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1 Nicole Y. Mitchell, Esq. [SBN: 321443]
HOMAN, STONE & ROSSI ATTORNEYS
2 1461 Ford Street, Suite 201
Redlands, CA 92373
3 (909) 307-9380
4 (909) 793-0210 - Fax
5 Attorneys for Betsy Renee Dunkel
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF KERN
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11 CHRISTINE ROSHELLE DELGADO, Case No.: BCV-24-100707
Unlimited Civil Jurisdiction
12 Plaintiff,
ANSWER TO COMPLAINT
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vs.
14 [Assigned to Honorable T. Mark Smith Dept. T-2]
BETSY RENEE DUNKEL, and DOES 1 to 30,
15 Trial date: None Set
Defendants.
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COMES NOW Defendant BETSY RENEE DUNKEL (hereinafter collectively referred to as
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Defendant”), and hereby responds to the Complaint of Plaintiff, CHRISTINE ROSHELLE DELGADO,
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(hereinafter “Plaintiff”), for themselves alone and for no other person or entity as follows:
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1. Pursuant to Code of Civil Procedure § 431.30(d), this answering Defendant denies,
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generally and specifically, each and every allegation in Plaintiff’s Complaint and each and every cause
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of action set forth therein. This answering Defendant further generally and specifically denies that
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Plaintiff has been damaged in the amounts alleged or in any other sum, or at all, by reason of any act or
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omission on the part of this answering Defendant, or on the part of any of its agents, servants and/or
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employees.
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ANSWER TO COMPLAINT
1 FIRST AFFIRMATIVE DEFENSE
2 (FAILURE TO STATE CAUSE TO ACTION)
3 2. Plaintiff’s Complaint and each cause of action therein, fails to state facts sufficient to
4 constitute a cause of action against this answering Defendant.
5 SECOND AFFIRMATIVE DEFENSE
6 (STATUTE OF LIMITATIONS- PERSONAL INJURY)
7 3. Plaintiff’s Complaint, and each cause of action therein, separately, are barred by the two-
8 year statute of limitations set forth in Code of Civil Procedure §§335.1, 337, 338, 339, 340, and 343, as
9 well as any and all applicable limitations set forth in §§335 through 349.4.
10 THIRD AFFIRMATIVE DEFENSE
11 (COMPARATIVE NEGLIGENCE)
12 4. This answering Defendant is informed and believes, and thereon alleges that the acts,
13 injuries, and damages, if any, alleged in the Complaint either occurred and were proximately caused by
14 the sole negligence of Plaintiff, whose sole negligence bars said Plaintiff’s recovery, or was contributed
15 to by Plaintiff’s negligence. Plaintiff’s recovery, if any, should be reduced by an amount proportionate
16 to the amount by which Plaintiff’s negligence contributed to the happening of the alleged damages and
17 the alleged injuries.
18 FOURTH AFFIRMATIVE DEFENSE
19 (MITIGATION OF DAMAGES)
20 5. Plaintiff’s recovery against this answering Defendant, if any, is barred by Plaintiff’s
21 failure to mitigate the damages alleged in the Complaint. If not completely barred, Plaintiff’s recovery
22 against this answering Defendant must be reduced to the extent that Plaintiff’s damages, if any, were
23 caused by Plaintiff’s failure to mitigate their damages properly.
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25 FIFTH AFFIRMATIVE DEFENSE
26 (CONCURRENT TORTFEASORS)
27 6. This answering Defendant alleges that, if held liable, the Plaintiff was one of many
28 concurrent tortfeasors, named or unnamed, so that the negligence, if any, of this answering Defendant is
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ANSWER TO COMPLAINT
1 imputed to, and/or should be indemnified by, said named or unnamed tortfeasors along with a
2 comparative allocation of negligence among concurrent tortfeasors.
3 SIXTH AFFIRMATIVE DEFENSE
4 (CONTRIBUTORY NEGLIGENCE)
5 7. This answering Defendant alleges that any and all events and happenings, injuries and
6 damages, if any, referred to in Plaintiff’s Complaint and each cause of action thereof were proximately
7 caused and contributed to by the negligence of Plaintiff in that Plaintiff failed to exercise ordinary care
8 on their own behalf at the time and place referred to, and said negligence on their part bars recovery
9 herein.
