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MEM
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
May-03-2010 3:49 pm
Case Number: CGC-10-497688
Filing Date: Apr-30-2010 3:48
Juke Box: 001 Image: 02838613
ANSWER
INFINITY INSURANCE COMPANY VS. BRANDI GREGG KEISER et al
001002838613
Instructions:
Please place this sheet on top of the document to be scanned.-~ PLD-PI-003
ATTORNEY OR PARTY WITHOUT arrow nan ‘AND ADDRESS); TELEPHONE NO.:“we# | FOR COURT USE ONLY
(916) 912-5605
Narrmayet Taonus, In Pro Per
3016 8th Street
Sacramento, CA 95817 F J
ATTORNEY FOR (AME): In Pro Per
Insert name of court, judicial district or branch court, if any, and post office and street address: Superior a aural Calfomia
San Francisco County Superior Court
San Francsico District-Limited APR 3 0 2010
400 McAllister, Room 103 CLERK OF THE,COURT
San Francisco, CA_94102 BY: i
PLAINTIFF: ‘Deputy Clerk
INFINITY INSURANCE COMPANY
DEFENDANT:
BRANDI GREGG KEISER; NARRMAYET TAONUS
CASE NUMBER:
ANSWER-Personal Injury, Property Damage, Wrongful Death CGC-10-497688
({) COMPLAINT OF (name): Infinity Insurance Company
LJ CROSS-COMPLAINT OF (name):
4. This pleading, including attachments and exhibits, consists of the following number of pages: 2
DEFENDANT OR CROSS-DEFENDANT (name):
NARRMAYET TAONUS
2. () Generally denies each allegation of the unverified complaint or cross-complaint.
3. a. CC) DENIES each allegation of the following numbered paragraphs:
b. ] ADMITS each allegation of the following numbered paragraphs:
c. (DENIES, ON INFORMATION AND BELIEF, each allegation of the following numbered paragraphs:
d. (2) DENIES, BECAUSE OF LACK OF SUFFICIENT INFORMATION OR BELIEF TO ANSWER, each allegation
of the following numbered paragraphs:
e. LJ ADMITS the following allegations and generally denies all other allegations:
page 1of2
Fe red for Of val Use . Code of Civil Procedure § 425,12
‘Tose Counc of Caltornta, ANSWER - Personal Injury, Property Damage, Wrongful Death ve eburteoa gov
PLD-P1-003 [Rev. January 1, 2007}
Martin Deans
ESSENTIAL FORMS™fo ~ PLD-PI-003
SHORT TITLE: —~ CASE NUMBER:
INFINITY V. KEISER CGC-10-497688
ANSWER-Personal Injury, Property Damage, Wrongful Death
f. [Z) DENIES the following allegations and admits all other allegations:
g. CJ Other (specify):
AFFIRMATIVELY ALLEGES AS A DEFENSE
4, (QQ The comparative fault of plaintiff or cross-complainant (name) :Brandi Gregg Keiser
as follows:
Brandi Gregg Keiser was the owner of the vehicle she purchased from me. 1 was not a participant in the
accident that is the subject of this action.
5. [2] The expiration of the Statute of Limitations as follows:
6. [KJ Other (specify):
As a second affirmative defense, this answering Defendant alleges that she is not liable because the vehicle was sold to the codefendant and
that the necessary paperwork to release the Defendant's liability was properly submitted to the California Department of Motor Vehicles.
Asa result, Defendant is not liable for reasons that include, but are not limited to, Vehicle Code section 5602.
Asa third affirmative defense, and in the alternative to the second affirmative defense, this answering Defendant claims that her liability
is limited pursuant to Vehicle Code section 17151
As a fourth affirmative defense, the Complaint and each cause of action fails to state a cause of action against this Defendant,
7. DEFENDANT OR CROSS-DEFENDANT PRAYS
For costs of suit and that plaintiff or cross-complainant take nothing
(E] Other (specify):
For such other and further relief as the Court deems just and proper.
