This cookie is set by GDPR Cookie Consent plugin. (Advantac Group, Inc. v. Edwins Plumbing Co., Inc. (2007) 153 Cal.App.4th 621, 627. (b) The answer to a complaint shall contain: (1) The general or specific denial of the material allegations of the complaint controverted by the defendant. Filing and Service Time of Filing Since a general denial puts in issue the material allegations of the complaint, affirmative defenses which only redress the essential elements of plaintiffs claims can be adequately stated with mere generic references. hb```" ,`q/>jK`nN&S66pt\P37C The only strategical advantage comes when the plaintiff desires the defendant to file a verified answer. As a result, even where a defense is defectively pled, it may be allowed if the defendants pleading gives sufficient notice to enable the plaintiff to prepare to meet the defense, in part because un-pled defenses are waived. VERIFIED COMPLAINT Analay Souza Campos ("Analay" or "Ms. Campos"), by and through counsel, Callagy Law, P.C., alleges as follows: 1. unless the defendant consents in writing, or in open court (consent in open court Accessing Verdicts requires a change to your plan. 430.40(b)). In many jurisdictions, a complaint does not need to be verified unless a rule or statute . But opting out of some of these cookies may affect your browsing experience. All rights reserved. Plaintiff's unverified Third Amended Complaint ("Complaint") by admitting, denying and alleging as follows: / / / E-FILED Apr 19, 2016 2:45 PM David H. Yamasaki Chief Executive Officer/Clerk Superior Court of CA, County of Santa Clara Case #1-13-CV-258281 Filing #G-82948 By R. Walker, Deputy 2d 725, 733). Ifyou decide to amend your complaint after some defendants have been served with your original complaint and summons but before other defendants have been served (or you have added new defendants in your amended complaint), you should take the following steps: 1. This is due to the fact that an answer that contains nothing but "boilerplate" affirmative defenses is vulnerable to a demurrer on the grounds that the answer fails to state facts sufficient to state any defenses to the complaint. endstream endobj However you should also be sure to include specific affirmative defenses that are tailored to the individual case. . App. If you are filing the answer for yourself and another) Tj 0 -17.28 TD -0.0448 Tc -0.0043 Tw (defendant named in the Complaint, put both your names in line 1.) January 1, 2007] www.courtinfo.ca.gov Page 1 of 2 Your Phone # Your Name Your Street Address 2008) Pleading, 1082, p. Attorneys for Defendant(s) Peggy Osborn-Parker court and court location for the trial thereof, all proper proceedings may be had, 0000011878 00000 n Matthew M. Macke, Esq. Proc. Stay up-to-date with how the law affects your life. The Right California Business Lawyers For All Corporate Lawsuits. TENTATIVE RULING Bar No. Proc. January 1, 2007] (NAME AND ADDRESS): (NAME): (name): www.courtinfo.ca.gov Page 1 of 2 Your Phone# Your Name Your Street Address Your City, State, Zip Code IN PRO PER Superior Court of California CIVIL DIVISION CHECK WITH STAFF Person . IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA commenced, or a judge thereof, shall, whenever that fact appears, transfer it to the Plaintiff and cross-defendant Garth Murrins motion for judgment on the pleadings for each cause of action in both his complaint against defendant Tram Phan and as to Ms. Phams cross-complaint against Plaintiff/Cross-Defendant is denied in part and granted in part. Pursuant to section 1010.6 of the Code of Civil Procedure, rule 2.253 (b) (2) of the California Rules of Court, Orange County Superior Court Rule 352, and Administrative Order 13/03, all documents filed by attorneys in limited, unlimited, and complex civil actions must be filed electronically unless the Court rules otherwise. 10 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA If you wish to keep the information in your envelope between pages, The benefit of forcing a verified answer will often outweigh that cost especially if the benefit is an almost certain lie the defendant will make in a verified answer. