Plaintiff Summary

Satisfactory Essays
7. Deny: we had permits from the city and inspectors came out and approved that our Property did comply with the city’s codes and regulations. 12. Neither admit nor deny: the Plaintiff stated that he “…discovered on the County of San Joaquin website that a construction case was filed against…” him but we are not sure how exactly he made this effort if the City of Stockton had not given him any notices. 13. Deny: we finished all construction and did competently close out the permits. 14. Deny: we completed all the work we got permits for, for which the city approved. 15. Deny: when we owned the Property, we did not have any problems with the roof; however, we did extend the left side of the roof, which was approved by the city. 16. Neither…show more content…
32. Deny: when we sold the Property, we disclosed all information about the Property, and the Plaintiff was due diligent to inspect the Property before purchasing. 34. Neither admit nor deny: the Plaintiff had been collecting rent from the Property since January 17, 2014, since which we have been more than reasonable, but for some reason, he could not pay us the Note 35. Neither admit nor deny: the Note was due on January 17, 2017, but we did not hear back from the Plaintiff until May 1, 2017 so we had no choice but to foreclose the Property. 36. Deny: when we first took over the Property, it was inhabitable in many units, but we spent a substantial amount of money renovating the Property; the Property was exactly in the condition we represented to the Plaintiff and we made great effort to resolve the issues without going to foreclosure, but the Plaintiff did not meet our deadline. 37. Deny: we deny all allegations presented in Paragraphs 1 through 36. 38. Deny: During the time we were negotiating with the Plaintiff of the sale of the Property, the permits we had for all the work we did were approved by the City of Stockton and we did not make any false statements, misrepresent, or omit any material facts. The Plaintiff checked all the paperwork that we did on the Property and the City of Stockton’s approval. 39. Deny: the broker had made a
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