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1 DENAE HILDEBRAND BUDDE, #166980
dbudde@donahue.com 5/21/2024
2 DONAHUE FITZGERALD LLP
Attorneys at Law
3 1646 N. California Boulevard, Suite 250
Walnut Creek, California 94596
4 Telephone: (925) 746-7770
Facsimile: (925) 746-7776
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Attorneys for Defendants
6 AMY WANG and MANN CHOW
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN MATEO
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SASSAN SADIGH, Case No. 24-CIV-00445
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Plaintiff, DEFENDANTS AMY WANG AND MANN
12 CHOW'S ANSWER TO PLAINTIFF'S
v. FIRST AMENDED COMPLAINT
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AMY WANG, MANN CHOW, MAHOP
14 CHOW, INC., and DOES 1 through 10,
inclusive, Action Filed: January 30, 2024
15 Trial Date: Not Set
Defendants.
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18 Pursuant to Sections 431.10, et seq., of the California Code of Civil Procedure, Defendants
19 AMY WANG ("Wang") and MANN CHOW ("Chow") ( collectively "Defendants") answer the First
20 Amended Complaint of Plaintiff SASSAN SADIGH ("Plaintiff" or "Sadigh"). Defendants deny,
21 both generally and specifically, each and every allegation of the Complaint and denies that Plaintiff
22 is entitled to any relief whatsoever.
23 GENERAL DENIAL
24 By virtue of the provisions of section 431.30 of the Code of Civil Procedure, Defendants
25 generally deny each and all of the allegations of the Complaint and further deny that the Plaintiff
26 has been damaged or is entitled to recover any sum or sums whatsoever or to any other relief from
27 Defendants.
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4878-0713-5671.2 1 Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
1 AFFIRMATIVE DEFENSES
2 Defendants plead the following separate defenses. Defendants reserve the right to assert
3 additional affirmative defenses that discovery indicates are proper.
4 FIRST AFFIRMATIVE DEFENSE
5 (Failure to State a Cause of Action)
6 1. As a separate and first affirmative defense to the Complaint, and to the purported
7 causes of action set forth therein, Defendant alleges that the Complaint, and the breach of contract
8 cause of action asserted therein against Defendant, fails to state facts sufficient to constitute any
9 valid cause of action against Defendant.
10 SECOND AFFIRMATIVE DEFENSE
11 (Equitable Estoppel)
12 2. As a separate and second affirmative defense to the Complaint and each purported
13 cause of action contained therein, Defendant alleges that Plaintiff, by its acts, omissions, and
14 statements, are estopped from asserting any of the claims upon which they seek relief.
15 THIRD AFFIRMATIVE DEFENSE
16 (Unclean Hands)
17 3. As a separate and third affirmative defense to the Complaint and each purported
18 cause of action contained therein, Defendant alleges that Plaintiff is barred in whole or in part from
19 prosecuting the purported causes of action set forth in the Complaint by the doctrine of unclean
20 hands.
21 FOURTH AFFIRMATIVE DEFENSE
22 (Laches)
23 4. As a separate and fourth affirmative defense to the Complaint and each purported
24 cause of action contained therein, Defendant alleges that Plaintiff is barred in whole or in part from
25 prosecuting the purported causes of action set forth in the Complaint by the doctrine of laches.
26 FIFTH AFFIRMATIVE DEFENSE
27 (Waiver)
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4878-0713-5671.2 -2- Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
1 5. As a separate and fifth affirmative defense to the Complaint and each purported cause
2 of action contained therein, Defendant alleges that Plaintiff, by its acts and omissions, have waived
3 its rights, if any, and, therefore, are not entitled to assert any of the claims upon which they seek
4 relief.
5 SIXTH AFFIRMATIVE DEFENSE
6 (Statute of Limitations)
7 6. As a separate and sixth affirmative defense to the Complaint and each purported
8 cause of action contained therein, Defendant alleges that the purported causes of action asserted in
9 the Complaint are barred by such statutes of limitation as may be applicable, including, but not
10 limited to, California Code of Civil Procedure sections 337, 338, 339, and 343.
