Free Answer to Complaint - District Court of California - California

Case 3:07-cv-02404-BTM-CAB

Document 3

Filed 02/12/2008

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Stuart B. Wolfe, Esq. (SBN 156471) s bwolfe(Qwolfewyman.com
David 1\ Chute, Esq. (SBN 136564)

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WOLFE'& WYMAN LLP
5 Park Plaza, Suite 1100

dm ch ute(Qwolfe",yman.com

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Irvine, California 92614-5979
Telephone: (949) 475-9200 Facsimile: (949) 475-9203

Attorneys for Defendant GMAC MORTGAGE, LLC in its own capacity and dba DITECH, 7 erroneously sued and served as GMAC MORTGAGE CORPORATION dba DITECH.COM
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UNITED STATES DISTRICT COURT

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SOUTHERN DISTRICT OF CALIFORNIA

HARU LINDSEY, an individual,
Plaintiff,
v.

Case No. 07 CV 2404 BTM CAB

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GMAC MORTGAGE CORPORATION, dba DITECH.COM, an entity of unknown form; and DOES 1-10, inclusive,
Defendants.

DEFENDANT GMAC MORTGAGE, LLC's ANSWER TO PLAINTIFF'S COMPLAINT

19

Defendant GMAC MORTGAGE, LLC (hereinafter "GMACM" or
"ANSWERIG DEFENDANT") severing itself

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from all others and answers the

allegations of

the Complaint ofPlaintiffHARU LINSEY as follows:

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1. ANSWERING DEFENDANT admits that the Complaint purports to be

a lawsuit under the Truth in Lending Act ("TILA") wherein Plaintiff seeks to rescind

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and recover damages. As to the remaining the allegations of Paragraph 1,

25 ANSWERING DEFENDANT denies.
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2.

ANSWERING DEFENDANT lacks information and belief sufficient to

27 answer the allegations in Paragraph 2 and basing its denial on this ground, denies

28 each and every allegation thereof.
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3. ANSWERIG DEFENDANT lacks information and belief

sufficient to

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answer the allegations in Paragraph 3 and basing its denial on this ground, denies
each and every allegation thereof.

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4. ANSWERING DEFENDANT admits that it is a LLC. As to the
remaining allegations of

Paragraph 4, ANSWERING DEFENDANT denies.
sufficient to

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5. ANSWERIG DEFENDANT lacks information and belief

answer the allegations in Paragraph 5 and on that basis denies each and every
allegation of the Paragraph 5.
6. ANSWERING DEFENDANT lacks information and belief

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sufficient to

answer the allegations in Paragraph 6 and on that basis denies each and every
allegation of

Paragraph 6.

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7. In response to the allegations in Paragraph 7 of the Complaint,

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ANSWERIG DEFENDANT incorporates herein by reference the answers to the
allegations made in Paragraphs 1 through 6.
8. ANSWERING DEFENDANT admits that Plaintiff

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refinanced with

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ANSWERIG DEFENDANT regarding the property located at 6031 Paseo
Alameda, Carlsbad, California 92009 with a $95,000.00 equity line of credit and that
a deed of

trust secured the equity line. Except as admitted, ANSWERIG

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DEFENDANT denies the remaining allegations of Paragraph 8.
9. ANSWERIG DEFENDANT denies the allegations of

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Paragraph 9.

10. ANSWERIG DEFENDANT denies the allegations of

Paragraph 10.

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11. ANSWERING DEFENDANT lacks information and belief sufficient to

answer the allegations of Paragraph 11 and on that basis denies each and every

24 allegation in Paragraph 11.
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12. ANSWERING DEFENDANT denies the allegations of

Paragraph 12. Paragraph 13.

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13. ANSWERING DEFENDANT denies the allegations of

14. In response to the allegations in Paragraph 14 of

the Complaint,

ANSWERIG DEFENDANT incorporates herein by reference the answers to the
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allegations made in Paragraphs 1 through 13.
15. ANSWERIG DEFENDANT denies the allegations of

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3

Paragraph 15. Paragraph 16. Paragraph 17. Paragraph 18.

