Always consult your attorney for their professional advice as each case is unique. AnswerContract (PLD-C-010) AnswerContract. %%EOF /P 8 0 R /O /Layout 31 0 obj (a) Every pleading shall be subscribed by the party or his or her attorney. March 5, 2021 | Structure Law Group, LLP. /P 8 0 R /Pg 5 0 R /A << endstream That means that the complaint itself will be limited as you can only include the facts that you know at that time and not the facts that you still need to prove are true. The real estate attorneys at Talkov Law are well versed in a variety of real estate issues, including quiet title actions. /A << Broker for Fraud. /Registry (BookmanOldStyle-BoldOPExtFont0) >> >> /Placement /Block All forms provided by US Legal Forms, the nations leading legal forms publisher. CCP 2030.310 (a), 2030.410. This can be done without needing to have the document notarized. Answering paragraph 19, CIPA admits the allegations thereof. . One COPY for plaintiff. Verified answers must admit or deny each and every paragraph of the complaint, and must also . CASE NUMBER: ANSWERUNLAWFUL DETAINER UD-105. /O /Layout Code of Civil Procedure Section 446 states in pertinent part that, "When the complaint is verified, the answer shall be verified." Section 446 also specifies other situations in which an answer to a complaint or cross-complaint must be verified. However, if a tenant wants to have a jury trial, the tenant must file a verified answer with a jury demand. endstream What laws can be overridden by contracts? Plaintiff alleges the following based upon information and belief, except as to those allegations concerning Plaintiff, which are alleged upon personal knowledge. endobj 3. << 2 Verification of Pleading (Code Civ. end If it is verified, the plaintiff makes assertions under the pains and penalties of perjury. <84> <84> <201E> Entire fee simple sample answer verified to complaint or the california. /A << A Practice Note outlining how to answer a complaint in California superior court. endobj /Placement /Block <9B> <9B> <203A> If the plaintiff makes statements to their attorney under oath before a full investigation has been performed, the plaintiff may also end up being guilty of perjury. Each defendant submitting the Answer must sign it. /Pg 5 0 R Electronic Access: On the Law Library's computers, using . Sign up for our free summaries and get the latest delivered directly to you. September 1, 2019] ANSWERUNLAWFUL DETAINER Page 2 of 2 UD-105 (Each defendant for whom this answer is filed must be named in item 1 and must sign this answer unless his or her attorney signs.) seq require specific statements in your response. /Ordering (UCS) Plaintiff's information and belief is based upon, among other things . >> /O /Layout 19 0 obj >> /FirstChar 0 3p5DH)ZkD*\#,rb-J-@dpT]Dr)Hz+WvH(TB#2J9j,e=>Z nV uu"'}f|m7at"!& foXaO)&SmAZrif nw42X"WFUsC:32@3tfsp/|f\cyq3O92I 47t>-m(:2129+\:b+OU4]9)'W5+D%MsgE}*Mi>WJdQC";@){dDdN~(1tmkv&9-o{ -";7JJY&lTG5ZH`l.+yUuwh oQ"J< _[VBexUNVe}6NU9Bc- iYJldI=x0_. <90> <90> <2022> Blog. However I want to point out that any plaintiff can choose to verify their complaint. <09> <0A> <0009> This site is protected by reCAPTCHA and the Google, There is a newer version of the California Code. Can a contract prohibit something that is legal? <7F> <7F> <2022> /K 5 FIRST DIVISION. Defendant's request for sanctions in the amount of $500 against Plaintiff and his counsel is GRANTED. << /Encoding << <82> <82> <201A> &*vl"F[ ;(:h2T`&@ FQE2=Uda"1*IC3)9U&h[QBOQT1X>^q UcJP1SZQGECL.-riE[|Y0B@hLl`< Ux=t%a"dkh91ad2e\ShgN,gTVV3;9Op 'P% /S /P <91> <92> <2018> Answering an unverified complaint in California is the topic of this blog post. AAupa'H)f endcodespacerange endobj endbfrange x+-534R0 BsKk A The sample requests that the entire answer be stricken as it is not verified, or in the alternative that all of the affirmative defenses contained in the answer should be stricken as they contain only immaterial allegations. 