11 SEVENTH AFFIRMATIVE DEFENSE
12 (Reasonable and Legal Actions)
13 7. As a separate and seventh affirmative defense to the Complaint and each purported
14 cause of action contained therein, Defendant acted reasonably, and within the scope of all relevant
15 laws, at all times and in all ways in connection with the matters described in the Complaint.
16 EIGHTH AFFIRMATIVE DEFENSE
17 (Failure to Mitigate Damages)
18 8. As a separate and eighth affirmative defense to the Complaint and each purported
19 cause of action contained therein, Defendant alleges that Plaintiff's claims, if any, are barred for its
20 failure, and/or the failure of the persons and/or entities acting on its behalf, to mitigate any purported
21 damages.
22 NINTH AFFIRMATIVE DEFENSE
23 (Lack of Actual and Proximate Causation)
24 9. As a separate and ninth affirmative defense to the Complaint and each purported
25 cause of action contained therein, Defendant is informed and believes that Plaintiff has suffered no
26 damages from any actual or proximate acts or omissions attributable to Defendant and no facts are
27 pleaded alleging any causal connection between Defendant's alleged omission and any injury
28 Plaintiff claims to have sustained.
4878-0713-5671.2 -3- Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
1 TENTH AFFIRMATIVE DEFENSE
2 (Third Party Conduct)
3 10. As a separate and tenth affirmative defense to the Complaint and each purported
4 cause of action contained therein, Defendant is informed and believe that if Plaintiff sustained any
5 of the losses or damages alleged in the Complaint, such losses or damages were caused, entirely or
6 in part, by the acts and/or omissions of third persons or entities, other than Defendants, over which
7 they had or have no direction or control.
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ELEVENTH AFFIRMATIVE DEFENSE
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(Third Party Damages)
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11. As a separate and eleventh affirmative defense to the Complaint and each purported
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cause of action contained therein, Defendant is informed and believe that as to all such losses or
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damages legally caused by the acts of others, Defendant cannot be held responsible or liable.
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14 TWELFTH AFFIRMATIVE DEFENSE
15 (Contract Performance)
16 12. As a separate and twelfth affirmative defense to the Complaint and each purported
17 cause of action contained therein, Defendant did what they were required to do under the alleged
18 contracts in the Complaint and so do not owe Plaintiff any damages for breach of contract.
19 THIRTEENTH AFFIRMATIVE DEFENSE
20 (Breach of Contract by Plaintiff)
21 13. As a separate and thirteenth affirmative defense to the Complaint and each purported
22 cause of action contained therein, Defendant is informed and believes that if Plaintiff sustained any
23 losses or damages, such losses or damages were caused by Plaintiff's failure to perform its
24 obligations under the alleged contract(s).
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4878-0713-5671.2 -4- Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
1 FOURTEENTH AFFIRMATIVE DEFENSE
2 (Plaintiff Negligence)
3 14. As a separate and fourteenth affirmative defense to the Complaint and each purported
4 cause of action contained therein, Defendant is informed and believes that Plaintiff was careless and
5 negligent about the matters alleged in its Complaint, and failed to exercise ordinary care, and such
6 carelessness and negligence comparatively contributed entirely or in some measure to Plaintiff's
7 damages such that Plaintiff's comparative negligence either bars or reduces any potential liability or
8 damages attributable to Defendant.
9 FIFTEENTH AFFIRMATIVE DEFENSE
10 (Unjust Enrichment)
11 15. As a separate and fifteenth affirmative defense to the Complaint and each purported
12 cause of action contained therein, Defendants are informed and believe that and thereon allege that
13 Plaintiff has suffered no damages from any actual or proximate acts or omissions attributable to
14 Defendants and would be unjustly enriched, if any relief were granted to Plaintiff as against
15 Defendant.
16 SIXTEENTH AFFIRMATIVE DEFENSE
17 (Uncertainty and Ambiguity)
18 16. As a separate and sixteenth affirmative defense to the Complaint and each purported
19 cause of action contained therein, Defendant is informed and believe that Plaintiff's cause of action
20 for breach of contract and is uncertain, ambiguous, and unintelligible.