10 SEVENTH AFFIRMATIVE DEFENSE
11 (NEGLIGENCE OF THIRD PARTIES)
12 8. This answering Defendant denies that Plaintiff was damaged as a proximate result of any
13 conduct on the part of this answering Defendant. This answering Defendant affirmatively alleges that
14 Plaintiff’s damages, if any, were proximately caused by the independent conduct of third parties.
15 Plaintiff’s recovery against this answering Defendant, if any, must therefore be reduced to the extent that
16 those damages, if any, were caused by the independent conduct of third parties.
17 EIGHTH AFFIRMATIVE DEFENSE
18 (REDUCTION TO PERCENT OF FAULT)
19 9. Plaintiff’s right to recover herein, if any right exists, is reduced and limited to the
20 percentage of negligence attributable to this answering Defendant pursuant to Civil Code §1431.2.
21 NINTH AFFIRMATIVE DEFENSE
22 (ASSUMPTION OF RISK)
23 10. The injuries, loss and/or damage, if any, sustained by Plaintiff was and is the result of an
24 open, obvious and apparent danger which was known to and recognized by Plaintiff who, nevertheless,
25 knowingly, willingly, intentionally and voluntarily exposed said Plaintiff to said danger and assumed the
26 risk of accident, injury and damage.
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ANSWER TO COMPLAINT
1 TENTH AFFIRMATIVE DEFENSE
2 (FAILURE TO COMPLY WITH
3 PERSONAL FINANCIAL RESPONSIBILITY REQUIREMENTS)
4 11. This answering Defendant is informed and believes, and thereon allege that Plaintiff
5 and/or their agents failed to comply with the Personal Responsibility Act of 1996, Civil Code §3333.4
6 and related statutes requiring insurance maintained by or for Plaintiff in accordance with the financial
7 responsibility laws of this state.
8 ELEVENTH AFFIRMATIVE DEFENSE
9 (UNAVOIDABLE ACCIDENT)
10 12. This answering Defendant is informed and believes, and on that basis allege that any and
11 all injuries, losses or damages, if any, were the direct and proximate result of an unavoidable incident or
12 condition and, as such, were an act of God without fault or liability on the part of this Defendant.
13 TWELFTH AFFIRMATIVE DEFENSE
14 (SPOLIATION OF EVIDENCE)
15 13. This answering Defendant is informed and believes, and thereon alleges that Plaintiff
16 and/or its agents failed to preserve evidence, and by way of spoliation of evidence, Plaintiff and/or its
17 agents have prevented and/or precluded this answering Defendant from properly investigating and
18 preparing an adequate defense to the matters herein alleged, all to this answering Defendant’s
19 irreparable damage, thereby and thereupon providing a legal basis for relief, including, but not limited
20 to, an order barring introduction of evidence.
21 THIRTEENTH AFFIRMATIVE DEFENSE
22 (LACK OF STANDING)
23 14. This answering Defendant is informed and believes, and on that basis alleges that
24 Plaintiff’s lack standing to sue this answering Defendant.
25 FOURTEENTH AFFIRMATIVE DEFENSE
26 (SUPERSEDING CAUSES)
27 15. This answering Defendant is informed and believes, and on that basis alleges, that any
28 and all damages, if any, were the direct and proximate result of the intervening and superseding actions
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ANSWER TO COMPLAINT
1 of other parties, either served or unserved, and not this answering Defendant, and that such intervening
2 and superseding actions of other parties, whether or not served, bar recovery herein on behalf of
3 Plaintiff.
4 FIFTEENTH AFFIRMATIVE DEFENSE
5 (LACHES)
6 16. Plaintiff has unreasonably delayed the commencement of the within action to the
7 substantial prejudice of this answering Defendant and by reason thereof have been guilty of laches, and
8 Plaintiff is thereby precluded from recovery in the within action.
9 SIXTEENTH AFFIRMATIVE DEFENSE
10 (UNCLEAN HANDS)
11 17. Plaintiff’s conduct with respect to the matters alleged in the Complaint deprives Plaintiff
12 of clean hands, and by reason of not coming into court with clean hands Plaintiff is precluded from
13 recovery in the within action.
14 SEVENTEENTH AFFIRMATIVE DEFENSE
15 (ESTOPPEL)
16 18. This answering Defendant is informed and believes, and thereon allege, that the Plaintiff
17 engaged in conduct and activity with respect to the subject of this litigation, which are the subject of
18 Plaintiff’s Complaint, and by reason of said activities and conduct is estopped from asserting any claims
19 for damages or seeking any other relief against this answering Defendant.
