: 22CV02476, Answer Tj -102.24 -45.12 TD /F1 19.92 Tf 0.09 Tc (5.) to the information and belief of the defendant. When the complaint is verified, the answer shall be verified. or according to the information and belief of the defendant, even if the complaint trailer If the moving party is a plaintiff, the plaintiff may make a motion on the ground that the complaint states facts sufficient to constitute a cause or causes of action against the defendant and the answer does not state facts sufficient to constitute a defense to the complaint. (Code Civ. 3 2125 Ygnacio Valley Road, Suite 101 If there is a separate verification following the signed complaint, you must check box 3(b) and respond to each paragraph of the complaint . Stay up-to-date with how the law affects your life. The 30-day extension shall commence from the date the responsive pleading was previously due, and the demurring party shall not be subject to default during the period of the extension. 0000002272 00000 n it is a rare case in which a court will be justified in refusing a party leave to amend his pleadings so that he may properly present his case. If the motion to amend is timely made and the granting of the motion will not prejudice the opposing party, it is error to refuse permission to amend and where the refusal also results in a party being deprived of the right to assert a meritorious cause of action or a meritorious defense, it is not only error but an abuse of discretion. (Morgan v. Superior Court (1959) 172 Cal.App.2d 527, 530 (internal citations omitted)). As discussed, the most pressing pro is that it forces the defendant to submit a verified answer. The contact form sends information by non-encrypted email, which is not secure. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-431-30/, Read this complete California Code, Code of Civil Procedure - CCP 431.30 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', SCOTUS to Decide Constitutionality of Consumer Financial Protection Bureau. of Sections 1812.10 and 2984.4 of the Civil Code or subdivision (b) of Section 395 of the Code of Civil Procedure, or is an action for an unlawful detainer. You can, as long as you include this blurb with it: Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. 1962) 208 Cal. Tj 153.6 0 TD /F0 16.08 Tf -0.0921 Tc 0 Tw (WARNING) Tj 80.64 0 TD /F1 16.08 Tf -0.0801 Tc 0.2087 Tw (: If you believe the plaintiff owes) Tj -234.24 -18.48 TD -0.0452 Tc 0.0683 Tw (you money over and above what the plaintiff is suing you for, you must) Tj 0 -18.48 TD -0.0508 Tc 0.1108 Tw (file a ) Tj 36.48 0 TD /F0 16.08 Tf -0.0329 Tc 0 Tw (cross-complaint) Tj 108.48 0 TD /F1 16.08 Tf -0.0489 Tc 0.0653 Tw ( if you want the court to order the plaintiff to pay) Tj -144.96 -18.24 TD -0.0491 Tc 0.0891 Tw (you the additional money. answerinstruct2.pdf 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 (4) Tj ET Q BT 36 678.96 TD /F1 19.92 Tf 0.09 Tc (3.) 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. A Professional Corporation 12/28/2021 E-Service: pgr@swr-law.com and mxl@swr-law.com (SBN 187152) 515.) Copyright 2023, Thomson Reuters. 0000002120 00000 n (b) The answer to a complaint shall contain: (1) The general or specific denial of the material allegations of the complaint controverted 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. 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. 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 . App. (SBN 334726) All rights reserved. by the defendant. to the causes of action which they are intended to answer, in a manner by which they STRATMAN & WILLIAMS-ABREGO (5th ed. Proc. This is called the \223short title\224 of the) Tj 0 -18.24 TD -0.0269 Tc -0.0222 Tw (case. 8 FOR THE COUNTY OF SANTA CRUZ You will likely need to file more than once to win your case in court. 438(c)(1)(A)). These statements can be disproven in litigation which means your attorney can ask for the defendant to be penalized for lying under oath. 9, 1 Michelle L. Burton, Esq. The sample answer on which this preview is based has been revised and updated in May 2018, is 16 . Keep one copy for your own records. 116 If it is verified, the plaintiff makes assertions under the pains and penalties of perjury. The Court notes that Defendant Heaven Leaf Inc. has not filed an answer to plain ..n (Narek) who had for a number of years pursued a business in which he could invent and sell shisha made from tea leaves, free of tobacco, nicotine, tar, chemicals, dyes and other artificial ingredients, sought the assistance and advice of plaintiff and ultimately offered plaintiff a 45% ownership interest in the company, to which plaintiff agreed. This case involves an innocent person, Plaintiff Analay Campos, becoming collateral damage in a three-way conspiracy to "take-down" Anthony Robbins - an If a complaint is not verified you can answer with a general denial pursuant to Code of Civil Procedure 431.30(b) and generally deny all of the allegations of the complaint. 