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UM
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Documeni Scanning Lead Sheet
Apr-08-2013 10:17 am
Case Number: CGC-10-50280S
Filing Date: Apr-08-2013 10:10
Filed by: WESLEY G. RAMIREZ
Juke Box: 001 Image: 04008385
ANSWER
CITY AND COUNTY OF SAN FRANCISCO et al VS. DONNIE THOMAS et al
001004008385
Instructions:
Please place this sheet on top of the document to be scanned.ELIZABETH BRADFORD, In Pro Per
1000 Grand Avenue, #4
South San Francisco, California 94080
Telephone: (650) 291-2793
ABP
APR 08 2013
CLERK 2 E COURT
ort Deputy Cle
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED CIVIL JURISDICTION
CITY AND COUNTY OF SAN
FRANCISCO, and THE PEOPLE OF
THE STATE OF CALIFORNIA, By and
Through San Francisco City Attorney
Dennis Herrera and SAN FRANCISCO
CITY ATTORNEY DENNIS J.
HERRERA, as civil prosecutor,
Plaintiffs,
vs.
DONNIE THOMAS, MILES BONNER,
JOHN RAUCH, ROBERT
MAZARIEGOS, VINCENT PADILLA,
ELIZABETH BRADFORD,
CENTENNIAL DISTRIBUTORS, INC.,
JEAN QUIROZ, CARLOS QUIROZ,
AND DOES 1-30 (INCLUSIVE)
Defendants.
Defendant ELIZABETH BRADFORD answers plaintiffs’ First Amended Complaint as
follows:
Case No. CGC-10-502-809
ANSWER OF DEFENDANT
ELIZABETH BRADFORD TO
PLAINTIFFS’ FIRST AMENDED
COMPLAINT; PROOF OF SERVICE
Trial Date: Not Set
Pursuant to California Code of Civil Procedure Section 431.30, defendant denies each
and every allegation contained in the complaint.
This answering defendant denies that plaintiffs have been damaged in any sum or sums,
or otherwise, or at all, by reason of any act or omission of defendant.
1
DEF. BRADFORD'S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
The complaint fails to state facts sufficient to constitute a cause of action against this
answering defendant.
SECOND AFFIRMATIVE DEFENSE
Each and every allegation contained in the complaint is barred by the statutes of
limitation as set forth in Sections 335 et seq. of the California Code of Civil Procedure.
THIRD AFFIRMATIVE DEFENSE
Plaintiffs do not have the legal capacity to sue this answering defendant.
FOURTH AFFIRMATIVE DEFENSE
Plaintiffs are responsible for any and all damages which it suffered, if any there be.
Plaintiffs should therefore take nothing by way of its complaint, or its damages should be
reduced pursuant to the doctrine of comparative negligence.
FIFTH AFFIRMATIVE DEFENSE
Plaintiffs are estopped from pursuing this action against this answering defendant.
Plaintiffs’ acts, omissions, representations, and courses of conduct were relied upon by
answering defendant to her detriment.
SIXTH AFFIRMATIVE DEFENSE
Plaintiffs were comparatively negligent in and about the matters and activities alleged in
the complaint; said comparative negligence contributed to and was a proximate cause of
plaintiffs’ alleged injuries and damages, if any, or was the sole cause thereof; and if plaintiffs are
entitled to recover damages against this defendant by virtue of said complaint, this defendant
prays that the recovery be diminished or extinguished by reason of the negligence of the
plaintiffs in proportion to the degree of fault attributable to the plaintiffs.
SEVENTH AFFIRMATIVE DEFENSE
The fault of persons other than this defendant contributed to and proximately caused the
alleged incident; under the principles formulated in the case American Motorcycle Association v.
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DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 st Oe ely inn FACCo IN Dn
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Superior Court (1978) 20 Cal.3d 578, this defendant prays that the percentage of such
contribution be established by special verdict or other procedure, and that this defendant’s
ultimate liability be reduced to the extent of such contribution.
EIGHTH AFFIRMATIVE DEFENSE
The complaint and each cause of action are barred by the doctrine of unclean hands.