16. ANSWERING DEFENDANT denies the allegations of

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17. ANSWERIG DEFENDANT denies the allegations of

18. ANSWERIG DEFENDANT denies the allegations of

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19. ANSWERIG DEFENDANT lacks sufficient information and belief

to

answer the allegations of Paragraph 19 and on that basis denies the allegations of
Paragraph 19.
20. ANSWERING DEFENDANT lacks sufficient information and belief

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to

answer the allegations of Paragraph 20 and on that basis denies the allegations of
Paragraph 20.
21. ANSWERING DEFENDANT denies the allegations of

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Paragraph 21.
Paragraph 22.

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22. ANSWERIG DEFENDANT denies the allegations of

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23. ANSWERING DEFENDANT denies the allegations of

Paragraph 23.
Paragraph 24. Paragraph 25.

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24. ANSWERIG DEFENDANT denies the allegations of

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25. ANSWERING DEFENDANT denies the allegations of

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26. ANSWERIG DEFENDANT lacks sufficient information and belief

to

answer the allegations of Paragraph 26 and on that basis denies the allegations of
Paragraph 26.
27. ANSWERING DEFENDANT denies the allegations of

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Paragraph 27. Paragraph 28. Paragraph 29.

28. ANSWERIG DEFENDANT denies the allegations of

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29. ANSWERIG DEFENDANT denies the allegations of

30. In response to the allegations in Paragraph 30 of

the Complaint,

24 ANSWERIG DEFENDANT incorporates herein by reference the answers to the
25
allegations made in Paragraphs 1 through 29.
31. ANSWERIG DEFENDANT denies the allegations of

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Paragraph 31. Paragraph 32.

32. ANSWERING DEFENDANT denies the allegations of

33. In response to the allegations in Paragraph 33 of

the Complaint,
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ANSWERING DEFENDANT incorporates herein by reference the answers to the
allegations made in Paragraphs 1 through 32.

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34. ANSWERING DEFENDANT admits it claims an interest in the subject
property by virtue of the trust deed. As to the remaining allegations of Paragraph 34,
ANSWERING DEFENDANT lacks sufficient information and belief and on that
basis denies the remaining allegations of

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Paragraph 34.

35. ANSWERIG DEFENDANT lacks sufficient information and belief

to

answer to the allegations of

Paragraph 35 and on that basis denies the allegations of

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Paragraph 35.
36. In response to the allegations in Paragraph 36 of

the Complaint,

ANSWERING DEFENDANT incorporates herein by reference the answers to the
allegations made in Paragraphs 1 through 32.
37. ANSWERING DEFENDANT denies the allegations of

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Paragraph 37.

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38. ANSWERIG DEFENDANT lacks sufficient information and belief

to

answer to the allegations of

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Paragraph 38 and on that basis denies the allegations of

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Paragraph 38.
Answering Paragraphs 1 through 22 of

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the prayer, ANSWERING

DEFENDANT denies that Plaintiff is entitled to any of the relief requested.

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AFFIRMATIVE DEFENSES

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FIRST AFFIRMATIVE DEFENSE
(Failure to State a Claim or Cause of Action)

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1. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges, that each of the purported causes of action fail to state a claim or cause of
action against ANSWERING DEFENDANT.

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SECOND AFFIRMATIVE DEFENSE

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(Statute of Limitations)

2. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges, that each and every purported cause of action contained in the Complaint is
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1 barred by the applicable statute of limitations including, but not limited to, California
2 Code of

Civil Procedure §§ 337, 338, 339, 340, 343; California Civil Code §

3 1788.30; and Truth in Lending Act § 130. This defense is alleged in the alternative
4 and does not admit any of the allegations contained in the Complaint.