4 Your attorney will be limited in how the complaint is written. However, in Brisson v. The Third Circuit disagreed. Pleasanton, California 94588 5 Email: mkeshavarzi@sheppardmullin.com 8, 1 NICHOLAS J. BOOS (SBN 233399) Does a verified complaint require a verified answer? (f) If a motion is made for transfer of an action or proceeding to a different court Warren v. Harootunian (1961) 189 Cal.App.2d 546, 548. 430.40(b)). The cookie is used to store the user consent for the cookies in the category "Analytics". Facsimile: 213.620.1398 ISSUES OF LAW As with anything in life, there are pros and cons to using a verified complaint. xc```b``a`a``L``@ +s8H g`7m~>$}Jh;N^ JKM48Hz?c"LqS[};]kL4E|wA q / 5 Napa, CA 94559 Proc. (Central Bank v. Superior Court (1978) 81 Cal. Demurrer and Strike to Answer 4 1450 Frazee Road, Suite 501 application/pdf 223759 Of course, there are also cons to using a verified complaint. App. When the affidavit is filed with the complaint, a copy thereof shall be served with If you have no defenses, skip to number 6.) x@0 9h@::P(:|k r\SN\=?# "B-:A admitted. If a complaint is verified the answer must be verified and any answer to a complaint filed by a governmental entity must be verified whether or not the complaint is verified pursuant to Code of Civil Procedure section 446. (Advantac Group, Inc. v. Edwins Plumbing Co., Inc. (2007) 153 Cal.App.4th 621, 627.) Case No: EC 067416 Trial Date: None Set 0000023020 00000 n court or court location where the action or proceeding is commenced is not the proper 7 JEANETTE N. LITTLE & ASSOCIATES Your credits were successfully purchased. Tj ET 8 2 Marissa E. Buck, SBN 293373 Because conclusory allegations are not admitted by demurrer, and because conclusory allegations have no pleading value, conclusory and "boilerplate" affirmative defenses are insufficient. 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. Petition (name extension) - Petition For Declaratory Relief. Demurrer to Answer is OVERRULED. ********************************* 2. What is meant by the competitive environment? What is the effect of a verified complaint? Verified Complaint. However, if the cause of action is a claim assigned to a third party for collection The Court noted that the original pleading is of no effect unless the amended complaint specifically refers to or adopts the original pleading. The only strategical advantage comes when the plaintiff desires the defendant to file a verified answer. 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 . 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 . 196158 These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. (e) A motion for a transfer of the action or proceeding to a different superior court 3 . By clicking Accept All, you consent to the use of ALL the cookies. We also use third-party cookies that help us analyze and understand how you use this website. ********************************* 4. Can an amended complaint overturn the original pleadings? oath, or the oath of the plaintiff's attorney, or in an affidavit of the plaintiff To make certain, to substantiate, or to confirm by formal oath, affirmation, or Affidavit. (SBN: 155707) (SBN: 129773) If the complaint is verified, unless the complaint is subject to Article 2 (commencing C R.UU# 1ZOsl March 5, 2021 | Structure Law Group, LLP. 1 Timothy Schweigerdt, State Bar No. The U.S. legal system relies on its participants to tell the truth. Proc. be had as provided by local rules of the superior court. No trial has been set. Representing Yourself (Pro Se)? 0000000747 00000 n being entered in the minutes of the court), to the keeping of the action or proceeding in the court or court location App. How many times should a shock absorber bounce? This could be enough to overrule it, but since defendant did not raise the issue, this Court will proceed to Demurrer to Answer If it is verified, the plaintiff makes assertions under the pains and penalties of perjury. 446(a). may be intelligibly distinguished. Attorneys for Defendant 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 (6) Tj ET Q BT 72 705.6 TD /F1 16.08 Tf -0.0393 Tc 0.0439 Tw (If you want the court to order something else, you can mark \(c\) and) Tj 0 -18.24 TD -0.0378 Tc 0.0978 Tw (explain what you want. ) When filing a lawsuit in California, the original complaint may be either verified or unverified. One or two word search terms work best. Bx!+ 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. Allegations in the Cross Complaint Moving Party: Plaintiff Hovhannes Markosyan, in pro per (See Camp v. Jeffer, Mangels, Butler & Marmaro (1995) 35 Cal.App.4th 620, 638639. 2 Including Professional Corporations In all cases of a verification of a pleading, the affidavit of the party shall state that the same is true of his own knowledge, except as to the matters which . 291126 Calendar: 3 EC065007 We will email you (Harris v. City of Santa Monica (2013) 56 Cal. If the main difference amongst a verified and unverified complaint . A case management conference is set for this hearing. 