Case 2:20-cv-01437-FWS-AS Document 32 Filed 05/19/20 Page 1 of 75 Page ID #:381

1 Alan J. Jackson (State Bar No. 173647)

Caleb E. Mason (State Bar No. 246653)
2 WERKSMAN JACKSON & QUINN LLP
888 W 6th St, Fourth Floor
3 Los Angeles, CA 90017
Telephone: 213.688.0460
4 Facsimile: 213.624.1942
5 Attorneys for Defendant
NAASÓN JOAQUÍN GARCÍA
6 UNITED STATES DISTRICT COURT
7 CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION - LOS ANGELES
8
SOCHIL MARTIN, Case No.: 2:20−cv−01437 ODW (ASx)
9
Plaintiff, DEFENDANT NAASÓN JOAQUÍN
10 GARCÍA’S ANSWER TO
v.
PLAINTIFF SOCHIL MARTIN’S
11
COMPLAINT
12 LA LUZ DEL MUNDO, an Complaint Filed: February 12, 2020
13 unincorporated association, NAASÓN Trial Date: None Set
JOAQUÍN GARCÍA, an individual, EL
14 CONSEJO DE OBISPOS, an
15 unincorporated association,
INTERNATIONAL BEREA USA, an
16 unincorporated association, GILBERTO
17 GARCÍA GRANADOS, an individual,
JOSE HERNANDEZ, an individual,
18 UZZIEL JOAQUÍN, an individual,
19 SILVERIO CORONADO, an individual,
AURELIO ZAVALETA, an individual,
20 JOSE LUIS ESTRADA, an individual,
21 JONATHAN MENDOZA, an individual,
ALMA ZAMORA DE JOAQUÍN, an
22 individual, BENJAMIN JOAQUÍN
23 GARCÍA, an individual, RAHEL
JOAQUÍN GARCÍA, an individual,
24 ADORAIM JOAQUÍN, ZAMORA, an
25 individual, DAVID MENDOZA, an
individual and DOES 1 through 10,
26 inclusive.
27 Defendants.
28

NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT

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Defendant Naasón Joaquín García (“Defendant”) by his undersigned

1
attorneys, Werksman Jackson & Quinn LLP, for his Answer to Plaintiff Sochil
2
Martin’s (“Plaintiff”) Complaint (the “Complaint”), states as follows: In providing
3
this unsworn Answer through his undersigned counsel, Defendant does not intend to,
4
and does not, waive any privileges in this or any other proceeding, including but not
5
limited to the privilege against self-incrimination guaranteed to him by the Fifth
6
Amendment to the United States Constitution and Article I Section 15 of the
7
California Constitution. Defendant reserves the right to assert any such applicable
8
privileges in this or other proceedings. Defendant is presently facing criminal
9
prosecution in People v. Naason Joaquin Garcia et al., Case No. BA-475856 (Los
10
Angeles Sup. Ct.).
11
1. In response to Paragraph 1 of the Complaint, Defendant asserts his
12
privilege against self-incrimination guaranteed by the Fifth Amendment of the
13
United States Constitution, Article I Section 15 of the California Constitution, and
14
California Evidence Code section 940. On that basis, Defendant declines to respond
15
to each and every allegation therein. Moreover, Defendant’s right to assert and
16
assertion of his privilege against self-incrimination shall not be deemed or
17
considered an admission of any allegation therein.
18
2. In response to Paragraph 2 of the Complaint, Defendant asserts his
19
privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20
the United States Constitution, Article I Section 15 of the California Constitution,
21
and California Evidence Code section 940. On that basis, Defendant declines to
22
respond to each and every allegation therein. Moreover, Defendant’s right to assert
23
and assertion of his privilege against self-incrimination shall not be deemed or
24
considered an admission of any allegation therein.
25
3. In response to Paragraph 3 of the Complaint, Defendant asserts his
26
privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27
the United States Constitution, Article I Section 15 of the California Constitution,
28

NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT

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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 4. In response to Paragraph 4 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 5. In response to Paragraph 5 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 6. In response to Paragraph 6 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 7. In response to Paragraph 7 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
2
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 8. In response to Paragraph 8 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 9. In response to Paragraph 9 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 JURISDICTION AND VENUE
21 10. In response to Paragraph 10 of the Complaint, this Paragraph contains
22 legal assertions which do not require an answer. To the extent any response is
23 required, Defendant asserts his privilege against self-incrimination that is
24 guaranteed by the Fifth Amendment of the United States Constitution, Article I
25 Section 15 of the California Constitution, and California Evidence Code section
26 940. On that basis, Defendant declines to respond to each and every allegation
27 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
28
3
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 self-incrimination shall not be deemed or considered an admission of any allegation

