Answer Unlimited Fee AppliesCal. Super. - 6th Dist.June 25, 2020b.) UI 9 10 11 12 16 17 18 19 20 21 22 ZOCV367587 Santa Clara - Civil ROBERT T. TANG, Esq, SBN 296544 The Law Office 0f Robert T. Tang 1580 Oakland Road, #C205 San Jose, CA 95131 (408) 816-8098 Attomey for Plaintiff, PTL Construction; and Cross-Defendants Liem Le and Yen Thanh Si H0. Electronically Filed by Superior Court of CA, County of Santa Clara, on 10/21/2020 10:58 AM Reviewed By: Y. Chavez Case #20CV367587 Envelope: 5149480 SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA UNLIMITED CIVIL CASE PTL CONSTRUCTION, A CALIFORNIA CORPORATION, Plaintiff, HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST; HUNG MAI; and CHI MAI, Defendants. HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST; HUNG MAI; and CHI MAI, Cross-Complainants, V. PTL CONSTRUCTION, A CALIFORNIA CORPORATION; LIEM LE, an individual; YEN THANH SI HO, an individual; and ROES 1-500, inclusive, Cross-Defendants Case No.2 20CV367587 | | | | CROSS-DEFENDANTS | LIEM LE AND l YEN THANH SI HO’S l ANSWER TO | UNVERIFED | CROSS-COMPLAINT | OF HUNG DINH MAI, | TRUSTEE OF MAI I HUNG 2014 LIVING | TRUST, HUNG MAI, l. CHI MAI | | | | | | | | | | | Complaint Filed: 06/25/2020 | FAC filed: 07/28/2020 | Cross-Complaint filed: 08/ 14/2020 l CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 20 14 LIVING TRUST, HUNG MAI, CHI MAI 1 Y. Chavez DJ UI 10 11 12 H DJ 14 16 17 18 19 20 COME NOW Cross-Defendants LIEM LE and YEN THANH SI HO (“CROSS-DEFENDANTS”) answer the unverified allegations of CROSS-COMPLAINANTS HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST. HUNG MAI AND CH1 MAI’s (hereinafter collectively “CROSS-COMPLAINTS”) as follows: GENERAL DENIAL 1. Pursuant to California Code of Civil Procedure § 431.30, CROSS-DEFENDANTS deny the allegations of the CROSS-COMPLAINT. and each cause of action, and each paragraph in each cause of action, and each and ever}; part thereof, including a denial that CROSS-COMPLAINANTS were damaged in the sum or sums alleged, or to be alleged, or any other sum or sums whatsoever. 2. Further answering the CROSS-COMPLAINT on file herein- and the whole thereof, including each and every purported cause of action therein, CROSS-DEFENDANTS deny that CROSS-COMPLAINANTS sustained any injury. damage or loss, if any. b): reason of any act or omission on its part. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE (Failure t0 State a Cause of Action) 3. The claims alleged in the CROSS-COMPLAINT fails to state facts sufficient to constitute a cause of action and/o: fail to state a claim upon which relief can be granted. SECOND AFFIRMATIVE DEFENSE (Contributory Negligence) 4. All events relevant to the allegations of the CROSS-COMPLAINT were proximately caused and contributed to by the legal fault of CROSS-COMPLAINANTS and, if there is any recovery, such amount must be reduced in proportion to the extent their own legal fault cased or contributed to their claimed damages. CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 2 COMPLAINT OF HUNG DINH MAI. TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAI. CHI MAI 10 ll 12 l6 l7 18 19 20 21 22 THIRD AFFIRMATIVE DEFENSE (Comparative Negligence - Fault 0f Others) 5. All events relevant t0 the allegations 0f the CROSS-COMPLAINT were proximately caused and contributed to by the legal fault of persons or entities other than CROSS-DEFENDANTS and, if there is a verdict in favor of CROSS- COMPLAINANTS, there should be apportionment of damages according to CROSS-DEFENDANTS‘ pro rata fault ancL to this extent, CROSS-DEFENDANTS are entitled to panial indemnity from others on a comparative fault basis. FOURTH AFFIRMATIVE DEFENSE (Compliance with All Laws) 