AnswerCal. Super. - 3rd Dist.June 9, 2021PLD-C-010 ATTORNEY OR PARTY WITHOUT ATTORNEY (NAME AND ADDRESS): teLePpHone: Bar No. 176815 FOR COURT USE ONLY J. David Mufioz, Esq. Law Office of J. David Muftoz 7915 Painter Avenue Whittier, CA 80602 ATTORNEY FOR (NAME): Defendant, Robert Cales 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 Placer County Courthouse PLAINTIFF: LVNV FUNDING, LLC DEFENDANT: ROBERT CALES ANSWER-Contract CASE NUMBER: |_x | TO COMPLAINT OF (name): LVNV FUNDING, LLC M-CV-0079277 |__| TO CROSS-COMPLAINT (name): 1. This pleading, including attachments and exhibits, consists of the following number of pages: 2 2. DEFENDANT (name): ROBERT CALES answers the complaint or cross-complaint as follows: 3. Check ONLY ONE of the next two boxes: a. ([x_] 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). If this form is used to answer a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Paga 1 of 2 proved i Code of Civi 8 425. * judioal Council of Galfornia ANSWER-Contract aoe ro: courtsca.gov PLD-C-010 (Rev. January 1, 2007} PLD-C-010 SHORT TITLE: CASE NUMBER: LVNV FUNDING, LLC VS. ROBERT CALES, ET.AL M-GV-0079277 ANSWER-Contract 4. [x] AFFIRMATIVE DEFENSES Defendant alleges the following additional reasons that plaintiff is not entitled to recover anything: (1) Failure to State any Cause of Action (2) Failure to Mitigate (3) Laches (4) Unclean Hands (5) Statute. of Limitations. (6) Setoff (7)Waiver (8) Release (9) Consent (10) Reliance-Fraud (11) Equitable Estoppel (12) Statute of Frauds.(13) Statute of Limitations (14) Reservation of Future Defenses (__] Continued on Attachment-4. 5. [ _] Other 6. DEFENDANT PRAYS a. that plaintifftake nothing. b. [x] for costs of suit. c. [|] Other (specify): J. David Mufioz, Esq. ---------- nn FAS (Type or print name} {Signature of party or attorney) PLD-C:- 010 (Rev. January 71,2007] ANSWER-Contra ct Page 2 of 2