2 therein.
3 11. In response to Paragraph 11 of the Complaint, this Paragraph contains
4 legal assertions which do not require an answer. To the extent any response is
5 required, Defendant asserts his privilege against self-incrimination that is
6 guaranteed by the Fifth Amendment of the United States Constitution, Article I
7 Section 15 of the California Constitution, and California Evidence Code section
8 940. On that basis, Defendant declines to respond to each and every allegation
9 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
10 self-incrimination shall not be deemed or considered an admission of any allegation
11 therein.
12 12. In response to Paragraph 12 of the Complaint, this Paragraph contains
13 legal assertions which do not require an answer. To the extent any response is
14 required, Defendant asserts his privilege against self-incrimination that is
15 guaranteed by the Fifth Amendment of the United States Constitution, Article I
16 Section 15 of the California Constitution, and California Evidence Code section
17 940. On that basis, Defendant declines to respond to each and every allegation
18 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
19 self-incrimination shall not be deemed or considered an admission of any allegation
20 therein.
21 THE PARTIES
22 13. In response to Paragraph 13 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
4
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 14. In response to Paragraph 14, Defendant asserts his privilege against
4 self-incrimination that is guaranteed by the Fifth Amendment of the United States
5 Constitution, Article I Section 15 of the California Constitution, and California
6 Evidence Code section 940. On that basis, Defendant declines to respond to each
7 and every allegation therein. Moreover, Defendant’s right to assert and assertion of
8 his privilege against self-incrimination shall not be deemed or considered an
9 admission of any allegation therein.
10 15. In response to Paragraph 15 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 16. In response to Paragraph 16 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 17. In response to Paragraph 17 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
5
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 18. In response to Paragraph 18 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 19. In response to Paragraph 19 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 20. In response to Paragraph 20 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 21. In response to Paragraph 21 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
6
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 22. In response to Paragraph 22 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 23. In response to Paragraph 23 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 24. In response to Paragraph 24 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 25. In response to Paragraph 25 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
7
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 26. In response to Paragraph 26 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 27. In response to Paragraph 27 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 28. In response to Paragraph 28 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
8
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 29. In response to Paragraph 29 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 30. In response to Paragraph 30 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 31. In response to Paragraph 31 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 32. In response to Paragraph 32 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
9
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 33. In response to Paragraph 33 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 34. In response to Paragraph 34 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 35. In response to Paragraph 35 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 36. In response to Paragraph 36 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
10
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 37. In response to Paragraph 37 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 38. In response to Paragraph 38 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 39. In response to Paragraph 39 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 GENERAL ALLEGATIONS
26 40. In response to Paragraph 40 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
11
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 41. In response to Paragraph 41 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 42. In response to Paragraph 42 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 43. In response to Paragraph 43 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
12
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 44. In response to Paragraph 44 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 45. In response to Paragraph 45 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 46. In response to Paragraph 46 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 47. In response to Paragraph 47 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 48. In response to Paragraph 48 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 49. In response to Paragraph 49 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 50. In response to Paragraph 50 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 51. In response to Paragraph 51 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
14
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 52. In response to Paragraph 52 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 53. In response to Paragraph 53 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 54. In response to Paragraph 54 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 55. In response to Paragraph 55 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
15
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 56. In response to Paragraph 56 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 57. In response to Paragraph 57 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 58. In response to Paragraph 58 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 59. In response to Paragraph 59 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
16
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 60. In response to Paragraph 60 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 61. In response to Paragraph 61 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 62. In response to Paragraph 62 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
17
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1 63. In response to Paragraph 63 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 64. In response to Paragraph 64 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 65. In response to Paragraph 65 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 66. In response to Paragraph 66 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
18
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 67. In response to Paragraph 67 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 68. In response to Paragraph 68 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 69. In response to Paragraph 69 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 70. In response to Paragraph 70 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
19
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 71. In response to Paragraph 71 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 72. In response to Paragraph 72 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 73. In response to Paragraph 73 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 74. In response to Paragraph 74 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
20
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 75. In response to Paragraph 75 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 76. In response to Paragraph 76 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 77. In response to Paragraph 77 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 78. In response to Paragraph 78 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
21
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 79. In response to Paragraph 79 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 80. In response to Paragraph 80 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 81. In response to Paragraph 81 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
22
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1 82. In response to Paragraph 82 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 83. In response to Paragraph 83 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 84. In response to Paragraph 84 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 85. In response to paragraph 85 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
23
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 86. In response to Paragraph 86 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 87. In response to Paragraph 87 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 88. In response to Paragraph 88 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 89. In response to Paragraph 89 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
24
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 90. In response to Paragraph 90 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 91. In response to Paragraph 91 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 92. In response to Paragraph 92 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 93. In response to Paragraph 93 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
25
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 94. In response to Paragraph 94 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 95. In response to Paragraph 95 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein
19 96. In response to Paragraph 96 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein
26 97. In response to Paragraph 97 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
26
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 98. In response to Paragraph 98 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein
13 99. In response to Paragraph 99 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 100. In response to Paragraph 100 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
27
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 101. In response to Paragraph 101 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 102. In response to Paragraph 102 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 103. In response to Paragraph 103 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 104. In response to Paragraph 104 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
28
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 105. In response to Paragraph 105 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 106. In response to Paragraph 106 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 107. In response to Paragraph 107 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 108. In response to Paragraph 108 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
29
NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 109. In response to Paragraph 109 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 110. In response to Paragraph 110 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 111. In response to Paragraph 111 of the Complaint, Defendant asserts his
19 privilege against self-incrimination -that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 112. In response to Paragraph 112 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
30
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 113. In response to Paragraph 113 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 114. In response to Paragraph 114 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 115. In response to Paragraph 115 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 116. In response to Paragraph 116 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 117. In response to Paragraph 117 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 118. In response to Paragraph 118 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 119. In response to Paragraph 119 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
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1 120. In response to Paragraph 120 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 121. In response to Paragraph 121 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 122. In response to Paragraph 122 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 123. In response to Paragraph 123 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 124. In response to Paragraph 124 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 125. In response to Paragraph 125 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 126. In response to paragraph 126 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 127. In response to paragraph 127 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 128. In response to Paragraph 128 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 129. In response to Paragraph 129 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 130. In response to Paragraph 130 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 131. In response to Paragraph 131 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 132. In response to Paragraph 132 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 133. In response to Paragraph 133 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 134. In response to Paragraph 134 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 135. In response to Paragraph 135 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
36
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 136. In response to Paragraph 136 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 137. In response to Paragraph 137 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 138. In response to Paragraph 138 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
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1 139. In response to Paragraph 139 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 140. In response to Paragraph 140 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 141. In response to Paragraph 141 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 142. In response to Paragraph 142 of the Complaint, Defendant asserts his
23 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
24 the United States Constitution, Article I Section 15 of the California Constitution,
25 and California Evidence Code section 940. On that basis, Defendant declines to
26 respond to each and every allegation therein. Moreover, Defendant’s right to assert
27
28
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 143. In response to Paragraph 143 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 144. In response to Paragraph 144 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 145. In response to Paragraph 145 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 146. In response to Paragraph 146 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 147. In response to Paragraph 147 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 148. In response to Paragraph 148 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 149. In response to Paragraph 149 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 150. In response to Paragraph 150 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 151. In response to Paragraph 151 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 152. In response to Paragraph 152 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 153. In response to paragraph 153 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 154. In response to Paragraph 154 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
41
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 155. In response to Paragraph 155 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 156. In response to Paragraph 156 of the Complaint, Defendants asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 ANSWER TO FIRST CLAIM FOR RELIEF
21 Alleged Violation of 18 U.S.C. § 1584
22 157. In response to Paragraph 157, Defendant incorporates by reference
23 each assertion of privilege and related statement contained in Paragraphs 1 through
24 156 herein.
25 158. In response to Paragraph 158, this paragraph contains legal
26 conclusions to which no response is required. To the extent any response is
27 required, Defendant asserts his privilege against self-incrimination that is
28
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1 guaranteed by the Fifth Amendment of the United States Constitution, Article I

