Answer: MURRAY VS SIMPLIFIED STAFFING Print

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           ILL FARRER       BURRILL LLP                                           s
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    r1    ClaytonJ Hix BarNo 236718
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                                                                                                        r F A FoaNiA
                                                                                             C FS NANBE Nf pf INt
          Casey L Morris Bar No 238455                                                  PFRtva           r   e r   iv

     2   Elissa L Gysi    Bar No 281338
         One California Plaza 37th Floor                                                         EP 2        Z
     3   300 South Grand Avenue
         Los Angeles CA 90071 3147
    4    Telephone   213 620 0460                                                                r

         Fax    213    624 4840                                                                 k RK wARtvER DEPU f
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         Attorneys for Defendant SIMPLIFIED
    6    STAFFING LABOR SOLUTIONS LLC

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                           SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                        COLJNTY OF SAN BERNARDINO


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         ABRAHAM MUR RAY                                                     CASE NO       CIVDS 1907075
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                            Plaintiff                                        ANSVVER TO FIRST AMENDED

12                                                                           COMPLAINT
                vs

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         SIMPLIFIED STAFFING LABOR
14        OLUTIONS   ONTARIO
         SIMPLIFIED STAFFING LABOR
1S       SOLUTIONS LLC and llOES 1 to 20

1                           Defendants


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                NOW COMES defendant Simplified Sta ffing Labor Solutions LLC                                       Defendant or
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          Simplified    for itself and no other defendants and for its Answer to Plaintiff s unverified First

         Amended Complaint      FAC     al1eges as follows
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21              Pursuant to 431 30 d of the Calif rnia Code of Civil Pmcedure Defen dant gsnerally

2        denies each and every allegation contair ed in Plaintiff s FAC and denies that Plaintiffsustained

G        damages by reason of any act breach or omission of Defendant
                Furthermore as to each of the causes of action alleged in the FAC Defend nt aileges the
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    5    tallowing affirrnative defenses however Def ndant has not had a reasonable opportunity to

26       invest gate a l of the claims and allegations set forth in the FAC and Defendant hereby reserves

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2b                          ANSWER OF SIMPLIFIED STAFFING LABOR SOLUTIONS LLC
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    1       the right to waive any affirmative d fenses asserted in this Ans ver or to assert additional
            a ffirmative defenses as the facts become known
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                                            FIRST A FIRMATIVE DEFENSE

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                     The FAC and each of the causes of action alleged therein fails io state facts sufficient to

            constitute a cause of action against Defendant

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                                          SECOND AFFIRMATIVE DEFENSE


                     The FAC and each of the causes of action alleged thereir fails to state facts sufficient to
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            constitute a cause of action against Defendant because Defendant was not Plaintiff s employer
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                                           THIRD AFFIRMA I IVE D FENSE

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                     The FAC   and each purported cause of actior                                                     of


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            laches and acquiescence

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                                          FOURTH AFFIRIVIATIVE DEFENSE


IS                   The FAC is barred in whole crr in part by the equitable pririciple of unclean hands

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                                            FIFTH AFFIRMATIVE DEFENSE

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                     The FAC and all causes of action allege therein against L efendant are bat7 ed by the
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            conduct actions and inactions of I lair tiff which constitute an estoppel ga inst any reli fsought

            herein

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                                           SIXTH AFF RMATIVE DEFEN
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                     The FAC is barred   by Pla   ntifT s ovir conduct   actior s   rd inactions which constitute a


    3       waiver of any right or claim Plaintiffmay or mi ght have had in reference torth mattars and things

            alleged in the FAC
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    S


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    R                            ANSWER OF SIMPLIFIED STAFFING LABOK SOLUTIONS Lt 0