Answer: JOANN VALDEZ -v- SEIU LOCAL 121RN. AS A CALIFORNIA ORGANIZATION Print

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                                1   William D Naeve SBN 92270                                                   F i                  r
                                                                                                          LiFORNIA

                                                                        su   R oR co
     MURCHISON         CUMMING LLP
 2   18201 Von Karman Avenue Suite 950                                   COAN E            r1s   ii   c   isR
     Irvine California 92612 1077
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 4   E Mail       wnaeve@murchisonlaw com
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                                                                                      rA
 5   Attorneys for ATTORNEYS FOR
     DEFENDANT SEIU LOCAL 121 RN
 6


 7

 8                        SUPERIOR COURT OF THE STATE OF CALIFORNIA


 9                  COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT


10

11   JOANN VALDEZ          individually                  CASE NO CIV DS 2003745

12                    Plaintiff                          Assigned to Hon Janet Frangie
                                                         Dept S29
13             vs

                                                         ANSWER OF DEFENDANT SEIU LOCAL
14   SEIU Local 121 RN as a California                   121 RN TO PLAINTIFF S UNVERIFIED
     Organization and DOES 1 through 25                  COMPLAINT
15   inclusive
                                                         Cal Code Civ Proc                 431 30 d
16                    Defendant
                                                         Action Filed                February 4 2020
17                                                       Trial Dat                   None Set
                                                                                                                     17 t
                                                                         h   A        u           7             1
18
               COMES NOW defendant SEIU LOCAL 121 RN and in answer to plaintiffs
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     unverified complaint on file herein for itself and itself alone admits denies and alleges as
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     follows
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               1      Pursuant to the provisions of California Code of Civil Procedure section
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     431 30 d       this answering defendant denies both generally and specifically each and
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     every allegation contained within plaintiff s form complaint and each and every cause of
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     action contained within plaintiff s complaint and the whole thereof This answering
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     defendant further specifically denies that plaintiff was damaged in the sum or sums
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     alleged or to be alleged or in any sums whatsoever or at all and further specifically
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     denies that plaintiff has sustained any injury damage or loss if any by reason of any act
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          ANSWER OF DEFENDANT SEIU LOCAL 121RN TO PLAINTIFF S UNVERIFIED COMPLAINT
 1   or omission on the part of this answering defendant and further denies that plaintiff is
 2   entitled to the relief sought within plaintiffs form complaint or to any other relief of whatever

 3   character   or at all



 4                                     FIRST AFFIRMATIVE DEFENSE


 5          2       As and for a first separate and distinct affirmative defense to each and every

 6   cause of action contained in Plaintiff s unverified complaint this answering Defendant

 7   alleges that Plaintiff s complaint fails to allege facts sufficient to constitute any cause of

 8   action against this answering Defendant

 9                                    SECOND AFFIRMATIVE DEFENSE

10          3       As and for a second separate and distinct affirmative defense to each and

11   every cause of action contained in Plaintiff s unverified complaint this answering
12   Defendant alleges that Plaintiff is equitably estopped from asserting any cause of action

13   against this answering Defendant because of the acts errors and or omissions of Plaintiff
14                                     THIRD AFFIRMATIVE DEFENSE


15          4       As and for a third separate and distinct affirmative defense to each and

16   every cause of action contained in Plaintiff s unverified complaint this answering

17   Defendant alleges that it acted in good faith and in a reasonable manner with respect to all

18   decisions and actions that affected Plaintiff

19                                    FOURTH AFFIRMATIVE DEFENSE


20          5       As and for a fourth separate and distinct affirmative defense to each and

21   every cause of action contained in Plaintiff s unverified complaint this answering
22   Defendant alleges that the at all times pertinent this answering Defendant acted

23   reasonably and with a good faith belief in its legal right to act in the manner in which it did
24                                     FIFTH AFFIRMATIVE DEFENSE


25          6       As and for a fifth separate and distinct affirmative defense to each and every

26   cause of action contained in Plaintiff s unverified complaint this answering Defendant

27   alleges that any and all conduct of which Plaintiff complains and which is attributed to this

28   answering Defendant was a just and proper exercise of management discretion on the

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           ANSWER OF DEFENDANT SEIU LOCAL 121 RN TO PLAINTIFF S UNVERIFIED COMPLAINT