2 Section 15 of the California Constitution, and California Evidence Code section
3 940. On that basis, Defendant declines to respond to each and every allegation
4 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
5 self-incrimination shall not be deemed or considered an admission of any allegation
6 therein.
7 159. In response to Paragraph 159, this paragraph contains legal
8 conclusions to which no response is required. To the extent any response is
9 required, Defendant asserts his privilege against self-incrimination that is
10 guaranteed by the Fifth Amendment of the United States Constitution, Article I
11 Section 15 of the California Constitution, and California Evidence Code section
12 940. On that basis, Defendant declines to respond to each and every allegation
13 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
14 self-incrimination shall not be deemed or considered an admission of any allegation
15 therein.
16 160. In response to Paragraph 160 of the Complaint, Defendant asserts his
17 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
18 the United States Constitution, Article I Section 15 of the California Constitution,
19 and California Evidence Code section 940. On that basis, Defendant declines to
20 respond to each and every allegation therein. Moreover, Defendant’s right to assert
21 and assertion of his privilege against self-incrimination shall not be deemed or
22 considered an admission of any allegation therein.
23 161. In response to Paragraph 161 of the Complaint, Defendant asserts his
24 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
25 the United States Constitution, Article I Section 15 of the California Constitution,
26 and California Evidence Code section 940. On that basis, Defendant declines to
27 respond to each and every allegation therein. Moreover, Defendant’s right to assert
28
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1 and assertion of his privilege against self-incrimination shall not be deemed or