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-396a/. Email: norcal.legal@farmersinsurance.com FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. 2011-10-17T15:32:09-07:00 What is the effect of a verified complaint? xZ{xT_{sf& @3LL*d f5L4 VkQ(TVmWWJ}B3$^k^{}NBU[XXLSZ9@V7o-"Wc"k[Snecc]KWqDrm$uijKso7;? _=M-SSvQ!D !2|7$Kw.l"=M4RUAuRHJO^*b*Kot G')68!j4#p6=J Facsimile: 213.620.1398 10 Tj 0 -45.12 TD /F1 19.92 Tf 0.09 Tc 0 Tw (7.) It could hurt your case greatly for the minor benefit of possibly catching the defendant in a lie. Ifthe defendant has filed a motion to dismiss but has not filed an answer, you are still entitled to file one amended complaint without permission. You might be awarded attorneys fees or discovery sanctions for the perjured evidence. Tj 108 -36.72 TD 0.0673 Tc 0 Tw (B.) 4 Can you amend a complaint to add a cause of action? An unverified answer is subject to a motion to strike in its entirety; but the motion must be made within 10 days after service of the answer. 0000023020 00000 n if the answer pleads a contract, it cannot be ascertained from the answer whether the contract is written or oral. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. I want to stress again that if you include only boilerplate affirmative defenses you run the risk of the plaintiff filing a demurrer to your answer. (State Farm Mut. 223759 App. The plaintiff knows or believes that all allegations that the plaintiff has personal knowledge of to be true. Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors. How do I amend a civil complaint against a defendant? You will lose the information in your envelope, D.H. Slater & Son, Inc's First Amended Answer to Cross-Complaint of Guy Re, Guthrie, Samuel vs. DH Slater & Son, Inc et al, Paul Nickel et al vs Liberty Mutual Insurance Company et al, COMMUNITY HOSPITAL OF THE MONTEREY PENINSULA vs. KAISER FOUNDATION HEALTH . This is an answer which must admit or deny each . At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. 184 0 obj<> endobj 186 0 obj<>/Font<>>>/Contents 187 0 R/CropBox[0 0 612 792]/Parent 181 0 R>> endobj 187 0 obj<>stream 438(c)(1)(A)). We use cookies on our website to give you the most relevant experience by remembering your preferences and repeat visits. Any further extensions shall be obtained by court order upon a showing of good cause. 0000018863 00000 n 3 San Francisco, California 94111 paragraphs or parts of the complaint; or by express admission of certain allegations What body systems are affected by smoking? Most civil complaints in California are not verified unless a particular statute or code provides otherwise, although any plaintiff may choose to verify their complaint if they want. 4 (Harris v. City of Santa Monica (2013) 56 Cal. pgr@swr-law.com x@0 9h@::P(:|k r\SN\=?# "B-:A The pleader must include ultimate facts sufficient to put the plaintiff on notice of the nature of the defense. Tj 0 -45.6 TD /F0 19.92 Tf 0.0338 Tc 0.0022 Tw (If you have defenses to the lawsuit, go to the next) Tj 0 -22.8 TD 0.023 Tc 0.037 Tw (section. 2d 439, 440; See also Adjustment Corp v. Hollywood etc. Do you want to use this article on your website, blog or e-zine? equal employment Tj 0 -34.32 TD 0.09 Tc 0 Tw (b.) Many) Tj 0 -18.48 TD -0.0481 Tc 0.0644 Tw (common affirmative defenses can be found on the lists in the \223Answer) Tj T* -0.0344 Tc 0.0044 Tw (Notebook.\224 Explanations of the different affirmative defenses can be) Tj 0 -18.24 TD -0.0246 Tc 0.0046 Tw (found in booklet ) Tj 109.92 0 TD /F0 16.08 Tf 0 Tc 0 Tw (2a) Tj 16.08 0 TD /F1 16.08 Tf -0.06 Tc 0.12 Tw ( entitled ) Tj 55.92 0 TD /F7 16.08 Tf -0.03 Tc -0.0472 Tw (\223Legal Reasons Why I Should Not Have to) Tj -181.92 -18.48 TD -0.0437 Tc 0.1037 Tw (Pay the Money.