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DAN FARRAR Electronically Filed
Attorney at Law 4/30/2020 2:14 PM
SBN 155217 Superior Court of California
P.O. Box 3382 County of Stanislaus
Turlock CA 95381-3382 Clerk of the Court
Telephone (209)634-5500
Facsimile (209)634-5556
By: Kimberly Mean, Deputy
Attorney for Defendant
\lONU'lsBWN
County of Stanislaus
m SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF STANISLAUS
lO
Jasmine Mariah Segoviano, et a1. CASE NO: CV-l9-007741
ll Plaintiffs,
12 vs. Answer to Amended Petition for
Declaratory Relief and Writ of Mandate
13 Stanislaus County Sheriffs Department, Vvvvvvvv
l4 Defendants.
15
16
Respondents answer the veried petition for writ of mandate and complaint for
17
declaratory and injunctive relief as follows:
18
Respondents admit this Court has jurisdiction over the issues presented and is the proper
19
venue.
20
As to paragraph 1, the referenced legal principles speak for themselves.
21
As to paragraph 2, the referenced attachments speak for themselves. Respondents deny
22
the remainder of the allegations.
23
As to paragraph 3, the referenced attachments speak for themselves. Respondents deny
24
the remainder of the allegations.
25
As to paragraph 4, the referenced attachments speak for themselves. Respondents deny
26
the remainder of the allegations.
27
As to paragraph 5, the referenced legal principles speak for themselves.
28
Answer to Complaint
As to paragraph 6, respondents admit the allegations.
AWNI—J
As to paragraph 7, respondents admit the allegations.
As to paragraph 8, respondents admit the allegations.
As to paragraph 9, respondents admit the allegations.
As to paragraph 10, respondents admit the allegations.
As to paragraph 11, respondents admit the allegations.
As to paragraph 12, respondents admit the allegations.
l—‘komQOWU'I
As to paragraph 13, respondents deny the allegations.
As to paragraph l4, the referenced documents speak for themselves. Respondents deny
the remaining allegations.
As to paragraph 15, the referenced documents speak for themselves. Respondents deny
12 the remaining allegations.
l3 As to paragraph 16, respondents deny the allegations.
14 As to paragraph 17, the referenced legal principles speak for themselves.
15 As to paragraph l8, respondents deny the allegations.
l6 As to paragraph 19, the referenced documents speak for themselves. Respondents deny
l7 the remaining allegations.
l8 As to paragraph 20, the referenced legal principles speak for themselves.
l9 As to paragraph 21, the referenced legal principles speak for themselves.
20 As to paragraph 22, respondents deny the allegations.
21 Respondents deny petitioner is entitled to any of the relief for which it prays.
22 As and for afrmative defenses, respondents assert:
23 As and for a first, separate and distinct afrmative defense, these answering
24 respondents allege no justiciable dispute exists, the petition is premature, and the alleged disputes
25 are not ripe for adjudication.
26 As and for a second, separate and distinct afrmative defense, these answering
27 respondents allege the petition fails to state facts sufcient to state a cause of action against
28 respondents.
Answer to Complaint
As and for a third, separate and distinct affirmative defense, these answering
respondents allege that with respect to issues that were not raised in the prior proceedings
petitioner may not raise those issues or claims for the rst time in this lawsuit by reason of the
4:.me
doctrine of exhaustion of administrative remedies.
As and for a fourth, separate and distinct afrmative defense, these answering
respondents allege that the petition, and each and every purported cause of action
(D\IO\U1
contained therein, is barred by laches.
As and for a fth, separate and distinct affirmative defense, these answering
respondents allege that the petition, and each and every purported cause of action.
lO contained therein, is barred by waiver.
ll As and for a sixth, separate and distinct afrmative defense, these answering
12 respondents allege that the petition, and each and every purported cause of action
l3 contained therein, is barred by estoppel.
l4 Wherefore, these answering respondents pray:
15 1. That the petition be denied in its entirety;
l6 2. That respondents be awarded their costs of suit; and
l7 3. That the court award such further relief as is just.