20 EIGHTEENTH AFFIRMATIVE DEFENSE
21 (COMPLAINT IS FRIVOLOUS)
22 19. This answering Defendant is informed and believes and thereon alleges that the
23 Complaint is frivolous and is not based on good faith within the meaning of Code of Civil Procedure
24 §128.5 et seq. and therefore answering Defendant is entitled to recover reasonable expenses, including
25 attorney’s fees in defending the Complaint.
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ANSWER TO COMPLAINT
1 NINETEENTH AFFIRMATIVE DEFENSE
2 (RESERVATION)
3 20. This answering Defendant presently has insufficient knowledge or information on which
4 to form a belief as to whether it may have additional, as yet, unstated affirmative defenses available.
5 This answering Defendant herein reserves the right to assert additional defenses in the event that the
6 discovery indicates they would be appropriate.
7 WHEREFORE, this answering Defendant prays for judgment as follows:
8 1. That Plaintiff take nothing by way of this litigation;
9 2. For costs of suit;
10 3. For such other and further relief as the court may deem just and proper.
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DATED: April 9, 2024 HOMAN, STONE & ROSSI ATTORNEYS
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_______________________________
15 Nicole Y. Mitchell, Esq.
Attorneys for Betsy Renee Dunkel
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ANSWER TO COMPLAINT
PROOF OF SERVICE (Code Civ. Proc., §§ 1013a, 2015)
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STATE OF CALIFORNIA, COUNTY OF SAN BERNARDINO
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3 I am employed in the County of San Bernardino, State of California. I am over the age of 18 and not
a party to the within action; my business address is 1461 Ford Street, Suite 201, Redlands, CA 92373.
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On April 9, 2024, I served the foregoing document(s) described as ANSWER TO COMPLAINT on
5 the other parties in this action as follows:
6 SEE ATTACHED MAILING LIST
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[ ] (BY MAIL) By placing [X] the original [X] a true copy thereof enclosed in a sealed envelope(s)
8 addressed as to the above-named counsel of record or parties in propria persona. [X] I deposited
such envelope(s) in the mail at Redlands, California, with postage thereon fully prepaid. [X] I am
9 readily familiar with the firm’s practice of collection and processing correspondence for mailing. It is
deposited with the U.S. Postal Service on the same day in the ordinary course of business. I am aware
10 that on motion of party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after date of deposit for mailing in affidavit.
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[X] (BY PERSONAL SERVICE) By placing [X] the original [X] a true copy thereof enclosed in a
12 sealed envelope(s) addressed as to the above-named counsel of record or parties in propria persona. I
13 caused such envelope(s) to be delivered to the addressee.
14 [X] (BY FEDERAL EXPRESS NEXT-DAY DELIVERY) By placing [X] the original [X] a true
copy thereof enclosed in a sealed envelope(s) addressed to the above-named counsel of record or
15 parties in propria persona. I caused such envelope(s) to be prepared and picked up by Federal
Express box at 1461 Ford Street Suite 201, Redlands, California, with delivery fees prepaid and
16 provided for, addressed to the person on whom said document is to be served.
17 [X] BY ELECTRONIC SERVICE: A copy of said document(s) was delivered by electronic
transmission to the addressee(s) pursuant to C.C.P.1010.6(3) and/or C.R.C. Rule 2.251(a).
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19 [X] (BY FACSIMILE) I caused said document(s), along with an unsigned copy of this Declaration, to
be transmitted to a facsimile machine telephone number as last given by said counsel or party in
20 propria persona as noted above.
21 [X] FEDERAL: I declare that I am employed in the office of a member of the bar of this court at
whose direction the service was made. Pursuant to L.R. 5-3.2.1 and 5-3.2.2 the undersigned
22 declares service has been affected by way of CM/ECF or via Mail service as indicated above.
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[X] (STATE) I declare under penalty of perjury under the laws of the State of California that the
24 foregoing is true and correct.