\224) Tj 0 -36.72 TD /F1 16.08 Tf -0.0552 Tc 0.1352 Tw (If you choose to attach one of the affirmative defense lists, mark the) Tj 0 -18.48 TD -0.0471 Tc 0.0871 Tw (letters of the affirmative defenses that apply to your case, and place the) Tj T* -0.0462 Tc 0.0822 Tw (attachment behind the answer form, but in front of the ) Tj 350.64 0 TD /F0 16.08 Tf -0.0228 Tc -0.1572 Tw (certificate of) Tj -350.64 -18.24 TD -0.0461 Tc 0.1061 Tw (service by mail) Tj 102.24 0 TD /F1 16.08 Tf 0.06 Tc 0 Tw (.) Tj ET endstream endobj 22 0 obj <> endobj xref notice of the filing. Answering an unverified complaint should be done within 30 calendar days from the date that you were served unless the plaintiff or their attorney has granted you an extension of time. 8 JOSE LUIS MENDEZ I am submitting my complaint on pleading paper (as opposed to using the standard forms, i.e., PLD-PI-001). 2 How do you respond to a verified complaint? 2 SAMUELSON, WILSON & ROE Warren v. Harootunian (1961) 189 Cal.App.2d 546, 548. (FPI Development, Inc. v. Nakashima (1991) 231 Cal.App.3d 367, 384; 5 Witkin, Cal. A denial needs no support. complaint is considered verified if, in the complaint, the plaintiff swears under penalty of perjury that everything is true and correct. They are currently arriving within 30 minutes of purchase. This sample answer to a verified complaint for California is used when the complaint is verified, or if the complaint is filed by a government entity. The experienced California business litigators at Structure Law Group know the litigation strategy that is best for your particular case. 0000023131 00000 n 8 Necessary cookies are absolutely essential for the website to function properly. Right out of the gate this demurrer is procedurally defective in that it fails to separately specify each defense challenged and the challenge grounds thereto. Pleasanton, California 94588 trailer MARC J. FELDMAN, Cal. Tj 36 0 TD 0.0114 Tc 0.0966 Tw (Telling the Court What You Want) Tj ET 108 192.96 273.36 0.96 re f BT 72 176.64 TD /F1 16.08 Tf -0.0583 Tc 0.1355 Tw (If you believe you do not owe the plaintiff any money at all, and that) Tj 0 -18.24 TD -0.0374 Tc 0.0236 Tw (you should not have been sued, you can ask the court to order the) Tj 0 -18.48 TD -0.0447 Tc 0.0532 Tw (plaintiff to pay you back the costs you paid to the court to file your) Tj T* -0.036 Tc 0.024 Tw (answer. 3 Diego E. Garcia, SBN 333411 Two Embarcadero Center, Suite 1450 Effective immediately we have updated our refund policy! Sometimes the verification will be separate from the complaint; other times it will be included at the end of the Complaint itself. 0000001879 00000 n The movant shall file the motion, in six copies, within five (5) days from the date on which he receives notice of the order or decision, object of the motion for reconsideration, the same to be verified under oath with respect to the correctness of the allegations of fact, and serving a copy thereof, personally or by . Your subscription was successfully upgraded. Accordingly, the Answer is not filed in conformity with the statutory and is subject in be stricken. LIBERTY MUTUAL, 41906-50-25 (BEAT/LEON, BULMARO) 22-2517560 If it is verified, the plaintiff makes assertions under the pains and penalties of perjury. 3d 1372, 1379-81. However, in Brisson v. The Third Circuit disagreed. Code of Civil Procedure 430.41 requires that before filing a demurrer, the demurring party must meet and confer. Email Address: tim.schweigerdt@statefarm.com The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". may be made as in other cases, within the time, upon the grounds, and in the manner A defendant raising such new matters must allege ultimate facts sufficient to prove the defense with the same level of detail that a plaintiff is required to allege ultimate facts to support a cause of action in a complaint. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. Typically, a plaintiff verifies a complaint by attaching a page at the end containing a statement made under oath that: Except when otherwise specifically required by law or rule, pleadings need not be under oath, verified or accompanied by affidavit. This can start your case off on the wrong foot entirely and make your case appear weaker than it actually is. Stay up-to-date with how the law affects your life. Plaintiff apparently takes issue with all twelve affirmative defenses. The contact form sends information by non-encrypted email, which is not secure. Walnut Creek, CA 94598 ********************************* 1. 5 0000002092 00000 n 3 Phone: (510) 457-3440 291126 This often means that the defendants most egregious conduct cannot be detailed in the complaint. Proc. Can a divorce complaint be amended to add a verification? Demurrer to Answer If you cannot type the forms, make sure you) Tj T* 0.0075 Tc 0.0525 Tw (print neatly using ) Tj 144.72 0 TD 0.0107 Tc 0 Tw (black) Tj 43.2 0 TD 0.0706 Tc -0.0106 Tw ( ink.) The cookie is used to store the user consent for the cookies in the category "Performance". 7 When filing a lawsuit in California, the original complaint may be either verified or unverified. When filing a lawsuit in California, the original complaint may be either verified or unverified. 0>WdG@aDc6>gY{otDo75MuZ]6X0qi2g9Jr nGA }Wg 1|^ku(){Ky)U|( F1Bj1Lu=>^N8=vf]}Oo.6^*-^k'3tdVfY((P(uDigwM{6a?aAy``O8d|*fZgy| equal access law Summary: California courts generally are to liberally permit amendments to the Complaint during any stage of the case if the defendant is not prejudiced by the delay; such includes adding a new cause of action after the statute of limitations has run if the cause of action is based on the same general set of facts . 144830 to any defendant, so served, who has not appeared in the action or proceeding, the State Bar No. be had as provided by local rules of the superior court. 2 Marissa E. Buck, SBN 293373 If the complaint is verified, defendant must verify the answer. (1) Complaint includes a cross-complaint. [CCP 430.20 et. A general demurrer to an answer admits all facts well pleaded in the answer, including denials. A plaintiff may recover judgment on a motion for judgment on the pleadings only if his complaint states facts sufficient to constitute a cause of action and the answer neither raises a material issue nor states a defense. (Mclain v. City of South Pasadena (1957) 155 Cal. Under the California Code of Civil Procedure ("C.C.P."), if a complaint is verified, the defendant must verify his answer, C.C.P. 435. A pleading is verified by an affidavit that the affiant has read the pleading and that the allegations therein are true and correct of his personal knowledge or based on authentic records. (SBN: 129773) THE MODEL BAKERY, LLC and mbuck@dpf-law.com ), A general denial in an answer puts in issue the material allegations of the complaint, including all essential elements of the claims. The demurrer as to the remaining affirmative defenses, is overruled. In all cases of a verification of a pleading, the affidavit of For full print and download access, please subscribe at https://www.trellis.law/. more analytics for Honigsberg, Christopher M. Lucie Michail vs. PACIFIC SPECIALTY INSURANCE COMPANY, et al. 515.) 2 MAYNARD NEXSEN LLP The motion is denied as to the fourth cause of action for quiet title in Plaintiffs complaint. However, the court may, on terms that are just, permit the affidavit to be filed BT 72 74.64 TD 0 0 0 rg /F1 10.08 Tf -0.0013 Tc 0 Tw (SC__3/00) Tj ET q 303.6 72 5.04 11.52 re W n BT 303.6 74.64 TD 0 Tc (5) Tj ET Q BT 116.16 701.52 TD /F0 19.92 Tf 0.03 Tc 0.03 Tw (IF YOU HAVE DEFENSES TO THE CASE) Tj -44.16 -45.36 TD /F1 19.92 Tf 0.09 Tc 0 Tw (4.) Answering an unverified complaint should be done within 30 calendar days from the date that you were served unless the plaintiff or their attorney has granted you an extension of time. try clicking the minimize button instead. may be intelligibly distinguished. Spirit Aviation Servcies, Inc. VS C&D Zodiac, Inc. SECRET RECIPES, INC. VS FELIX LOPEZ, AN INDIVIDUAL, HOVHANNES MARKOSYAN VS NAREK PAPUKYAN, ET AL. As with anything in life, there are pros and cons to using a verified complaint. One or two word search terms work best. Your subscription has successfully been upgraded. Posted on Oct 22, 2014. If you do this, you do not need to mark anything other than the box) Tj 0 -18.48 TD -0.0244 Tc 0.0244 Tw (next to the letter \(b\).) C R.UU# 1ZOsl 6) Unfair Competition, Violation of Business and Professions Code section 17200 (Advantac Group, Inc. v. Edwins Plumbing Co., Inc. (2007) 153 Cal.App.4th 621, 627.) 