Preview
THOMAS S. GELINI (SBN: 154314)
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JENNIFER A. KUNG GELINI (SBN: 169364)
2 BENNETT, GELINI & GELINI
A Professional Corporation
3 1301 Marina Village Parkway, Suite 300
Alameda, CA 94501-1084
4 Telephone: 510-444-7688
Facsimile: 510-444-5849
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Email: tgelini@bsralaw.com
6 jgelini@bsralaw.com
7 Attorneys for Defendant and Cross-Complainant
Judith H. Wood
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9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SANTA BARBARA
11 UNLIMITED CIVIL JURISDICTION
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KIMBERLY M. JONES, an individual; CASE NO. 23CV00522
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Plaintiff, DEFENDANT JUDITH H. WOOD’S
14 ANSWER TO PLAINTIFF KIMBERLY M.
vs. JONES’ THIRD AMENDED COMPLAINT
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16 LEFT COAST INSPECTIONS LLC, a Complaint Filed: February 7, 2023
California Limited Liability Company; WOOD SAC Filed: August 9, 2023
17 ENVIRONMENTAL SERVICES, LLC, a Trial Date: Not yet set
California Limited Liability Company;
18 JUDITH H. WOOD, an individual; and DOES
1 - 15.
19
20 Defendants.
21 AND RELATED CROSS ACTIONS
22
23 COMES NOW DEFENDANT JUDITH H. WOOD, and answers Plaintiff’s Third Amended
24 Complaint on file herein as follows:
25 This answering defendant denies each and every, all and singular, generally and
26 specifically, the allegations contained in the Third Amended Complaint, and in each cause of
27 action thereof, and each and every part thereof, and in this connection, this defendant denies
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DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED
COMPLAINT
1 that plaintiff has been injured or damaged in the unspecified sum or sums alleged in the Third
2 Amended Complaint, or in any other sum, or sums, or otherwise, or at all.
3 AFFIRMATIVE DEFENSES
4 FIRST AFFIRMATIVE DEFENSE
5 Defendant alleges that plaintiff and others were negligent in and about the matters
6 referred to in said Third Amended Complaint, and that such negligence bars and/or diminishes
7 plaintiff’s right to recovery against this answering defendant. Should plaintiff recover damages
8 against any defendant, said defendant or defendant are entitled to have the amount abated,
9 reduced, or eliminated to the extent plaintiff’s negligence caused or contributed to their
10 damages, if any there were.
11 SECOND AFFIRMATIVE DEFENSE
12 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD
13 AMENDED COMPLAINT (and each and every cause of action thereof), this Defendant alleges
14 that plaintiff voluntarily and knowingly entered into and engaged in operations and conduct
15 alleged in said Third Amended Complaint and voluntarily and knowingly assumed all of the risks
16 incident to said operations, acts, and conduct at the time and place mentioned in said Third
17 Amended Complaint.
18 THIRD AFFIRMATIVE DEFENSE
19 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
20 COMPLAINT (and each and every cause of action thereof), this Defendant alleges that plaintiff’s
21 Third Amended Complaint fails to state facts sufficient to constitute a cause of action against
22 this answering defendant.
23 FOURTH AFFIRMATIVE DEFENSE
24 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
25 COMPLAINT (and each and every cause of action thereof), this Defendant alleges that plaintiff
26 has not adequately mitigated their damages, if any there were.
27 ///
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DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED
COMPLAINT
1 FIFTH AFFIRMATIVE DEFENSE
2 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
3 COMPLAINT (and each and every cause of action thereof), this Defendant alleges, upon
4 information and belief, that the damages allegedly sustained by plaintiff was either wholly or in
5 part negligently, carelessly, willfully, or otherwise wrongfully caused by persons, firms,
6 corporations or public entities other than this answering defendant, and that this defendant shall
7 only be liable, if at all, in accordance with the provisions of Civil Code §§1431-1431.5.