25 Executed on April 9, 2024, at Redlands, California.
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HM
_____________________________________
27 HEATHER McCLURE
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ANSWER TO COMPLAINT
MAILING LIST
1 CASE NO.: BCV-24-100707
2 John C. Hall, Esq.
LAW OFFICES OF JOHN C. HALL
3 900 Truxtun Ave. Ste. 130
Bakersfield, CA 93301-4831
4 Email: john@johnchalllaw.com, olga@johnchalllaw.com, alethat@johnchalllaw.com
Attorneys for Plaintiff, CHRISTINE ROSHELLE DELGADO
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ANSWER TO COMPLAINT
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1 Nicole Y. Mitchell, Esq. [SBN: 321443] HOMAN, STONE & ROSSI ATTORNEYS 2 1461 Ford Street, Suite 201 Redlands, CA 92373 3 (909) 307-9380 4 (909) 793-0210 - Fax 5 Attorneys for Betsy Renee Dunkel 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF KERN 10 11 CHRISTINE ROSHELLE DELGADO, Case No.: BCV-24-100707 Unlimited Civil Jurisdiction 12 Plaintiff, ANSWER TO COMPLAINT 13 vs. 14 [Assigned to Honorable T. Mark Smith Dept. T-2] BETSY RENEE DUNKEL, and DOES 1 to 30, 15 Trial date: None Set Defendants. 16 17 COMES NOW Defendant BETSY RENEE DUNKEL (hereinafter collectively referred to as 18 Defendant”), and hereby responds to the Complaint of Plaintiff, CHRISTINE ROSHELLE DELGADO, 19 (hereinafter “Plaintiff”), for themselves alone and for no other person or entity as follows: 20 1. Pursuant to Code of Civil Procedure § 431.30(d), this answering Defendant denies, 21 generally and specifically, each and every allegation in Plaintiff’s Complaint and each and every cause 22 of action set forth therein. This answering Defendant further generally and specifically denies that 23 Plaintiff has been damaged in the amounts alleged or in any other sum, or at all, by reason of any act or 24 omission on the part of this answering Defendant, or on the part of any of its agents, servants and/or 25 employees. 26 // 27 // 28 -1- ANSWER TO COMPLAINT 1 FIRST AFFIRMATIVE DEFENSE 2 (FAILURE TO STATE CAUSE TO ACTION) 3 2. Plaintiff’s Complaint and each cause of action therein, fails to state facts sufficient to 4 constitute a cause of action against this answering Defendant. 5 SECOND AFFIRMATIVE DEFENSE 6 (STATUTE OF LIMITATIONS- PERSONAL INJURY) 7 3. Plaintiff’s Complaint, and each cause of action therein, separately, are barred by the two- 8 year statute of limitations set forth in Code of Civil Procedure §§335.1, 337, 338, 339, 340, and 343, as 9 well as any and all applicable limitations set forth in §§335 through 349.4. 10 THIRD AFFIRMATIVE DEFENSE 11 (COMPARATIVE NEGLIGENCE) 12 4. This answering Defendant is informed and believes, and thereon alleges that the acts, 13 injuries, and damages, if any, alleged in the Complaint either occurred and were proximately caused by 14 the sole negligence of Plaintiff, whose sole negligence bars said Plaintiff’s recovery, or was contributed 15 to by Plaintiff’s negligence. Plaintiff’s recovery, if any, should be reduced by an amount proportionate 16 to the amount by which Plaintiff’s negligence contributed to the happening of the alleged damages and 17 the alleged injuries. 18 FOURTH AFFIRMATIVE DEFENSE 19 (MITIGATION OF DAMAGES) 20 5. Plaintiff’s recovery against this answering Defendant, if any, is barred by Plaintiff’s 21 failure to mitigate the damages alleged in the Complaint. If not completely barred, Plaintiff’s recovery 22 against this answering Defendant must be reduced to the extent that Plaintiff’s damages, if any, were 23 caused by Plaintiff’s failure to mitigate their damages properly. 24 25 FIFTH AFFIRMATIVE DEFENSE 26 (CONCURRENT TORTFEASORS) 27 6. This answering Defendant alleges that, if held liable, the Plaintiff was one of many 28 concurrent tortfeasors, named or unnamed, so that the negligence, if any, of this answering Defendant is -2- ANSWER TO COMPLAINT 1 imputed to, and/or should be indemnified by, said named or unnamed tortfeasors along with a 2 comparative allocation of negligence among concurrent tortfeasors. 3 SIXTH AFFIRMATIVE DEFENSE 4 (CONTRIBUTORY NEGLIGENCE) 5 7. This answering Defendant alleges that any and all events and happenings, injuries and 6 damages, if any, referred to in Plaintiff’s Complaint and each cause of action thereof were proximately 7 caused and contributed to by the negligence of Plaintiff in that Plaintiff failed to exercise ordinary care 8 on their own behalf at the time and place referred to, and said negligence on their part bars recovery 9 herein. 