21 SEVENTEENTH AFFIRMATIVE DEFENSE
22 (No Contractual Relationship)
23 17. As a separate and seventeenth affirmative defense to the Complaint and each
24 purported cause of action contained therein, Defendant alleges that no contractual relationship exists
25 between Plaintiff and Defendant and, therefore, Plaintiff's claims for breach of contract fails to state
26 a claim upon which relief can be granted against said Defendant, insofar as Plaintiff purports to
27 assert those claims against said Defendant.
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4878-0713-5671.2 -5- Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
1 EIGHTEENTH AFFIRMATIVE DEFENSE
2 (Intervening and Superseding Cause)
3 18. As a separate and eighteenth affirmative defense to the Complaint and each purported
4 cause of action contained therein, Defendants allege that Plaintiff's alleged loss and damages, if any,
5 were proximately caused by an intervening and superseding event, and therefore Plaintiff is barred
6 from recovering against Defendants.
7 NINETEENTH AFFIRMATIVE DEFENSE
8 (Good Faith)
9 19. As a separate and nineteenth affirmative defense to the Complaint and each purported
10 cause of action contained therein, Defendants are informed and believe that all acts or omissions of
11 Defendants as alleged in the Complaint, if in fact done, were performed in good faith, pursuant to
12 reasonable business justifications, and per the escrow instructions.
13 TWENTIETH AFFIRMATIVE DEFENSE
14 (Consent)
15 20. As a separate and twentieth affirmative defense to the Complaint and each purported
16 cause of action contained therein, Defendants allege that Plaintiff is barred from prosecuting the
17 purported causes of action set forth in the Complaint because Plaintiff, and/or the persons and/or
18 entities acting on its behalf, consented to and acquiesced in the subject conduct.
19 TWENTY-FIRST AFFIRMATIVE DEFENSE
20 (Additional Affirmative Defenses)
21 21. As a separate and twenty-first affirmative defense to the Complaint and each
22 purported cause of action contained therein, Defendants reserve the right to assert additional
23 affirmative defenses in the event that additional defenses become apparent during the course of this
24 litigation.
25 PRAYER FOR RELIEF
26 WHEREFORE, Defendant prays for relief as follows:
27 1. That take nothing by way of its Complaint;
28 2. For attorneys' fees and costs incurred in defense of this action; and
4878-0713-5671.2 -6- Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
1 3. For such other and further relief as the court may deem proper.
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3 Dated: May 21, 2024 DONAHUE FITZGERALD LLP
Attorneys at Law
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6 By:
Denae Hildebrand Budde
7 Attorneys for Defendants
AMY WANG and MANN CHOW
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4878-0713-5671.2 -7- Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
1 PROOF OF SERVICE
2 Sadigh v. Wang, et al.
Case No. 24CIV00445
3
STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA
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At the time of service, I was over 18 years of age and not a party to this action. I am
5 employed in the County of Contra Costa, State of California. My business address is 1646 N.
California Boulevard, Suite 250, Walnut Creek, CA 94596.
6
On May 21, 2024, I served true copies of the following document(s) described as
7 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST
AMENDED COMPLAINT on the interested parties in this action as follows:
8
Jeffrey R. Windsor, Esq. Attorneys for Plaintiff
9 WINDSOR PROFESSIONAL LAW SASSAN SADIGH
CORPORATION
10 177 Bovet Rd., Ste. 600
San Mateo CA 94402
11 Tel: (650) 638-2360
Fax: (415) 358-4677
12 jeff@windsor-plc.com
antonella@windsor-plc.com
13
14 BY E-MAIL 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
15 document(s) to be sent from e-mail address lbarrett@donahue.com to the persons at the e-mail
addresses listed in the Service List. I did not receive, within a reasonable time after the transmission,
16 any electronic message or other indication that the transmission was unsuccessful.
17 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
18
Executed on May 21, 2024, at Walnut Creek, California.