20 0 obj /CIDSystemInfo The sample answer on which this preview is based has been revised and updated in May 2018, is 16 pages and includes brief instructions, over twenty five generic affirmative defenses, a verification, and a proof of service by mail. /Type /Encoding endstream endobj startxref %PDF-1.6 % /O /Layout They are currently arriving within 30 minutes of purchase. Estate, Trust, and Elder Abuse litigation begins with the pleading stage, in which the parties formally state their claims and defenses. ORIGINAL for Court. If you are answering a verified complaint in California you must admit or deny each and every paragraph of the complaint, and you must also include a verification signed by the defendant or defendants or their attorney stating that they have read the answer and everything contained therein is true and correct to the best of their knowledge. <00> <00> <0000> /Pg 5 0 R <81> <81> <2022> /Placement /Block /Pg 5 0 R (2) A statement of any new matter constituting a defense. A verified complaint is a complaint that has been verified by the plaintiff or their attorney verifying that the facts stated in the complaint are true. <9A> <9A> <0161> /Placement /Block CMapName currentdict /CMap defineresource pop <41> <5B> <0041> /Placement /Block stream 263 0 obj <>/Filter/FlateDecode/ID[<6F91244A77F804641FBF2D7AB20B59B4><04AA19A82420B74A9122BFAAEEFFA4F1>]/Index[238 49]/Info 237 0 R/Length 109/Prev 567362/Root 239 0 R/Size 287/Type/XRef/W[1 2 1]>>stream >> Set Aside A Fraudulent Transfer. /O /Layout In many jurisdictions, a complaint does not need to be verified unless a rule or statute . Wrongful death/product liability. /A << /K 14 Have AN ADULT WHO IS NOT A PARTY TO THE ACTION mail one of the . >> /A << 13 0 obj /S /P This may, in turn, make the defendant less trustworthy in the eyes of the jury and you can have a stronger hold throughout the case. << >> >> 17 0 obj An answer's "failure to state facts sufficient to constitute a defense" may be raised at any time (i.e., no waiver). 43. This blog post will discuss answering a verified complaint in California. /Placement /Block . Ameriquest Mortgage Company, et al., brought in the United States District Court for the Central District of California. endcodespacerange (See also Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 892-893 (trial court did not abuse its discretion in denying . When verified answer required; by whom made for corporate defendant In all cases where the plaintiff files a pleading with an affidavit attached to the effect that the facts stated in the pleading are true to the best of his knowledge and belief, the defendant shall in like manner verify any answer. >> /K 20 /O /Layout /O /Layout /O /Layout KFC 1020 .C35. <30> <3B> <0030> /K 1 h\7vo~ zLvLBPG,)r}%Y]jKg@Y\~N=bhO)NOSz8N5I~zv >> /O /Layout California Deposition and Discovery Practice. endcmap <0D> <0D> <000D> <9D> <9D> <2022> How is a business divided during a divorce? Case Number: _____ Case Type: Criminal Small Claims - ($10,000 or less) Traffic Civil - $25,000 . << <99> <99> <2122> 9 0 obj H2P(2003P04310T043Q04R(J*2T0 B_}8PB:PO9W @ D E C I S I O N. LEONARDO-DE CASTRO, J.: For review under Rule 45 of the Rules of Court is the Decision 1 dated November 17, 2005 and the Resolution 2 dated November 16, 2006 of the Court Appeals in CA-G.R. over . Denied. /K 2 << <83> <83> <0192> /P 8 0 R begincmap California Discovery Citations . xU]TGD!aS?x4d;$ fE!yX}Ns&d]:uNw5s 9 beginbfrange /O /Layout Any plaintiff can choose to verify their complaint but most civil cases in California are not verified unless theres a particular