This case was last updated from San Francisco County Superior Courts on 04/11/2016 at 20:07:24 (UTC).

J&R SAN FRANCISCO, INC. et al VS. CHO QUON FUNG et al

Case Summary

On 06/26/2012 J R SAN FRANCISCO, INC filed an Other - Declaratory Judgment lawsuit against CHO QUON FUNG. This case was filed in San Francisco County Superior Courts, Civic Center Courthouse located in San Francisco, California. The case status is Not Classified By Court.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    *******1881

  • Filing Date:

    06/26/2012

  • Case Status:

    Not Classified By Court

  • Case Type:

    Other - Declaratory Judgment

  • Court:

    San Francisco County Superior Courts

  • Courthouse:

    Civic Center Courthouse

  • County, State:

    San Francisco, California

 

Party Details

Plaintiffs, Respondents and Cross Defendants

J&R SAN FRANCISCO, INC.

TIMBRELL, CLAYTON

FUNG FAMILY TRUST

FUNG, CHO QUON

ROES 1-10, INCLUSIVE

ROES 1 THROUGH 20

FUNG, CHU QUON (MISS-IDENTIFIED AS CHO QUON FUNG)

FUNG, CHU QUON AS TRUSTEE OF THE FUNG FAMILY TRUST (ERRONEOUSLY SUED AS THE FUNG FAMILY TRUST)

Defendant, Appellant and Cross Plaintiff

FONDAHL, MEREDITH

Defendants, Cross Defendants and Cross Plaintiffs

DOES 1 TO 10, INCLUSIVE

FUNG FAMILY TRUST

FUNG, CHO QUON

DOES 2-10, INCLUSIVE

FONDAHL, MEREDITH

FONDAHL, MEREDITH VICTORIA

FUNG, CHU QUON (MISS-IDENTIFIED AS CHO QUON FUNG)

Attorney/Law Firm Details

Plaintiff and Cross Defendant Attorneys

ANDERSON ELLIS R

ANDERSON, ELLIS ROSS

Attorney at ANDERSON & POOLE, P.C.

601 California St Ste 1300

San Francisco, CA 94108-2818

SMITH, ZACHARY

Attorney at STRATMAN, PATTERSON & HUNTER

P.O. Box 258829

Oklahoma City, OK 73125-8829

PAGANELLI, CARL

Attorney at FIDELITY NAITIONAL LAW GROUP

1550 Parksidedrive, Ste 300

Walnut Creek, CA 94596

BIERNAT, JAMES DAVID

WOO, JEFFERY PETER

Attorney at COOPER, WHITE & COOPER LLP

201 California St 17Th Fl

San Francisco, CA 94111

Defendant, Appellant and Cross Plaintiff Attorney

MARCO, QUAZZO

Attorney at BARTKO, ZANKEL, BUNZEL & MILLER

One Embarcadero Center, Ste 80

San Francisco, CA 94111

Cross Defendant, Defendant and Cross Plaintiff Attorneys

WOO, JEFFERY PETER

Attorney at COOPER, WHITE & COOPER LLP

201 California St 17Th Fl

San Francisco, CA 94111

MARCO, QUAZZO

Attorney at BARTKO, ZANKEL, BUNZEL & MILLER

One Embarcadero Center, Ste 80

San Francisco, CA 94111

 

Court Documents

DECLARATION OF

DECLARATION OF (AMENDED) JAMIE C COUCHE FILED IN SUPPORT OF MTN FOR PREFERENCE AND TRIAL SETTING FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

CASE MANAGEMENT STATEMENT

CASE MANAGEMENT STATEMENT {JOINTLY} FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 6.0 DAYS

GENERIC CIVIL FILING (NO FEE)

CLERK'S NOTICE TO COUNSEL RE MISSING DOCUMENTS

Notice of Entry of Judgment or Order

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 56753799) FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

MINUTES FOR MAR-02-2015 9:30 AM

MINUTES FOR MAR-02-2015 9:30 AM

PLAINTIFFS AND CROSS DEFENDANTS J&R SAN FRANCISCO, INC. AND CLAYTO

J&R SAN FRANCISCO, INC. AND CLAYTON TIMBRELLS JOINT POST TRIAL BRIEF (TRANSACTION ID # 15082093) FILED BY PLAINTIFF TIMBRELL, CLAYTON

COURT JUDGMENT - GENERAL

THE COURT ORDERED THE FOLLOWING JUDGMENT ENTERED: IT IS ADJUDGED THAT PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON RECOVER FROM DEFENDANT FUNG FAMILY TRUST FUNG, CHU QUON (MISS-IDENTIFIED AS CHO QUON FUNG) PLAINTIFFS ARE ENTITILED TO COSTS OF SUIT. SEE SCANNED DOC FOR DETAILS OF JUDGEMENT ON BIFURCATED CLAIMS.