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19 Date: April 30, 2020
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21 Dan Farrar
Attorney for Defendant
22 County of Stanislaus
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Answer to Complaint
PROOF OF SERVICE
Case Name: Segoviano v. County ofStam'slaus
Case No.: CV-19-007741
My business address is 600 East Main Street, Suite 100, Turlock, California, 95380, where this
serv1ce occurs.
\OOONQUIAUJNu—t
I am a resident of or employed in the County of Stanislaus. I am over the age of
18 years, and not a party to this action.
On the date set forth below, following ordinary business practice, I served a true copy of the
following document(s):
Answer to Amended Petition for Declaratory Relief and Writ of Mandate
(Facsimile) by transmitting via facsimile the document(s) listed above to the fax
number(s) set forth below, or as stated on the attached service list, on this date before
5 :00 p.m.
XXX (Ordinary Course of Business) by placing the document(s) listed above in a sealed
envelope addressed to the persons set forth below, or as stated on the attached service list,
with postage thereon fully prepaid for rst-class mail, for collection and mailing
following ordinary business practices: correspondence is deposited with the U.S. Postal
Service the same day as the day of collection in the ordinary course of business.
(Personal Service) by placing the document(s) listed above in a sealed envelope and
causing such envelopes to be delivered by hand this date to the ofces of the address of
the persons set forth below, or as stated on the attached service list.
(Overnight Delivery) by placing the document(s) listed above in a sealed envelope and
causing such envelopes to be delivered to an overnight delivery carrier with delivery fees
provided for, addressed to the persons on whom it is to be served.
NNNNNNNNNr—dp—‘v—nn—‘Hv—lr—Hu—an—a
Stephen Solano
WNQMAMNHOOmNQm-hwwh‘o
Robert D. Chase
Attorney at Law Attorney at Law
P.O. Box 578068 802 14‘“ Street, Suite B
Modesto, CA 95357 Modesto, CA 95354
John J. Hillenbrand
Attorney at Law
520 13m Street
Modesto, CA 95354
I declare under penalty of perjury under the laws of the State of' California that the
foregoing is true and correct. Executed in Turlock, California on A 30, 20.
Guadalu‘pgallm
Preview
DAN FARRAR Electronically Filed Attorney at Law 4/30/2020 2:14 PM SBN 155217 Superior Court of California P.O. Box 3382 County of Stanislaus Turlock CA 95381-3382 Clerk of the Court Telephone (209)634-5500 Facsimile (209)634-5556 By: Kimberly Mean, Deputy Attorney for Defendant \lONU'lsBWN County of Stanislaus m SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF STANISLAUS lO Jasmine Mariah Segoviano, et a1. CASE NO: CV-l9-007741 ll Plaintiffs, 12 vs. Answer to Amended Petition for Declaratory Relief and Writ of Mandate 13 Stanislaus County Sheriffs Department, Vvvvvvvv l4 Defendants. 15 16 Respondents answer the veried petition for writ of mandate and complaint for 17 declaratory and injunctive relief as follows: 18 Respondents admit this Court has jurisdiction over the issues presented and is the proper 19 venue. 20 As to paragraph 1, the referenced legal principles speak for themselves. 21 As to paragraph 2, the referenced attachments speak for themselves. Respondents deny 22 the remainder of the allegations. 23 As to paragraph 3, the referenced attachments speak for themselves. Respondents deny 24 the remainder of the allegations. 25 As to paragraph 4, the referenced attachments speak for themselves. Respondents deny 26 the remainder of the allegations. 27 As to paragraph 5, the referenced legal principles speak for themselves. 28 Answer to Complaint As to paragraph 6, respondents admit the allegations. AWNI—J As to paragraph 7, respondents admit the allegations. As to paragraph 8, respondents admit the allegations. As to paragraph 9, respondents admit the allegations. As to paragraph 10, respondents admit the allegations. As to paragraph 11, respondents admit the allegations. As to paragraph 12, respondents admit the allegations. l—‘komQOWU'I As to paragraph 13, respondents deny the allegations. As to paragraph l4, the referenced documents speak for themselves. Respondents deny the remaining allegations. As to paragraph 15, the referenced documents speak for themselves. Respondents deny 12 the remaining allegations. l3 As to paragraph 16, respondents deny the allegations. 