NINTH AFFIRMATIVE DEFENSE
Plaintiffs have waived their rights. By reason of said waiver, defendant is excused from
further performance of any obligations under the alleged contract.
TENTH AFFIRMATIVE DEFENSE
The complaint and each and every cause of action therein is barred by res judicata and the
case law prohibiting a plaintiffs from “splitting” claims or causes of action. Ferraro v. Southern
Cal. Gas Co. (1980) 102 Cal.App.3d 33, 41.
ELEVENTH AFFIRMATIVE DEFENSE
Plaintiffs’ actions constitute a full waiver and release of any and all claims which
plaintiffs may have against this answering defendant.
TWELFTH AFFIRMATIVE DEFENSE
The complaint and the causes of action alleged therein are barred by the statute of frauds
pursuant to section 1624 of the California Civil Code.
THIRTEENTH AFFIRMATIVE DEFENSE
The allegations contained within the complaint are barred as a result of a failure of
consideration.
FOURTEENTH AFFIRMATIVE DEFENSE
Plaintiffs’ claims are barred under the doctrine of unclean hands.
FIFTEENTH AFFIRMATIVE DEFENSE
Plaintiffs’ claims would result in unjust enrichment.
SIXTEENTH AFFIRMATIVE DEFENSE
Any and all claims, rights, or obligations alleged in plaintiffs’ complaint are
unenforceable by reason of mutual mistake.
3
DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 sno Une cy Dein res FACSEVENTEENTH AFFIRMATIVE DEFENSE
Any and all claims, rights, or obligations alleged in plaintiffs’ complaint are
unenforceable because the alleged written contract, if any, is not fully integrated.
EIGHTEENTH AFFIRMATIVE DEFENSE
Plaintiffs are barred as a result of a failure to investigate and timely act.
NINETEENTH AFFIRMATIVE DEFENSE
This answering defendant has suffered damage as a result of plaintiffs’ conduct; thus,
she has the right of offset.
TWENTIETH AFFIRMATIVE DEFENSE
The complaint and each cause of action are barred by the doctrine of laches.
TWENTY-FIRST AFFIRMATIVE DEFENSE
Defendant alleges that plaintiffs failed to mitigate damages although plaintiffs had a
reasonable opportunity to do so.
TWENTY-SECOND AFFIRMATIVE DEFENSE
Defendant alleges that plaintiffs are not entitled to injunctive relief because any alleged
injury to plaintiffs is not immediate or irreparable, and plaintiffs have an adequate remedy at law.
TWENTY-THIRD AFFIRMATIVE DEFENSE
Defendant alleges that plaintiffs’ claim for violations of the False Claims Act is barred
based upon agreements between plaintiffs and their vendors or former vendors.
TWENTY-FOURTH AFFIRMATIVE DEFENSE
Defendant alleges that plaintiffs’ claim for violation of the San Francisco Campaign and
Government Code is barred based upon agreements between plaintiffs and their vendors or
former vendors.
TWENTY-FIFTH AFFIRMATIVE DEFENSE
Defendant alleges that plaintiffs’ claim for violations of the Unfair Competition Law is
barred based upon agreements between plaintiffs and their vendors or former vendors.
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DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 an Ue ny Dori re wn FACTWENTY-SIXTH AFFIRMATIVE DEFENSE
Defendant alleges that plaintiffs’ claim for violations of the Political Reform Act is
barred based upon agreements between plaintiffs and their vendors or former vendors.
TWENTY-SEVENTH AFFIRMATIVE DEFENSE
Defendant alleges that plaintiffs’ claims are barred for lack of privity.
ADDITIONAL AFFIRMATIVE DEFENSES
Defendant presently has insufficient knowledge or information on which to form a belief
as to whether it may have additional, as yet unstated, defenses available. Defendant reserves the
right to assert additional defenses in the event that discovery indicates that they would be
appropriate.
5
DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 ut enn omit FHC0 ON DW BP WN
NY N NY NY YN NN DY He eee we ee Be eB
oN DA BH HN &§ So we AR DAH BF BW NH SF DS
WHEREFORE, defendant prays for judgment as follows:
1. That plaintiffs take nothing from defendant by this complaint.
Dismiss plaintiffs’ suit;
2
3. Award the a judgment for its costs of suit herein incurred; and
4.