2 considered an admission of any allegation therein.
3 162. In response to Paragraph 162 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 163. In response to Paragraph 163 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 164. In response to Paragraph 164 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 165. In response to Paragraph 165 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 166. In response to Paragraph 166 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 167. In response to Paragraph 167 of the Complaint, this Paragraph contains
12 legal assertions which do not require an answer. To the extent any response is
13 required, Defendant asserts his privilege against self-incrimination that is
14 guaranteed by the Fifth Amendment of the United States Constitution, Article I
15 Section 15 of the California Constitution, and California Evidence Code section
16 940. On that basis, Defendant declines to respond to each and every allegation
17 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
18 self-incrimination shall not be deemed or considered an admission of any allegation
19 therein.
20 ANSWER TO SECOND CLAIM FOR RELIEF
21 Alleged Violation of 18 U.S.C. § 1589
22 168. In response to Paragraph 168, Defendant incorporates by reference
23 each assertion of privilege and related statement contained in Paragraphs 1 through
24 167 herein.
25 169. In response to Paragraph 169 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 170. In response to Paragraph 170 of the Complaint, this Paragraph contains
6 legal assertions which do not require an answer. To the extent any response is
7 required, Defendant asserts his privilege against self-incrimination that is
8 guaranteed by the Fifth Amendment of the United States Constitution, Article I
9 Section 15 of the California Constitution, and California Evidence Code section
10 940. On that basis, Defendant declines to respond to each and every allegation
11 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
12 self-incrimination shall not be deemed or considered an admission of any allegation
13 therein.
14 171. In response to Paragraph 171 of the Complaint, Defendant asserts his
15 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
16 the United States Constitution, Article I Section 15 of the California Constitution,
17 and California Evidence Code section 940. On that basis, Defendant declines to
18 respond to each and every allegation therein. Moreover, Defendant’s right to assert
19 and assertion of his privilege against self-incrimination shall not be deemed or
20 considered an admission of any allegation therein.
21 172. In response to Paragraph 172 of the Complaint, Defendant asserts his
22 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
23 the United States Constitution, Article I Section 15 of the California Constitution,
24 and California Evidence Code section 940. On that basis, Defendant declines to
25 respond to each and every allegation therein. Moreover, Defendant’s right to assert
26 and assertion of his privilege against self-incrimination shall not be deemed or
27 considered an admission of any allegation therein.
28
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1 173. In response to Paragraph 173 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 174. In response to Paragraph 174 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 175. In response to Paragraph 175 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 176. In response to Paragraph 176 of the Complaint, this Paragraph contains
23 legal assertions which do not require an answer. To the extent any response is
24 required, Defendant asserts his privilege against self-incrimination that is
25 guaranteed by the Fifth Amendment of the United States Constitution, Article I
26 Section 15 of the California Constitution, and California Evidence Code section
27 940. On that basis, Defendant declines to respond to each and every allegation
28
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1 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
2 self-incrimination shall not be deemed or considered an admission of any allegation
3 therein.
4 ANSWER TO THIRD CLAIM FOR RELIEF
5 Alleged Violation of 18 U.S.C. § 1590
6 177. In response to Paragraph 177, Defendant incorporates by reference
7 each assertion of privilege and related statement contained in Paragraphs 1 through
8 176 herein.
9 178. In response to Paragraph 178 of the Complaint, Defendant asserts his
10 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
11 the United States Constitution, Article I Section 15 of the California Constitution,
12 and California Evidence Code section 940. On that basis, Defendant declines to
13 respond to each and every allegation therein. Moreover, Defendant’s right to assert
14 and assertion of his privilege against self-incrimination shall not be deemed or
15 considered an admission of any allegation therein.
16 179. In response to Paragraph 179 of the Complaint, this Paragraph contains
17 legal assertions which do not require an answer. To the extent any response is
18 required, Defendant asserts his privilege against self-incrimination that is
19 guaranteed by the Fifth Amendment of the United States Constitution, Article I
20 Section 15 of the California Constitution, and California Evidence Code section
21 940. On that basis, Defendant declines to respond to each and every allegation
22 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
23 self-incrimination shall not be deemed or considered an admission of any allegation
24 therein.
25 180. In response to Paragraph 180 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 181. In response to Paragraph 181 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 182. In response to Paragraph 182 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 183. In response to Paragraph 183 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 184. In response to Paragraph 184 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 185. In response to Paragraph 185 of the Complaint, this Paragraph contains
7 legal assertions which do not require an answer. To the extent any response is
8 required, Defendant asserts his privilege against self-incrimination that is
9 guaranteed by the Fifth Amendment of the United States Constitution, Article I
10 Section 15 of the California Constitution, and California Evidence Code section
11 940. On that basis, Defendant declines to respond to each and every allegation
12 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
13 self-incrimination shall not be deemed or considered an admission of any allegation
14 therein.
15 ANSWER TO FOURTH CLAIM FOR RELIEF
16 Alleged Conspiracy in Violation of 18 U.S.C. § 1594
17 186. In response to Paragraph 186, Defendant incorporates by reference
18 each assertion of privilege and related statement contained in Paragraphs 1 through
19 185 herein.
20 187. In response to Paragraph 187 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
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1 188. In response to Paragraph 188 of the Complaint, this Paragraph contains

2 legal assertions which do not require an answer. To the extent any response is
3 required, Defendant asserts his privilege against self-incrimination that is
4 guaranteed by the Fifth Amendment of the United States Constitution, Article I
5 Section 15 of the California Constitution, and California Evidence Code section
6 940. On that basis, Defendant declines to respond to each and every allegation
7 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
8 self-incrimination shall not be deemed or considered an admission of any allegation
9 therein.
10 189. In response to Paragraph 189 of the Complaint, Defendant asserts his
11 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
12 the United States Constitution, Article I Section 15 of the California Constitution,
13 and California Evidence Code section 940. On that basis, Defendant declines to
14 respond to each and every allegation therein. Moreover, Defendant’s right to assert
15 and assertion of his privilege against self-incrimination shall not be deemed or
16 considered an admission of any allegation therein.
17 190. In response to Paragraph 190 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 191. In response to Paragraph 191of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 192. In response to Paragraph 192 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 193. In response to Paragraph 193 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 194. In response to Paragraph 194 of the Complaint, this Paragraph contains
19 legal assertions which do not require an answer. To the extent any response is
20 required, Defendant asserts his privilege against self-incrimination that is
21 guaranteed by the Fifth Amendment of the United States Constitution, Article I
22 Section 15 of the California Constitution, and California Evidence Code section
23 940. On that basis, Defendant declines to respond to each and every allegation
24 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
25 self-incrimination shall not be deemed or considered an admission of any allegation
26 therein.
27
28
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1 ANSWER TO FIFTH CLAIM FOR RELIEF