_
Maman Nui \—
1
(Signature of party or attorney)
{Type or print name)
Page 2 of 2
LD-PI-003 [Rev January 1, 2007] ANSWER - Personal Injury, Property Damage, Wrongful Death
Martin Deans
ESSENTIAL FORMS"POS-030
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, ak number, and address) : FOR COURT USE ONLY
Narrmayet Taonus
3016 8th Street
Sacramento, CA 95817
teepHoneno: (916) 912-5605 FAX NO.(Optional)
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name): In Pro Per
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
strectaonress) 400 McAllister, Room 103
MAILING ADDRESS:
crryanpzpcone: San Francisco, CA 94102
srancHname: San Franesico District-Limited
PETITIONER/PLAINTIFF: INFINITY INSURANCE COMPANY
RESPONDENTIDEFENDANT: BRANDI GREGG KEISER; NARRMAYET TAQ
CASE NUMBER:
PROOF OF SERVICE BY FIRST-CLASS MAIL - CIVIL CGC-10-497688
(Do not use this Proof of Service to show service of a Summons and Complaint.)
1. Lam over 18 years of age and not a party to this action. | am a resident of or employed in the county where the mailing
took place.
2. My residence or business address is:
Civil Self Help Center, Sacramento County Public Law Library
813 Sixth Street
Sacramento, CA 95814
3, On (date): April 29, 2010 I mailed from {city and state): Sacramento, CA
the following documents (specify):
Answer-Personal Injury, Property Damage, Wrongful Death
(CQ The documents are listed in the Attachment to Proof of Service by First-Class Mail - Civil (Documents Served)
(form POS-030(D)).
4. | served the documents by enclosing them in an envelope and(check one):
a. [C) depositing the sealed envelope with the United States Postal Service with the postage fully prepaid.
b. [XJ placing the envelope for collection and mailing following our ordinary business practices. | am readily familiar with this
business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is
placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in
a sealed envelope with postage fully prepaid.
5. The envelope was addressed and mailed as follows:
a, Name ofperson served: Michael R. Lea
b. Address of person served:
Lea & Navinskus, A Law Corporation
134 W. Wilshire Avenue
Fullerton, CA 92832
(2) The name and address of each person to whom | mailed the documents is listed in the Attachment to Proof of Service
by First-Class Mail-Civil (Persons Served) (POS-030(P)).
| declare under penalty of perjury under the laws of the State of California the
Date: April 29, 2010
{TYPE OR PRINT NAME OF PERSON COMPLETING THIS FORM) PLETING THIS FORM)
Fam Approved for Optional Use PROOF OF SERVICE BY FIRST-CLASS MAIL H Cave of Givi Procedure, $§ 1013, 1013
POS.030 [New January 1, 2005} Manin Deans (Proof of Service) mene oeeIO C2. ON
“e) ESSENTIAL FORMS™
Preview
MEM SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet May-03-2010 3:49 pm Case Number: CGC-10-497688 Filing Date: Apr-30-2010 3:48 Juke Box: 001 Image: 02838613 ANSWER INFINITY INSURANCE COMPANY VS. BRANDI GREGG KEISER et al 001002838613 Instructions: Please place this sheet on top of the document to be scanned.-~ PLD-PI-003 ATTORNEY OR PARTY WITHOUT arrow nan ‘AND ADDRESS); TELEPHONE NO.:“we# | FOR COURT USE ONLY (916) 912-5605 Narrmayet Taonus, In Pro Per 3016 8th Street Sacramento, CA 95817 F J ATTORNEY FOR (AME): In Pro Per Insert name of court, judicial district or branch court, if any, and post office and street address: Superior a aural Calfomia San Francisco County Superior Court San Francsico District-Limited APR 3 0 2010 400 McAllister, Room 103 CLERK OF THE,COURT San Francisco, CA_94102 BY: i PLAINTIFF: ‘Deputy Clerk INFINITY INSURANCE COMPANY DEFENDANT: BRANDI GREGG KEISER; NARRMAYET TAONUS CASE NUMBER: ANSWER-Personal Injury, Property Damage, Wrongful Death CGC-10-497688 ({) COMPLAINT OF (name): Infinity Insurance Company LJ CROSS-COMPLAINT OF (name): 4. This pleading, including attachments and exhibits, consists of the following number of pages: 2 DEFENDANT OR CROSS-DEFENDANT (name): NARRMAYET TAONUS 2. () Generally denies each allegation of the unverified complaint or cross-complaint. 