For other and further relief the Court deems just or proper.
Dated: April 8, 2013
B
LIZABE|JH BRADFORD
IN PRO PER Defendant
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DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809
ach Un icy Deena bi FACem YN DH RF WN
YN N YY NY NY NN KY Bee Be Be we Be Be Be eS
ecN A A Fw NH F&F SO we QT DH BF WN KF Oo
PROOF OF SERVICE
LWle thaskde declare as follows:
I am a citizen of the United States, over the age of eighteen years and not a party to the
within entitled action. I am self-employed.
On April 8, 2013 I had personally served the attached:
ANSWER OF DEFENDANT ELIZABETH BRADFORD TO PLAINTIFFS’ FIRST
AMENDED COMPLAINT
on the interested parties in said action, by placing a true copy thereof in sealed envelope(s)
addressed as follows:
Kristine Poplawski, Esq.
San Francisco City Attorney’s Office
1390 Market Street, 7" Floor
San Francisco, CA 94102
FOR THE REST, SEE ATTACHED LIST
and served the named document in the manner indicated below:
& BY MAIL: | mailed true and correct copies of the above documents, by following ordinary business
practices, to be placed and sealed in envelope(s) addressed to the addressee(s).
oO BY PERSONAL SERVICE: | caused true and correct copies of the above documents to be placed
and sealed in envelope(s) addressed to the addressee(s) and I caused such envelope(s) to be delivered by
hand on the office(s) of the addressee(s).
oO BY EXPRESS SERVICES OVERNITE: | caused true and correct copies of the above
documents to be placed and sealed in envelope(s) addressed to the addressee(s) and I caused such
envelope(s) to be delivered to EXPRESS SERVICES OVERNITE for overnight courier service to the
office(s) of the addressee(s).
oO BY FACSIMILE: | caused a copy(ies) of such document(s) to be transmitted via facsimile machine.
The fax number(s) of the machine(s) to which the document(s) were transmitted are listed above. The fax
transmission was reported as complete and without error. I caused the transmitting facsimile machine to
print a transmission record of the transmission.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed April 8, 2013 at San Francisco, California.
“A=
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DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 HD Ui ney Dotson an OFA:co 0 Om ND HW PF WN BS
NY NR YN KN NY NK YD Bee we ew ewe ewe ee ee
cD DAA KR HN = SO we YN DH BRB WN
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Donnie A. Thomas
3 || CDCR# AM7769
San Quentin State Prison
§ || San Quentin, CA 94974
(Pro Se)
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‘Warner Berry
1 Maritime Pl Plaza, #1600
San Francisco, CA 94111
10 || (Counsel for Defendant John Rauch)
Robert Mazariegos
12 || 100 Zinnia Cir.
Vallejo, CA 94591
James A. Lassart
15 Spencer C. Martinez
opers, Majeski, Kohn & Bentley
16 worse Spear St., Suite 1000
San Francisco, CA 94105-1667
17 | Counsel for Defendant Jean Quiroz)
SERVICE LIST
Case No. CGC-10-502-809
CITY AND COUNTY OF SAN FRANCISCO, ET AL. V. DONNIE THOMAS, ET AL.
Miles T. Bonner
CDCR# AM1115
High Desert State Prison
P.O. Box 3030
Susanville, CA 96127
(Pro Se)
Carlos
2559 Marquee Trail
Katy, TX 77494-1359
Centennial Distributors, Inc.
Agent: Carlos Quiroz
2559 Marquette Trail
Katy, TX 77494-1359
Elizabeth Bradford
1000 Grand Avenue, #4
South San Francisco, CA 94080
Tel: 650-291-2793
(Pro Se)
Richard A. Madsen, Jr.