2 Alleged Violation of 18 U.S.C. § 1590(b)
3 195. In response to Paragraph 195, Defendant incorporates by reference
4 each assertion of privilege and related statement contained in Paragraphs 1 through
5 194 herein.
6 196. In response to Paragraph 196 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 197. In response to Paragraph 197 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 198. In response to Paragraph 198 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
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1 199. In response to Paragraph 199 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 200. In response to Paragraph 200 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 201. In response to Paragraph 201 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 202. In response to Paragraph 202 of the Complaint, this Paragraph contains
23 legal assertions which do not require an answer. To the extent any response is
24 required, Defendant asserts his privilege against self-incrimination that is
25 guaranteed by the Fifth Amendment of the United States Constitution, Article I
26 Section 15 of the California Constitution, and California Evidence Code section
27 940. On that basis, Defendant declines to respond to each and every allegation
28
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1 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
2 self-incrimination shall not be deemed or considered an admission of any allegation
3 therein.
4 203. In response to Paragraph 203 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 204. In response to Paragraph 204 of the Complaint, this Paragraph contains
12 legal assertions which do not require an answer. To the extent any response is
13 required, Defendant asserts his privilege against self-incrimination that is
14 guaranteed by the Fifth Amendment of the United States Constitution, Article I
15 Section 15 of the California Constitution, and California Evidence Code section
16 940. On that basis, Defendant declines to respond to each and every allegation
17 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
18 self-incrimination shall not be deemed or considered an admission of any allegation
19 therein.
20 ANSWER TO SIXTH CLAIM FOR RELIEF
21 Alleged Violation of 18 U.S.C. § 1593A
22 205. In response to Paragraph 205, Defendant incorporates by reference
23 each assertion of privilege and related statement contained in Paragraphs 1 through
24 204 herein.
25 206. In response to Paragraph 206 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 207. In response to Paragraph 207 of the Complaint, this Paragraph contains
6 legal assertions which do not require an answer. To the extent any response is
7 required, Defendant asserts his privilege against self-incrimination that is
8 guaranteed by the Fifth Amendment of the United States Constitution, Article I
9 Section 15 of the California Constitution, and California Evidence Code section
10 940. On that basis, Defendant declines to respond to each and every allegation
11 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
12 self-incrimination shall not be deemed or considered an admission of any allegation
13 therein.
14 208. In response to Paragraph 208 of the Complaint, Defendant asserts his
15 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
16 the United States Constitution, Article I Section 15 of the California Constitution,
17 and California Evidence Code section 940. On that basis, Defendant declines to
18 respond to each and every allegation therein. Moreover, Defendant’s right to assert
19 and assertion of his privilege against self-incrimination shall not be deemed or
20 considered an admission of any allegation therein.
21 209. In response to Paragraph 209 of the Complaint, Defendant asserts his
22 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
23 the United States Constitution, Article I Section 15 of the California Constitution,
24 and California Evidence Code section 940. On that basis, Defendant declines to
25 respond to each and every allegation therein. Moreover, Defendant’s right to assert
26 and assertion of his privilege against self-incrimination shall not be deemed or
27 considered an admission of any allegation therein.
28
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1 210. In response to Paragraph 210 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 211. In response to Paragraph 211 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 212. In response to Paragraph 212 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 213. In response to Paragraph 213 of the Complaint, this Paragraph contains
23 legal assertions which do not require an answer. To the extent a response is
24 required, Defendant asserts his privilege against self-incrimination that is
25 guaranteed by the Fifth Amendment of the United States Constitution, Article I
26 Section 15 of the California Constitution, and California Evidence Code section
27 940. On that basis, Defendant declines to respond to each and every allegation
28
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1 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
2 self-incrimination shall not be deemed or considered an admission of any allegation
3 therein.
4 ANSWER TO SEVENTH CLAIM FOR RELIEF
5 Alleged Violation of 29 U.S.C. § 201 et. seq.
6 214. In response to Paragraph 214, Defendant incorporates by reference
7 each assertion of privilege and related statement contained in Paragraphs 1 through
8 213 herein.
9 215. In response to Paragraph 215 of the Complaint, this Paragraph contains
10 legal assertions which do not require a response. To the extent any response is
11 required, Defendant asserts his privilege against self-incrimination that is
12 guaranteed by the Fifth Amendment of the United States Constitution, Article I
13 Section 15 of the California Constitution, and California Evidence Code section
14 940. On that basis, Defendant declines to respond to each and every allegation
15 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
16 self-incrimination shall not be deemed or considered an admission of any allegation
17 therein.
18 216. In response to Paragraph 216 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 217. In response to Paragraph 217 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 218. In response to Paragraph 218 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 219. In response to Paragraph 219 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 220. In response to Paragraph 220 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 221. In response to Paragraph 221 of the Complaint, this Paragraph contains
27 legal assertions, which do not require a response. To the extent any response is
28
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1 required, Defendant asserts his privilege against self-incrimination that is

2 guaranteed by the Fifth Amendment of the United States Constitution, Article I
3 Section 15 of the California Constitution, and California Evidence Code section
4 940. On that basis, Defendant declines to respond to each and every allegation
5 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
6 self-incrimination shall not be deemed or considered an admission of any allegation
7 therein.
8 ANSWER TO EIGHTH CLAIM FOR RELIEF
9 Alleged Violation of the California Labor Code
10 222. In response to Paragraph 222, Defendant incorporates by reference
11 each assertion of privilege and related statement contained in Paragraphs 1 through
12 221 herein.
13 223. In response to Paragraph 223 of the Complaint, this Paragraph contains
14 legal assertions which do not require a response. To the extent any response is
15 required, Defendant asserts his privilege against self-incrimination that is
16 guaranteed by the Fifth Amendment of the United States Constitution, Article I
17 Section 15 of the California Constitution, and California Evidence Code section
18 940. On that basis, Defendant declines to respond to each and every allegation
19 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
20 self-incrimination shall not be deemed or considered an admission of any allegation
21 therein.
22 224. In response to Paragraph 224 of the Complaint, this Paragraph contains
23 legal assertions which do not require a response. To the extent any response is
24 required, Defendant asserts his privilege against self-incrimination that is
25 guaranteed by the Fifth Amendment of the United States Constitution, Article I
26 Section 15 of the California Constitution, and California Evidence Code section
27 940. On that basis, Defendant declines to respond to each and every allegation
28
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1 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
2 self-incrimination shall not be deemed or considered an admission of any allegation
3 therein.
4 225. In response to Paragraph 225 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 226. In response to Paragraph 226 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 227. In response to Paragraph 227 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 228. In response to Paragraph 228 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 229. In response to Paragraph 229 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 230. In response to Paragraph 230 of the Complaint, this Paragraph contains
13 legal assertions, which do not require a response. To the extent any response is
14 required, Defendant asserts his privilege against self-incrimination that is
15 guaranteed by the Fifth Amendment of the United States Constitution, Article I
16 Section 15 of the California Constitution, and California Evidence Code section
17 940. On that basis, Defendant declines to respond to each and every allegation
18 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
19 self-incrimination shall not be deemed or considered an admission of any allegation
20 therein.
21 ANSWER TO NINTH CLAIM FOR RELIEF
22 Alleged Violation Act 18 U.S.C. § 1962(c)
23 231. In response to Paragraph 231, Defendant incorporates by reference
24 each assertion of privilege and related statement contained in Paragraphs 1 through
25 230 herein.
26 232. In response to Paragraph 232 of the Complaint, this Paragraph contains
27 legal assertions which do not require a response. To the extent any response is
28
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1 required, Defendant asserts his privilege against self-incrimination that is