Notice of Entry of Judgment

NOTICE OF ENTRY OF JUDGMENT (TRANSACTION ID # 57270700)

REMITTITUR

REMITTITUR AFFIRMED A141841 DIV 3

DECLARATION

DECLARATION IN SUPPORT OF MOTION FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

Notice of Time and Place of Trial

NOTICE OF TIME AND PLACE OF TRIAL, JURY TRIAL SET FOR JUL-01-2013 AT 9:30 AM IN DEPT. 206. CASE MANAGEMENT CONFERENCE ON NOV-28-2012 IS OFF CALENDAR. NOTICE SENT BY COURT.

CASE MANAGEMENT STATEMENT

CASE MANAGEMENT STATEMENT {JOINTLY} FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 4.0 DAYS

DECLARATION OF

DECLARATION OF JAMIE C. COUCHE FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

CASE MANAGEMENT STATEMENT

CASE MANAGEMENT STATEMENT FILED BY DEFENDANT FONDAHL, MEREDITH

CASE MANAGEMENT STATEMENT

CASE MANAGEMENT STATEMENT FILED BY DEFENDANT FUNG, CHO QUON FUNG FAMILY TRUST JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 5.0 DAYS

POST-TRIAL REPLY BRIEF

POST-TRIAL REPLY BRIEF (TRANSACTION ID # 15095066) FILED BY DEFENDANT FUNG FAMILY TRUST FUNG, CHU QUON (MISS-IDENTIFIED AS CHO QUON FUNG)

Plaintiffs and Cross Defendants J&R San Francisco, Inc. and Clayto

JOINT REPLY BRIEF/POST TRIAL (TRANSACTION ID # 15095124) FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

CROSS-COMPLAINT OF MEREDITH FONDAHL AGAINST CHO QUON FUNG AND THE FUNG

CROSS COMPLAINT (TRANSACTION ID # 58400465) FILED BY CROSS COMPLAINANT FONDAHL, MEREDITH AS TO CROSS DEFENDANT FUNG, CHO QUON FUNG FAMILY TRUST ROES 1-10, INCLUSIVE

129 More Documents Available

 

Docket Entries

  • 04/01/2016
  • View Court Documents
  • ORDER SETTING CASE MANAGEMENT CONFERENCE SENT BY COURT

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  • 04/01/2016
  • ADDED TO CALENDAR FOR CASE MANAGEMENT CONFERENCE , FOR THE SUBMISSION OF CASE MANAGEMENT STATEMENTS AND TRIAL SETTING HEARING SET FOR MAY-11-2016 AT 10:30 AM IN DEPT 610

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  • 03/02/2016
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  • ANSWER TO CROSS COMPLAINT (TRANSACTION ID # 100015062) FILED BY CROSS DEFENDANT FUNG, CHU QUON (MISS-IDENTIFIED AS CHO QUON FUNG) FUNG, CHU QUON AS TRUSTEE OF THE FUNG FAMILY TRUST (ERRONEOUSLY SUED AS THE FUNG FAMILY TRUST) (Fee:450.00)

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  • 02/24/2016
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  • DISMISSAL WITHOUT PREJUDICE ONLY AS TO PLAINTIFF CLAYTON TIMBRELL'S THIRD CAUSE OF ACTION FOR SLANDER OF TITLE (TRANSACTION ID # 58625712)

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  • 02/02/2016
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  • MEMORANDUM OF COSTS AND DISBURSEMENTS, $1,425.50 TOTAL COSTS, MATURE DATE FEB-22-2016,, (TRANSACTION ID # 58511508) FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