Madsen Law Firm
551 Hartz Avenue, Suite B
Danville, CA 94526
20 Tel: (925) 837-0900
Fax: (925) 837-0905
21 Email: Rick@ MadsenLawFirm.com
2 (Counsel for Vincent Padilla)
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Case No. 10-CGC-502809 sn \exlf\i2005108080 100669977 doc
PROOF OF SERVICE
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DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809
Mca Uy Downes FA
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UM SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Documeni Scanning Lead Sheet Apr-08-2013 10:17 am Case Number: CGC-10-50280S Filing Date: Apr-08-2013 10:10 Filed by: WESLEY G. RAMIREZ Juke Box: 001 Image: 04008385 ANSWER CITY AND COUNTY OF SAN FRANCISCO et al VS. DONNIE THOMAS et al 001004008385 Instructions: Please place this sheet on top of the document to be scanned.ELIZABETH BRADFORD, In Pro Per 1000 Grand Avenue, #4 South San Francisco, California 94080 Telephone: (650) 291-2793 ABP APR 08 2013 CLERK 2 E COURT ort Deputy Cle SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED CIVIL JURISDICTION CITY AND COUNTY OF SAN FRANCISCO, and THE PEOPLE OF THE STATE OF CALIFORNIA, By and Through San Francisco City Attorney Dennis Herrera and SAN FRANCISCO CITY ATTORNEY DENNIS J. HERRERA, as civil prosecutor, Plaintiffs, vs. DONNIE THOMAS, MILES BONNER, JOHN RAUCH, ROBERT MAZARIEGOS, VINCENT PADILLA, ELIZABETH BRADFORD, CENTENNIAL DISTRIBUTORS, INC., JEAN QUIROZ, CARLOS QUIROZ, AND DOES 1-30 (INCLUSIVE) Defendants. Defendant ELIZABETH BRADFORD answers plaintiffs’ First Amended Complaint as follows: Case No. CGC-10-502-809 ANSWER OF DEFENDANT ELIZABETH BRADFORD TO PLAINTIFFS’ FIRST AMENDED COMPLAINT; PROOF OF SERVICE Trial Date: Not Set Pursuant to California Code of Civil Procedure Section 431.30, defendant denies each and every allegation contained in the complaint. This answering defendant denies that plaintiffs have been damaged in any sum or sums, or otherwise, or at all, by reason of any act or omission of defendant. 1 DEF. BRADFORD'S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE The complaint fails to state facts sufficient to constitute a cause of action against this answering defendant. SECOND AFFIRMATIVE DEFENSE Each and every allegation contained in the complaint is barred by the statutes of limitation as set forth in Sections 335 et seq. of the California Code of Civil Procedure. THIRD AFFIRMATIVE DEFENSE Plaintiffs do not have the legal capacity to sue this answering defendant. FOURTH AFFIRMATIVE DEFENSE Plaintiffs are responsible for any and all damages which it suffered, if any there be. Plaintiffs should therefore take nothing by way of its complaint, or its damages should be reduced pursuant to the doctrine of comparative negligence. FIFTH AFFIRMATIVE DEFENSE Plaintiffs are estopped from pursuing this action against this answering defendant. Plaintiffs’ acts, omissions, representations, and courses of conduct were relied upon by answering defendant to her detriment. SIXTH AFFIRMATIVE DEFENSE Plaintiffs were comparatively negligent in and about the matters and activities alleged in the complaint; said comparative negligence contributed to and was a proximate cause of plaintiffs’ alleged injuries and damages, if any, or was the sole cause thereof; and if plaintiffs are entitled to recover damages against this defendant by virtue of said complaint, this defendant prays that the recovery be diminished or extinguished by reason of the negligence of the plaintiffs in proportion to the degree of fault attributable to the plaintiffs. SEVENTH AFFIRMATIVE DEFENSE The fault of persons other than this defendant contributed to and proximately caused the alleged incident; under the principles formulated in the case American Motorcycle Association v. 2 DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 st Oe ely inn FACCo IN Dn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Superior