10 SEVENTH AFFIRMATIVE DEFENSE 11 (NEGLIGENCE OF THIRD PARTIES) 12 8. This answering Defendant denies that Plaintiff was damaged as a proximate result of any 13 conduct on the part of this answering Defendant. This answering Defendant affirmatively alleges that 14 Plaintiff’s damages, if any, were proximately caused by the independent conduct of third parties. 15 Plaintiff’s recovery against this answering Defendant, if any, must therefore be reduced to the extent that 16 those damages, if any, were caused by the independent conduct of third parties. 17 EIGHTH AFFIRMATIVE DEFENSE 18 (REDUCTION TO PERCENT OF FAULT) 19 9. Plaintiff’s right to recover herein, if any right exists, is reduced and limited to the 20 percentage of negligence attributable to this answering Defendant pursuant to Civil Code §1431.2. 21 NINTH AFFIRMATIVE DEFENSE 22 (ASSUMPTION OF RISK) 23 10. The injuries, loss and/or damage, if any, sustained by Plaintiff was and is the result of an 24 open, obvious and apparent danger which was known to and recognized by Plaintiff who, nevertheless, 25 knowingly, willingly, intentionally and voluntarily exposed said Plaintiff to said danger and assumed the 26 risk of accident, injury and damage. 27 // 28 // -3- ANSWER TO COMPLAINT 1 TENTH AFFIRMATIVE DEFENSE 2 (FAILURE TO COMPLY WITH 3 PERSONAL FINANCIAL RESPONSIBILITY REQUIREMENTS) 4 11. This answering Defendant is informed and believes, and thereon allege that Plaintiff 5 and/or their agents failed to comply with the Personal Responsibility Act of 1996, Civil Code §3333.4 6 and related statutes requiring insurance maintained by or for Plaintiff in accordance with the financial 7 responsibility laws of this state. 8 ELEVENTH AFFIRMATIVE DEFENSE 9 (UNAVOIDABLE ACCIDENT) 10 12. This answering Defendant is informed and believes, and on that basis allege that any and 11 all injuries, losses or damages, if any, were the direct and proximate result of an unavoidable incident or 12 condition and, as such, were an act of God without fault or liability on the part of this Defendant. 13 TWELFTH AFFIRMATIVE DEFENSE 14 (SPOLIATION OF EVIDENCE) 15 13. This answering Defendant is informed and believes, and thereon alleges that Plaintiff 16 and/or its agents failed to preserve evidence, and by way of spoliation of evidence, Plaintiff and/or its 17 agents have prevented and/or precluded this answering Defendant from properly investigating and 18 preparing an adequate defense to the matters herein alleged, all to this answering Defendant’s 19 irreparable damage, thereby and thereupon providing a legal basis for relief, including, but not limited 20 to, an order barring introduction of evidence. 21 THIRTEENTH AFFIRMATIVE DEFENSE 22 (LACK OF STANDING) 23 14. This answering Defendant is informed and believes, and on that basis alleges that 24 Plaintiff’s lack standing to sue this answering Defendant. 25 FOURTEENTH AFFIRMATIVE DEFENSE 26 (SUPERSEDING CAUSES) 27 15. This answering Defendant is informed and believes, and on that basis alleges, that any 28 and all damages, if any, were the direct and proximate result of the intervening and superseding actions -4- ANSWER TO COMPLAINT 1 of other parties, either served or unserved, and not this answering Defendant, and that such intervening 2 and superseding actions of other parties, whether or not served, bar recovery herein on behalf of 3 Plaintiff. 4 FIFTEENTH AFFIRMATIVE DEFENSE 5 (LACHES) 6 16. Plaintiff has unreasonably delayed the commencement of the within action to the 7 substantial prejudice of this answering Defendant and by reason thereof have been guilty of laches, and 8 Plaintiff is thereby precluded from recovery in the within action. 9 SIXTEENTH AFFIRMATIVE DEFENSE 10 (UNCLEAN HANDS) 11 17. Plaintiff’s conduct with respect to the matters alleged in the Complaint deprives Plaintiff 12 of clean hands, and by reason of not coming into court with clean hands Plaintiff is precluded from 13 recovery in the within action. 14 SEVENTEENTH AFFIRMATIVE DEFENSE 15 (ESTOPPEL) 16 18. This answering Defendant is informed and believes, and thereon allege, that the Plaintiff 17 engaged in conduct and activity with respect to the subject of this litigation, which are the subject of 18 Plaintiff’s Complaint, and by reason of said activities and conduct is estopped from asserting any claims 19 for damages or seeking any other relief against this answering Defendant. 