14 As to paragraph 17, the referenced legal principles speak for themselves. 15 As to paragraph l8, respondents deny the allegations. l6 As to paragraph 19, the referenced documents speak for themselves. Respondents deny l7 the remaining allegations. l8 As to paragraph 20, the referenced legal principles speak for themselves. l9 As to paragraph 21, the referenced legal principles speak for themselves. 20 As to paragraph 22, respondents deny the allegations. 21 Respondents deny petitioner is entitled to any of the relief for which it prays. 22 As and for afrmative defenses, respondents assert: 23 As and for a first, separate and distinct afrmative defense, these answering 24 respondents allege no justiciable dispute exists, the petition is premature, and the alleged disputes 25 are not ripe for adjudication. 26 As and for a second, separate and distinct afrmative defense, these answering 27 respondents allege the petition fails to state facts sufcient to state a cause of action against 28 respondents. Answer to Complaint As and for a third, separate and distinct affirmative defense, these answering respondents allege that with respect to issues that were not raised in the prior proceedings petitioner may not raise those issues or claims for the rst time in this lawsuit by reason of the 4:.me doctrine of exhaustion of administrative remedies. As and for a fourth, separate and distinct afrmative defense, these answering respondents allege that the petition, and each and every purported cause of action (D\IO\U1 contained therein, is barred by laches. As and for a fth, separate and distinct affirmative defense, these answering respondents allege that the petition, and each and every purported cause of action. lO contained therein, is barred by waiver. ll As and for a sixth, separate and distinct afrmative defense, these answering 12 respondents allege that the petition, and each and every purported cause of action l3 contained therein, is barred by estoppel. l4 Wherefore, these answering respondents pray: 15 1. That the petition be denied in its entirety; l6 2. That respondents be awarded their costs of suit; and l7 3. That the court award such further relief as is just. 18 19 Date: April 30, 2020 20 21 Dan Farrar Attorney for Defendant 22 County of Stanislaus 23 24 25 26 27 28 Answer to Complaint PROOF OF SERVICE Case Name: Segoviano v. County ofStam'slaus Case No.: CV-19-007741 My business address is 600 East Main Street, Suite 100, Turlock, California, 95380, where this serv1ce occurs. \OOONQUIAUJNu—t I am a resident of or employed in the County of Stanislaus. I am over the age of 18 years, and not a party to this action. On the date set forth below, following ordinary business practice, I served a true copy of the following document(s): Answer to Amended Petition for Declaratory Relief and Writ of Mandate (Facsimile) by transmitting via facsimile the document(s) listed above to the fax number(s) set forth below, or as stated on the attached service list, on this date before 5 :00 p.m. XXX (Ordinary Course of Business) by placing the document(s) listed above in a sealed envelope addressed to the persons set forth below, or as stated on the attached service list, with postage thereon fully prepaid for rst-class mail, for collection and mailing following ordinary business practices: correspondence is deposited with the U.S. Postal Service the same day as the day of collection in the ordinary course of business. (Personal Service) by placing the document(s) listed above in a sealed envelope and causing such envelopes to be delivered by hand this date to the ofces of the address of the persons set forth below, or as stated on the attached service list. (Overnight Delivery) by placing the document(s) listed above in a sealed envelope and causing such envelopes to be delivered to an overnight delivery carrier with delivery fees provided for, addressed to the persons on whom it is to be served. NNNNNNNNNr—dp—‘v—nn—‘Hv—lr—Hu—an—a Stephen Solano WNQMAMNHOOmNQm-hwwh‘o Robert D. Chase Attorney at Law Attorney at Law P.O. Box 578068 802 14‘“ Street, Suite B Modesto, CA 95357 Modesto, CA 95354 John J. Hillenbrand Attorney at Law 520 13m Street Modesto, CA 95354 I declare under penalty of perjury under the laws of the State of' California that the foregoing is true and correct. Executed in Turlock, California on A 30, 20. Guadalu‘pgallm