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
First, rezoning action is quasi-judicial in nature, subject to strict scrutiny on certiorari review. Second, a landowner who demonstrates that proposed use of the property is consistent with comprehensive plan is not presumptively entitled to such use. Third, a landowner seeking to rezone a property has burden of proving that proposal is consistent with the comprehensive plan, and consequently burden shifts to the zoning board to demonstrate legitimate public purpose of maintaining existing zoning classification. Finally, the board is not
The Question: Has the Plaintiff, Linda D. Daugherty, included the operative facts for cause of action in her claim against the Defendants, Casual Lifestyles Realty, Inc. and Rauleigh J. Ringer, or has said Plaintiff insufficiently stated the facts, therefore making indefinite allegations and validating the move for a more definite statement? Or, is it that, the mechanisms of discovery could be an open alternative to the Defendants, which would aid in gathering any information needed for the defense to frame a response to said Plaintiff, therefore invalidating the Motion pursuant to Rule 12(E) of Indiana Rules of Trial Procedure?
Defendant will agree that Plaintiff filed an Affidavit of Compliance. However, Plaintiff failed to file the return receipt or any document which actually shows more than attempted service on Defendant, Norman Henson,
Furthermore, we noticed Plaintiff’s deposition based on our own availability because Plaintiff never provided deposition dates despite our repeated requests. We informed Mr. Torres that we intended to proceed with the deposition, as we had been repeatedly requesting dates, had provided more than adequate notice, and he never filed a Motion to Quash or requested alternate arrangements for his client.
The following responses and objections are based upon information presently available to Plaintiff, which this Plaintiff believes to be correct. These admissions are made without prejudice to the Plaintiff’s right to utilize subsequently discovered facts and documents.
B. However these promotions and ideas were only a cover-up of that the “governor got them to sign a deed for their land without their knowledge”. The chief’s considerer it out of consideration to that it was not in their power to do any such thing without consent from other nations.
That attached hereto as Exhibit A is a true and correct copy (with redactions and annotations) of Plaintiff’s legal billing summary (including a description of the work performed, the identity of the lawyer or legal assistant performing the work, and the hourly rate sought for the work performed) for attorney’s fees incurred through July, 2017in the above-referenced matter.
Procedural History: Respondents moved to suppress the evidence. The District Court suppressed in part, finding that the affidavit was inadequate to establish probable cause but also that none of the respondents had standing to challenge all of the searches. The Court also found a Burbank Police Officer acted in good faith.
In order to avoid repetition, the defendant refer to facts of case mentioned in statement of claim ,however it is necessary before defense and response hereinafter upholding lack of prima facie evidence mentioned and cited by the claimant especially for the contract which is being claimed made by parts contrary to facts as will be mentioned hereinafter.
City governments are tasked with writing and enforcing zoning laws that define all aspects of private use of property within the city’s district. In order for businesses and other groups to build and use plots, or zones, of land that they own within the city’s district, they must get approval from various city government officials. Failure to meet zoning requirements for the specific use proposed, as interpreted by certain officials, results in denial of the entity from using their land for that purpose. On March 22nd, I attended a meeting of the Salt Lake City Planning Commission (PC). The meeting concerned approving group’s proposed usage of property they own. Specifically, I will write about the Other Side Academy’s (OSA) proposal to build
Based on questionably liability and defense counsel’s analysis, the cede attempted to negotiate a settlement with the plaintiff’s estate. However, the plaintiff’s estate refused to accept any
Plaintiffs (Lloyd) leased property to defendant (Murphy) in 1941 for the purpose of selling cars. In 1942, the US government restricted car sales due to World War 2. Defendant repudiated the lease, and plaintiffs sought a declaratory judgment to determine whether defendant's obligations under the lease were terminated by the US government's restriction on car sales and, if not, to recover the unpaid rent.
Due to Mr. Raymond’s express refusal to grant me permission to inspect or conduct open houses, I am unable comply with the Court’s written instructions to the Commissioner to conduct open houses of the Property before the foreclosure sale.
(1) Whether a plaintiff must plead and prove willful and wanton conduct in order to
The Issue: here is whether the Mr. Rosemberg, under the facts and circumstances of this case, had the right to terminate the tenant’s lease pursuant to the termination clause.