Answer: HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL

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                                SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
Mar-12-2015 12:11 pm

Case Number: CGC-15-544243
Filing Date: Mar-12-2015 12:10

Filed by: DAVID YUEN
Juke Box: 001 Image: 04827877
ANSWER

HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL

001004827877

Instructions:
Please place this sheet on top of the document to be scanned.PLD-C-010

ATTORNEY OR PARTY WITHOUT ATTORNEY (NAME AND ADDRESS): TELEPHONE: 415-710-9296 FOR COURT USE ONLY:

VICTORIA L. CARD I L
P.O.BOX 502 ¢ E
PETALUMA, CA 94953 Superior Court
ATTORNEY FOR (NAME): IN PRO PER. ‘
Insert name of court, judicial district or branch court, if any, and post office and street address: MAR 1 2 201

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
400 MCALLISTER STREET ROOM 103
SAN FRANCISCO, CA 94102

PLAINTIFF:
HDM FURNITURE INDUSTRIES INC. HERTAGE HOME GROUP LLC.

a Far BE ee

DEFENDANT:
VICTORIA L. CARD

ANSWER—Contract CASE NUMBER:
[#1 TO COMPLAINT OF (name): HDM furniture Industries Inc. Heratage Home (|

(] To CROSS-COMPLAINT (name):

CGC - 15 - 544243

1. This pleading, including attachments and exhibits, consists of the following number of pages: 2
2. DEFENDANT (name): VICTORIAL. CARD
answers the complaint or cross-complaint as follows:
3. Check ONLY ONE of the next two boxes:
a. [4] Defendant generally denies each statement of the complaint or cross-complaint. (Do not check this box if
the verified complaint or cross-complaint demands more than $1,000.)
b. [£] Defendant admits that all of the statements of the complaint or cross-complaint are true EXCEPT:
(1) Defendant claims the following statements are false (use paragraph numbers or explain):

Plaintiff's statement is false. Plaintiff has no proof of any kind to substantiate claim.

This is pure harassment and in violation of CIVIL CODE SECTION 1788.10 and 1788.18
the Fair Debt Collection Act.

[#1 Continued on Attachment 3.b.(1).
(2) Defendant has no information or belief that the following statements are true, so defendant denies them (use
paragraph numbers or explain):

Paragraph 1 to 13

Plaintiff's allegations are without any proof, plain nonsense, fabrication and baseless. I
have never had any business dealings or otherwise with plaintiff.

[1 Continued on Attachment 3.b.(2).

tf this form is used to answer @ cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant.
Page tof2

Form Approved for Optional Use of Pr A:
“judicial Council of California ANSWER—Contract Cort of Ci Procedure, § 428.12
PLD-C-010 (Rev. January 1, 2007] wunw.courtinto.PLD-C-010
SHORT TITLE: CASE NUMBER:

VICTORIA L. CARD VS. HDM Industries Inc. Heritage Home Group LLC CGC - 15 - 544243

ANSWER—Contract

4. [4] AFFIRMATIVE DEFENSES Defendant alleges the following additional reasons that plaintiff is not
entitled to recover anything:

PLAINTIFF'S COMPLAINT IS ONLY A QUESTION WHICH RESTS ON AN UNWARRANTED
ASSUMPTION. I DON'T OWE PLAINTIFF A CENT.

WHEREFORE, defendant prays that this Court dismiss the ENTIRE complaint of the plaintiff.

[1 Continued on Attachment 4.
5. Other

Plaintiff's complaint has no basis nor proof. Defendant prays this court to dismiss plaintiff's
complaint.

6. DEFENDANT PRAYS
a. that plaintiff take nothing.
b. [#1] for costs of suit.
c. other (specify):

I am almost 60 year old, single women self employed in business for over 35 years in the Bay
Area. I have to represent myself without a lawyer because I can't afford or justify the expense. I

fully rely on the Honorable Judge in Court to apply the correct law and reach the right
conclusions.

1.I pray the court dismisses plaintiff's complaint.

2.1 pray judgment against plaintiff.

3.1 pray for cost of suit incurred; and

4. For such other further relief as the court may find just and proper.

nnn VietoriaL.Card Vite 7-Cad

(Signature of party or attorney)

PLD-C - 010 [Rev. January 1, 2007} ANSWER—C ct Page 2 of 2PROOF OF SERVICE
The undersigned declares as follows:
I am a citizen of the United States, over 18 years of age, reside in the County of
San Francisco State of California, and am not a party to the within cause of action. My
business address is 1495 Francisco Blvd G San Rafael, CA 94901
On 03/ 10 / 2015 I served a copy of the document (s) described as: ANSWER TO
COMPLAINT On all interested parties in this action as addressed below in the indicated

manner:

Law Offices of Steven A. Booska Case number: CGC - 15 - 544243

1141 Harbor Bay Pkwy Suite 206

Alameda CA 94502

T. 415-397-4345

F, 415-982-3440 / / / /

_____X (BY MAIL) I placed said document(s) in a sealed envelope, with postage
thereon fully prepaid for first class mail, and placed such envelope in the United States
mail at Sonoma County, California..

X (BY FAX) I caused said document to be faxed to the addressee(s) and then placed in
the United States Mail.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on this Tuesday day
of 03/10/2015 San Rafael, California.

Michael Mott Signature