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21 Laura Barrett
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4878-0713-5671.2 -8- Case No. 24-CIV-00445
DEFENDANTS AMY WANG AND MANN CHOW'S
ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT
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1 DENAE HILDEBRAND BUDDE, #166980 dbudde@donahue.com 5/21/2024 2 DONAHUE FITZGERALD LLP Attorneys at Law 3 1646 N. California Boulevard, Suite 250 Walnut Creek, California 94596 4 Telephone: (925) 746-7770 Facsimile: (925) 746-7776 5 Attorneys for Defendants 6 AMY WANG and MANN CHOW 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN MATEO 9 10 SASSAN SADIGH, Case No. 24-CIV-00445 11 Plaintiff, DEFENDANTS AMY WANG AND MANN 12 CHOW'S ANSWER TO PLAINTIFF'S v. FIRST AMENDED COMPLAINT 13 AMY WANG, MANN CHOW, MAHOP 14 CHOW, INC., and DOES 1 through 10, inclusive, Action Filed: January 30, 2024 15 Trial Date: Not Set Defendants. 16 17 18 Pursuant to Sections 431.10, et seq., of the California Code of Civil Procedure, Defendants 19 AMY WANG ("Wang") and MANN CHOW ("Chow") ( collectively "Defendants") answer the First 20 Amended Complaint of Plaintiff SASSAN SADIGH ("Plaintiff" or "Sadigh"). Defendants deny, 21 both generally and specifically, each and every allegation of the Complaint and denies that Plaintiff 22 is entitled to any relief whatsoever. 23 GENERAL DENIAL 24 By virtue of the provisions of section 431.30 of the Code of Civil Procedure, Defendants 25 generally deny each and all of the allegations of the Complaint and further deny that the Plaintiff 26 has been damaged or is entitled to recover any sum or sums whatsoever or to any other relief from 27 Defendants. 28 4878-0713-5671.2 1 Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1 AFFIRMATIVE DEFENSES 2 Defendants plead the following separate defenses. Defendants reserve the right to assert 3 additional affirmative defenses that discovery indicates are proper. 4 FIRST AFFIRMATIVE DEFENSE 5 (Failure to State a Cause of Action) 6 1. As a separate and first affirmative defense to the Complaint, and to the purported 7 causes of action set forth therein, Defendant alleges that the Complaint, and the breach of contract 8 cause of action asserted therein against Defendant, fails to state facts sufficient to constitute any 9 valid cause of action against Defendant. 10 SECOND AFFIRMATIVE DEFENSE 11 (Equitable Estoppel) 12 2. As a separate and second affirmative defense to the Complaint and each purported 13 cause of action contained therein, Defendant alleges that Plaintiff, by its acts, omissions, and 14 statements, are estopped from asserting any of the claims upon which they seek relief. 15 THIRD AFFIRMATIVE DEFENSE 16 (Unclean Hands) 17 3. As a separate and third affirmative defense to the Complaint and each purported 18 cause of action contained therein, Defendant alleges that Plaintiff is barred in whole or in part from 19 prosecuting the purported causes of action set forth in the Complaint by the doctrine of unclean 20 hands. 21 FOURTH AFFIRMATIVE DEFENSE 22 (Laches) 23 4. As a separate and fourth affirmative defense to the Complaint and each purported 24 cause of action contained therein, Defendant alleges that Plaintiff is barred in whole or in part from 25 prosecuting the purported causes of action set forth in the Complaint by the doctrine of laches. 26 FIFTH AFFIRMATIVE DEFENSE 27 (Waiver) 28 4878-0713-5671.2 -2- Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1 5. As a separate and fifth affirmative defense to the Complaint and each purported cause 2 of action contained therein, Defendant alleges that Plaintiff, by its acts and omissions, have waived 3 its rights, if any, and, therefore, are not entitled to assert any of the claims upon which they seek 4 relief. 5 SIXTH AFFIRMATIVE DEFENSE 6 (Statute of Limitations) 7 6. As a separate and sixth affirmative defense to the Complaint and each purported 8 cause of action contained therein, Defendant alleges that the purported causes of action asserted in 9 the Complaint are barred by such statutes of limitation as may be applicable, including, but not 10 limited to, California Code of Civil Procedure sections 337, 338, 339, and 343. 