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  • 01/08/2016
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  • CROSS COMPLAINT (TRANSACTION ID # 58400465) FILED BY CROSS COMPLAINANT FONDAHL, MEREDITH AS TO CROSS DEFENDANT FUNG, CHO QUON FUNG FAMILY TRUST ROES 1-10, INCLUSIVE

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  • 01/08/2016
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  • ANSWER TO 2ND AMENDED COMPLAINT (TRANSACTION ID # 58399941) FILED BY DEFENDANT FONDAHL, MEREDITH

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  • 12/31/2015
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  • REMITTITUR AFFIRMED A141841 DIV 3

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  • 06/15/2015
  • TRIAL MOTION CALENDAR ON JUN-25-2015 IN DEPT. 501, PLAINTIFFS MOTION FOR COST OF PROOF SANCTIONS NOTICE OF MOTION IS OFF CALENDAR PER STIPULATION AND ORDER SIGNED ON 6/15/15. (D501)

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  • 06/15/2015
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  • ORDER AND STIPULATION FOLLOWING TRIAL OF BIFURCATED CLAIMS; WITHDRAWAL OF MOTION FOR COSTS OF PROOF SANCTIONS HEARING [NO S.A.S.E. - COPY OF ORDER IN DEPT. 501 OUTBOX]

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221 More Docket Entries
  • 07/23/2012
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  • (REVISED) NOTICE OF MOTION AND MOITON FOR PREFERENCE AND TRIAL SETTING FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON HEARING SET FOR AUG-15-2012 AT 09:30 AM IN DEPT 206 (Fee:NO FEE)

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  • 07/19/2012
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  • DECLARATION OF STANLEY RIDDELL IN SUPPORT OF OPPOS. TO MTN FOR PREFERENCE & TRIAL SETTING FILED BY DEFENDANT FUNG FAMILY TRUST FUNG, CHU QUON (MISS-IDENTIFIED AS CHO QUON FUNG)

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  • 07/19/2012
  • View Court Documents
  • OPPOS/MEMO OF P & A IN SUPPORT OF OPPOS. TO MTN FOR PREFERENCE AND TRIAL SETTING FILED BY DEFENDANT FUNG FAMILY TRUST FUNG, CHU QUON (MISS-IDENTIFIED AS CHO QUON FUNG) (Fee:900.00)

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  • 07/18/2012
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  • PROOF OF SERVICE BY MAIL OF MOTION FOR PREFERENCE AND TRIAL SETTING FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

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  • 07/17/2012
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  • SUMMONS ON COMPLAINT, PROOF OF SERVICE ONLY, FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON SERVED JUL-06-2012, PERSONAL SERVICE ON DEFENDANT FUNG FAMILY TRUST

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  • 07/17/2012
  • View Court Documents
  • SUMMONS ON COMPLAINT, PROOF OF SERVICE ONLY, FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON SERVED JUL-06-2012, PERSONAL SERVICE ON DEFENDANT FUNG, CHO QUON

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  • 07/10/2012
  • View Court Documents
  • DECLARATION IN SUPPORT OF MOTION FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON

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  • 07/10/2012
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  • NTC OF MTN AND MTN FOR PREFERENCE AND TRIAL SETTING; MEMO P & A FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON HEARING SET FOR AUG-07-2012 AT 09:30 AM IN DEPT 206 (Fee:60.00)

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  • 06/26/2012
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  • NOTICE TO PLAINTIFF

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  • 06/26/2012
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  • DECLARATORY RELIEF, COMPLAINT FILED BY PLAINTIFF J&R SAN FRANCISCO, INC. TIMBRELL, CLAYTON AS TO DEFENDANT FUNG, CHO QUON FUNG FAMILY TRUST DOES 1 TO 10, INCLUSIVE SUMMONS ISSUED, JUDICIAL COUNCIL CIVIL CASE COVER SHEET FILED CASE MANAGEMENT CONFERENCE SCHEDULED FOR NOV-28-2012 PROOF OF SERVICE DUE ON AUG-27-2012 CASE MANAGEMENT STATEMENT DUE ON NOV-13-2012 (Fee:410.00)

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Complaint Information

COOPER, WHITE & COOPER LLP JEFFERY P. WOO (SBN 132697)

