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1 LAW OFFICES OF SANTANA, VIERRA, STEVENSON & HARRIS
Kenneth Vierra Jr. - SBN: 152143
2 Mailing Address: P.O. Box 7218
London, KY 40742
3 Telephone: (415) 777-1308
4 Facsimile: (603) 430-0513 3/11/2024
Email: kenneth.vierra@libertymutual.com
5 Eservice: SFMail@libertymutual.com
6 Attorneys for Defendant
Defendant, AMERICAN PARKING MANAGEMENT, INC.
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN MATEO
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11 SHARIF ETMAN, Case No.: 24-CIV-00998
Assigned to: Honorable Susan Greenberg, Dept.
12 Plaintiff, 3
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v.
14 ANSWER TO COMPLAINT
STANFORD UNIVERSITY, AMERICAN
15 PARKING MANAGEMENT, INC., and DOES
1 THROUGH 50,
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Defendants.
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Defendant, AMERICAN PARKING MANAGEMENT, INC., in answer to the unverified
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Complaint on file herein, and by virtue of the provisions of Code of Civil Procedure section 431.30,
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now files their general denial to said unverified Complaint and to each cause of action thereof and
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answering all of the allegations thereof, Defendant denies each and all of them. Defendant further
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specifically denies that Plaintiff has been damaged in any sum or sums whatsoever, or at all.
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Defendant states the following separate affirmative defenses to this action:
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AFFIRMATIVE DEFENSES
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1. As to each and every cause of action alleged in the Complaint herein, Defendant is informed
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and believes and thereon alleges that any and all alleged events, happenings, injuries and damages, if
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any, were proximately caused or contributed to by the failure of Plaintiff to exercise ordinary care at the
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time and place alleged.
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________________________________________________________________________________________________________________________
ANSWER TO COMPLAINT
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2. As to each and every cause of action alleged in the Complaint herein, Defendant is informed
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and believes and thereon alleges that Plaintiff fails to state facts sufficient to constitute a cause of action.
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3. As to each and every cause of action alleged in the Complaint herein, Defendant is informed
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and believes and thereon alleges that the injuries and damages complained of by Plaintiff, if any there
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were, were either wholly, or in part, directly and proximately caused by the conduct of persons or
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entities other than this answering Defendant.
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4. As to each and every cause of action alleged in the Complaint herein, Defendant is informed
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and believes and thereon alleges that the injuries and damages complained of by Plaintiff, if any there
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were, were either wholly, or in part, directly and proximately caused by the conduct of persons or
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entities other than this answering Defendant and said conduct is either imputed to Plaintiff by reason of
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the relationship between Plaintiff and said persons or entities, or comparatively reduces the proportion
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of liability of this answering Defendant.
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5. As to each and every cause of action alleged in the Complaint herein, Defendant is informed
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and believes and thereon alleges that Plaintiff has failed to mitigate his damages, if any.
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6. As to each and every cause of action alleged in the Complaint herein, Defendant is informed
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and believes and thereon alleges that any and all alleged events, happenings, injuries and damages, if
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any, were proximately caused or contributed to by Plaintiff, who assumed all risks and hazards incident
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to the conduct alleged in the charging allegations.
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7. As to each and every cause of action alleged in the Complaint herein, Defendant is informed
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and believes and thereon alleges that any injuries and damages which Plaintiff may have suffered were
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proximately caused by the several negligence of named Defendant or the fictitiously named Doe
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Defendants, or any of them, or others and accordingly, liability for non-economic damages, if any, must
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be apportioned, reduced, or allocated in direct proportion to that persons’ percentage of fault. C.C.
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§1431.1 et seq.
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WHEREFORE, this answering Defendant prays that Plaintiff take nothing by reason of the
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Complaint and that this answering Defendant be given judgment for its costs of suit incurred herein, to
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be incurred, and for such other and further relief as the Court deems just and proper.
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________________________________________________________________________________________________________________________
ANSWER TO COMPLAINT
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Dated: March 11, 2024 Santana, Vierra, Stevenson & Harris
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4 KENNETH VIERRA JR.
5 Attorneys for Defendant, AMERICAN
PARKING MANAGEMENT, INC.
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________________________________________________________________________________________________________________________
ANSWER TO COMPLAINT
Sharif Etman v. Stanford University, et al.
COUNTY OF SAN MATEO
Superior Court Case No. 24-CIV-00998
DECLARATION OF SERVICE [C.C.P. § 1013A, C.R.C. §§ 2003, 2008]
At the time of service, I was over 18 years of age and not a party to this action. I am an employee of the Law
Office of Santana, Vierra, Stevenson & Harris in California. My business mailing address is P.O. Box 7218,
London, KY 40742. On this date I served the following document(s) by the following means:
ANSWER TO COMPLAINT
U.S. MAIL: I enclosed the documents in a sealed envelope or package addressed to the persons at the
addresses as set forth below and placed the envelope for collection and mailing, following our ordinary
business practices. I am readily familiar with this business’s practice for collecting and processing
correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is
deposited in the ordinary course of business with the United States Postal Service at San Francisco,
California, in a sealed envelope with postage fully prepaid.
EMAIL or ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to
accept service by e-mail or electronic transmission, I caused the documents to be sent to the person at the
e-mail addresses listed below. I did not receive, within a reasonable time after the transmission, any
electronic message or other indication that the transmission was unsuccessful.
Richard Schoenberger, Esq. Attorneys for Plaintiff
Clifton Smoot, Esq.
Walkup, Melodia, Kelly & Schoenberger
650 California St., 26th Floor,
San Francisco, CA 94108-2615
T: (415) 981-7210; F: (415) 391-6965
rschoenberger@walkuplawoffice.com
csmoot@walkuoplawoffice.com
State: I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
EXECUTED on March 11, 2024, in San Francisco, California.