6. CROSS-DEFENDANTS are absolved from any and all liability for the wrongs alleged in the CROSS- COMPLAINT and/or CROSS-COMPLAINANTS’ claims are barred by reason of CROSS-DEFENDANTS’ compliance with statutes, regulations. and/or other laws in effect at the time of the conduct alleged in the CROSS- COIVIPLAINT. FIFTH AFFIRMATIVE DEFENSE (Cross-Complainants’ Conduct) 7. CROSS-COMPLAINANTS’ claims are barred, in whole or in part. by their own conduct and/or wrongful acts. SIXTH AFFIRMATIVE DEFENSE (Waiver) 8. CROSS-COMPLAINANTS’ claims are barred by the doctrine of waiver because by their own words and conduct they have expressly or impliedly waived any claims they may have had against CROSS-DEFENDANTS. SEVENTH AFFIRMATIVE DEFENSE (Unclcan Hands) CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 3 COIVIPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAI, CHI MAI 10 11 12 l6 17 18 19 20 21 22 9. Each and ever}: cause of action alleged against CROSS-DEFENDANTS are barred in its entirety by the doctrine 0f unclean hands. CROSS-COMPLAINANTS’ unconscionable conduct upon which the CROSS-DEFENDANTS relied caused harm to CROSS-DEFENDANTS. EIGHTH AFFIRMATIVE DEFENSE (Equitable Estoppel) 10. CROSS-COMPLAINANTS’ claims are barred b): the doctrine of estoppel as a defense to each and every cause of action set forth in the CROSS-COMPLAINT. CROSS-COMPLAINANTS should be estopped from seeking any relief because of their wrongful/willful conduct. NINTH AFFIRMATIVE DEFENSE (Good Faith) 1 l. CROSS-COMPLAINANTS’ claims are barred, in whole or in part, because at all times CROSS- DEFENDANTS’ conduct was in good faith. was justified by legitimate business purposes, was privileged, was in pursuit of its economic interests. and/or lacked any wrongful intent. TENTH AFFIRMATIVE DEFENSE (Business Justification) 12. CROSS-DEFENDANTS’ conducL if any, was justified as such conduct was proper, fair, and legitimate business activity and/or due to business-related reasons which were neither albitrary, capricious, nor unlawful. ELEVENTH AFFIRMATIVE DEFENSE (Cross-Complainant Frivolous and in Bad Faith) 13. The CROSS-COMPLAINT and each pmported cause of action therein were not brought in good faith and are frivolous. Therefore, the relief requested is precluded and CROSS-DEFENDANTS are entitled to recover its reasonable expenses, including attomey’s fees. incurred herein as a matter of law pursuant to this Court’s inherent authority and California Code of Civil Procedure § 128.7. CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 4 COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 20 14 LIVING TRUST, HUNG MAI, CHI MAI bJ UI 10 ll 12 .- l4.) ._. 'JI l6 l7 18 l9 20 TWELFTH AFFIRMATIVE DEFENSE (N0 Direct Liability) l4. CROSS-COMPLAINANTS’ claims against CROSS-DEFENDANTS are barred because CROSS- COMPLAINANTS fail to adequately allege affirmative conduct or actions by CROSS-DEFENDANTS. THIRTEENTH AFFIRMATIVE DEFENSE (Speculative Damages) 15. The damages soughtby CROSS-COMPLAINANTS are speculative, and CROSS-COMPLAINANTS, through , the exercise of reasonable effort could have mitigated their damages, but the}: have refused and continue to refuse to exercise reasonable effort to mitigate damages. FOURTEENTH AFFIRMATIVE DEFENSE (Assumption 0f the Risk) l6. CROSS-COMPLAINANTS fail to state a cause of action in that, as to each of the acts alleged in the CROSS- COMPLAINT which were allegedly committed by CROSS-DEFENDANTS. CROSS-COMPLAINANTS expressly and voluntarily assumed the risk of loss of the alleged damages claimed in the CROSS-COMPLAINT. FIFTEENTH AFFIRMATIVE DEFENSE (Reduction t0 Percent 0f Fault) l7. The right of CROSS-COMPLAINANTS to recovery herein, if an}: right exists, is reduced