2|l jwoo@cwclaw.com _. STANLEY W. RIDDELL (SBN 203338) F ' 3|| sriddell@cwclaw.com Sugerior Court of Calffomia ) 201 California Street, 17" Floor nty of San Franci San Francisco, California 94111 Telephone: (415) 433-1900 FEB 06 2014 S || Facsimile: ~ (415) 433-5530 g x ol Attorneys for Chu Quon Fung and The Fung 7 || Family Trust

10 SUPERIOR COURT OF THE STATE OF CALIFORNIA

lli COUNTY OF SAN FRANCISCO-UNLIMITED JURISDICTION

VERIFIED ANSWER AND

14 Plaintiffs and Cross- AFFIRMATIVE DEFENSES TO SECOND s Defendants, - AMENDED COMPLAINT 16 VS. Trial Date: None Set ', Chu Quon Fung and the Fung Family Trust; VA\ST 17 || and Does 1 through 10, inclusive, @F @E.@ 18 Defendants and Cross- 1 Complainants.

Defendants Chu Quon Fung and the Fung Family Trust (hereinafter “Answering

& COOPER LLP ATTORNEYS AT LAW 201 CALIFORNIA STREET

SAN FRANCISCO, CA 84111-5002

SAN FRANCISCO, CA 84111-5002 sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

3. Answering paragraph 3 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

4, Answering Defendants admit the allegations in paragraph 4 of the Complaint.

5. Answering Defendants admit the allegations in paragraph 5 of the Complaint.

6. Answering paragraph 6 of the Complaint, these Answering Defendants lack

sufficient information and belief to either admit or deny the allegations therein, and based on that

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| ground deny each and every allegation contained therein.

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7. Answering Defendants admit the allegations in paragraph 7 of the Complaint.

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8. Answering paragraph 8 of the Complaint, these Answering Defendants lack

sufficient information and belief to either admit or deny the allegations therein, and based on that

ground deny each and every allegation contained therein.

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9. Answering paragraph 9 of the Complaint, these Answering Defendants lack

sufficient information and belief to either admit or deny the allegations therein, and based on that

| ground deny each and every allegation contained therein.

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10. Answering paragraph 10 of the Complaint, these Answering Defendants

incorporate their answers and denials to paragraphs 1 through 10 of the Complaint as if fully set

| forth herein. As to the balance of the allegations contained therein, these Answering Defendants

lack sufficient information and belief to either admit or deny the allegations therein, and based on

that ground deny each and every remaining allegation contained therein.

& COOPER LLP ATTORNEYS AT LAW 201 CALIFORNIA STREET

SAN FRANCISCO, CA 84111-5002

sufficient information and belief to either admit or deny the allegations therein, and based on that

sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

ground deny each and every allegation contained therein.

14. Answering paragraph 14 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

15. Answering paragraph 15 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that | ground deny each and every allegation contained therein. | 16. Answering paragraph 16 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that

ground deny each and every allegation contained therein. 17. Answering paragraph 17 of the Cbmplaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

18. Answering paragraph 18 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ;'ground deny each and every allegation, and each and every legal conclusion, contained therein.

19. Answering paragraph 19 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

20. Answering paragraph 20 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

21. Answering paragraph 21 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that | ground deny each and every allegation contained therein.

22. Answering paragraph 22 of the Complaint, these Answering Defendants lack ;sufficient information and belief to either admit or deny the allegations therein, and based on that

ground deny each and every allegation contained therein.

& COOPER LLP ATTORNEYS AT LAW 201 CALIFORNIA STREET

8AN FRANCISCO, CA 841116002

sufficient information and belief to either admit or deny the allegations therein, and based on that

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39. Answering paragraph 39 of the Complaint, these Answering Defendants lack

|| sufficient information and belief to either admit or deny the allegations therein, and based on that

| ground deny each and every allegation contained therein, save and except that these Answering

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Defendants admit that an actual controversy does exist between Plaintiffs and these Answering

| Defendants as to their respective property rights concerning the casement(s) at issue in this matter,

| and that these Answering Defendants have requested that Plaintiffs encroaching utilities be

& COOPER LLP ATTORNEYS AT LAW 201 CALIFORNIA STREET

SAN FRANCISCO, CA 84111-6002

removed as part of their prayer for relief in their cross-complaint filed on August 6, 2012, in the

within action.

within action. 40. Answering paragraph 40 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein. l) 41. Answering paragraph 41 of the Complaint, these Answering Defendants lack %sufficient information and belief to either admit or deny the allegations therein, and based on that | ground deny each and every allegation contained therein.