8 SIXTH AFFIRMATIVE DEFENSE
9 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
10 COMPLAINT (and each and every cause of action thereof), this Defendant alleges, upon
11 information and belief, that the damages allegedly sustained by plaintiff was either wholly or in
12 part negligently, carelessly, willfully or otherwise wrongfully caused by persons, firms,
13 corporations, or public entities other than this answering defendant, and that said negligence,
14 carelessness, willful misconduct, or other wrongful acts comparatively reduce the percentage
15 of liability, if any, of this answering defendant.
16 SEVENTH AFFIRMATIVE DEFENSE
17 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
18 COMPLAINT (and each and every cause of action thereof), the plaintiff is barred from any
19 recovery, because of plaintiff’s lack of notice, in whole or in part to this answering defendant.
20 EIGHTH AFFIRMATIVE DEFENSE
21 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
22 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges
23 that plaintiff acted unreasonably in the possession, management, maintenance operation,
24 inspection, control, protection and care of the subject residence.
25 ///
26 ///
27 ///
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DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED
COMPLAINT
1 NINTH AFFIRMATIVE DEFENSE
2 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
3 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges
4 on information and belief that the Third Amended Complaint is barred by the doctrine of unclean
5 hands.
6 TENTH AFFIRMATIVE DEFENSE
7 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
8 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges
9 on information and belief that the Third Amended Complaint is barred and the relief requested
10 by the plaintiff is barred by virtue of the fact that the plaintiff themselves failed to do equity in
11 connection with the facts and circumstances alleged in the Third Amended Complaint.
12 ELEVENTH AFFIRMATIVE DEFENSE
13 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
14 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges
15 on information and belief that the Third Amended Complaint is barred by the doctrine of laches.
16 TWELFTH AFFIRMATIVE DEFENSE
17 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
18 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges
19 on information and belief that by reason of the acts and omissions of the plaintiff, the plaintiff
20 has waived the right to pursue this action and any entitlements to any recovery, for any breach
21 of any contract or any duty, or for any other cause.
22 THIRTEENTH AFFIRMATIVE DEFENSE
23 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED
24 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges
25 on information and belief, that by reason of the acts and omissions of the plaintiff, she has
26 estopped from pursuing this action and estopped from any entitlement to recovery, if any.
27 ///
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DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED
COMPLAINT
1 FOURTEENTH AFFIRMATIVE DEFENSE
2 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD
3 AMENDED COMPLAINT (and each and every cause of action thereof) this answering
4 Defendant alleges that neither plaintiff’s Third Amended Complaint nor any of the alleged
5 causes of action therein state facts sufficient to constitute a cause of action for punitive
6 damages against this answering defendant.
7 FIFTEENTH AFFIRMATIVE DEFENSE
8 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD
9 AMENDED COMPLAINT (and each and every cause of action thereof), this answering
10 Defendant alleges that certain of plaintiff’s claims in this matter have been settled and
11 compromised, as confirmed by releases.
12 SIXTEENTH AFFIRMATIVE DEFENSE
13 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD
14 AMENDED COMPLAINT (and each and every cause of action thereof), this answering
15 Defendant alleges that plaintiff’s claims are barred by all applicable statutes of limitation,
16 including, but not limited to, CCP sections 335.1, 337, 337.2, 338, 339, 339.5, and 340(c).
17 SEVENTEENTH AFFIRMATIVE DEFENSE
18 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD
19 AMENDED COMPLAINT (and each and every cause of action thereof), this answering
20 Defendant alleges, on information and belief, that plaintiff’s claims are subject to set-off and/or
21 adjustments.
22 WHEREFORE, this answering defendant prays that plaintiff takes nothing by reason of
23 said Third Amended Complaint; that this answering defendant be awarded costs of suit herein
24 and such other and further relief that the Court deems just; that if this answering defendant is
25 found liable, that the degree of responsibility and liability for the resulting damages be
26 determined, and that this answering defendant be held liable for only the portion of the total
27 damages for which she is legally responsible.
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DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED
COMPLAINT
1 DEMAND FOR JURY TRIAL
2 COMES NOW Judith H. Wood, and hereby demands a Trial by jury in the above-entitled
3 matter.