and limited to the percentage of negligence attributable to CROSS-DEFENDANTS pursuant to Civil Code § 1431.2. SIXTEENTH AFFIRMATIVE DEFENSE (Su pcrseding Causes) 18. CROSS-DEFENDANTS are informed and believes. and on such inf0rmation and belief alleges, that all damages, if any: were the direct and proximate result of the intervening and superseding actions of otherpaxties, either served or unserved, and not CROSS-DEFENDANTS, and that such intervening and superseding actions of CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 5 COMPLAINT OF HUNG DINH MAI. TRUSTEE OF MAI HUNG 2014 LIVING TRUST. HUNG MAI, CHI MAI 9 10 ll 12 l3 l4 l6 l7 18 20 21 22 26 27 28 other parties, whether or not sen‘ed. bar recovery herein against CROSS-DEFENDANTS by or on behalf of CROSS-COMPLAINANTS. SEVENTEENTH AFFIRMATIVE DEFENSE (Unavoidahle Accident) l9. CROSS-DEFENDANTS are informed and believes, and on such information and belief alleges, that all injuries, losses or damages, if any, were the direct and proximate result of an unavoidable incident or condition and, as such, were an act of God without fault or liability on the pan of CROSS-DEFENDANTS. EIGHTEENTH AFFIRMATIVE DEFENSE (Active-Passive Negligence) 20. If CROSS-DEFENDANTS are found reSponsible in damages to CROSS-COMPLAINANTS or some other party or parties, whether as alleged or otherwise, then CROSS-DEFENDANTS are informed and believes, and on such information and beliefalleges, that such liability would be predicated upon the active conduct of CROSS- COMPLAINANTS, which unlawful conduct proximately caused the alleged incident, and that CROSS- COMPLAINANTS’ actions against CROSS-DEFENDANTS are barred by that active and affirmative conduct. NINETEENTH AFFIRMATIVE DEFENSE (Laches and Unreasonable Delay) 2 1. Each and every cause of action of the CROSS-COMPLAINANT alleged against CROSS-DEFENDANTS are barred under the doctrine of laches and is barred due to the unreasonable delay in bringing this action ofwhich they had previous knowledge of that they did not have a reason for the delay in asserting any claim for relief against CROSS-DEFENDANTS. Such delay had prejudiced the CROSS-DEFENDANTS. TWENTIETH AFFIRMATIVE DEFENSE (Failure to Mitigate) 22. Without peril to CROSS-DEFENDANTS’ denial of the existence of every alleged defect and claimed damage, CROSS-DEFENDANTS allege that CROSS-COMPL4AINANTS, while knowing of the purported defects and CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 6 COMPLAINT OF HUNG DINH MAI. TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAI, CH1 MAI DJ UI 10 11 12 16 17 18 19 20 21 22 damages complained of, if any there be, failed to undertake to mitigate their damages and/or increased their damages, if any there be. Accordingly, if they suffered any damages proximately caused by CROSS- DEFENDANTS, which it expressly denies, such damages should have been mitigated by reasonable efforts on the part of CROSS-COMPLAINANTS. TWENTY-FIRST AFFIRMATIVE DEFENSE (Unjust Enrichment) 23. The CROSS-COMPLAINT and each cause of action contained therein is barred by the doctrine of unjust enrichment. TWENTY-SECOND AFFIRMATIVE DEFENSE (Complete Performance) 24. It has appropriately, completely, and fully performed and discharged any and all obligations and legal duties arising out of the matters alleged in the CROSS-COMPLAINT. TWENTY-THIRD AFFIRMATIVE DEFENSE (Standard 0f Care) 25. CROSS-DEFENDANTS are informed and believes and based thereon alleges that at no time prior to the filing of this action did CROSS-COMPLAINANTS, or any agent, representative or employee thereof notify CROSS- DEFENDANTS of any breach of any contract: warranty, or duty to them. By reason of said failure to notify, they are