6 RUSSELL BEATTIE 4);TA{!US7k`,l[X7{m (g) The defenses shall be separately stated, and the several defenses shall refer 0000023214 00000 n 196158 Responding Party: Defendant Heavenleaf, Inc. This tactic forces the defendant to immediately make statements about the allegations under oath. The parties could stipulate without leave of court to one 15-day extension beyond one 30-day time period prescribed for that ask per service the this original complaint. In the case of FPI Development, Inc vs. A1 Nakashima, (1991) 231 Cal.App.3d 367, 384, a California Court of Appeal held that the affirmative defenses pled in an answer to a complaint must be pled in the same fashion, and with the same specificity, as a cause of action in a complaint. The Cross-Complainants the ..mic Advantage We also use third-party cookies that help us analyze and understand how you use this website. In addition, a defendant has a significant incentive to be plead every affirmative defenses, because a party waives defenses that are not pleaded. 5 Email: mkeshavarzi@sheppardmullin.com When a defendant files an unverified answer to a verified complaint, the plaintiff may seek a default judgment in his favor by filing a motion to strike the answer, or alternatively, may bring a motion for judgment on the pleadings with respect to the defective answer. 5 SECRET RECIPES, INC. v FELIZ LOPEZ Sample Answer to Unverified Complaint for California, https://legaldocspro.myshopify.com/products, http://freeweeklylegalnewsletter.gr8.com/. JEANETTE N. LITTLE & ASSOCIATES after the filing of the complaint, and a copy of the affidavit shall be served on 5 Attorneys for Defendants Tj 283.68 0 TD /F0 16.08 Tf 0 Tc 0.06 Tw ( ) Tj 4.08 0 TD /F1 16.08 Tf -0.0683 Tc 0.1283 Tw (Not all reasons for) Tj ET 121.2 615.84 9.6 0.72 re f BT 72 600 TD -0.0483 Tc 0.1349 Tw (not paying money are legally recognized defenses. The author of this blog post, Stan Burman, is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. 446(a). )akB*D}&3,o3{)cyf'D4Q;}2i5=oQ=cC1\tW4:L0ju)i z=Xy|T5bfx^~Pw7h.Az aEg>>Z@4^S9Kc_TajW#z l"YVEm=EYEY/{JQJ0} )ADhU(j1et76~o74Bi)5:>M/y (e) If the defendant has no information or belief upon the subject sufficient to enable will be able to access it on trellis. 1500 First Street, Suite 200 (Doe v. City of Los Angeles (2007) 42 Cal.4th 531, 549-550; Hata v. Los Angeles County Harbor/UCLA Medical Center (1995) 31 Cal.App.4th 1791, 1805.) 6 Facsimile: (707) 340-7239 10 BULMAR, 1 GREGORY J. SOWDER, ESQ. 8 CIVIL COURT OF THE STATE OF CALIFORNIA 855-598-3258. when new changes related to "" are available. endstream endobj If the complaint is verified, unless the complaint is subject to Article 2 (commencing The cookies is used to store the user consent for the cookies in the category "Necessary". TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. You also have the option to opt-out of these cookies. 327, 328.) 4 Telephone: 213.620.1780 Tj 36 0 TD 0.0185 Tc 0.0415 Tw (Completing the Short Caption and Signing) Tj ET 108 565.44 341.04 0.96 re f BT 72 549.36 TD /F1 16.08 Tf -0.0523 Tc 0.0973 Tw (At the top of page 2 of the Answer form there is a small caption box like) Tj 0 -18.48 TD -0.0212 Tc 0 Tw (this:) Tj -30 -20.16 TD /F1 10.08 Tf -0.0433 Tc 0.1633 Tw (SHORT TITLE:) Tj 400.56 0 TD -0.0808 Tc 0.2008 Tw (CASE NUMBER:) Tj ET 35.52 525.84 0.72 0.96 re f 35.52 526.08 0.72 0.72 re f 36.24 526.08 399.84 0.72 re f 436.08 525.84 0.72 0.24 re f 436.08 526.08 0.72 0.72 re f 436.8 526.08 138.72 0.72 re f 575.52 525.84 0.72 0.96 re f 575.52 526.08 0.72 0.72 re f 35.52 482.64 0.72 43.2 re f 35.52 481.92 0.72 0.72 re f 35.52 481.92 0.72 0.72 re f 36.24 481.92 399.84 0.72 re f 436.08 482.64 0.72 43.2 re f 436.08 481.92 0.72 0.72 re f 436.8 481.92 138.72 0.72 re f 575.52 482.64 0.72 43.2 re f 575.52 481.92 0.72 0.72 re f 575.52 481.92 0.72 0.72 re f BT 72 456 TD /F1 16.08 Tf -0.0342 Tc 0.0204 Tw (Put the plaintiff\222s last name, \(or the name of the business if the plaintiff) Tj 0 -18.48 TD -0.0446 Tc 0.0703 Tw (is not a person\), followed by a \223v.