AnswerCal. Super. - 3rd Dist.November 27, 2019 PLD-C-010 ATTORNEY OR PARTY WITHOUT ATTORNEY (NAME AND ADDRESS): TELEPHONE: 405-212-2257 FOR COURT USE ONLY: Jennifer Tunder #291806 Law Offices of Robert S. Gitmeid P.C. s F I L E D 4401 NW 4th St., Suite 116, Oklahoma City, OK 73107 oe “our oy Of California acer ATTORNEY FOR (NAME): Carol Ringer JAN 07 2020 Insert name of court, judicial district or branch court, if any, and post office and street address: Superior Court of California, County of Placer 10820 Justice Center Drive Roseville, CA 95678 Bill Santucci Justice Center Jake Chatters Executive Officer & Cl By: E. Kouvdos, Dep LP PLAINTIFF: American Express National Bank DEFENDANT: Carol Ringer ANSWER-Contract - TO COMPLAINT OF (name): American Express National Bank MCV0075250 [__] TO CROSS-COMPLAINT (name): 1. This pleading, including attachments and exhibits, consists of the following number of pages: 2 \ 2. DEFENDANT (name): Carol Ringer \y answers the complaint or cross-compiaint as follows: ne 3. Check ONLY ONE of the next two boxes: ‘5 a. Defendant generally denies each statement of the complaint or cross-complaint. (Do not check this box if the verified complaint or cross-complaint demands more than $1,000.) b. [__] 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): [__] 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): [-_] Continued on Attachment 3.b.(2). y If this form is used to answer a cross-complaint, plaintiff means cross-complai and dant means cross-defend: <<“ Page 1 of 2 Form Approved for ¢ Optional Use ANSWER-Contract CaN mn ae PLD-C-010 [Rev. January 1, 2007] i Le 4) -_ col PLD-C-010 SHORT TITLE: CASE NUMBER: American Express National Bank v. Carol Ringer MCV0075250 ANSWER-Contract 4. AFFIRMATIVE DEFENSES Defendant alleges the following additional reasons that plaintiff is not entitled to recover anything: Ambiguity- Plaintiff did not clearly state the amount of the issue(s) in this case. Unclean Hands. Unjust Enrichment. Invalid/ Illegal Contract - The contract is invalid/ illegal and cannot be enforced because of fraud, deceit, or misrepresentation by Plaintiff or another party. Invalid/ Illegal Contract- The contract is invalid/illegal and cannot be enforced because of lack of consideration. Invalid/ Illegal Contract- The contract is invalid/illegal and cannot be enforced because of mistake. Waiver. Standing- Plaintiff is not who entered the Contract with it did not provide a copy of an agreement which shows it is the legal owner of the alleged debt and the right to bring this cause to collect the debt. Failure to state a case of action, Plaintiff failed to state an essential element for: Breach of contract: it did not state the specific date the contract was entered into/ it did not state the specific date the contract was breached/ not complied with. No Damage to Plaintiff. Usury-Cal. Civ. Code §§ 1914.12.2 1916.12.2. Plaintiff failed to give credit for payments made. Failure of validation of debts § 1692g § 809. Complaint is barred by both the doctrines of Laches and Estoppel, Defendant reserves the right to amend and or add additional Answers, Defenses and/or Counterclaims at a later date. Lt) Continued on Attachment 4. 5. [__] Other 6. DEFENDANT PRAYS a. that plaintiff take nothing. b. [__] for costs of suit. c. [_] other (specify): ei cd sateen e eee arene nnccere / / on. { PLD-C - 010 [Rev. January 1, 2007] ANSWER-Contract W Zi Page 2 of 2