barred from any right of recovety from CROSS-DEFENDANTS. Furthermore, CROSS-DEFENDANTS allege that CROSS-COMPLAINANTS are barred and precluded from any recovety in this action because CROSS- DEFENDANTS at all times complied with the applicable standard of care required of him at the time and location where professional sen'ices were rendered. TWENTY-FOURTH AFFIRMATIVE DEFENSE (Indemnification) CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- COWLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAI, CHI MAI 7 'u) Ut 10 11 12 l6 17 18 19 20 21 22 26. CROSS-DEFENDANTS are entitled to a right indemnification by apportionment against all other parties and persons whose negligence contn'buted proximately to the happening of the claimed accident or alleged injuries. TWENTY-FIFTH AFFIRMATIVE DEFENSE (Independent Causes) 27. The alleged inj uries, damages 0r loss, if any, for which CROSS-COMPLAINANTS seek recovery were the result of causes independent of any purported acts or omissions on the part of CROSS-DEFENDANTS, or any of its respective agents, representatives or employees, thereby eliminating or reducing the alleged liability of it. TWENTY-SIXTH AFFIRMATIVE DEFENSE (N0 Proximate Cause) 28. The acts and/or omissions, if any, of CROSS-DEFENDANTS was not the proximate cause of the losses, damage or injuries alleged in the CROSS-COMPLAINT. TWENTY-SEVENTH AFFIRMATIVE DEFENSE (Act 0f God) 29. The damages and defects of which CROSS-COMPLAINANTS complain, if any there are. were caused by acts of God for which CROSS-DEFENDANTS have no responsibility. TWENTY-EIGHTH AFFIRMATIVE DEFENSE (Unavoidable Conditions) 30. The alleged injuries, damages or loss, if any, for which CROSS-COMPLAINANTS seek recovely, were the direct and proximate result 0f unavoidable accidents or conditions without fault or liability on the part of CROSS- DEFENDANTS. // // CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 8 COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 20 14 LIVING TRUST. HUNG MAI, CHI MAI [Q Lu 9 10 11 12 l4 ._. 'JI 16 17 18 TWENTY-NINTH AFFIRMATIVE DEFENSE (Natu ral Causes) 3 1. The alleged injuries, damages or loss, if any, for which CROSS-COMPLAINANTS seek recovery were the direct and proximate result 0f natural deterioration wear and tear 0r other natural causes which were unforeseeable without fault 0r liability 0n the part 0f CROSS-DEFENDANTS. THIRTIETH AFFIRMATIVE DEFENSE (Passive Acts) 32. If CROSS-DEFENDANTS are found t0 have been negligent 0r liable in any manner‘ such negligence 0r liability was passive and secondary while the negligence 0r liability 0f CROSS-COMPLAINANTS and others was active and primary, and such active and primary negligence and liability bars, in whole or in part. the recovery requested, 0r any recovery, against CROSS-DEFENDANTS. THIRTY-FIRST AFFIRMATIVE DEFENSE (Intentional Conduct) 33. The CROSS-COMPLAINT, and each cause 0f action alleged therein, is barred by CROSS-COMPLAINANTS’ intentional conduct. THIRTY-SECOND AFFIRMATIVE DEFENSE (Justified Conduct) 34. The conduct 0fCROSS-DEFENDANTS with respect to the matters alleged in the CROSS-COMPLAINT was justified, and, by reason 0f the foregoing, CROSS-COMPLAINANTS are barred from any recovery against CROSS-DEFENDANTS. THIRTY-THIRD AFFIRMATIVE DEFENSE (Acquiescence) 35. CROSS-COMPLAINANTS acquiesced t0 any conduct engaged in by CROSS-DEFENDANTS. CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 9 COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAI, CHI MAI 10 11 12 13 l4 16 l7 18 20 21 22 THIRTY-FOURTH AFFIRMATIVE DEFENSE (Ratification) 36. CROSS-COMPLAINANTS expressly ordered. approved, authorized, participated in and ratified the actions and transactions complained of and