On May 15, 2023 a
Answer
was filed
involving a dispute between
Gastelum, Ramon Humberto,
and
Best Buy Purchasing Llc,
Best Buy Stores, L.P.,
Does 1 To 100, Inclusive,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
11/15/2023 10:52 AM
By: Alyssa Leber, DEPUTY
EL
SU
CO
SA
11/
By
COMES NOW, Cross-Defendant VERONICA MARTINEZ (“Cross-Defendant”)
and answers Cross-Complainant BEST BUY PURCHASING, LLC’s (erroneously sued
as BEST BUY STORES L.P.)(“Cross-Complainant”) Cross-Complaint for herself alone
and for no other Cross-Defendant as follows:
COWNOU'l-kwNA
By virtue of the provisions of California Code of Civil Procedure §431 .30, this
answering Cross-Defendant denies generally and specifically each and every allegation
contained in each cause of action of the Cross-Complaint, and further specifically
denies that Cross-Complainant has been damaged in the sum or sums alleged, or has
incurred any liability in the sum or sums alleged, has been damaged in any other
manner or form by way of any act, omission or obligation on the part of this answering
Cross—Defendant.
FIRST AFFIRMATIVE DEFENSE
(Failure to State Sufficient Facts)
The Cross-Complaint, and each and every cause of action contained therein,
fails to state facts sufficient to constitute a cause of action against Cross-Defendant.
NNNNNNNNNAJAAAAAA-t—x
SECOND AFFIRMATIVE DEFENSE
mNODU'l-hCDN—‘OCDmNO'DOT-hOJN—‘O
(Statute of Limitations)
The Cross—Complaint, and each and every cause of action contained therein, is
barred by the applicable statute of limitations including, but not limited to, California
Code of Civil Procedure § 335.1.
THIRD AFFIRMATIVE DEFENSE
(Substantial Factor)
Cross-Defendant denies that any act or omission on their part was a substantial
factor in causing Cross-Complainant's injuries or damages, if any.
2
ANSWER TO CROSS-COMPLAINT
Document Filed Date
November 15, 2023
Case Filing Date
May 15, 2023
Category
Other PI/PD/WD Unlimited
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Preview
ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT 11/15/2023 10:52 AM By: Alyssa Leber, DEPUTY EL SU CO SA 11/ By COMES NOW, Cross-Defendant VERONICA MARTINEZ (“Cross-Defendant”) and answers Cross-Complainant BEST BUY PURCHASING, LLC’s (erroneously sued as BEST BUY STORES L.P.)(“Cross-Complainant”) Cross-Complaint for herself alone and for no other Cross-Defendant as follows: COWNOU'l-kwNA By virtue of the provisions of California Code of Civil Procedure §431 .30, this answering Cross-Defendant denies generally and specifically each and every allegation contained in each cause of action of the Cross-Complaint, and further specifically denies that Cross-Complainant has been damaged in the sum or sums alleged, or has incurred any liability in the sum or sums alleged, has been damaged in any other manner or form by way of any act, omission or obligation on the part of this answering Cross—Defendant. FIRST AFFIRMATIVE DEFENSE (Failure to State Sufficient Facts) The Cross-Complaint, and each and every cause of action contained therein, fails to state facts sufficient to constitute a cause of action against Cross-Defendant. NNNNNNNNNAJAAAAAA-t—x SECOND AFFIRMATIVE DEFENSE mNODU'l-hCDN—‘OCDmNO'DOT-hOJN—‘O (Statute of Limitations) The Cross—Complaint, and each and every cause of action contained therein, is barred by the applicable statute of limitations including, but not limited to, California Code of Civil Procedure § 335.1. THIRD AFFIRMATIVE DEFENSE (Substantial Factor) Cross-Defendant denies that any act or omission on their part was a substantial factor in causing Cross-Complainant's injuries or damages, if any. 2 ANSWER TO CROSS-COMPLAINT