2d 367, 385 (internal citations omitted). The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. endstream endobj 3 0 obj <>/ProcSet 29 0 R>>/Rotate 0/Type/Page>> endobj 4 0 obj <>stream 0000022707 00000 n (c) Affirmative relief may not be claimed in the answer. (2) Defendant includes a person filing an answer to a cross-complaint. Effective immediately we have updated our refund policy! (See California Academy of Sciences v. County of Fresno (1987) 192 Cal.App.3d 1436, 1442). 0000001988 00000 n App. ********************************* 3. Answering an unverified complaint in California is the topic of this blog post. Who is the owner of Indian tobacco company? 6 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP (SBN 292718) been commenced in the proper superior court and the proper court location for the %%EOF. trailer Co. (1939) 35 Cal. 3 0000012047 00000 n Further, a general denial is not permitted if a complaint is verified, C.C.P. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 2 STONE & ASSOCIATES 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. Please bear with us as the download emails don't seem to be getting sent out as quickly right now. 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. 185 0 obj<>stream or of the plaintiff's attorney filed with the complaint, showing that the action has However I have to stress that any answer to a complaint or cross-complaint filed by a governmental entity must be verified regardless of whether the complaint or cross-complaint is verified. Contact us. Accessing Verdicts requires a change to your plan. 5 TOBY PRICE It does not store any personal data. 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. 9 That administrator is serving time in a federal prison for his shenanigan ..contract is oral or written. Can you amend a complaint to add a cause of action? There are three grounds for a demurrer to an answer: (Code Civ. 0000000918 00000 n 23 8 (Code Civ. BURTON | KELLEY, LLP 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.) | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-431-30/. 2. (a) The plaintiff shall state facts in the complaint, verified by the plaintiff's oath, or the oath of the plaintiff's attorney, or in an affidavit of the plaintiff or of the plaintiff's attorney filed with the complaint, showing that the action has been commenced in the proper superior court and the proper court location for the trial of the action or proceeding, and showing that the action . 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. THE MODEL BAKERY, LLC and Sample Answer to Unverified Complaint for California, https://legaldocspro.myshopify.com/products, http://freeweeklylegalnewsletter.gr8.com/. Proc. 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. 0000007342 00000 n (5th ed. 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. except to dismiss the action or proceeding without prejudice. Code of Civil Procedure 430.41 requires that before filing a demurrer, the demurring party must meet and confer. when new changes related to "" are available. ), In general, whatever a defendant bears the burden of proving at trial is new matter (also referred to as an affirmative defense), and thus must be specially pleaded in the answer. MARC J. FELDMAN, Cal. (Id.). Equitable defenses are new matter requiring ultimate facts pled. SUPERIOR COURT OF THE STATE OF CALIFORNIA 327, 328.) this section, proceedings shall be had, and the costs and fees shall be paid, as provided BT 104.88 692.16 TD 0 0 0 rg /F0 30 Tf -0.0212 Tc 0.0412 Tw (HOW TO COMPLETE YOUR) Tj 85.68 -34.32 TD -0.012 Tc -0.048 Tw (ANSWER FORM) Tj -118.56 -47.76 TD /F1 19.92 Tf 0.0157 Tc 0.0786 Tw (Complete the Answer form by typing the information) Tj 0 -23.04 TD -0.0062 Tc 0.1995 Tw (requested. If any action or proceeding is ordered transferred to another court as provided in Form Approved for Optional Use Code of Civil Procedure, 425.12 Judicial Council of California ANSWER- Contract PLD-C-010 [Rev. Here, the Complaint a verified or the Answer is unverified. Equal Access,equal employment,employment equal,equal policy,equal access law,equal access education,equal access employment service The motion is denied as to the fourth cause of action for quiet title in Plaintiffs complaint. The means by which the demurring party met and conferred with the party who filed the pleading subject to demurrer, and that the parties did not reach an agreement resolving the objections raised in the demurrer. the answer fails to state sufficient facts to constitute a defense; the answer is uncertain (including ambiguous and unintelligible); and. 3 Diego E. Garcia, SBN 333411 (c) In any case where the transfer of the action or proceeding is ordered under subdivision (a) or (b), if summons is served prior to the filing of the action or seq. ] Answering an unverified complaint in California is the topic of this blog post. 3.110(f)). 11, 1 Tj 108 -36.96 TD 0.0673 Tc 0 Tw (C.) Tj 36 0 TD -0.0449 Tc 0.0449 Tw (If you do not know) Tj 122.64 0 TD -0.0367 Tc 0.0487 Tw ( whether a statement in the) Tj -266.64 -18.24 TD -0.0377 Tc 0.0377 Tw (complaint is true or false, you can put the paragraph number of that) Tj 0 -18.48 TD -0.0274 Tc 0.0274 Tw (statement under the \223\(2\)\224 section.) 