11 SEVENTH AFFIRMATIVE DEFENSE 12 (Reasonable and Legal Actions) 13 7. As a separate and seventh affirmative defense to the Complaint and each purported 14 cause of action contained therein, Defendant acted reasonably, and within the scope of all relevant 15 laws, at all times and in all ways in connection with the matters described in the Complaint. 16 EIGHTH AFFIRMATIVE DEFENSE 17 (Failure to Mitigate Damages) 18 8. As a separate and eighth affirmative defense to the Complaint and each purported 19 cause of action contained therein, Defendant alleges that Plaintiff's claims, if any, are barred for its 20 failure, and/or the failure of the persons and/or entities acting on its behalf, to mitigate any purported 21 damages. 22 NINTH AFFIRMATIVE DEFENSE 23 (Lack of Actual and Proximate Causation) 24 9. As a separate and ninth affirmative defense to the Complaint and each purported 25 cause of action contained therein, Defendant is informed and believes that Plaintiff has suffered no 26 damages from any actual or proximate acts or omissions attributable to Defendant and no facts are 27 pleaded alleging any causal connection between Defendant's alleged omission and any injury 28 Plaintiff claims to have sustained. 4878-0713-5671.2 -3- Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1 TENTH AFFIRMATIVE DEFENSE 2 (Third Party Conduct) 3 10. As a separate and tenth affirmative defense to the Complaint and each purported 4 cause of action contained therein, Defendant is informed and believe that if Plaintiff sustained any 5 of the losses or damages alleged in the Complaint, such losses or damages were caused, entirely or 6 in part, by the acts and/or omissions of third persons or entities, other than Defendants, over which 7 they had or have no direction or control. 8 ELEVENTH AFFIRMATIVE DEFENSE 9 (Third Party Damages) 10 11. As a separate and eleventh affirmative defense to the Complaint and each purported 11 cause of action contained therein, Defendant is informed and believe that as to all such losses or 12 damages legally caused by the acts of others, Defendant cannot be held responsible or liable. 13 14 TWELFTH AFFIRMATIVE DEFENSE 15 (Contract Performance) 16 12. As a separate and twelfth affirmative defense to the Complaint and each purported 17 cause of action contained therein, Defendant did what they were required to do under the alleged 18 contracts in the Complaint and so do not owe Plaintiff any damages for breach of contract. 19 THIRTEENTH AFFIRMATIVE DEFENSE 20 (Breach of Contract by Plaintiff) 21 13. As a separate and thirteenth affirmative defense to the Complaint and each purported 22 cause of action contained therein, Defendant is informed and believes that if Plaintiff sustained any 23 losses or damages, such losses or damages were caused by Plaintiff's failure to perform its 24 obligations under the alleged contract(s). 25 26 27 28 4878-0713-5671.2 -4- Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1 FOURTEENTH AFFIRMATIVE DEFENSE 2 (Plaintiff Negligence) 3 14. As a separate and fourteenth affirmative defense to the Complaint and each purported 4 cause of action contained therein, Defendant is informed and believes that Plaintiff was careless and 5 negligent about the matters alleged in its Complaint, and failed to exercise ordinary care, and such 6 carelessness and negligence comparatively contributed entirely or in some measure to Plaintiff's 7 damages such that Plaintiff's comparative negligence either bars or reduces any potential liability or 8 damages attributable to Defendant. 9 FIFTEENTH AFFIRMATIVE DEFENSE 10 (Unjust Enrichment) 11 15. As a separate and fifteenth affirmative defense to the Complaint and each purported 12 cause of action contained therein, Defendants are informed and believe that and thereon allege that 13 Plaintiff has suffered no damages from any actual or proximate acts or omissions attributable to 14 Defendants and would be unjustly enriched, if any relief were granted to Plaintiff as against 15 Defendant. 16 SIXTEENTH AFFIRMATIVE DEFENSE 17 (Uncertainty and Ambiguity) 18 16. As a separate and sixteenth affirmative defense to the Complaint and each purported 19 cause of action contained therein, Defendant is informed and believe that Plaintiff's cause of action 20 for breach of contract and is uncertain, ambiguous, and unintelligible. 