On December 27, 2023 a
Answer
was filed
involving a dispute between
Beaudine, Amy,
and
Vivin, Dario,
Vivin, Heidi,
for Breach of Contract/Warranty Unlimited (06)
in the District Court of Napa County.
Preview
PLD450
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 092334 FOR COURT If SE ONLY
NAME:Vincent M. Soohn. Eso.
FIRM NAME:Law Offices of Vincent M. Soohn
STREET ADDREss: 1475 Fourth Street
cnY: NaOa srATE: CA zip coDE: 94581
TELEPHQNE Nos (707) 255-1885 FAX NOJ
EMAIL AooREss: admin@vsoohnlaw.corn; vms(mvsoohnlaw.corn
ATTORNEY FOR (name)r DefendantS. Daria ViVan and Heidi ViVan
SUPERIOR COURT OF CALIFORNIA, COUNTY OF NAPA
BTREETADDRESB. 825Brown Street
MAILING ADDREss.825 Brown Street
OITY AND TIP coDE:Naoa 94559
sRANcH NAME: Historic Courthouse
PLAINTIFF/PETITIONER:Amv Besudine
DEFENDANT/RESPONDENT: DsriiDVivgn Bnd Heidi Vivsn
CASE
GENERAL DENIAL NUMBER'3CV001690
If you want to file a general denial, you MUST use this form if the amount asked for in the complaint or the value of the property
involved is $ 1,000 or less.
You MAY use this form for a general denial if
1. The complaint is not verified; or
2. The complaint is verified and the case is a limited civil case (the amount in controversy is $ 35,000 or less),
BUT NOT if the complaint involves a claim for more than $ 1,000 that has been assigned to a third party for collection.
(See Code of Civil Procedure sections 85-4)6, 90-100, 431.30, and 431.40.)
1. DEFENDANT (name)f Dario Vivan and Heidi Vivan
generally denies each and every allegation of plaintiffs complaint.
2, ~x DEFENDANT states the following FACTS as separate affirmative defenses to plaintiffs complaint (attach additional
pagesifnecessary)f
a.) Plaintiff, her offspring and Cross-Defendant Bryan Pritchard damaged the property described in the Complaint; the
repairs of such damage far exceeded the security deposit, and lost rent.
b.) No Defendant caused any defamatory communication to be published.
c.) If either Defendant expressed any fact or opinion about Plaintiff, such expression was true.
Date: March 20, 2024
Vincent M. Spohn, Esq.
(TYPE OR PRINT NAME) (SIGNATURE OF DEFfiNDANT OR ATTORNEY)
Ifyou have a claim for damages or other relief against the plaintiff, the law may require you to state your claim in a special pleading
called a cross-complaint or you may lose your right to bring the claim. (See Code of Civil Procedure sections 426.10-426.40.)
The original of this Genera/ Denial must be filed with the clerk of this court with proof that a copy was served on each plaintiffs
attorney and on each plaintiff not represented by an attorney. There are two main ways to serve this General Denial: by personal
delivery or by mail. It may be served by anyone at least 18 years of age EXCEPT you or any other party to this legal action. Be sure
that whoever serves the General Denial fills out and signs a proof of service. You may use the applicable Judicial Council form (such
as form POS-020, POS-030, or POS-040) for the proof of service.
Page1of1
Form Adopted for Mandatory Use Cods of Civil Procedure, Ijl) 43130, 43140
Judrcial Council of California GENERAL DENIAL www. co uris. ca.gov
PLD-030 (Rev. January I, 2024]
For your protection and privacy, please press the Clear
This Form button after you have printed the form. Print this form Save this form Clear this form ]
[ [ ] ( )
Document Filed Date
March 22, 2024
Case Filing Date
December 27, 2023
Category
Breach of Contract/Warranty Unlimited (06)
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PLD450 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 092334 FOR COURT If SE ONLY NAME:Vincent M. Soohn. Eso. FIRM NAME:Law Offices of Vincent M. Soohn STREET ADDREss: 1475 Fourth Street cnY: NaOa srATE: CA zip coDE: 94581 TELEPHQNE Nos (707) 255-1885 FAX NOJ EMAIL AooREss: admin@vsoohnlaw.corn; vms(mvsoohnlaw.corn ATTORNEY FOR (name)r DefendantS. Daria ViVan and Heidi ViVan SUPERIOR COURT OF CALIFORNIA, COUNTY OF NAPA BTREETADDRESB. 825Brown Street MAILING ADDREss.825 Brown Street OITY AND TIP coDE:Naoa 94559 sRANcH NAME: Historic Courthouse PLAINTIFF/PETITIONER:Amv Besudine DEFENDANT/RESPONDENT: DsriiDVivgn Bnd Heidi Vivsn CASE GENERAL DENIAL NUMBER'3CV001690 If you want to file a general denial, you MUST use this form if the amount asked for in the complaint or the value of the property involved is $ 1,000 or less. You MAY use this form for a general denial if 1. The complaint is not verified; or 2. The complaint is verified and the case is a limited civil case (the amount in controversy is $ 35,000 or less), BUT NOT if the complaint involves a claim for more than $ 1,000 that has been assigned to a third party for collection. (See Code of Civil Procedure sections 85-4)6, 90-100, 431.30, and 431.40.) 1. DEFENDANT (name)f Dario Vivan and Heidi Vivan generally denies each and every allegation of plaintiffs complaint. 2, ~x DEFENDANT states the following FACTS as separate affirmative defenses to plaintiffs complaint (attach additional pagesifnecessary)f a.) Plaintiff, her offspring and Cross-Defendant Bryan Pritchard damaged the property described in the Complaint; the repairs of such damage far exceeded the security deposit, and lost rent. b.) No Defendant caused any defamatory communication to be published. c.) If either Defendant expressed any fact or opinion about Plaintiff, such expression was true. Date: March 20, 2024 Vincent M. Spohn, Esq. (TYPE OR PRINT NAME) (SIGNATURE OF DEFfiNDANT OR ATTORNEY) Ifyou have a claim for damages or other relief against the plaintiff, the law may require you to state your claim in a special pleading called a cross-complaint or you may lose your right to bring the claim. (See Code of Civil Procedure sections 426.10-426.40.) The original of this Genera/ Denial must be filed with the clerk of this court with proof that a copy was served on each plaintiffs attorney and on each plaintiff not represented by an attorney. There are two main ways to serve this General Denial: by personal delivery or by mail. It may be served by anyone at least 18 years of age EXCEPT you or any other party to this legal action. Be sure that whoever serves the General Denial fills out and signs a proof of service. You may use the applicable Judicial Council form (such as form POS-020, POS-030, or POS-040) for the proof of service. Page1of1 Form Adopted for Mandatory Use Cods of Civil Procedure, Ijl) 43130, 43140 Judrcial Council of California GENERAL DENIAL www. co uris. ca.gov PLD-030 (Rev. January I, 2024] For your protection and privacy, please press the Clear This Form button after you have printed the form. Print this form Save this form Clear this form ] [ [ ] ( )