4
5 DATED: November 22, 2023 BENNETT, GELINI & GELINI, APC
6
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By: THOMAS S. GELINI
8 JENNIFER A. KUNG GELINI
Attorneys for Defendant and Cross-
9 Complainant Judith H. Wood
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DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED
COMPLAINT
PROOF OF SERVICE
1
I am a resident of the State of California, over the age of eighteen years, and not a party
2
to the within action. My business address is BENNETT, GELINI & GELINI, APC, 1301 Marina
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Village Parkway, Suite 300, Alameda, California 94501.
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On November 22, 2023, I served the following document(s) by the method indicated
5
below:
6
DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’
7 THIRD AMENDED COMPLAINT
8 ☐ BY MAIL - by placing the document(s) listed above in a sealed envelope with postage
thereon fully prepaid, in the United States mail at Alameda, California addressed as set forth
9 below:
10
☒ BY EMAIL - by electronically transmitting a true copy thereof via computer, addressed to
11 the person(s) and email address(es) below:
12
Majed Dakak Catherine L. Deter
13 Ryan Davis Briana J. Kutinsky
14 KESSELMAN BRANTLY STOCKINGER LLP WOOD, SMITH, HENNING & BERMAN
1230 Rosecrans Ave, Suite 400 LLP
15 Manhattan Beach, CA 90266 6A Liberty Street, Suite 200
Ph: 310-307-4555 Aliso Viejo, California 92656
16 Fax: 310-307-4570 Tel: 949-757-4500
Email: mdakak@kbslaw.com Fax: 949-757-4550
17 Email: rdavis@kbslaw.com Email: cdeter@wshblaw.com
18 Email: bkutinsky@wshblaw.com
Attorneys for Plaintiff Kimberly Jones Email: cleong@wshblaw.com
19
Attorneys for Def Left Coast Inspections,
20 LLC
21 I declare under penalty of perjury under the laws of the State of California that the above
22 is true and correct. Executed on November 22, 2023, at Alameda, California.
23
24 ___________________________________
Kat Nguyen
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DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED
COMPLAINT
Preview
THOMAS S. GELINI (SBN: 154314) 1 JENNIFER A. KUNG GELINI (SBN: 169364) 2 BENNETT, GELINI & GELINI A Professional Corporation 3 1301 Marina Village Parkway, Suite 300 Alameda, CA 94501-1084 4 Telephone: 510-444-7688 Facsimile: 510-444-5849 5 Email: tgelini@bsralaw.com 6 jgelini@bsralaw.com 7 Attorneys for Defendant and Cross-Complainant Judith H. Wood 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SANTA BARBARA 11 UNLIMITED CIVIL JURISDICTION 12 KIMBERLY M. JONES, an individual; CASE NO. 23CV00522 13 Plaintiff, DEFENDANT JUDITH H. WOOD’S 14 ANSWER TO PLAINTIFF KIMBERLY M. vs. JONES’ THIRD AMENDED COMPLAINT 15 16 LEFT COAST INSPECTIONS LLC, a Complaint Filed: February 7, 2023 California Limited Liability Company; WOOD SAC Filed: August 9, 2023 17 ENVIRONMENTAL SERVICES, LLC, a Trial Date: Not yet set California Limited Liability Company; 18 JUDITH H. WOOD, an individual; and DOES 1 - 15. 19 20 Defendants. 21 AND RELATED CROSS ACTIONS 22 23 COMES NOW DEFENDANT JUDITH H. WOOD, and answers Plaintiff’s Third Amended 24 Complaint on file herein as follows: 25 This answering defendant denies each and every, all and singular, generally and 26 specifically, the allegations contained in the Third Amended Complaint, and in each cause of 27 action thereof, and each and every part thereof, and in this connection, this defendant denies 28 -1- DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED COMPLAINT 1 that plaintiff has been injured or damaged in the unspecified sum or sums alleged in the Third 2 Amended Complaint, or in any other sum, or sums, or otherwise, or at all. 3 AFFIRMATIVE DEFENSES 4 FIRST AFFIRMATIVE DEFENSE 5 Defendant alleges that plaintiff and others were negligent in and about the matters 6 referred to in said Third Amended Complaint, and that such negligence bars and/or diminishes 7 plaintiff’s right to recovery against this answering defendant. Should plaintiff recover damages 8 against any defendant, said defendant or defendant are entitled to have the amount abated, 9 reduced, or eliminated to the extent plaintiff’s negligence caused or contributed to their 10 damages, if any there were. 11 SECOND AFFIRMATIVE DEFENSE 12 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD 13 AMENDED COMPLAINT (and each and every cause of action thereof), this Defendant alleges 14 that plaintiff voluntarily and knowingly entered into and engaged in operations and conduct 15 alleged in said Third Amended Complaint and voluntarily and knowingly assumed all of the risks 16 incident to said operations, acts, and conduct at the time and place mentioned in said Third 17 Amended Complaint. 