5 THIRD AFFIRMATIVE DEFENSE

6 (Laches)

7 3. ANSWERING DEFENDANT is informed and believes, and thereon
8 alleges, that PLAINTIFF unjustifiably delayed in commencing this action, and that
9 said delay has prejudiced the rights of ANSWERIG DEFENDANT and therefore,

10 the Complaint should be barred under the Doctrine of Laches. This defense is alleged
i i in the alternative and does not admit any of the allegations contained in the

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13 FOURTH AFFIRMATIVE DEFENSE
14 (Estoppel/EQuitable Estoppel/Judicial Estoppel)
15 4. ANSWERIG DEFENDANT is informed and believes, and thereon
16 alleges, that PLAINTIFF is estopped and/or should be equitably and/or judicially
i 7 estopped, from obtaining the relief

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sought from ANSWERING DEFENDANT. This

18 defense is alleged in the alternative and does not admit any of the allegations

19 contained in the Complaint.

20 FIFTH AFFIRMATIVE DEFENSE
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(Unclean Hands)

22 5. ANSWERIG DEFENDANT is informed and believes, and thereon
23 alleges, that the Complaint should be barred due to PLAINTIFF's unclean hands.

24 This defense is alleged in the alternative and does not admit any of the allegations
25 contained in the Complaint.
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27 III 28 III
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SIXTH AFFIRMATIVE DEFENSE

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(Damages Claimed Attributable to Unknown Parties) 6. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges, that if ANSWERING DEFENDANT is subjected to any liability to

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PLAINTIFF herein, it wil be due in whole and/or in part to the conduct, acts,

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omissions andlor activities of a party and/or parties unkown to ANSWERIG
DEFENDANT at this time, and any recovery obtained by PLAINTIFF should be

barred andlor reduced according to law, up to and including the whole thereof. This
defense is alleged in the alternative and does not admit any of the allegations
contained in the Complaint.

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SEVENTH AFFIRMATIVE DEFENSE
(Preem ption)
7. ANSWERING DEFENDANT is informed and believes, and thereon
alleges, that federal

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law preempts Plaintiff s state law claims. This defense is alleged

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in the alternative and does not admit any of the allegations contained in the
Complaint.

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EIGTHTH AFFIRMATIVE DEFENSE
(Lack of Proximate Cause)
8. ANSWERING DEFENDANT is informed and believes, and thereon

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alleges, that any alleged conduct or omission by ANSWERING DEFENDANT was not the cause in fact, or proximate cause, of any injuries or damages alleged by

22 PLAINTIFF. This defense is alleged in the alternative and does not admit any of the
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allegations contained in the Complaint.

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NINTH AFFIRMATIVE DEFENSE
(No Liabilty for Third Party Acts)

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9. ANSWERING DEFENDANT is informed and believes, and thereon
alleges, that ANSWERIG DEFENDANT is not liable for independent acts of

third
third parties.

parties and PLAINTIFF's damages, if any, is attributable to acts of

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This defense is alleged in the alternative and does not admit any of the allegations
contained in the Complaint.

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TENTH AFFIRMATIVE DEFENSE
(Waiver)
10. ANSWERING DEFENDANT is informed and believes, and thereon
alleges, that PLAINTIFF voluntarily and knowingly failed to take action to protect

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her rights and thus have waived such rights. This defense is alleged in the alternative
and does not admit any of the allegations contained in the Complaint.

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ELEVENTH AFFIRMATIVE DEFENSE
(Failure to Mitigate Damages)

11. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges, that any recovery by PLAINTIFF is barred by PLAINTIFF's failure to

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mitigate damages, or that any recovery must be reduced by those damages that

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PLAINTIFF failed to so mitigate. This defense is alleged in the alternative and does
not admit any of the allegations contained in the Complaint.

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TWELFTH AFFIRMATIVE DEFENSE
(Lack of Standing)
12. ANSWERING DEFENDANT is informed and believes, and thereon
alleges, that PLAINTIFF lacks standing to maintain the claims in the Complaint.

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This defense is alleged in the alternative and does not admit any of the allegations
contained in the Complaint.