the actions upon which recovery is allegedly sought, and they are accordingly precluded from recovery. THIRTY-FIFTH AFFIRMATIVE DEFENSE (Express Consent) 37. CROSS-COMPLAINANTS expressly consented to the actions alleged to have caused their damages. THIRTY-SIXTH AFFIRMATIVE DEFENSE (Implied Consent) 38. CROSS-COMPLAINANTS impliedly consented to the actions alleged to have caused their damages. THIRTY-SEVENTH AFFIRMATIVE DEFENSE (Privilege and Consent) 39. CROSS-COMPLAINANTS' claims against CROSS-DEFENDANTS are barred in that any conduct by CROSS- DEFENDANTS was privileged and/or fully consented to by the parties. THIRTY-EIGHTH AFFIRMATIVE DEFENSE (Lack of Notice) 40. The CROSS-COMPLAINT, and cach cause of action allcgcd therein, is barred by CROSS-COMPLAINANTS’ failure to timely notify CROSS-DEFENDANTS of the alleged defects, breach and/or damages, if any, which any part}: may have sustained. THIRTY-NINTH AFFIRMATIVE DEFENSE (No Reliance) CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 10 COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAI, CHI MAI b.) UI 10 11 12 16 17 18 19 20 21 22 26 27 28 4 l. CROSS-COMPLAINANTS did not rely on any representations or conduct of CROSS-DEFENDANTS and therefore it is not responsible for any damages, if any exist. In the event that they did rely on representations, which CROSS-DEFENDANTS deny, such reliance was notjustified. FORTIETH AFFIRMATIVE DEFENSE (Ofi'set) 42. By Virtue of the acts, omissions and misrepresentations of CROSS-COMPLAINANTS, CROSS-DEFENDANTS have incurred damages and expenses, all in amounts to be ascertained and applied as an offset against the claims of CROSS-COMPLAINANTS. FORTY-FIRST AFFIRMATIVE DEFENSE (Absence 0f Necessary Parties) 43. The purported claims and causes of action contained in the CROSS-COMPLAINT require, for complete adjudication the joining of additional, necessary or indispensable parties, without whom the purported claims and causes of action cannot by fully, finally and completely resolved. FORTY-SECOND AFFIRMATIVE DEFENSE (N0 Justiciable Controversy) 44. CROSS-DEFENDANTS are informed and believes and based thereonalleges that the CROSS-COMPLAINT, and each purported cause of action contained therein, was brought without reasonable care and without a good faith belief that there was a justiciable controversy under the facts and the law which warranted the filing of the CROSS- COMPLAINT against CROSS-DEFENDANTS: therefore, CROSS-COMPLAINANTS are responsible for all necessary and reasonable costs including attomey‘s fees incurred by CROSS-DEFENDANTS as more particularly set forth in California Code of Civil Procedure section 128.5. FORTY-THIRD AFFIRMATIVE DEFENSE (California Business and Professions Code § 7031) CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 11 COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 201-1 LIVING TRUST, HUNG MAI, CHI MAI 10 11 12 16 17 18 19 20 21 22 26 27 28 45. CROSS-DEFENDANTS allege that CROSS-COMPLAINANTS are prohibited from bringing any action pursuant to California Business and Professions Code § 703 1, which states: No personengaged in the business or acting in the capacity of a contractor, may bring or maintain any action. 