210 N 4th St #201 Tj ET or by denial of certain allegations upon information and belief, or for lack of sufficient Tj 36 0 TD 0.0121 Tc 0.0479 Tw (Identify Yourself) Tj ET 72 261.84 137.76 0.96 re f BT 36 246.72 TD /F1 15.12 Tf -0.0466 Tc 0.0106 Tw (If there is more than one defendant listed in the ) Tj 287.52 0 TD /F0 15.12 Tf -0.0404 Tc 0 Tw (complaint) Tj 64.32 0 TD /F1 15.12 Tf -0.0752 Tc 0.0752 Tw ( each must respond, or) Tj -351.84 -17.28 TD -0.0326 Tc 0 Tw (default) Tj 41.76 0 TD /F0 15.12 Tf 0 Tc 0.06 Tw ( ) Tj 3.84 0 TD /F1 15.12 Tf -0.055 Tc 0.015 Tw (may be entered against the defendants who do not file an answer. 0000022606 00000 n If there is no verification you can generally deny all the statements in the complaint by checking box 3(a). All rights reserved. This tactic forces the defendant to immediately make statements about the allegations under oath. 4 F: (408) 295-5799 A positive side of using a verified complaint is that the defendant has to submit a verification of the answers. notice of the filing. 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. Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features. A denial needs no support. (d) If the complaint is subject to Article 2 (commencing with Section 90) of Chapter 5.1 of Title 1 of Part 1 or is not verified, a general denial is sufficient but only T: (408) 790-5320 Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 431.30 - last updated January 01, 2019 Electronically FILED by Superior Court of California, County of Los Angeles on 04/18/2022 06:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by G. Villarreal,Deputy Clerk 22STCP01382 1 MICHAEL L. ODDENINO, ESQ (SBN 126125) ODDENINO LAW GROUP , APC 2 3848 E. COLORADO BLVD. The function of the answer is to put the case "at issue" as to all material allegations in the complaint. Verified Complaint for Declaratory and Injunctive Relief United States District CourtDistrict of Columbia Republican National Committee 310 First Street, SEWashington, DC 20003 Reince Priebus, as Chairman of the Repub-lican National Committee310 First Street, SEWashington, DC 20003 Republican Party of Louisiana Tj 36 0 TD 0.0129 Tc 0.0471 Tw (Stating Your Defenses) Tj ET 108 653.04 180.48 0.96 re f BT 72 636.72 TD /F1 16.08 Tf -0.0518 Tc 0.1118 Tw (If you have defenses to the complaint, you ) Tj 276 0 TD -0.0189 Tc 0 Tw (must) Tj 31.2 0 TD -0.076 Tc 0.136 Tw ( state them in your) Tj ET 348 634.32 30.96 0.72 re f BT 72 618.24 TD -0.0698 Tc 0.1298 Tw (answer ) Tj 49.2 0 TD 0.0076 Tc 0 Tw (if) Tj 9.84 0 TD -0.0421 Tc 0.0754 Tw ( you want the court to consider them at trial.) 0 7 Including Professional Corporations (SBN 304551) try clicking the minimize button instead. Can I file an amended complaint without permission of court? Make copies ofyour amended complaint. How do you respond to a verified complaint? Sebago, Inc. v. City of Alameda (1989) 211 Cal. 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. Proc. The demurrer as to the second, seventh, eighth, tenth, twelfth, fifteenth affirmative defenses, is sustained with 15 days leave to amend. This is a simple cost-benefit analysis. I am submitting my complaint on pleading paper (as opposed to using the standard forms, i.e., PLD-PI-001). What body systems are affected by smoking? Tj 0 -36.96 TD -0.0422 Tc 0.0542 Tw (At the bottom of page 2 of the answer form, type or print your name on) Tj 0 -18.24 TD -0.0602 Tc 0.1373 Tw (the left side, and sign your name on the right side. Click the on our main page to search for what you are looking for. Learn more about this litigation tactic so you can ask your litigator if it is right for your case. 2 Except as provided in this section, if the complaint or affidavit is not filed pursuant 0000007173 00000 n 0000023430 00000 n provided in this title, and if upon that motion it appears that the action or proceeding Tj -155.04 -36.72 TD /F1 16.08 Tf -0.0383 Tc 0.0183 Tw (Section 4 of the answer form has space to state your defenses. The answer form is two pages, so if you are adding any attachments you) Tj 0 -17.28 TD -0.051 Tc 0.015 Tw (will start the page numbering of the attachment with page 3. 4 DICKENSON PEATMAN & FOGARTY Some vagueness may exist in a defendants answer because most defendants do not have the ability to prove their defenses at the initial answering phase, which usually occurs before discovery. 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. 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. Where it says \223attorney for\224 put \223Defendant, In Pro Per.\224 This means you) Tj 0 -17.28 TD -0.0546 Tc 0.1146 Tw (represent yourself.) 6 5 What is the legal definition of verified? (State Farm Mut. equal employment 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| MANATT, PHELPS & PHILLIPS, LLP CRAIG A. MOYER (SBN 094187) cmover@,manatt.com 11355 West Olympic Boulevard
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