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THIRTEENTH AFFIRMATIVE DEFENSE

(Failure to Name Indispensable Parties)
13. ANSWERING DEFENDANT is informed and believes, and thereon
alleges, that PLAINTIFF failed to join all indispensable parties as defendants to the

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Complaint. This defense is alleged in the alternative and does not admit any of the
allegations contained in the Complaint.
III
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FOURTEENTH AFFIRMATIVE DEFENSE

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(Uncertain, Ambiguous, and Unintellgible Complaint)
14. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges, that the Complaint is uncertain, ambiguous and unintelligible. This defense
is alleged in the alternative and does not admit any of the allegations contained in the
Complaint.

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FIFTEENTH AFFIRMATIVE DEFENSE
(Consent)

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15. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges, that PLAINTIFF gave her consent, express or implied, to the acts, omissions

and conduct alleged of ANSWERIG DEFENDANT in the Complaint. This
defense is alleged in the alternative and does not admit any of the allegations
contained in the Complaint.

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SIXTEENTH AFFIRATIVE DEFENSE
(Ratification)
16. ANSWERING DEFENDANT is informed and believes, and thereon
alleges, that PLAINTIFF ratified the alleged acts of ANSWERIG DEFENDANT.
This defense is alleged in the alternative and does not admit any of the allegations
contained in the Complaint.

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SEVENTEETH AFFIRMATIVE DEFENSE

(Truth in Lending)
17. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges, that PLAINTIFF failed to plead sufficient facts to recover under the Truth in

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Lending Act. This defense is alleged in the alternative and does not admit any of the
allegations contained in the Complaint.

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III

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EIGTHEENTH AFFIRMATIVE DEFENSE
(Damages Set-Off)

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18. ANSWERING DEFENDANT is informed and believes, and thereon
alleges, that PLAINTIFF's damages, if any, is set-offby any value and/or benefit
PLAINTIFF obtained due to her own conduct andlor contributory negligence, and
any recovery obtained by PLAINTIFF should be barred and/or reduced according to

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law, up to and including the whole thereof. This defense is alleged in the alternative
and does not admit any of the allegations contained in the Complaint.

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NINETEENTH AFFIRMATIVE DEFENSE
(Quiet Title Estopped/EQuitably Estopped)
19. ANSWERING DEFENDANT is informed and believes, and thereon
alleges that PLAINTIFF, by virte of

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her own acts and/or the acts or omissions of

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others chargeable to her, are estopped and/or should be equitably estopped from

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obtaining quiet title. This defense is alleged in the alternative and does not admit
any of the allegations contained in the Complaint.

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TWENTIETH AFFIRMATIVE DEFENSE
(Waiver of

Equitable Remedies)
is barred because PLAINTIFF,

20. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges that PLAINTIFF's claim for equitable relief

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by virte of

her own acts and/or the acts and omissions of others chargeable to her,

expressly, impliedly andlor equitably waived her rights to equitable remedies. This
defense is alleged in the alternative, and does not admit any of the allegations
contained in the Complaint.

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TWENTY-FIRST AFFIRMATIVE DEFENSE

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(Subject Matter Jurisdiction) 21. ANSWERING DEFENDANT is informed and believes, and thereon
alleges that each and every purported cause of action contained in the Complaint is

barred by the lack of subject matter jurisdiction. This defense is alleged in the
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alternative and does not admit any of

the allegations contained in the Complaint.

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TWENTY-SECOND AFFIRMATIVE DEFENSE
(Bona Fide Error)

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5

22. ANSWERING DEFENDANT is informed and believes, and thereon
alleges that any error was not intentional and resulted from a bona fide error. This
defense is alleged in the alternative and does not admit any of the allegations
contained in the Complaint.

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TWENTY-THIRD AFFIRMATIVE DEFENSE
(Good Faith)
23. ANSWERING DEFENDANT is informed and believes, and thereon
alleges that it acted in good faith. This defense is alleged in the alternative and does
not admit any of the allegations contained in the Complaint.

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TWENTY-FOURTH AFFIRMATIVE DEFENSE
(Right to Add Additional Affirmative Defenses)

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24. ANSWERIG DEFENDANT is informed and believes, and thereon
alleges that because the Complaint herein is couched in conclusory terms,

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ANSWERING DEFENDANT presently has insufficient knowledge or information
on which to form a belief as to whether it may have additional, as yet unstated, affirmative defenses available and cannot fully anticipate all affirmative defenses

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20 that may be applicable to the within action. Accordingly, the right to assert
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additional affirmative defenses, if and to the extent that such affirmative defenses are

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applicable, is hereby reserved. This defense is alleged in the alternative and does not
admit any of the allegations contained in the Complaint.