Court (1978) 20 Cal.3d 578, this defendant prays that the percentage of such contribution be established by special verdict or other procedure, and that this defendant’s ultimate liability be reduced to the extent of such contribution. EIGHTH AFFIRMATIVE DEFENSE The complaint and each cause of action are barred by the doctrine of unclean hands. NINTH AFFIRMATIVE DEFENSE Plaintiffs have waived their rights. By reason of said waiver, defendant is excused from further performance of any obligations under the alleged contract. TENTH AFFIRMATIVE DEFENSE The complaint and each and every cause of action therein is barred by res judicata and the case law prohibiting a plaintiffs from “splitting” claims or causes of action. Ferraro v. Southern Cal. Gas Co. (1980) 102 Cal.App.3d 33, 41. ELEVENTH AFFIRMATIVE DEFENSE Plaintiffs’ actions constitute a full waiver and release of any and all claims which plaintiffs may have against this answering defendant. TWELFTH AFFIRMATIVE DEFENSE The complaint and the causes of action alleged therein are barred by the statute of frauds pursuant to section 1624 of the California Civil Code. THIRTEENTH AFFIRMATIVE DEFENSE The allegations contained within the complaint are barred as a result of a failure of consideration. FOURTEENTH AFFIRMATIVE DEFENSE Plaintiffs’ claims are barred under the doctrine of unclean hands. FIFTEENTH AFFIRMATIVE DEFENSE Plaintiffs’ claims would result in unjust enrichment. SIXTEENTH AFFIRMATIVE DEFENSE Any and all claims, rights, or obligations alleged in plaintiffs’ complaint are unenforceable by reason of mutual mistake. 3 DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 sno Une cy Dein res FACSEVENTEENTH AFFIRMATIVE DEFENSE Any and all claims, rights, or obligations alleged in plaintiffs’ complaint are unenforceable because the alleged written contract, if any, is not fully integrated. EIGHTEENTH AFFIRMATIVE DEFENSE Plaintiffs are barred as a result of a failure to investigate and timely act. NINETEENTH AFFIRMATIVE DEFENSE This answering defendant has suffered damage as a result of plaintiffs’ conduct; thus, she has the right of offset. TWENTIETH AFFIRMATIVE DEFENSE The complaint and each cause of action are barred by the doctrine of laches. TWENTY-FIRST AFFIRMATIVE DEFENSE Defendant alleges that plaintiffs failed to mitigate damages although plaintiffs had a reasonable opportunity to do so. TWENTY-SECOND AFFIRMATIVE DEFENSE Defendant alleges that plaintiffs are not entitled to injunctive relief because any alleged injury to plaintiffs is not immediate or irreparable, and plaintiffs have an adequate remedy at law. TWENTY-THIRD AFFIRMATIVE DEFENSE Defendant alleges that plaintiffs’ claim for violations of the False Claims Act is barred based upon agreements between plaintiffs and their vendors or former vendors. TWENTY-FOURTH AFFIRMATIVE DEFENSE Defendant alleges that plaintiffs’ claim for violation of the San Francisco Campaign and Government Code is barred based upon agreements between plaintiffs and their vendors or former vendors. TWENTY-FIFTH AFFIRMATIVE DEFENSE Defendant alleges that plaintiffs’ claim for violations of the Unfair Competition Law is barred based upon agreements between plaintiffs and their vendors or former vendors. 4 DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 an Ue ny Dori re wn FACTWENTY-SIXTH AFFIRMATIVE DEFENSE Defendant alleges that plaintiffs’ claim for violations of the Political Reform Act is barred based upon agreements between plaintiffs and their vendors or former vendors. TWENTY-SEVENTH AFFIRMATIVE DEFENSE Defendant alleges that plaintiffs’ claims are barred for lack of privity. ADDITIONAL AFFIRMATIVE DEFENSES Defendant presently has insufficient knowledge or information on which to form a belief as to whether it may have additional, as yet unstated, defenses available. Defendant reserves the right to assert additional defenses in the event that discovery indicates that they would be appropriate. 