\224 and the last name of the first) Tj T* -0.0396 Tc 0.0596 Tw (defendant listed in the complaint. Tj 36 0 TD 0.0081 Tc 0.0519 Tw (Page Numbers) Tj ET 72 422.88 116.64 0.96 re f BT 36 407.52 TD /F1 15.12 Tf -0.0578 Tc 0.0321 Tw (Each page of your answer must be numbered in order, including any exhibits you may) Tj 0 -17.04 TD -0.0586 Tc 0.0436 Tw (choose to attach. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. action or proceeding shall be ordered transferred as provided in this title. Your attorney will be limited in how the complaint is written. 0000015406 00000 n FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. This cookie is set by GDPR Cookie Consent plugin. However, defendants should only plead viable defenses when the evidence supports it, and seek leave to amend if need be which is to be routinely granted. These cookies track visitors across websites and collect information to provide customized ads. We will email you Can I file an amended complaint without permission of court? 0 Click the on our main page to search for what you are looking for. where commenced. 0000000647 00000 n gM&Td'%r+':~7:[(\~IFlxEI Nkf+y and the action or proceeding may be tried in that court at that location. The Cross-Defendants entered into a sub-lease, but were evicted when they failed to make their monthly payments. MOE KESHAVARZI, Cal. 438(h)(2)). endstream endobj 9 0 obj <>/ProcSet 29 0 R>>/Rotate 0/Type/Page>> endobj 10 0 obj <>stream BURTON | KELLEY, LLP That will be added to the back of the entire answer packet.) Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. Proc. to this subdivision, no further proceedings may occur in the action or proceeding, Notwithstanding Section 1801.1 and subdivision (f) of Section 2983.7 of the Civil Code, that consent may be given by a defendant who is represented by counsel at the time trailer Your credits were successfully purchased. 3 San Jose, CA 95112 BT 107.52 687.6 TD 0 0 0 rg /F0 35.04 Tf -0.0231 Tc 0.0631 Tw (Superior Court, County of) Tj 136.08 -40.08 TD -0.001 Tc 0 Tw (Ventura) Tj -163.68 -40.32 TD -0.0272 Tc 0.1472 Tw (Self-Help Legal Access Center) Tj 18.72 -110.4 TD /F0 36 Tf -0.0261 Tc 0.1461 Tw (DEFENDING LAWSUITS) Tj 186.24 -26.4 TD /F0 19.92 Tf 0.063 Tc 0 Tw (FOR) Tj -192.96 -37.92 TD /F0 36 Tf -0.0203 Tc 0.1403 Tw (BREACH OF CONTRACT) Tj 198.96 -26.4 TD /F0 19.92 Tf 0.06 Tc 0 Tw (OR) Tj -210 -38.16 TD /F0 36 Tf -0.0162 Tc 0.1362 Tw (COLLECTION OF MONEY) Tj 102.72 -31.2 TD /F0 25.92 Tf 0.0429 Tc -0.0429 Tw (\(COMMON COUNT) Tj 235.92 0 TD /F1 25.92 Tf 0.0086 Tc 0 Tw (\)) Tj -131.52 -142.56 TD /F1 72 Tf 0 Tc (2) Tj -115.92 -41.28 TD /F1 28.08 Tf -0.0181 Tc -0.1619 Tw (Completing the Answer) Tj 0.24 -23.04 TD /F1 18 Tf -0.0037 Tc 0.0637 Tw (Judicial Council Form No. If the parties are not able to meet and confer at least five days prior to the date the responsive pleading is due, the demurring party shall be granted an automatic 30-day extension of time within which to file a responsive pleading, by filing and serving, on or before the date on which a demurrer would be due, a declaration stating under penalty of perjury that a good faith attempt to meet and confer was made and explaining the reasons why the parties could not meet and confer. Proc. Tj 0 -34.56 TD 0.0334 Tc 0 Tw (c.) Tj 36 0 TD -0.0451 Tc 0.0051 Tw (Complete the rest of the caption box with the names of the ) Tj 355.2 0 TD /F0 15.12 Tf -0.0505 Tc 0 Tw (parties) Tj 44.16 0 TD /F1 15.12 Tf -0.0542 Tc -0.0058 Tw ( \(plaintiff and) Tj -435.36 -17.28 TD -0.0473 Tc -0.0018 Tw (defendants\) and the case number just as they appear on the Complaint.)
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