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III
III
III

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III
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1 WHEREFORE, ANSWERING DEFENDANT prays as follows:
2 1. That Plaintiff takes nothing by the Complaint herein;

3

2. 3.

For costs of suit incurred he . , 'ncluding reasonable attorney's fees;

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F or such other and further elief as ~e Court d~'ems just and proper

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DATED: February 7, 2008

OL ~ A~LLP

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STU . ODfE
V . M. CHUTE

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Attorn~ys for Defendant

GMAC MORTGAGE, LLC in its own capacity and dba DITECH, erroneously sued and served as GMAC MORTGAGE CORPORATION dba DITECH.COM

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PROOF OF SERVICE

2
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STATE OF CALIFORNIA
COUNTY OF ORANGE

"

) ) )

SS.

4 i am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action. My business address is 5 Park Plaza, Suite 1100, Irvine, California 92614-5979.
5

On February 12, 2008, I served the document(s) described as DEFENDANT GMAC MORTGAGE, LLC's ANSWER

6 TO PLAINTIFF'S COMPLAINT on all interested parties in said action by placing a true copy thereof in a sealed
envelope addressed as stated on the ATTACHED SERVICE LIST.

7
(E BY MAIL: as follows:

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(E FEDERAL - I deposited such envelope in the U.S. Mail at Irvine, California, with postage thereon
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fully prepaid.

D

BY EXPRESS MAIL as follows: I caused such envelope to be deposited in the U.S. Mail at Irvine, California. The envelope was mailed with Express Mail postage thereon fully prepaid.

D

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BY CERTIFIED MAIL as follows: I am "readily familiar" with Wolfe & Wyman LLP's practice for the collection and processing of correspondence for mailing with the United States Postal Service; such envelope will be deposited with the United States Postal Service on the above date in the ordinary course of business at
the business address shown above; and such envelope was placed for collection and mailing, by Certified United

States Mail, Return Receipt Requested, on the above date according to Wolfe & Wyman LLP's ordinary

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business practice.

D

BY PERSONAL SERVICE as follows: I caused a copy of such document(s) to be delivered by hand to the the addressee between the hours of9:00 A.M. and 5:00 P.M. offices of

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D

BY OVERNIGHT COURIER SERVICE as follows: I caused such envelope to be delivered by overnight
courier service to the offces of the addressee. The envelope was deposited in or with a facility regularly maintained by the overnight courier service with delivery fees paid or provided for.

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D

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BY FACSIMILE as follows: I caused such documents to be transmitted to the telephone number of the addressee listed on the attached service list, by use of facsimile machine telephone number. The facsimile
machine used complied with California Rules of Court, Rule 2004 and no error was reported by the machine.
Pursuant to California Rules of Court, Rule 2006(d), a transmission record of

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the transmission was printed.

D

STATE and correct.

I declare under penalty of perjury under the laws of the State of California that the above is true

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(E
FEDERAL I declare that I am employed in the offices of a member of

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direction the service was made.
Executed on February 12,2008, at Irvine, California.

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~..... "
--H--HA - IER -"

'~

the State Bar of this Court at whose

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2
.)

SERVICE LIST USDC - SOUTHERN DISTRICT - Case No. 07 CV 2404 BTM CAB HARU LINDSEY v. GMAC MORTGAGE, et aI.
W & W File No. 1353-066

"

(Revised: (Date))

4
5

Deborah L. Raymond, Esq. Attorneys for PlaintiffHARU LINDSEY
LA W OFFICES OF DEBORAH L. RAYMOND
480 Stevens Avenue, Suite 205

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Solana Beach, CA 92075 (858) 471-9559

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doc H:\Matters\GMAC Mortgage Corporation (1353)\066 (Lindsey)\PROOF OF SERVICE.