaintiff, with full knowledge of the matters and things alleged in the Complaint, and the risk incident thereto, did nevertheless knowingly and willingly expose herself to said risks, and thereby assumed the risk thereof so as to bar 10 or reduce her recovery herein. ll XVI. 12 FOR A FURTHER, SEPARATE AND SIXTEENTH AFFIRMATIVE DEFENSE to each and 13 every cause of action herein, this answering Defendant alleges that Plaintiff failed to mitigate her 14 damages so as to bar or reduce her recovery herein. 15 XVII. 16 FOR A FURTHER, SEPARATE AND SEVENTEENTH AFFIRMATIVE DEFENSE to each 17 and every cause of action herein, this answering Defendant alleges that in the event this answering 18 Defendant is found to be liable (which supposition is denied and merely stated for purposes of this 19 affirmative defense), this answering Defendant may elect to have future damages paid, offset or 20 adjusted, in whole or in part, as specified in Government Code § 985. 21 XIX. 22 FOR A FURTHER, SEPARATE AND EIGHTEENTH AFFIRMATIVE DEFENSE to each 23 and every cause of action herein, this answering Defendant presently has insufficient knowledge or 24 information on which to form a belief as to whether additional, as yet unstated affirmative defenses 25 may be appropriate. This answering Defendant reserves herein the right to assert additional 26 affirmative defenses as necessary based upon investigation and discovery. 27 //1 28 /// 5 CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT XX. FOR A FURTHER, SEPARATE AND NINETEENTH AFFIRMATIVE DEFENSE to each and every cause of action herein, this answering Defendant denies that it owned, controlled, or maintained the premises described in Plaintiffs Complaint. PRAYER WHEREFORE, Defendant prays judgment that Plaintiff take nothing by reason of the Complaint on file herein, for costs of suit incurred herein and for such other and further relief as the court deems just and proper. 10 11 12 DATED: September 15, 2023 CLIFFORD & BRO 13 14 By Ju A 15 WILLIAM A . BRUCE, ESQ. Attorneys for Defendant, 16 CITY OF BAKERSFIELD 17 18 19 20 21 22 23 24 25 26 27 28 6 CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT PROOF OF SERVICE STATE OF CALIFORNIA COUNTY OF KERN: Iam a resident of the County aforesaid; I am over the age of eighteen years and not a party to the within entitled action; my business address is 1430 Truxtun Avenue, Suite 900, Bakersfield, California, 93301. My electronic address is: afeltus@clifford-brownlaw.com. On September 15, 2023, I served the within CITY OF BAKERSFIELD’S ANSWER TO COMPLAINT on the interested party in said action, as listed below: [SEE ATTACHED MAILING LIST] (xx) ELECTRONIC TRANSMISSION [CCP § 1010.6]. Only by e-mailing the document(s) to the person(s) at the e-mail address(es) listed below, this office will not send physical mail as usual, and is therefore using only electronic mail. No electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. 10 OVERNIGHT DELIVERY. I enclosed the documents in an envelope or package provided by 11 an overnight delivery carrier and addressed to the person(s) at the address(es) stated below. I 12 placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. 13 14 C) U.S. MAIL. I enclosed the documents in a sealed envelope or package addressed to the person(s) at the address(es) stated below by placing the envelope for collection and mailing, 15 following our ordinary business practices. I am readily familiar with this business's practice for collecting and processing documents for mailing. On the same day that the document is placed 16 for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. 17 PERSONAL/MESSENGER SERVICE. I served the documents by placing them in an 18 envelope or package addressed to the person(s) at the address(es) listed below and providing 19 them to a professional messenger service for service. 20 I declare, under penalty of perjury under the laws of the State of California, that the foregoing is true and correct. 21 Executed on September 15, 2023, at “OL D-2 22 23 ARIEL FELTUS 24 25 26 27 28 MAILING LIST Irene Helen Curtis v. City of Bakersfield; et al. Superior Court of California, County of Kern, Case No. BCV-23-102343-TSC Raymond Ghermezian, Esq. Attorneys for Plaintiff, Irene H. Curtis RAYMOND GHERMEZIAN, A PROFESSIONAL LAW CORPORATION 8383 Wilshire Boulevard, Suite 1030 Beverly Hills, CA 90211 Telephone: (323) 900-5800 Facsimile: (323) 900-5801 Email: raymond@ghermezianlaw.com rberry@ghermezianlaw.com 10 Stephanie Virrey Gutcher, Esq. Attorneys for Defendant, County of Kern Kyle Holmes, Esq. 11 County Counsel, County of Kern 1115 Truxtun Ave. 4th Floor 12 Bakersfield, CA 93301 Direct Line: (661) 868-3813 13 Fax: (661) 868-3805 Email: kholmes@kerncounty.com 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28