2 guaranteed by the Fifth Amendment of the United States Constitution, Article I
3 Section 15 of the California Constitution, and California Evidence Code section
4 940. On that basis, Defendant declines to respond to each and every allegation
5 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
6 self-incrimination shall not be deemed or considered an admission of any allegation
7 therein.
8 233. In response to Paragraph 233 of the Complaint, this Paragraph contains
9 legal assertions which do not require a response. To the extent any response is
10 required, Defendant asserts his privilege against self-incrimination that is
11 guaranteed by the Fifth Amendment of the United States Constitution, Article I
12 Section 15 of the California Constitution, and California Evidence Code section
13 940. On that basis, Defendant declines to respond to each and every allegation
14 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
15 self-incrimination shall not be deemed or considered an admission of any allegation
16 therein.
17 234. In response to Paragraph 234 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 235. In response to Paragraph 235 of the Complaint, Defendant asserts his
25 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
26 the United States Constitution, Article I Section 15 of the California Constitution,
27 and California Evidence Code section 940. On that basis, Defendant declines to
28
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1 respond to each and every allegation therein. Moreover, Defendant’s right to assert
2 and assertion of his privilege against self-incrimination shall not be deemed or
3 considered an admission of any allegation therein.
4 236. In response to Paragraph 236 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 237. In response to Paragraph 237 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 238. In response to Paragraph 238 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 239. In response to Paragraph 239 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 240. In response to Paragraph 240 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 241. In response to Paragraph 241 of the Complaint, Defendant asserts his
13 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
14 the United States Constitution, Article I Section 15 of the California Constitution,
15 and California Evidence Code section 940. On that basis, Defendant declines to
16 respond to each and every allegation therein. Moreover, Defendant’s right to assert
17 and assertion of his privilege against self-incrimination shall not be deemed or
18 considered an admission of any allegation therein.
19 242. In response to Paragraph 242 of the Complaint, Defendant asserts his
20 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
21 the United States Constitution, Article I Section 15 of the California Constitution,
22 and California Evidence Code section 940. On that basis, Defendant declines to
23 respond to each and every allegation therein. Moreover, Defendant’s right to assert
24 and assertion of his privilege against self-incrimination shall not be deemed or
25 considered an admission of any allegation therein.
26 243. In response to Paragraph 243 of the Complaint, Defendant asserts his
27 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
28
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1 the United States Constitution, Article I Section 15 of the California Constitution,

2 and California Evidence Code section 940. On that basis, Defendant declines to
3 respond to each and every allegation therein. Moreover, Defendant’s right to assert
4 and assertion of his privilege against self-incrimination shall not be deemed or
5 considered an admission of any allegation therein.
6 244. In response to Paragraph 244of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 245. In response to Paragraph 245 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 246. In response to Paragraph 246 of the Complaint, this Paragraph contains
21 legal assertions, which do not require a response. To the extent that any response is
22 required, Defendant asserts his privilege against self-incrimination that is
23 guaranteed by the Fifth Amendment of the United States Constitution, Article I
24 Section 15 of the California Constitution, and California Evidence Code section
25 940. On that basis, Defendant declines to respond to each and every allegation
26 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
27
28
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1 self-incrimination shall not be deemed or considered an admission of any allegation

2 therein.
3 247. In response to Paragraph 247 of the Complaint, Defendant asserts his
4 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
5 the United States Constitution, Article I Section 15 of the California Constitution,
6 and California Evidence Code section 940. On that basis, Defendant declines to
7 respond to each and every allegation therein. Moreover, Defendant’s right to assert
8 and assertion of his privilege against self-incrimination shall not be deemed or
9 considered an admission of any allegation therein.
10 248. In response to Paragraph 248 of the Complaint, this Paragraph contains
11 legal assertions, which do not require a response. To the extent that any response is
12 required, Defendant asserts his privilege against self-incrimination that is
13 guaranteed by the Fifth Amendment of the United States Constitution, Article I
14 Section 15 of the California Constitution, and California Evidence Code section
15 940. On that basis, Defendant declines to respond to each and every allegation
16 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
17 self-incrimination shall not be deemed or considered an admission of any allegation
18 therein.
19 ANSWER TO TENTH CLAIM FOR RELIEF
20 Alleged Violation of Cal. Civ. Code § 1708.5
21 249. In response to Paragraph 249, Defendant incorporates by reference
22 each assertion of privilege and related statement contained in Paragraphs 1 through
23 248 herein.
24 250. In response to Paragraph 250 of the Complaint, this Paragraph contains
25 legal assertions, which do not require a response. To the extent a response is
26 required, Defendant asserts his privilege against self-incrimination that is
27 guaranteed by the Fifth Amendment of the United States Constitution, Article I
28
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1 Section 15 of the California Constitution, and California Evidence Code section