statute that requires a cause of action to be verified (this rule applies to unlimited civil cases where the complaint is over $25,000). Admissions or denials generally consist of the following: A. <> Verification. This Note does not address specific issues regarding answers in . January 1, 2007] www.courtinfo.ca.gov Page 1 of 2 Your Phone # 1 begincodespacerange 1 0 obj Western University answers Hugh's Verified Complaint as follows: 1. /Pg 5 0 R /P 8 0 R /P 8 0 R <90> <90> <2022> A verified complaint also forces the defendant to respond to the lawsuit with a verified answer. endcodespacerange (PLD-C-010) Tells the court and the other side that you challenge the Complaint-Contract, and what defenses you might raise. /O /Layout endobj California Civil Litigation and Discovery. /A << /K 4 << STATE OF CALIFORNIA, COUNTY OF ORANGE I have read the foregoing_____ _____and know its contents. 2. /P 8 0 R Sample Answer to Verified Complaint for California by Stan Burman on Scribd, To view more information on over 300 sample legal documents for California and Federal litigation visit:https://legaldocspro.myshopify.com/products. <8C> <8C> <0152> CMapName currentdict /CMap defineresource pop << /Length 6 0 R /Filter /FlateDecode >> stream << /Supplement 0 /ToUnicode 12 0 R File Memorandum of points and authorities. KFC 1020 .D44. a. ^;y]*ZLFQU2Eil+SWS|.lOi%e @W,~6v.UHtehG 36 beginbfrange /K 12 Go to. <09> <0A> <0009> << /ProcSet [ /PDF /Text /ImageB ] /Font << /F0 175 0 R /F1 181 0 R /F2 187 0 R /F3 193 0 R /F4 199 0 R /F5 205 0 R >> /XObject << /im2 7 0 R >> >> endobj 12 dict begin /O /Layout Escrow. California Code, Code of Civil Procedure - CCP 446. Superior Court of California, County of Contra Costa. <80> <80> <20AC> >> hb```g``:tA, 'y:00UJ2Kn``hh@E@Z%"aB ,\ 1rFF[,.p3l`.`R`pPZfrcVeiFc1M"*@k', 258(e0 q(e Please check official sources. Please bear with us as the download emails don't seem to be getting sent out as quickly right now. The parties. California Civil Writ Practice, CEB Practice Guide, 4th Ed., April 2012. . The sample at the end of this Guide includes the four most common responses to a request for production, and includes the legally required statements. <> Some claims, however, like a quiet title claim does require that the complaint be verified. I. Respondent denies the allegations as sel fanh within paragraph "1" of the Complaint. 3 Frivolous and Bad Faith Claims: Defense Strategies in Employment Litigation A successful motion to dismiss under Rule 12 allows an employer to dispose of a frivolous lawsuit before I want to stress that failure to file a verified answer when one is required will subject the answer to a motion to strike on the grounds that it is not verified. endobj /A << Nursing home. 609 0 obj <>/Filter/FlateDecode/ID[]/Index[580 92]/Info 579 0 R/Length 132/Prev 344734/Root 581 0 R/Size 672/Type/XRef/W[1 3 1]>>stream VALLACAR TRANSIT, INC., Petitioner, vs. JOCELYN CATUBIG, Respondent. /CIDInit /ProcSet findresource begin /O /Layout /Placement /Block Except when otherwise specifically required by law or rule, pleadings need not be under oath, verified or accompanied by affidavit. ~9>A4 - /BaseEncoding /WinAnsiEncoding /Pg 5 0 R /K 0 /Widths [ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 340 360 419 0 0 0 0 239 320 320 0 0 340 360 340 0 661 661 661 660 660 660 659 660 660 659 340 340 0 0 0 661 0 720 721 740 780 720 680 780 821 400 640 800 640 940 740 800 660 800 780 660 701 740 720 940 780 699 640 300 0 300 0 0 400 581 600 580 639 580 379 580 680 361 339 660 340 1000 679 620 640 620 459 520 460 661 600 800 601 620 560 319 0 320 0 0 600 ] This complaint alleges that the Company and 12 other lenders violated the Fair Housing Act, Equal Credit Opportunity Act, and Civil Rights Act by steering African-American applicants who would otherwise qualify for prime . /Placement /Block <91> <92> <2018> /K 10 You can receive 10 free gifts just for subscribing. >> /Pg 5 0 R >> <81> <81> <2022> /A << Defendant denies the allegations of paragraph 1. 32 0 obj J0pe/x9VP&j?7b . This usually means that the defendants most flagrant behaviors may not be detailed and may cause your case to look much weaker than it actually is. $hpz) F.=>(&7BU=/A-3j.l(+j\=3 8hc(_oqfw). <9A> <9A> <0161> /K 11 Fill out my Wufoo form!Fill out my Wufoo form! >> HK >> stream /Encoding << >> /Registry (Times-RomanOPBaseFont0) <80> <80> <20AC> /K 22 Make 2 Copies of the Answer. >> << /Length 4 0 R /Filter /FlateDecode >> stream Western University admits that Hugh was employed in the County of Los Angeles, State of California within this judicial >> /Placement /Block endstream endobj 244 0 obj <>stream 1335 0 obj <> endobj >> endbfrange /S /P /Widths [ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 250 340 560 500 500 1000 825 285 340 340 500 575 250 340 250 280 500 500 500 500 500 500 500 500 500 500 340 340 565 565 565 500 925 715 670 715 715 670 615 780 780 385 500 770 670 945 715 775 615 775 725 555 665 725 725 1000 720 720 665 335 275 335 580 500 340 500 555 445 555 450 340 500 555 280 340 555 280 830 555 500 555 555 445 390 340 555 500 730 500 500 445 395 225 395 525 350 500 350 340 500 500 1000 500 500 340 1000 565 340 1000 350 665 350 350 340 340 500 500 350 500 1000 340 1000 390 340 720 350 450 730 250 340 500 500 500 500 225 500 340 750 300 500 570 340 750 340 400 570 300 300 340 610 540 250 340 300 340 500 750 750 750 500 730 730 730 730 730 730 1000 720 680 680 680 680 380 380 380 380 730 730 780 780 780 780 780 575 780 730 730 730 730 730 610 560 500 500 500 500 500 500 730 450 450 450 450 450 280 280 280 280 500 560 500 500 500 500 500 565 500 560 560 560 560 500 560 500 ] endstream endobj 581 0 obj <>/Metadata 46 0 R/Outlines 133 0 R/Pages 578 0 R/StructTreeRoot 164 0 R/Type/Catalog>> endobj 582 0 obj <>/ExtGState<>/Font<>/XObject<>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 583 0 obj <>stream begincmap Any allegations of the complaint that are not specifically denied are considered admitted so it is critical that all of the allegations of the complaint that can be truthfully denied are in fact denied. A General Denial is a type of answer filed in response to a complaint. hN0@epHJDPB=qT ( Click the on our main page to search for what you are looking for. Adverse Possession. endobj /Pg 5 0 R <8F> <8F> <2022> 1381 0 obj <>stream 12 dict begin Defendants. hbbd```b``"*yD2e@$*XV6`5`5]`!8 Lu J `"zb`7l:LLGI a2D endstream endobj startxref district, public agency, or public corporation, in his or her official capacity, is plaintiff, the answer shall be verified, unless an admission of the truth of the complaint might subject the party to a criminal prosecution, or, unless a county . << >> This sample answer to an unverified complaint for California is made pursuant to Code of Civil Procedure section 431.30(d) and should ONLY be used for an unverified complaint. This information is not intended to create, and receipt or viewing does not constitute an attorney-client relationship. /K 6 /BaseFont /BookmanOldStyle-Bold KFC 995 .G674. << /CMapType 2 def . J,hEpx endobj UNI6~x|l!.K&0aMfvORtOJp:G3PfU^D0YQR4OdzEv|NY4ltrIPI4KKiKGUk?L`At=~!|,x '}/H2z3Ut9Cr%>fF}8 u^w(;=Pim[^fi-OobU\S/= Zu^wmy%yt|Q08'o{yji/mtw.uZcGbuIv4n$~.WAyUtSZEuw|0z?Jxi ^ o9_'\. /Pg 5 0 R >> /K [ 38 0 R ] /Pg 5 0 R /P 8 0 R sufficient to enable it to answer, and basing its denial on that ground, denies the allegations of paragraph 18. If the lawsuit involves a verified complaint from a third party collecting on . <8F> <8F> <2022> California may have more current or accurate information. Be careful to change the information the form asks for to fit the facts and circumstances of your case. << <83> <83> <0192> <89> <89> <2030> Disputes concerning General Denials arise based on whether the plaintiff filed a verified or unverified complaint. << c. One COPY for yourself. It is verified by the plaintiff or their attorney and may come attached with exhibits. The allegations of paragraph 33 of the Complaint require no answer of Defendants but to the extent that they require an answer, Defendants deny those allegations. /BaseEncoding /WinAnsiEncoding hXmo6+ !j+0G$em($rA&E=#1aHB)f <00AE> <85> <85> <2026> Dh" V HpX{@=F dT9 $6>d`bdhYH?k m Description General Denial Form California. << <7F> <7F> <2022> << endobj The term "pleading paper" is often used to describe the format of a document that is filed with the Court when a pre-made form is not available. /K 3 SAMPLE Use the samples to help you complete the packet of blank forms. <002D> The form referenced in Paragraph 43 is a writing that speaks for itself endstream << endobj ccp 446 ccp verification discovery when is a verified complaint required verification ccp 446 and 2015.5 los angeles verified complaint california sample attorney verification california verification of an answer to a complaint is mandatory. Complaint vs. Get free summaries of new opinions delivered to your inbox! /P 8 0 R /Supplement 0 /A << Breach of Real Estate Contract. The sample answer on which this preview is based has been revised and updated in May 2018, is 16 pages and includes brief instructions, over twenty five generic affirmative defenses, a verification, and a proof of service by mail. 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. >> def /Subtype /Type1 stream /K 13 a. /Name /OPBaseFont0 Use the sample as a guide for writing your own responses, to ensure that you /S /P _Yuxa;6 . 19. $25,000 Although this blog post will refer to an answer to a complaint the same principles discussed here also apply to cross-complaints. hRPW5?B&M@2I )V[7F "VHWfiS1EHqhm3RtVy3= v.>0vz);{4_$hx9[)w!~p EhS1q7bZi M&UHV+%FLlX9J miv\K}a\> S?K:%sbkS*oq^U endstream endobj 243 0 obj <>stream %PDF-1.6 % When you need Answer And Cross Complaint Sample California, don't accept anything less than the USlegal brand. 150 0 obj<> endobj 152 0 obj<>/Font<>>>/Contents 153 0 R/CropBox[0 0 612 792]/Parent 146 0 R>> endobj 153 0 obj<>stream /Differences [ 0 /.null 1 /.null 2 /.null 3 /.null 4 /.null 5 /.null 6 /.null 7 /.null 8 /.null 9 /.null 10 /.null 11 /.null 12 /.null 13 /.null 14 /.null 15 /.null 16 /.null 17 /.null 18 /.null 19 /.null 20 /.null 21 /.null 22 /.null 23 /.null 24 /.null 25 /.null 26 /.null 27 /.null 28 /.null 29 /.null 30 /.null 31 /.null 35 /.null 36 /.null 37 /.null 38 /.null 42 /.null 43 /.null 47 /.null 60 /.null 61 /.null 62 /.null 64 /.null 92 /.null 94 /.null 95 /.null 124 /.null 126 /.null 127 /.null 128 /section ] >> Get form UD-105. These rules only apply in unlimited civil cases in which the demand of the complaint exceeds $25,000.00. CA Corp and Individual combined answer. 38 0 obj ?7p/.>`q8ib,rjROTJ=sQm1btN!GGU]B0NRS>W 4ZK9z>. Lexis Advance. 3 0 obj Do you want to use this article on your website, blog or e-zine? 4. <98> <98> <02DC> Quiet Title Complaint Example. /A << A person verifying a pleading need not swear to the truth or his or her belief in the truth of the matters stated therein but may, instead, assert the truth or his or her belief in the truth of those matters "under penalty of perjury.". /A << Search California Codes. Is Conversion Law only applicable in property and civil cases? CV No. ********************************* 3. A verified complaint is a verification of the facts that have been stated in a complaint as truth. >> Code of Civil Procedure section 431.30(b) explains what you should put in your answer. Verified Complaint. <95> <95> <2022> << endstream endobj 765 0 obj <>stream Under the California Code of Civil Procedure 760.010 - 764.010, a quiet title action is a lawsuit filed to "quiet" title to real property, meaning that it seeks to establish or find a definite resolution to title between multiple . 5 0 obj The property being levied upon is held until the determination of the plaintiff's claim. <00A0> <9C> <9C> <0153> the allegations in Complaint paragraph 21. endobj /S /P B. >> %PDF-1.3 Most civil complaints in California are not verified unless a particular statute or code provides otherwise, although any plaintiff . Business Law. endobj >> >> 34 0 obj 1 defendants pqrs corporation, tom adams, kenny adams and paul roberts's notice of hearing and demurrer to plaintiff's first amended complaint One or two word search terms work best. endobj DEFENDANTS' ORIGINAL ANSWER AND AFFIRMATIVE DEFENSES PAGE 5 4844-1160-2190/02415-101 33. /Type /Encoding /FirstChar 0 G CHECK APPLICABLE PARAGRAPHS G I am a party to this action. /K 8 `.L!zk?[wc^#;;vd=8S):CSKn0O]/l g6pB; }UCty1(6ERl_gpMlV endobj endobj endobj This sample verified complaint for financial elder abuse in California contains a cause of action for financial elder abuse under Welfare and Institutions Code section 15610.30 as well as causes of action for fraud, quiet title, cancellation of written instrument and constructive trust. 1 begincodespacerange (TYPE OR PRINT NAME) (SIGNATURE OF DEFENDANT) UD-105 [Rev. /ToUnicode 39 0 R You will likely need to file more than once to win your case in court. << %PDF-1.4 n.n/b{qHe`'g0Mgl,59[~s{x7cqXd 2 Hy{KR/v d+%ZDPZH/rT'o4$`=27}D~ Fk}H <=m@FF/_:o6;f2^2)>vWtkG 28 0 obj /P 4 0 R 446. 00ttt00ut400X d&(1t@,6Ac:%022dc`z7JC^z2V1hJMwf/H3 4XK : << >> (1) " Complaint " includes a cross-complaint. The download manager is not working as well as usual. /Placement /Block /LastChar 128 >> Complete Answer Form (front and back), including title of case and case number. endobj Consider using a verified complaint to your advantage if you have evidence of all your claims. /S /P 22 0 obj /Ordering (UCS) endstream endobj 245 0 obj <>stream /S /P << << /Pg 5 0 R 4 0 obj Proc., 446) Declaration under Penalty of Perjury Form (Code Civ. hYoF+pHPr~aJJzV6m)wfg3+LzR1-J(Q7msT:b&8&Y hb```".VA!b`0p`k`9>i?N5 You already receive all suggested Justia Opinion Summary Newsletters. G.R. <8E> <8E> <017D> <8B> <8B> <2039> /S /P eN&:X*ZdD%F 3*2et$)op7WW!2Wl,U@j9!6\!s$z%?Q8TDP+=:1gH BkC^~Im`g"K{RFg :fSHv?F:\e#A{K?Tqe/W.KByPp8"],omFP1r(p++5y*h?|h{J{ydB-UP06/iB:)y 6JrOIQt(#Utb_V]!z5ke uNCM_SJ0*@}x* 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. /LastChar 255 >> 7)[>qaU26H/ 6 }J$Apu#4=1J Fp"6Q"Z 5. end << << <00AE> 5060 California Avenue, Suite 700 Post Office Box 2026 Bakersfi eld, Calilomia 93303 -2026 Telephone: (661) 322-3051 Facsimile : (661) 322-4628 . /Type /Font /S /P 158 0 obj<]>>stream >> def <7D> <7D> <007D> When the state, any county thereof, city, school district, district, public agency, or public corporation, or any officer of the state, or of any county thereof . SUPREME COURT Manila. %PDF-1.6 % The second ground clearly authorizes striking an unverified answer to a verified complaint. 671 0 obj <>stream /A << /Subtype /TrueType 29 0 obj Read your Answer, making sure all blanks are filled in, and to confirm that all of the statements are true. /BaseFont /Times-Bold 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. Usually, at the time of filing the complaint, not all of the facts about the legal claim has been discovered. V. JURY DEMAND 34. Proc., 446, 2015.5) 25 0 obj 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.
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verified answer california sample