5 DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 ut enn omit FHC0 ON DW BP WN NY N NY NY YN NN DY He eee we ee Be eB oN DA BH HN &§ So we AR DAH BF BW NH SF DS WHEREFORE, defendant prays for judgment as follows: 1. That plaintiffs take nothing from defendant by this complaint. Dismiss plaintiffs’ suit; 2 3. Award the a judgment for its costs of suit herein incurred; and 4. For other and further relief the Court deems just or proper. Dated: April 8, 2013 B LIZABE|JH BRADFORD IN PRO PER Defendant 6 DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 ach Un icy Deena bi FACem YN DH RF WN YN N YY NY NY NN KY Bee Be Be we Be Be Be eS ecN A A Fw NH F&F SO we QT DH BF WN KF Oo PROOF OF SERVICE LWle thaskde declare as follows: I am a citizen of the United States, over the age of eighteen years and not a party to the within entitled action. I am self-employed. On April 8, 2013 I had personally served the attached: ANSWER OF DEFENDANT ELIZABETH BRADFORD TO PLAINTIFFS’ FIRST AMENDED COMPLAINT on the interested parties in said action, by placing a true copy thereof in sealed envelope(s) addressed as follows: Kristine Poplawski, Esq. San Francisco City Attorney’s Office 1390 Market Street, 7" Floor San Francisco, CA 94102 FOR THE REST, SEE ATTACHED LIST and served the named document in the manner indicated below: & BY MAIL: | mailed true and correct copies of the above documents, by following ordinary business practices, to be placed and sealed in envelope(s) addressed to the addressee(s). oO BY PERSONAL SERVICE: | caused true and correct copies of the above documents to be placed and sealed in envelope(s) addressed to the addressee(s) and I caused such envelope(s) to be delivered by hand on the office(s) of the addressee(s). oO BY EXPRESS SERVICES OVERNITE: | caused true and correct copies of the above documents to be placed and sealed in envelope(s) addressed to the addressee(s) and I caused such envelope(s) to be delivered to EXPRESS SERVICES OVERNITE for overnight courier service to the office(s) of the addressee(s). oO BY FACSIMILE: | caused a copy(ies) of such document(s) to be transmitted via facsimile machine. The fax number(s) of the machine(s) to which the document(s) were transmitted are listed above. The fax transmission was reported as complete and without error. I caused the transmitting facsimile machine to print a transmission record of the transmission. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed April 8, 2013 at San Francisco, California. “A= 7 DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 HD Ui ney Dotson an OFA:co 0 Om ND HW PF WN BS NY NR YN KN NY NK YD Bee we ew ewe ewe ee ee cD DAA KR HN = SO we YN DH BRB WN 2 3 4 Donnie A. Thomas 3 || CDCR# AM7769 San Quentin State Prison § || San Quentin, CA 94974 (Pro Se) 7 8 9 ‘Warner Berry 1 Maritime Pl Plaza, #1600 San Francisco, CA 94111 10 || (Counsel for Defendant John Rauch) Robert Mazariegos 12 || 100 Zinnia Cir. Vallejo, CA 94591 James A. Lassart 15 Spencer C. Martinez opers, Majeski, Kohn & Bentley 16 worse Spear St., Suite 1000 San Francisco, CA 94105-1667 17 | Counsel for Defendant Jean Quiroz) SERVICE LIST Case No. CGC-10-502-809 CITY AND COUNTY OF SAN FRANCISCO, ET AL. V. DONNIE THOMAS, ET AL. Miles T. Bonner CDCR# AM1115 High Desert State Prison P.O. Box 3030 Susanville, CA 96127 (Pro Se) Carlos 2559 Marquee Trail Katy, TX 77494-1359 Centennial Distributors, Inc. Agent: Carlos Quiroz 2559 Marquette Trail Katy, TX 77494-1359 Elizabeth Bradford 1000 Grand Avenue, #4 South San Francisco, CA 94080 Tel: 650-291-2793 (Pro Se) Richard A. Madsen, Jr. Madsen Law Firm 551 Hartz Avenue, Suite B Danville, CA 94526 20 Tel: (925) 837-0900 Fax: (925) 837-0905 21 Email: Rick@ MadsenLawFirm.com 2 (Counsel for Vincent Padilla) 23 24 25 26 27 28 Case No. 10-CGC-502809 sn \exlf\i2005108080 100669977 doc PROOF OF SERVICE 8 DEF. BRADFORD’S ANSWER TO PLNTFS’ FAC, CASE NO. 502-809 Mca Uy Downes FA