2 940. On that basis, Defendant declines to respond to each and every allegation
3 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
4 self-incrimination shall not be deemed or considered an admission of any allegation
5 therein.
6 251. In response to Paragraph 251 of the Complaint, this Paragraph contains
7 legal assertions, which do not require a response. To the extent a response is
8 required, Defendant asserts his privilege against self-incrimination that is
9 guaranteed by the Fifth Amendment of the United States Constitution, Article I
10 Section 15 of the California Constitution, and California Evidence Code section
11 940. On that basis, Defendant declines to respond to each and every allegation
12 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
13 self-incrimination shall not be deemed or considered an admission of any allegation
14 therein.
15 252. In response to Paragraph 252 of the Complaint, Defendant asserts his
16 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
17 the United States Constitution, Article I Section 15 of the California Constitution,
18 and California Evidence Code section 940. On that basis, Defendant declines to
19 respond to each and every allegation therein. Moreover, Defendant’s right to assert
20 and assertion of his privilege against self-incrimination shall not be deemed or
21 considered an admission of any allegation therein.
22 253. In response to Paragraph 253 of the Complaint, this Paragraph contains
23 legal assertions, which do not require a response. To the extent any response is
24 required, Defendant asserts his privilege against self-incrimination that is
25 guaranteed by the Fifth Amendment of the United States Constitution, Article I
26 Section 15 of the California Constitution, and California Evidence Code section
27 940. On that basis, Defendant declines to respond to each and every allegation
28
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1 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
2 self-incrimination shall not be deemed or considered an admission of any allegation
3 therein.
4 254. In response to Paragraph 254 of the Complaint, Defendant asserts his
5 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
6 the United States Constitution, Article I Section 15 of the California Constitution,
7 and California Evidence Code section 940. On that basis, Defendant declines to
8 respond to each and every allegation therein. Moreover, Defendant’s right to assert
9 and assertion of his privilege against self-incrimination shall not be deemed or
10 considered an admission of any allegation therein.
11 255. In response to Paragraph 255 of the Complaint, Defendant asserts his
12 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
13 the United States Constitution, Article I Section 15 of the California Constitution,
14 and California Evidence Code section 940. On that basis, Defendant declines to
15 respond to each and every allegation therein. Moreover, Defendant’s right to assert
16 and assertion of his privilege against self-incrimination shall not be deemed or
17 considered an admission of any allegation therein.
18 256. In response to Paragraph 256 of the Complaint, Defendant asserts his
19 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
20 the United States Constitution, Article I Section 15 of the California Constitution,
21 and California Evidence Code section 940. On that basis, Defendant declines to
22 respond to each and every allegation therein. Moreover, Defendant’s right to assert
23 and assertion of his privilege against self-incrimination shall not be deemed or
24 considered an admission of any allegation therein.
25 257. In response to Paragraph 257 of the Complaint, Defendant asserts his
26 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
27 the United States Constitution, Article I Section 15 of the California Constitution,
28
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1 and California Evidence Code section 940. On that basis, Defendant declines to
2 respond to each and every allegation therein. Moreover, Defendant’s right to assert
3 and assertion of his privilege against self-incrimination shall not be deemed or
4 considered an admission of any allegation therein.
5 258. In response to Paragraph 258 of the Complaint, Defendant asserts his
6 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
7 the United States Constitution, Article I Section 15 of the California Constitution,
8 and California Evidence Code section 940. On that basis, Defendant declines to
9 respond to each and every allegation therein. Moreover, Defendant’s right to assert
10 and assertion of his privilege against self-incrimination shall not be deemed or
11 considered an admission of any allegation therein.
12 259. In response to Paragraph 259 of the Complaint, this Paragraph contains
13 legal assertions, which do not require a response. To the extent any response is
14 required, Defendant asserts his privilege against self-incrimination that is
15 guaranteed by the Fifth Amendment of the United States Constitution, Article I
16 Section 15 of the California Constitution, and California Evidence Code section
17 940. On that basis, Defendant declines to respond to each and every allegation
18 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
19 self-incrimination shall not be deemed or considered an admission of any allegation
20 therein.
21 ANSWER TO ELEVENTH CLAIM FOR RELIEF
22 Alleged Violation of Cal. Civ. Code § 52.4
23 260. In response to Paragraph 260, Defendant incorporates by reference
24 each assertion of privilege and related statement contained in Paragraphs 1 through
25 259 herein.
26 261. In response to Paragraph 261 of the Complaint, this Paragraph contains
27 legal assertions, which do not require a response. To the extent a response is
28
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1 required, Defendant asserts his privilege against self-incrimination that is