40. Answering paragraph 40 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein. l) 41. Answering paragraph 41 of the Complaint, these Answering Defendants lack %sufficient information and belief to either admit or deny the allegations therein, and based on that | ground deny each and every allegation contained therein.

42. Answering paragraph 42 of the Complaint, these Answering Defendants deny each ‘and every allegation contained therein.

43. Answering paragraph 43 of the Complaint, these Answering Defendants lack | vvsufficient information and belief to either admit or deny the allegations therein, and based on that ‘ground deny each and every allegation contained therein. | 44. Answering paragraph 44 of the Complaint, these Answering Defendants | incorporate their answers and denials to paragraphs 1 through 43 of the Complaint as if fully set forth herein.

45. Answering paragraph 45 of the Complaint, these Answering Defendants lack | sufficient information and belief to either admit or deny the allegations therein, and based on that | ground deny each and every allegation contained therein.

l 46. Answering paragraph 46 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

47. Answering paragraph 47 of the Complaint, these Answering deny each and every allegation, and each and every legal conclusion, contained therein, and further deny that Plaintiffs have been injured in any sum, or at all, though any fault of these Answering Defendants.

48. Answering paragraph 48 of the Complaint, these Answering Defendants incorporate their answers and denials to paragraphs 1 through 47 of the Complaint as if fully set | forth herein. | 49, Answering paragraph 49 of the Complaint, these Answering Defendants lack

sufficient information and belief to either admit or deny the allegations therein, and based on that

sufficient information and belief to either admit or deny the allegations therein, and based on that e ®N

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COOPER, WHITE

& COOPERLLP ATTORNEYS AT LAW 201 CALIFORNIA STREET

SAN FRANCISCO, CA 94111-5002

ground deny each and every allegation contained therein.

50. Answering paragraph 50 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

51. Answering paragraph 51 of the Complaint, these Answering Defendants lack

sufficient information and belief to either admit or deny the allegations therein, and based on that

| ground deny each and every allegation contained therein.

52. Answering paragraph 52 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein. |

53. Answering paragraph 53 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the aliegations therein, and based on that ground deny each and every allegation contained therein.

54, Answering paragraph 54 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

55. Answering paragraph 55 of the Complaint, these Answering Defendants

| incorporate their answers and denials to paragraphs 1 through 54 of the Complaint as if fully set

| forth herein.

56. Answering paragraph 56 of the Complaint, these Answering Defendants lack

{| sufficient information and belief to either admit or deny the allegations therein, and based on that

ground deny each and every allegation contained therein.

57. Answering paragraph 57 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

58. Answering paragraph 58 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that

ground deny each and every allegation contained therein.

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743752.1 8 » Y ‘ < - v,."”"-mv . > . - - 59. Answering paragraph 59 of the Comf)laint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

59. Answering paragraph 59 of the Comf)laint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

60. Answering paragraph 60 of the Complaint, these Answering Defendants lack | sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

61. Answering paragraph 61 of the Complaint, these Answering Defendants | incorporate their answers and denials to paragraphs 1 through 60 of the Complaint as if fully set forth herein.

62. Answering paragraph 62 of the Complaint, these Answering Defendants lack

sufficient information and belief to either admit or deny the allegations therein, and based on that ‘ground deny each and every allegation contained therein. 63. Answering paragraph 63 of the Complaint, these Answering Defendants lack | sufficient information and belief to either admit or deny the allegations therein, and based on that | ground deny each and every allegation contained therein. 64. Answering paragraph 64 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

65. Answering paragraph 65 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein. "i 66. Answering paragraph 66 of the Complaint, these Answering Defendants lack :sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

67. Answering paragraph 67 of the Complaint, these Answering Defendants lack sufficient information and belief to either admit or deny the allegations therein, and based on that ground deny each and every allegation contained therein.

68. Answering paragraph 68 of the Complaint, these Answering Defendants

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