18 THIRD AFFIRMATIVE DEFENSE 19 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 20 COMPLAINT (and each and every cause of action thereof), this Defendant alleges that plaintiff’s 21 Third Amended Complaint fails to state facts sufficient to constitute a cause of action against 22 this answering defendant. 23 FOURTH AFFIRMATIVE DEFENSE 24 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 25 COMPLAINT (and each and every cause of action thereof), this Defendant alleges that plaintiff 26 has not adequately mitigated their damages, if any there were. 27 /// 28 -2- DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED COMPLAINT 1 FIFTH AFFIRMATIVE DEFENSE 2 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 3 COMPLAINT (and each and every cause of action thereof), this Defendant alleges, upon 4 information and belief, that the damages allegedly sustained by plaintiff was either wholly or in 5 part negligently, carelessly, willfully, or otherwise wrongfully caused by persons, firms, 6 corporations or public entities other than this answering defendant, and that this defendant shall 7 only be liable, if at all, in accordance with the provisions of Civil Code §§1431-1431.5. 8 SIXTH AFFIRMATIVE DEFENSE 9 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 10 COMPLAINT (and each and every cause of action thereof), this Defendant alleges, upon 11 information and belief, that the damages allegedly sustained by plaintiff was either wholly or in 12 part negligently, carelessly, willfully or otherwise wrongfully caused by persons, firms, 13 corporations, or public entities other than this answering defendant, and that said negligence, 14 carelessness, willful misconduct, or other wrongful acts comparatively reduce the percentage 15 of liability, if any, of this answering defendant. 16 SEVENTH AFFIRMATIVE DEFENSE 17 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 18 COMPLAINT (and each and every cause of action thereof), the plaintiff is barred from any 19 recovery, because of plaintiff’s lack of notice, in whole or in part to this answering defendant. 20 EIGHTH AFFIRMATIVE DEFENSE 21 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 22 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges 23 that plaintiff acted unreasonably in the possession, management, maintenance operation, 24 inspection, control, protection and care of the subject residence. 25 /// 26 /// 27 /// 28 -3- DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED COMPLAINT 1 NINTH AFFIRMATIVE DEFENSE 2 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 3 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges 4 on information and belief that the Third Amended Complaint is barred by the doctrine of unclean 5 hands. 6 TENTH AFFIRMATIVE DEFENSE 7 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 8 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges 9 on information and belief that the Third Amended Complaint is barred and the relief requested 10 by the plaintiff is barred by virtue of the fact that the plaintiff themselves failed to do equity in 11 connection with the facts and circumstances alleged in the Third Amended Complaint. 12 ELEVENTH AFFIRMATIVE DEFENSE 13 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 14 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges 15 on information and belief that the Third Amended Complaint is barred by the doctrine of laches. 16 TWELFTH AFFIRMATIVE DEFENSE 17 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 18 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges 19 on information and belief that by reason of the acts and omissions of the plaintiff, the plaintiff 20 has waived the right to pursue this action and any entitlements to any recovery, for any breach 21 of any contract or any duty, or for any other cause. 