Sandra Stepisnik
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1 LAW OFFICES OF SANTANA, VIERRA, STEVENSON & HARRIS Kenneth Vierra Jr. - SBN: 152143 2 Mailing Address: P.O. Box 7218 London, KY 40742 3 Telephone: (415) 777-1308 4 Facsimile: (603) 430-0513 3/11/2024 Email: kenneth.vierra@libertymutual.com 5 Eservice: SFMail@libertymutual.com 6 Attorneys for Defendant Defendant, AMERICAN PARKING MANAGEMENT, INC. 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN MATEO 10 11 SHARIF ETMAN, Case No.: 24-CIV-00998 Assigned to: Honorable Susan Greenberg, Dept. 12 Plaintiff, 3 13 v. 14 ANSWER TO COMPLAINT STANFORD UNIVERSITY, AMERICAN 15 PARKING MANAGEMENT, INC., and DOES 1 THROUGH 50, 16 Defendants. 17 Defendant, AMERICAN PARKING MANAGEMENT, INC., in answer to the unverified 18 Complaint on file herein, and by virtue of the provisions of Code of Civil Procedure section 431.30, 19 now files their general denial to said unverified Complaint and to each cause of action thereof and 20 answering all of the allegations thereof, Defendant denies each and all of them. Defendant further 21 specifically denies that Plaintiff has been damaged in any sum or sums whatsoever, or at all. 22 Defendant states the following separate affirmative defenses to this action: 23 AFFIRMATIVE DEFENSES 24 1. As to each and every cause of action alleged in the Complaint herein, Defendant is informed 25 and believes and thereon alleges that any and all alleged events, happenings, injuries and damages, if 26 any, were proximately caused or contributed to by the failure of Plaintiff to exercise ordinary care at the 27 time and place alleged. 28 -1- ________________________________________________________________________________________________________________________ ANSWER TO COMPLAINT 1 2. As to each and every cause of action alleged in the Complaint herein, Defendant is informed 2 and believes and thereon alleges that Plaintiff fails to state facts sufficient to constitute a cause of action. 3 3. As to each and every cause of action alleged in the Complaint herein, Defendant is informed 4 and believes and thereon alleges that the injuries and damages complained of by Plaintiff, if any there 5 were, were either wholly, or in part, directly and proximately caused by the conduct of persons or 6 entities other than this answering Defendant. 7 4. As to each and every cause of action alleged in the Complaint herein, Defendant is informed 8 and believes and thereon alleges that the injuries and damages complained of by Plaintiff, if any there 9 were, were either wholly, or in part, directly and proximately caused by the conduct of persons or 10 entities other than this answering Defendant and said conduct is either imputed to Plaintiff by reason of 11 the relationship between Plaintiff and said persons or entities, or comparatively reduces the proportion 12 of liability of this answering Defendant. 13 5. As to each and every cause of action alleged in the Complaint herein, Defendant is informed 14 and believes and thereon alleges that Plaintiff has failed to mitigate his damages, if any. 15 6. As to each and every cause of action alleged in the Complaint herein, Defendant is informed 16 and believes and thereon alleges that any and all alleged events, happenings, injuries and damages, if 17 any, were proximately caused or contributed to by Plaintiff, who assumed all risks and hazards incident 18 to the conduct alleged in the charging allegations. 19 7. As to each and every cause of action alleged in the Complaint herein, Defendant is informed 20 and believes and thereon alleges that any injuries and damages which Plaintiff may have suffered were 21 proximately caused by the several negligence of named Defendant or the fictitiously named Doe 22 Defendants, or any of them, or others and accordingly, liability for non-economic damages, if any, must 23 be apportioned, reduced, or allocated in direct proportion to that persons’ percentage of fault. C.C. 24 §1431.1 et seq. 25 WHEREFORE, this answering Defendant prays that Plaintiff take nothing by reason of the 26 Complaint and that this answering Defendant be given judgment for its costs of suit incurred herein, to 27 be incurred, and for such other and further relief as the Court deems just and proper. 28 -2- ________________________________________________________________________________________________________________________ ANSWER TO COMPLAINT 1 Dated: March 11, 2024 Santana, Vierra, Stevenson & Harris 2 3 4 KENNETH VIERRA JR. 5 Attorneys for Defendant, AMERICAN PARKING MANAGEMENT, INC. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3- ________________________________________________________________________________________________________________________ ANSWER TO COMPLAINT Sharif Etman v. Stanford University, et al. COUNTY OF SAN MATEO Superior Court Case No. 24-CIV-00998 DECLARATION OF SERVICE [C.C.P. § 1013A, C.R.C. §§ 2003, 2008] At the time of service, I was over 18 years of age and not a party to this action. I am an employee of the Law Office of Santana, Vierra, Stevenson & Harris in California. My business mailing address is P.O. Box 7218, London, KY 40742. On this date I served the following document(s) by the following means: ANSWER TO COMPLAINT U.S. MAIL: I enclosed the documents in a sealed envelope or package addressed to the persons at the addresses as set forth below and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service at San Francisco, California, in a sealed envelope with postage fully prepaid. EMAIL or ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents to be sent to the person at the e-mail addresses listed below. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. Richard Schoenberger, Esq. Attorneys for Plaintiff Clifton Smoot, Esq. Walkup, Melodia, Kelly & Schoenberger 650 California St., 26th Floor, San Francisco, CA 94108-2615 T: (415) 981-7210; F: (415) 391-6965 rschoenberger@walkuplawoffice.com csmoot@walkuoplawoffice.com State: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. EXECUTED on March 11, 2024, in San Francisco, California. Sandra Stepisnik