Answer Limited Up to 10K

Cal. Super. - 6th Dist.July 9, 2018

FILED PLD-C-D10 ATTORNEY 0R PARTY WITHOUT ATrORNEY (NAME AND ADDRESS): TELEPHONE: (408) 690-2391 nqugJoua'zmgomv: Juan Ruiz 122 Millhaven Place, San Jose, California 951 11 ATrORNEY FOR (NAME): In pm per Insert name of court, judicial district or branch court, if any, and post office and street address: SUPERIOR COURT 0F CALIFORNIA, COUNTY OF Santa Clara Downtown Superior Court 191 N. First Street. San Jose. CA 951 13 PLAINTIFF: Midland Funding LLC DEFENDANT: Juan Ruiz ANSWER-Contract CASE ”UMBER To COMPLAINT 0F (name): Midland Funding LLC 180V331224D To eRoss-COMPLAINT (name): 1. This pleading, including attachments and exhibits. consists of the following number of pages: 2 2. DEFENDANT (name): Juan Ruiz answers the complaint or cross-complaint as follows: 3. Check ONLY ONE of the next two boxes: a. E Defendant generally denies each statement of the complaint or cross-complaint. (Do not check this boxif the verified complaint or cross-complaint demands more than $1, 000.) b. E 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): D 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): E Continued on Attachment 3.b.(2). l1 this tam ls used ta answera mss-eomplalnt. plaintiff means cross-complatnant and defendant means cross-defendant. Fags 1 o! 2 Form Approved tor Optional Use c Code o! Civil Procedure. § 425.12 Ju didal Ccundl ot California ANSWER antract meourtinlo.m.gov PLD-c-ow [Rem January 1. 2007] PLD-C-010 SHORT TITLE: CASE NUMBER: Midland Funding LLC v. Juan Ruiz 1SCV331224 ANSWER-Contract 4. m AFFIRMATIVE DEFENSES Defendant alleges the following additional reasons that plaintiff is not entitled to recdver anything: Defendant is informed and believes and thereon alleges that Defendant does not owe the amount demanded or any other sum. Plaintiff has suffered no damages whatsoever as a result of any conduct by this answering Defendant. Defendant alleges that Defendant is informed and believes upon such information that Defendant never agreed in writing to the alleged amounts owed. This suit is time barred by the statute of limitations. The cOmpiaint, and each and every claim therein, is barred by applicable statutes of limitations, including without limitation pursuant to Sections 337. 338(d), 339(1), 339(3). 340, andlor 343 of the California Code of Civil Procedure. Defendant is a victim of identity theft related to this account. E Continued on Attachment 4. 5. D Other l. 6. DEFENDANT PRAYS a. that plaintiff take nothing. b. E for costs of suit. c- E other (specify): Juan Ruiz ”“7; (Type or print name) (Signatumfirty or atlonTey) PLD-C-010 [Rem January 1. 2007] ANSWER-contract PageZ 0'2 \OWQQMAWNH H O 11 12 13 14 15 l6 17 18 19 20 21 22 23 24 25 26 27 28 FILED AUGZI 2m Name of Case: MIDLAND FUNDING LLC v. JUAN RUIZ Case Number: 18CV331224 . .- _ 1F COURTfl (.1913? fPROOF 0F SERVICE BY MAIL ‘=. “=1 Sam“; €13ng (Code Civ. Proc., sections 1012, 1013a, 2015.5; Fed. Rules Civ.Proc., Rule 5(b).) I declare that my address is Bay Area Legal Aid, 1800 Market Street, Third Floor, San Francisco CA 94102; that I am a citizen of the United States, over 18 years of age, employed by Bay Area Legal Aid and not a party to the within action; and, thatI am readily familiar with the Bay Area Legal Aid business practice for collection and processing of correspondence for mailing with the United States Postal Services, and know that in the ordinary course of BayLegal’s office business practice the document described below will be deposited with the United States Postal Service on the same date that it is sealed and placed at BayLegal's office with fully prepaid postage thereon. I further declare that on August 16, 2018 I served a true copy o'f the attached: ANSWER by placing said copy in an envelope(s) addressed as follows: Charles Ricth Hoeg III Midland Funding LLC 10601-G Tierrasanta Blvd, #4540 San Diego, CA 92124 which place has mail service, which envelope was then sealed, postage fully prepaid thereon, and deposited today by directly depositing said envelope in the United States Mail. I declare under penalty of perjury that the foregoing is true and correct. Executed on August 16 2018, at San Francisco, California. Jason Luu {1% o g“- ' Print Name Signature