22 THIRTEENTH AFFIRMATIVE DEFENSE 23 AS AND FOR A FURTHER AND SEPARATE DEFENSE TO THE THIRD AMENDED 24 COMPLAINT (and each and every cause of action thereof), this answering Defendant alleges 25 on information and belief, that by reason of the acts and omissions of the plaintiff, she has 26 estopped from pursuing this action and estopped from any entitlement to recovery, if any. 27 /// 28 -4- DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED COMPLAINT 1 FOURTEENTH AFFIRMATIVE DEFENSE 2 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD 3 AMENDED COMPLAINT (and each and every cause of action thereof) this answering 4 Defendant alleges that neither plaintiff’s Third Amended Complaint nor any of the alleged 5 causes of action therein state facts sufficient to constitute a cause of action for punitive 6 damages against this answering defendant. 7 FIFTEENTH AFFIRMATIVE DEFENSE 8 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD 9 AMENDED COMPLAINT (and each and every cause of action thereof), this answering 10 Defendant alleges that certain of plaintiff’s claims in this matter have been settled and 11 compromised, as confirmed by releases. 12 SIXTEENTH AFFIRMATIVE DEFENSE 13 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD 14 AMENDED COMPLAINT (and each and every cause of action thereof), this answering 15 Defendant alleges that plaintiff’s claims are barred by all applicable statutes of limitation, 16 including, but not limited to, CCP sections 335.1, 337, 337.2, 338, 339, 339.5, and 340(c). 17 SEVENTEENTH AFFIRMATIVE DEFENSE 18 AS AND FOR A FURTHER AND SEPARATE AFFIRMATIVE DEFENSE TO THE THIRD 19 AMENDED COMPLAINT (and each and every cause of action thereof), this answering 20 Defendant alleges, on information and belief, that plaintiff’s claims are subject to set-off and/or 21 adjustments. 22 WHEREFORE, this answering defendant prays that plaintiff takes nothing by reason of 23 said Third Amended Complaint; that this answering defendant be awarded costs of suit herein 24 and such other and further relief that the Court deems just; that if this answering defendant is 25 found liable, that the degree of responsibility and liability for the resulting damages be 26 determined, and that this answering defendant be held liable for only the portion of the total 27 damages for which she is legally responsible. 28 -5- DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED COMPLAINT 1 DEMAND FOR JURY TRIAL 2 COMES NOW Judith H. Wood, and hereby demands a Trial by jury in the above-entitled 3 matter. 4 5 DATED: November 22, 2023 BENNETT, GELINI & GELINI, APC 6 7 By: THOMAS S. GELINI 8 JENNIFER A. KUNG GELINI Attorneys for Defendant and Cross- 9 Complainant Judith H. Wood 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -6- DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED COMPLAINT PROOF OF SERVICE 1 I am a resident of the State of California, over the age of eighteen years, and not a party 2 to the within action. My business address is BENNETT, GELINI & GELINI, APC, 1301 Marina 3 Village Parkway, Suite 300, Alameda, California 94501. 4 On November 22, 2023, I served the following document(s) by the method indicated 5 below: 6 DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ 7 THIRD AMENDED COMPLAINT 8 ☐ BY MAIL - by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United States mail at Alameda, California addressed as set forth 9 below: 10 ☒ BY EMAIL - by electronically transmitting a true copy thereof via computer, addressed to 11 the person(s) and email address(es) below: 12 Majed Dakak Catherine L. Deter 13 Ryan Davis Briana J. Kutinsky 14 KESSELMAN BRANTLY STOCKINGER LLP WOOD, SMITH, HENNING & BERMAN 1230 Rosecrans Ave, Suite 400 LLP 15 Manhattan Beach, CA 90266 6A Liberty Street, Suite 200 Ph: 310-307-4555 Aliso Viejo, California 92656 16 Fax: 310-307-4570 Tel: 949-757-4500 Email: mdakak@kbslaw.com Fax: 949-757-4550 17 Email: rdavis@kbslaw.com Email: cdeter@wshblaw.com 18 Email: bkutinsky@wshblaw.com Attorneys for Plaintiff Kimberly Jones Email: cleong@wshblaw.com 19 Attorneys for Def Left Coast Inspections, 20 LLC 21 I declare under penalty of perjury under the laws of the State of California that the above 22 is true and correct. Executed on November 22, 2023, at Alameda, California. 23 24 ___________________________________ Kat Nguyen 25 26 27 28 -7- DEFENDANT JUDITH H. WOOD’S ANSWER TO PLAINTIFF KIMBERLY M. JONES’ THIRD AMENDED COMPLAINT