2 guaranteed by the Fifth Amendment of the United States Constitution, Article I
3 Section 15 of the California Constitution, and California Evidence Code section
4 940. On that basis, Defendant declines to respond to each and every allegation
5 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
6 self-incrimination shall not be deemed or considered an admission of any allegation
7 therein.
8 262. In response to Paragraph 262 of the Complaint, this Paragraph contains
9 legal assertions, which do not require a response. To the extent a response is
10 required, Defendant asserts his privilege against self-incrimination that is
11 guaranteed by the Fifth Amendment of the United States Constitution, Article I
12 Section 15 of the California Constitution, and California Evidence Code section
13 940. On that basis, Defendant declines to respond to each and every allegation
14 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
15 self-incrimination shall not be deemed or considered an admission of any allegation
16 therein.
17 263. In response to Paragraph 263 of the Complaint, Defendant asserts his
18 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
19 the United States Constitution, Article I Section 15 of the California Constitution,
20 and California Evidence Code section 940. On that basis, Defendant declines to
21 respond to each and every allegation therein. Moreover, Defendant’s right to assert
22 and assertion of his privilege against self-incrimination shall not be deemed or
23 considered an admission of any allegation therein.
24 264. In response to Paragraph 264 of the Complaint, this Paragraph contains
25 legal assertions, which do not require a response. To the extent a response is
26 required, Defendant asserts his privilege against self-incrimination that is
27 guaranteed by the Fifth Amendment of the United States Constitution, Article I
28
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1 Section 15 of the California Constitution, and California Evidence Code section

2 940. On that basis, Defendant declines to respond to each and every allegation
3 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
4 self-incrimination shall not be deemed or considered an admission of any allegation
5 therein.
6 265. In response to Paragraph 265 of the Complaint, Defendant asserts his
7 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
8 the United States Constitution, Article I Section 15 of the California Constitution,
9 and California Evidence Code section 940. On that basis, Defendant declines to
10 respond to each and every allegation therein. Moreover, Defendant’s right to assert
11 and assertion of his privilege against self-incrimination shall not be deemed or
12 considered an admission of any allegation therein.
13 266. In response to Paragraph 266 of the Complaint, Defendant asserts his
14 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
15 the United States Constitution, Article I Section 15 of the California Constitution,
16 and California Evidence Code section 940. On that basis, Defendant declines to
17 respond to each and every allegation therein. Moreover, Defendant’s right to assert
18 and assertion of his privilege against self-incrimination shall not be deemed or
19 considered an admission of any allegation therein.
20 267. In response to Paragraph 267 of the Complaint, Defendant asserts his
21 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
22 the United States Constitution, Article I Section 15 of the California Constitution,
23 and California Evidence Code section 940. On that basis, Defendant declines to
24 respond to each and every allegation therein. Moreover, Defendant’s right to assert
25 and assertion of his privilege against self-incrimination shall not be deemed or
26 considered an admission of any allegation therein.
27
28
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1 268. In response to Paragraph 268 of the Complaint, Defendant asserts his

2 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
3 the United States Constitution, Article I Section 15 of the California Constitution,
4 and California Evidence Code section 940. On that basis, Defendant declines to
5 respond to each and every allegation therein. Moreover, Defendant’s right to assert
6 and assertion of his privilege against self-incrimination shall not be deemed or
7 considered an admission of any allegation therein.
8 269. In response to Paragraph 269 of the Complaint, Defendant asserts his
9 privilege against self-incrimination that is guaranteed by the Fifth Amendment of
10 the United States Constitution, Article I Section 15 of the California Constitution,
11 and California Evidence Code section 940. On that basis, Defendant declines to
12 respond to each and every allegation therein. Moreover, Defendant’s right to assert
13 and assertion of his privilege against self-incrimination shall not be deemed or
14 considered an admission of any allegation therein.
15 270. In response to Paragraph 270 of the Complaint, this Paragraph contains
16 legal assertions, which do not require a response. To the extent any response is
17 required, Defendant asserts his privilege against self-incrimination that is
18 guaranteed by the Fifth Amendment of the United States Constitution, Article I
19 Section 15 of the California Constitution, and California Evidence Code section
20 940. On that basis, Defendant declines to respond to each and every allegation
21 therein. Moreover, Defendant’s right to assert and assertion of his privilege against
22 self-incrimination shall not be deemed or considered an admission of any allegation
23 therein.
24 The remainder of the Complaint contains Plaintiff’s request for relief, to
25 which no response is required.
26
27
28
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REQUEST FOR RELIEF

1
WHEREFORE, Defendant prays for judgment against Plaintiff as follows:
2
1. The Plaintiff takes nothing by way of her Complaint;
3
2. That Plaintiff’s Complaint be dismissed with prejudice and judgment
4
entered in favor of Defendant;
5
3. That Defendant be awarded costs of suit incurred in this action;
6
4. That Defendant be awarded Attorneys’ Fees to the extent allowed by
7
law; and
8
5. For such further relief the Court deems fair and just.
9
10 Dated: May 19, 2020 WERKSMAN JACKSON & QUINN LLP

11
By:/s/ Alan J. Jackson /s/ Caleb E. Mason
12 Alan J. Jackson
13 Caleb E. Mason
Attorneys for Defendant
14 NAASÓN JOAQUÍN GARCÍA
15
16
DEMAND FOR JURY TRIAL
17
Defendant demands a jury trial.
18
19 Dated: May 19, 2020 WERKSMAN JACKSON & QUINN LLP
20
21 By:/s/ Alan J. Jackson /s/ Caleb E. Mason
Alan J. Jackson
22 Caleb E. Mason
23 Attorneys for Defendant
NAASÓN JOAQUÍN GARCÍA
24
25
26
27
28
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NAASÓN JOAQUÍN GARCÍA’S ANSWER TO COMPLAINT