20 EIGHTEENTH AFFIRMATIVE DEFENSE 21 (COMPLAINT IS FRIVOLOUS) 22 19. This answering Defendant is informed and believes and thereon alleges that the 23 Complaint is frivolous and is not based on good faith within the meaning of Code of Civil Procedure 24 §128.5 et seq. and therefore answering Defendant is entitled to recover reasonable expenses, including 25 attorney’s fees in defending the Complaint. 26 // 27 // 28 // -5- ANSWER TO COMPLAINT 1 NINETEENTH AFFIRMATIVE DEFENSE 2 (RESERVATION) 3 20. This answering Defendant presently has insufficient knowledge or information on which 4 to form a belief as to whether it may have additional, as yet, unstated affirmative defenses available. 5 This answering Defendant herein reserves the right to assert additional defenses in the event that the 6 discovery indicates they would be appropriate. 7 WHEREFORE, this answering Defendant prays for judgment as follows: 8 1. That Plaintiff take nothing by way of this litigation; 9 2. For costs of suit; 10 3. For such other and further relief as the court may deem just and proper. 11 DATED: April 9, 2024 HOMAN, STONE & ROSSI ATTORNEYS 12 13 14 _______________________________ 15 Nicole Y. Mitchell, Esq. Attorneys for Betsy Renee Dunkel 16 17 18 19 20 21 22 23 24 25 26 27 28 -6- ANSWER TO COMPLAINT PROOF OF SERVICE (Code Civ. Proc., §§ 1013a, 2015) 1 STATE OF CALIFORNIA, COUNTY OF SAN BERNARDINO 2 3 I am employed in the County of San Bernardino, State of California. I am over the age of 18 and not a party to the within action; my business address is 1461 Ford Street, Suite 201, Redlands, CA 92373. 4 On April 9, 2024, I served the foregoing document(s) described as ANSWER TO COMPLAINT on 5 the other parties in this action as follows: 6 SEE ATTACHED MAILING LIST 7 [ ] (BY MAIL) By placing [X] the original [X] a true copy thereof enclosed in a sealed envelope(s) 8 addressed as to the above-named counsel of record or parties in propria persona. [X] I deposited such envelope(s) in the mail at Redlands, California, with postage thereon fully prepaid. [X] I am 9 readily familiar with the firm’s practice of collection and processing correspondence for mailing. It is deposited with the U.S. Postal Service on the same day in the ordinary course of business. I am aware 10 that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. 11 [X] (BY PERSONAL SERVICE) By placing [X] the original [X] a true copy thereof enclosed in a 12 sealed envelope(s) addressed as to the above-named counsel of record or parties in propria persona. I 13 caused such envelope(s) to be delivered to the addressee. 14 [X] (BY FEDERAL EXPRESS NEXT-DAY DELIVERY) By placing [X] the original [X] a true copy thereof enclosed in a sealed envelope(s) addressed to the above-named counsel of record or 15 parties in propria persona. I caused such envelope(s) to be prepared and picked up by Federal Express box at 1461 Ford Street Suite 201, Redlands, California, with delivery fees prepaid and 16 provided for, addressed to the person on whom said document is to be served. 17 [X] BY ELECTRONIC SERVICE: A copy of said document(s) was delivered by electronic transmission to the addressee(s) pursuant to C.C.P.1010.6(3) and/or C.R.C. Rule 2.251(a). 18 19 [X] (BY FACSIMILE) I caused said document(s), along with an unsigned copy of this Declaration, to be transmitted to a facsimile machine telephone number as last given by said counsel or party in 20 propria persona as noted above. 21 [X] FEDERAL: I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Pursuant to L.R. 5-3.2.1 and 5-3.2.2 the undersigned 22 declares service has been affected by way of CM/ECF or via Mail service as indicated above. 23 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the 24 foregoing is true and correct. 25 Executed on April 9, 2024, at Redlands, California. 26 HM _____________________________________ 27 HEATHER McCLURE 28 -7- ANSWER TO COMPLAINT MAILING LIST 1 CASE NO.: BCV-24-100707 2 John C. Hall, Esq. LAW OFFICES OF JOHN C. HALL 3 900 Truxtun Ave. Ste. 130 Bakersfield, CA 93301-4831 4 Email: john@johnchalllaw.com, olga@johnchalllaw.com, alethat@johnchalllaw.com Attorneys for Plaintiff, CHRISTINE ROSHELLE DELGADO 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -8- ANSWER TO COMPLAINT