21 SEVENTEENTH AFFIRMATIVE DEFENSE 22 (No Contractual Relationship) 23 17. As a separate and seventeenth affirmative defense to the Complaint and each 24 purported cause of action contained therein, Defendant alleges that no contractual relationship exists 25 between Plaintiff and Defendant and, therefore, Plaintiff's claims for breach of contract fails to state 26 a claim upon which relief can be granted against said Defendant, insofar as Plaintiff purports to 27 assert those claims against said Defendant. 28 4878-0713-5671.2 -5- Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1 EIGHTEENTH AFFIRMATIVE DEFENSE 2 (Intervening and Superseding Cause) 3 18. As a separate and eighteenth affirmative defense to the Complaint and each purported 4 cause of action contained therein, Defendants allege that Plaintiff's alleged loss and damages, if any, 5 were proximately caused by an intervening and superseding event, and therefore Plaintiff is barred 6 from recovering against Defendants. 7 NINETEENTH AFFIRMATIVE DEFENSE 8 (Good Faith) 9 19. As a separate and nineteenth affirmative defense to the Complaint and each purported 10 cause of action contained therein, Defendants are informed and believe that all acts or omissions of 11 Defendants as alleged in the Complaint, if in fact done, were performed in good faith, pursuant to 12 reasonable business justifications, and per the escrow instructions. 13 TWENTIETH AFFIRMATIVE DEFENSE 14 (Consent) 15 20. As a separate and twentieth affirmative defense to the Complaint and each purported 16 cause of action contained therein, Defendants allege that Plaintiff is barred from prosecuting the 17 purported causes of action set forth in the Complaint because Plaintiff, and/or the persons and/or 18 entities acting on its behalf, consented to and acquiesced in the subject conduct. 19 TWENTY-FIRST AFFIRMATIVE DEFENSE 20 (Additional Affirmative Defenses) 21 21. As a separate and twenty-first affirmative defense to the Complaint and each 22 purported cause of action contained therein, Defendants reserve the right to assert additional 23 affirmative defenses in the event that additional defenses become apparent during the course of this 24 litigation. 25 PRAYER FOR RELIEF 26 WHEREFORE, Defendant prays for relief as follows: 27 1. That take nothing by way of its Complaint; 28 2. For attorneys' fees and costs incurred in defense of this action; and 4878-0713-5671.2 -6- Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1 3. For such other and further relief as the court may deem proper. 2 3 Dated: May 21, 2024 DONAHUE FITZGERALD LLP Attorneys at Law 4 5 6 By: Denae Hildebrand Budde 7 Attorneys for Defendants AMY WANG and MANN CHOW 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4878-0713-5671.2 -7- Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1 PROOF OF SERVICE 2 Sadigh v. Wang, et al. Case No. 24CIV00445 3 STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA 4 At the time of service, I was over 18 years of age and not a party to this action. I am 5 employed in the County of Contra Costa, State of California. My business address is 1646 N. California Boulevard, Suite 250, Walnut Creek, CA 94596. 6 On May 21, 2024, I served true copies of the following document(s) described as 7 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT on the interested parties in this action as follows: 8 Jeffrey R. Windsor, Esq. Attorneys for Plaintiff 9 WINDSOR PROFESSIONAL LAW SASSAN SADIGH CORPORATION 10 177 Bovet Rd., Ste. 600 San Mateo CA 94402 11 Tel: (650) 638-2360 Fax: (415) 358-4677 12 jeff@windsor-plc.com antonella@windsor-plc.com 13 14 BY E-MAIL 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 15 document(s) to be sent from e-mail address lbarrett@donahue.com to the persons at the e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, 16 any electronic message or other indication that the transmission was unsuccessful. 17 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 18 Executed on May 21, 2024, at Walnut Creek, California. 19 20 21 Laura Barrett 22 23 24 25 26 27 28 4878-0713-5671.2 -8- Case No. 24-CIV-00445 DEFENDANTS AMY WANG AND MANN CHOW'S ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT