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answer by Brian Hildreth, attorney for Damon Dunn. (somebody will post a pdf soon)

Posted on | June 18, 2010 | 1 Comment

–

ATTOPilEY OR PARTY WITHOUT

AnORNEY (Nmne. Stale Barnurnbe,, and address) FOR COURT USE ONLYCharles

H. Bell, Jr. , SBN 060553 t B r l a ~Ti . Hildreth, S B N 214131 1 Bell, ~ c ~ n d r e w&s ,H iltachk. LLP455 Capitol Mall, Suite 801, Sacramento, CA 95814

TELEPHONE NO

9 16-442-7757 FAXNO (oDjlonajl 916-442-7759E-MALADDRESS

IOpliona!lATTORNEY

F O R ~ N , ~ , , Defendant, Damon J e l ~ e lDl unn (Damon Dunn)SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sacrament0

STREETAOORESS

720 Ninth StreetM~ILING~OORESS

720 Ninth Streetc l r v a ~

ZoIP CODE.S acramento, CA 9 58 14BRANCH

NAME: Gordon D. SchaberPLAINTIFF~PETITIONER

P: amela Bamett1

~EFENOANT~RE~POFIDDENamT on Jer rel l Dunn (aka Damon Dunni, et a1GENERAL DENIAL

If you want to file a general denial, you MUST use this form if the amount asked for in the complaint

~nvolvedis $1,000 or less.

You MAY use this form for a general denial if:

1. The complaint is not verified:

o r the value of the propertyor2. The complaint is veriiied and the case is a limited civil case (the amount in controversy is $25,000 or less),

BUT NOT if the complaint involves a claim for more than $1,000 that has been assigned to a third party for collection

(See Code of Civil Procedure sections 85-86,90-100. 431.30, and 431.40.)

1.

DEFENDANT (name): Damon Jerrell Dunn (Damon Dunn)generally denies each and every allegation of plaintiffs complaint.

2.

pages

See

DEFENDANT states the foilowing FACTS as separate affirmative defenses to plaintiffs complaint (attach addriionaiif necessary):Attachment ADate:

6117110 iCharles

H. Bell, Jr. – —(TYPE OR

PRINT NAME) L. . ISGNATURE OF DEFENDANT OR PTZRNEY)–

a claim for damages or other relief against the plaintiff, the law may rewire you to state your claim in a special pleading

called a cross-complaint or you may lose your right to bring the claim. (See Code of Civil Procedure sections 42610426.40.)

attorney and on each plaintiff not represented by an attorney. There are two main ways to serve this General Denfal: by personal

delivery or by mail. It may be served by anyone at least 18 years of age EXCEPT you or any other party to this legal action. Be sure

that whoever serves the General Denial fills out and signs a proof of service. You may use the applicable Judicial Council form (such

as form POS-020, POS-030, or POS-040) for the proof of service.

1 The origlnal of this General Denial must be filed with the clerk of this court with proof that a copy was served on each plaintiffsGENERAL DENIAL

Page 1 of

1 —code ~~ci

pvroi lc edure. 55 433 30,n 314amruaunln1a.cagov

ATTACHMENT A

(Attachment to Form

DEFENDANT DAMON DUNN states the following FACTS as separate affirmative defenses to

Plaintiffs complaint:

FIRST AFFIRMATIVE DEFENSE

(Failure to State a Cause of Action)

Pld 050 “General Denial”)1 .

each cause of action fails to state facts sufficient to constitute a cause of action.

SECOND AFFIRMATIVE DEFENSE

(Laches)

As a First and Separate Affirmative Defense, Defendant Damon Dunn alleges that2.

that Plaintiffs delay in bringing this action, is inexcusable and has caused prejudice to

Defendant Damon Dunn and that each cause of action is barred by the doctrine of laches.

THIRD AFFIRMATIVE DEFENSE

(Waiver)

3. As a Third and Separate Affirmative Defense, Defendant Damon Dunn alleges

that each cause of action is barred by the doctrine of waiver.

FOURTH AFFIRMATIVE DEFENSE

(Estoppel)

As a Second and Separate Affirmative Defense, Defendant Dainon Dunn alleges4.

that each cause of action is barred by the doctrine of estoppel.

AFFIRMATIVE DEFENSE

(Compliance with All Statutes)

As a Fourth and Separate Affirmative Defense, Defendant Dainon Dunn alleges5.

with all statuto~yre quirements to qualify to be placed on the ballot for the primary election and

that any violation or omission was caused by the actions of others for which Defendant Damon

Dunn is not liable.

As a Fifth and Separate Affirmative Defense, Defendant Darnon Dunn compliedPage 2 of 2

ATTACHMENT A

(Attachment to Form Pld

SIXTH AFFIRMATIVE DEFENSE

(Protected First Amendment Activity)

050 “General Denial”)6.

that they are engaging in First Amendment political activity and are protected from litigation

abuse, such as this, by California Code of Civil Procedure section 425.16.

As a Sixth and Separate Affirmative Defense, Defendant Damon Dunn allegesWHEREFORE,

1. That plaintiff takes nothing by their Complaint;

2. That the Complaint, and each purported cause of action contained therein, be

dismissed in its entirety;

Defendant Damon Dunn prays:3.

For such other and further relief as the Courtdeems just and proper.PROOF OF SERVICE

I,

the undersigned, declare under penalty of perjury that:I

of action. My business address is 455 Capitol Mall, Suite 801, Sacramento, CA 95814.

On June 17,2010,

am a citizen of the United States, over the age of 18, and not a party to the within causeI served the following:GENERAL DENIAL

on the following party(ies) in said action:

Pamela Ba~nett

2541 Warrego Way

Sacramento.

Telephone: (415) 846-7 170

Facsimile: (866) 908-2252

Edmund G. Brown

Attorney General of California

Stephen C. Acquisto

Supelvising Deputy Attorney General

Anthong

Deputy Attorney General

1300

P.O. Box 944255

Sacramento, CA 94244-2550

Telephone (916) 323-6879

Facsimile: (916) 324-8835

Email: Anthony.O’Brien@doj.ca.gov

CA 95826P. O’BrienI Street, Suite 125Plaintif

IN

Attorrreyfor Defendunts

PRO PEREDMUND G. BROWN JR, Attorney General,

and DEBRA BOWEN, Secretary ofstate

–

envelope, with postage thereon fully prepaid,

in Sacramento, California, addressed to said party(ies), in the ordinary course of business.

I am aware that on motion of the party served, service is presumed invalid if postal

cancellation date or postage meter date is more than one day after date of deposit for

mailing in affidavit.

I declare under penalty of perjury under the laws of the State of Califonlia that the

foregoing is true and correct, and that this declaration was executed on June 17, 2010 at

Sacramento, California.

1

X BY U.S. MAIL: By placing said document(s) in a sealed envelope and depositing saidin the United States Postal Service mailboxProof of Service

Category: Uncategorized

Comments

One Response to “answer by Brian Hildreth, attorney for Damon Dunn. (somebody will post a pdf soon)”

  1. Evelyn
    June 18th, 2010 @ 5:10 pm

    It is so disappointing that our judges will NOT hear cases nor appeals to them. What are the people supposed to do now? We know one thing for sure. We must be more careful before we allow someone to be given the position of being a judge. We must elect only Christians who will appoint just, honorable and Christian judges. We need to ask Congress to remove some judges for bad decisions, bad behavior, lack of obeying our Constitution. Judges are not there for life. They are subject to recall and removal from office. Remember: WE THE PEOPLE..,.

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