Answer Limited Up to 10K

Cal. Super. - 6th Dist.March 19, 2021

Anthony M Ortiz 1703 Eisenhower Dr Santa Clara, CA 95054 eo95054@yahoo.com Defendant is selfirepresented SUPERIOR COURT OF THE STATE 0F CALIFORNIA FOR THE COUNTY OF* SANTA CLARA Bank ofAmen'ca N.A, ANSWER Plaintifi‘, Civil N0.: 21CV379162 vs. Judge: Anthony M Ortiz, Defendant(s). Defendant answers Plaintiff’s Complaint as follows. RESPONSE T0 ALLEGATIONS J AllegationvNumper , 7 4f g; “3;: C d ‘0 r;*?“,fij; u’efspgjnse'j f :75; '3: 3; U_=‘j‘}::ag:1h 7. Lg“ ‘n‘ 1. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. 2. Defendant admits the allegation. 3. Defendant admits the allegation. 4. Defendant denies the allegation for lack ofknowledge sufiicient to know the truth or falsity thereof. S. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. 6. Defendant denies the allegation for lack of knowledge sufficient to know the truth or falsity thereof. 7. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. 8. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. 9. Defendant denies the allegation. 1 10. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. II. Defendant denies the allegation. 12. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. 13. Defendant denies the allegation for lack of knowledge sufficient to know the truth or falsity thereof. 14. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. 15. Defendant denies the allegation. 16. Defendant denies the allegation. 17. Defendant denies the allegation for lack 0fknowledge sufficient to know the truth or falsity thereof. 18. Defendant denies the allegation for lack ofknowledge sufficient to know the truth or falsity thereof. Defendant denies each and every allegation in the Complaint that is not expressly admitted herein. With respect to all paragraphs in which Plaintiff prays for damages or other relief, Defendant denies that Plaintiff is entitled to such relief under law. AFFIRMATIVE DEFENSES 1. Plaintifi"s claims are barred in whole or in part by the doctrines of laches, equitable estoppel, and unclean hands. 2. Plaintifi’s claims are barred in whole or in part because of a failure to mitigate damages. 3. Plaintiff‘s claims are barred in whole or in part by the statute of limitations. 4. Plaintiff’s claims are barred in whole or in part because Plaintiff harassed Defendant for the debt in violation of the law. 5. Defendant requests that Plaintiff perform an accounting and provide Defendant with documentation that proves the amount that Defendant allegedly owes. 6. Plaintiff’s claims are barred in whole 0r in part because the contragt language is vague and ambiguous. WHEREFORE, Defendant requests the following relief: 1. That Plaintiff’s Complaint be dismissed with prejudice, and Plaintiff take nothing therefrom; 2. The Defendant recover its reasonable fees and costs incurred in defending against this lawsuit; 3. For such other and filrther relief as this Court may deem just and proper. DATED 05/05/2021. ls/ Anthony M Ortiz Anthony M Ortiz Self-represented Original 0f the forgoing was caused to be filed via US Mail on 05/05/2021 t0: The court Copy caused to be sent via US Mail on this day t0: Erin E Patterson SBN 262285 P.O. Box C90006 Bellevue California 98009 /s/ AnthonyM Ortiz Anthony M Ortiz Ser-represented