3. a. CC) DENIES each allegation of the following numbered paragraphs: b. ] ADMITS each allegation of the following numbered paragraphs: c. (DENIES, ON INFORMATION AND BELIEF, each allegation of the following numbered paragraphs: d. (2) DENIES, BECAUSE OF LACK OF SUFFICIENT INFORMATION OR BELIEF TO ANSWER, each allegation of the following numbered paragraphs: e. LJ ADMITS the following allegations and generally denies all other allegations: page 1of2 Fe red for Of val Use . Code of Civil Procedure § 425,12 ‘Tose Counc of Caltornta, ANSWER - Personal Injury, Property Damage, Wrongful Death ve eburteoa gov PLD-P1-003 [Rev. January 1, 2007} Martin Deans ESSENTIAL FORMS™fo ~ PLD-PI-003 SHORT TITLE: —~ CASE NUMBER: INFINITY V. KEISER CGC-10-497688 ANSWER-Personal Injury, Property Damage, Wrongful Death f. [Z) DENIES the following allegations and admits all other allegations: g. CJ Other (specify): AFFIRMATIVELY ALLEGES AS A DEFENSE 4, (QQ The comparative fault of plaintiff or cross-complainant (name) :Brandi Gregg Keiser as follows: Brandi Gregg Keiser was the owner of the vehicle she purchased from me. 1 was not a participant in the accident that is the subject of this action. 5. [2] The expiration of the Statute of Limitations as follows: 6. [KJ Other (specify): As a second affirmative defense, this answering Defendant alleges that she is not liable because the vehicle was sold to the codefendant and that the necessary paperwork to release the Defendant's liability was properly submitted to the California Department of Motor Vehicles. Asa result, Defendant is not liable for reasons that include, but are not limited to, Vehicle Code section 5602. Asa third affirmative defense, and in the alternative to the second affirmative defense, this answering Defendant claims that her liability is limited pursuant to Vehicle Code section 17151 As a fourth affirmative defense, the Complaint and each cause of action fails to state a cause of action against this Defendant, 7. DEFENDANT OR CROSS-DEFENDANT PRAYS For costs of suit and that plaintiff or cross-complainant take nothing (E] Other (specify): For such other and further relief as the Court deems just and proper. _ Maman Nui \— 1 (Signature of party or attorney) {Type or print name) Page 2 of 2 LD-PI-003 [Rev January 1, 2007] ANSWER - Personal Injury, Property Damage, Wrongful Death Martin Deans ESSENTIAL FORMS"POS-030 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, ak number, and address) : FOR COURT USE ONLY Narrmayet Taonus 3016 8th Street Sacramento, CA 95817 teepHoneno: (916) 912-5605 FAX NO.(Optional) E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): In Pro Per SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco strectaonress) 400 McAllister, Room 103 MAILING ADDRESS: crryanpzpcone: San Francisco, CA 94102 srancHname: San Franesico District-Limited PETITIONER/PLAINTIFF: INFINITY INSURANCE COMPANY RESPONDENTIDEFENDANT: BRANDI GREGG KEISER; NARRMAYET TAQ CASE NUMBER: PROOF OF SERVICE BY FIRST-CLASS MAIL - CIVIL CGC-10-497688 (Do not use this Proof of Service to show service of a Summons and Complaint.) 1. Lam over 18 years of age and not a party to this action. | am a resident of or employed in the county where the mailing took place. 2. My residence or business address is: Civil Self Help Center, Sacramento County Public Law Library 813 Sixth Street Sacramento, CA 95814 3, On (date): April 29, 2010 I mailed from {city and state): Sacramento, CA the following documents (specify): Answer-Personal Injury, Property Damage, Wrongful Death (CQ The documents are listed in the Attachment to Proof of Service by First-Class Mail - Civil (Documents Served) (form POS-030(D)). 4. | served the documents by enclosing them in an envelope and(check one): a. [C) depositing the sealed envelope with the United States Postal Service with the postage fully prepaid. b. [XJ placing the envelope for collection and mailing following our ordinary business practices. | am readily familiar with this business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. 5. The envelope was addressed and mailed as follows: a, Name ofperson served: Michael R. Lea b. Address of person served: Lea & Navinskus, A Law Corporation 134 W. Wilshire Avenue Fullerton, CA 92832 (2) The name and address of each person to whom | mailed the documents is listed in the Attachment to Proof of Service by First-Class Mail-Civil (Persons Served) (POS-030(P)). | declare under penalty of perjury under the laws of the State of California the Date: April 29, 2010 {TYPE OR PRINT NAME OF PERSON COMPLETING THIS FORM) PLETING THIS FORM) Fam Approved for Optional Use PROOF OF SERVICE BY FIRST-CLASS MAIL H Cave of Givi Procedure, $§ 1013, 1013 POS.030 [New January 1, 2005} Manin Deans (Proof of Service) mene oeeIO C2. ON “e) ESSENTIAL FORMS™