01 recovery in law or equity in any action. in any court of this state for the collection of compensation for the performance of any act or contract where a license is required by [California Business and Professions Code section 7031] without alleging that he or she was a duly licensed contractor at all times during the performance of that act or contract, regardless of the merits of the cause of action brought by the person FORTY-FOURTH AFFIRMATIVE DEFENSE (Unstated Additional Defenses) 46. CROSS-DEFENDANTS presently have insufficient knowledge and information on which to form a belief as to whether there exist additional, as yet unstated. affirmative defenses. CROSS-DEFENDANTS reserve herein the right to assert additional affirmative defenses in the event that discovery indicates that such defenses would be appropriate. FORTY-FIFTH AFFIRMATIVE DEFENSE (False Claims) 47. Each and every cause of action alleged against CROSS-DEFENDANTS is barred as a matter of law as the CROSS-COMPLAINANTS makes numerous blatantly false claims. FORTY-SIXTH AFFIRMATIVE DEFENSE (N0 Actual Injury) 48. As a defense to each and every cause of action set forth in the CROSS-COMPLAINT, CROSS- COMPLAINANTS have suffered no actual injury and no harm resulted out of the cause of action. FORTY-SEVENTH AFFIRMATIVE DEFENSE (Standing) CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 12 COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 20 14 LIVING TRUST, HUNG MAI, CHI MAI 10 ll 12 13 14 16 17 18 19 20 21 22 23 2-1 26 27 28 49. As a defense to each and every cause of action in the CROSS-COMPLAINT, CROSS-COMPLAINANTS have not sustained any legally cognizable inj ury and therefore lack standing. FORTY-EIGHTH AFFIRMATIVE DEFENSE (Reservation 0f Rights) 50. As discovery has not yet been completed, CROSS-DEFENDANTS respectfully request to reserve their right to amend and state additional affirmative defenses that have not been pleaded as of this time. RELIEF REQUESTED WHEREFORE, CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO pray that the Court: l. Dismiss the CROSS-COMPLAINT against CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO, with prejudice and on the men’ts; 2. Award CROSS-DEFENDANTS LIEM LE and YEN THANH SI HO their costs, attomeys’ fees, and disbursements herein; and Order such other further relief as this Court ma}: find just and proper./€ Dated: October 21. 2020 (I / f7%4% //7// Robefi T. Tang, Esci. Attorney for a LIEM LE and CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS- 13 COMPLAINT OF HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAI. CHI MAI 24 25 26 27 PROOF OF SERVICE [CCP §§ 1013(a); CCP§1010.6.; and 2015.5; FRCP 5] I am employed in the County ofSANTA CLARA. I am over the age of I 8 and not a party to the within action. My business address is 1580 Oakland Road, C205, San Jose, California 95 13 1. My email address is: annie@r0berttlaw.org On the below date, I served the foregoing document described as: CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO’S ANSWER TO UNVERIFIED CROSS-COMPLAINT OF HUNG MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST. HUNG MAI. CHI MAI on the interested parties in this action addressed as follows: Law Offices of Jonathan J . Sweet Jonathan J. Sweet, Esq. (SBN 122876) 75 E Santa Clara Street. Suite 1 180 San Jose, CA 951 13-1834 Email: jonathansweetlaw@comcast.net Attorneys for Def'endants/C ross-Complainants HUNG DINH MAI, TRUSTEE OF MAI HUNG 2014 LIVING TRUST HUNG MAI, CHI MAI LEWIS BRISBOIS BISGAARD & SMITH LLP Barry G. Kaiman, Esq. (SBN 76934) 333 Bush Street, Suite 1100 San Francisco, California 94104 E-Mail: Barry.Kaiman@lewisbrisb0is.com Attorneys for Cross-Def‘endant PTL Construction, a California Corporation X (BY ELECTRONIC SERVICE) -I sent this document via electronic transmission to the offices of the addressees as listed above pursuant to CCP §101 0.6. Executed on October 21, 2020 at SAN JOSE, California. I declare under penalty of perjury under the laws ofthe State of‘Califbmia that the above is true and correct.%1 . I/ Annie Lu CROSS-DEFENDANTS LIEM LE AND YEN THANH SI HO'S ANSWER T0 UNVERIFIED CROSS- COMPLAINT OF HUNG DINH MAL TRUSTEE OF MAI HUNG 2014 LIVING TRUST, HUNG MAL CHI MAI 14