Answer to Complaint

YOUR NAME

Street Address

City, State Zip

Phone Number (with area code)

Fax Number (If applicable)

Email Address (If applicable)

Plaintiff In Pro Per

SUPERIOR COURT OF THE STATE OF XXXXIN AND FOR THE COUNTY OF XXX
XXX, and XXX,                   Plaintiffs,

     Vs.
XXX, individually & dba EXPERTS OF REAL ESTATE & CAL REAL ESTATE EXPERTS, and

Does 1 through 25, inclusive 

                  Defendant(s)

 Case No.: XXX-VTA
ANSWER AND GENERAL DENIAL.

COMES NOW, Defendants XXX, individually & dba Experts of Real Estate & Cal Real Estate Experts. and Does 1 through 25 (hereinafter “these answering Defendants”), and answering the Complaint on file herein for and on behalf of itself alone, answers Plaintiff’s Complaint as follows:

Under and pursuant to the provisions of California Code of Civil Procedure, specifically, Section 431.30 thereof, these answering Defendants generally denies each and every allegation of said Complaint, and the whole thereof, and each and every allegation of each and every cause of action alleged therein, and further expressly deny that as a direct or proximate result of any acts or omissions on the part of these answering Defendants, Plaintiff herein sustained or suffered injury or damage in the amount alleged in the unverified Complaint, or in any amount at all, or that Plaintiff has suffered injury or damage for any reason in the sums alleged in the Complaint, or in any other sum or sums, or at all. 

FIRST CAUSE OF ACTION

  1. Defendants deny the allegations in Paragraph 1 that each of the fictitiously named defendants is responsible in some actionable manner for any event that caused any damage to the plaintiffs. 
  2. Defendants deny Paragraph 2 in its entirety.
  3. Defendants deny Paragraph 3 in its entirety.
  4. Defendants deny Paragraph 4 in its entirety and state that they are unaware of any wrongful conduct done by either or all of the Defendants in Oxnard, California.
  5. Defendants deny Paragraph 5 in its entirety.
  6. Defendants deny Paragraph 6 in its entirety.
  7. Defendants deny Paragraph 7 in its entirety.
  8. Defendants deny Paragraph 8 in its entirety and state that they are not, individually or jointly, aware of any Francisco and Elizabeth Gillen and that they are not, individually or jointly, privy to any transaction with either the plaintiffs or the said individuals. 
  9. Defendants deny Paragraph 9 in its entirety and state that they are not aware of any oral agreement entered into with the plaintiffs. Further, the Defendants aver that they did not agree to represent the plaintiffs in any matter. 
  10. Defendants deny Paragraph 10 in its entirety and restate Answer 9 above in full.
  11. Defendants deny Paragraph 11 in its entirety. 
  12. Defendants deny Paragraph 12 in its entirety. 
  13. Defendants deny Paragraph 13 in its entirety. 
  14. Defendants deny Paragraph 14 in its entirety. 
  15. The allegations of paragraph 15 of the Complaint require no answer of Defendants but to the extent that they require an answer, Defendants deny those allegations.

SECOND CAUSE OF ACTION

  1. Defendants restate and incorporate herein by this reference, each of the answers contained in Paragraphs 1 through 15 inclusive.
  2. Defendants deny Paragraph 17 in its entirety and state that they are not aware of any promise they made to the plaintiffs. Further, the Defendants aver that at no point did they represent the plaintiffs in any matter.
  3. Defendants deny only so much of Paragraph 18 of the Complaint that alleges that the Defendants made any representations to the plaintiffs and that the plaintiffs entrusted their financial well-being to the Defendants.  The remaining allegations require no answer of Defendants but to the extent that they require an answer, Defendants deny those allegations.
  4. Defendants deny Paragraph 19 in its entirety and restates the answer in paragraph 18 above.
  5. Defendants deny Paragraph 20 in its entirety and restates the answer in paragraph 18 above.
  6. Defendants deny Paragraph 21 in its entirety and restates the answer in paragraph 18 above.
  7. Defendants deny Paragraph 22 in its entirety and restates the answer in paragraph 18 above.
  8. Defendants deny Paragraph 23 to the extent that the plaintiff’s attribute their injuries to the Defendants’ actions.
  9. Defendants deny Paragraph 24 in its entirety. 
  10. Defendants deny Paragraph 25 in its entirety. 
  11. Defendants deny Paragraph 26 in its entirety.
  12. Defendants deny Paragraph 27 in its entirety.

THIRD CAUSE OF ACTION

  1. Defendants restate and incorporate herein by this reference, each of the answers contained in Paragraphs 1 through 15 inclusive and 16 through 27 inclusive.
  2. Defendants deny Paragraph 29 in its entirety.
  3. Defendants deny Paragraph 30 in its entirety.
  4. Defendants deny Paragraph 31 in its entirety.
  5. The allegations of paragraph 32 of the Complaint require no answer of Defendants.
  6. The allegations of paragraph 33 of the Complaint require no answer of Defendants but to the extent that they require an answer, Defendants deny participating in any blameworthy conduct.

FOURTH CAUSE OF ACTION

  1. Defendants restate and incorporate herein by this reference, each of the answers contained in Paragraphs 1 through 33 inclusive.
  2. Defendants deny Paragraph 35 in its entirety and restate that they did not enter any relationship with the plaintiffs.
  3. Defendants deny Paragraph 36 in its entirety and restate that they did not enter any relationship with the plaintiffs.

FIFTH CAUSE OF ACTION

  1. Defendants restate and incorporate herein by this reference, each of the answers contained in Paragraphs 1 through 36 inclusive.
  2. Defendants deny Paragraph 38 in its entirety and restate that they did not enter any relationship with the plaintiffs.
  3. Defendants deny Paragraph 39 in its entirety.

SIXTH CAUSE OF ACTION

  1. Defendants restate and incorporate herein by this reference, each of the answers contained in Paragraphs 1 through 39 inclusive.
  2. Defendants deny Paragraph 41 in its entirety and state that they made no such representation to the plaintiffs. 

SEVENTH CAUSE OF ACTION

  1. Defendants restate and incorporate herein by this reference, each of the answers contained in Paragraphs 1 through 41 inclusive.
  2. Defendants deny Paragraph 43 in its entirety and restate that they did not enter any relationship with the plaintiffs.

EIGHTH CAUSE OF ACTION

  1. Defendants restate and incorporate herein by this reference, each of the answers contained in Paragraphs 1 through 43 inclusive.
  2. Defendants deny Paragraph 45 in its entirety.
  3. Defendants deny Paragraph 46 and state that they are not familiar with any transaction with the said Francisco’s Mexican Restaurant.
  4. Defendants deny Paragraph 47 in its entirety.

PRAYER

WHEREFORE, these answering Defendants pray for judgment that their answer be deemed good and sufficient and all claims by Plaintiff against Defendants be dismissed, with prejudice, and such other and further relief, legal and equitable, including attorney’s fees, be

awarded Defendants.

DATED: XXX

        Respectfully Submitted

    Your signature
  NAME   Pro Se

 

CERTIFICATE OF SERVICE

 The undersigned does hereby certify that a true and correct copy of this Defendants’

answer to plaintiff’s complaint was duly served upon [ENTER ADDRESSES], on [ENTER DATE].

  Your signature
  NAME   Pro Se

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