/P 8 0 R
California Civil Litigation and Discovery.
/Placement /Block
/Placement /Block
ymu lgv` nm hnmwa`fe` wl`tl`r g pgrtkjuagr pgrgergpl ks tru`", f`ny wkaa b` jmnskf`r`f gfcktt`f gnf tlgt ymu cust gfckt mr, '()*+#), - -#)*# ''/)4*/# F#'#-#- tm `g%l gnf ``r& %g"s` mi g%tkmn, mi tl` %mcpagknt, tlks nsw`rkne F`i`nfgnt ks knimrc`f gnf b`ak``s, gnf mn s"%l, Do not sell or share my personal information, lttp?//www.a`egafmjsprm.n`t/n`wsa`tt`r.ltc. 39 0 obj
Sample Answer to Verified Complaint for California, This sample answer to a verified complaint for California is used when the complaint is verified, or if the complaint is filed by a government entity.
The author is . endcmap
endobj
All parties whose names appear as a defendant must sign the Answer and the Verification. CCP 2030.310-2030.410. endbfrange >>
Get form PLD-C-010. /P 8 0 R
<30> <3B> <0030> endcmap endstream
endobj
763 0 obj
<>stream
Is it legal to run a business in a residential property. B4JgR(8#`6-;K0b] :9n'YNM0M|Y)ZxaEz3n+JT`I^0SM]$R3v&RLHQKI\&KRG
CMapName currentdict /CMap defineresource pop <00> January 1, 2007] www.courtinfo.ca.gov Page 1 of 2 Your Phone # /O /Layout
Hl{LSg\"C9J6PwuBI,,qbkKM)Vfp;`F9g3Afe,^[6dKwxV!v[iF}-+!_4c{uQZ`(My).BXb|&.aXB8GmjZ{,z(GjC}iU]1-DwF/PSSW~*24=Glw1
L%rR=Ek9Ep'e5B3T`R@. <86> <87> <2020> 18 0 obj
3 Frivolous and Bad Faith Claims: Defense Strategies in Employment Litigation A successful motion to dismiss under Rule 12 allows an employer to dispose of a frivolous lawsuit before The matters stated in the foregoing document are true of my own knowledge, except as to those matters which are stated on information and belief, and as to those matters, I believe them to . The sample answer on which this preview is based has been revised and updated in May 2018, is 14 pages and includes brief instructions, over twenty five generic affirmative defenses and a proof of service by mail. OnLaw. ********************************* 3. hMO0ph'*m'&qjAF[jJ q1UD6``r!GM80*O)
P# |3Mv4|UQUw|bF(b#('yF)f5XYzJV`aOct^cQLN{SK+,L:~^wcdT8 2]Yr8
~}E"b14z 9W
Crossclaim pages. 3p5DH)ZkD*\#,rb-J-@dpT]Dr)Hz+WvH(TB#2J9j,e=>Z nV uu"'}f|m7at"!& foXaO)&SmAZrif nw42X"WFUsC:32@3tfsp/|f\cyq3O92I 47t>-m(:2129+\:b+OU4]9)'W5+D%MsgE}*Mi>WJdQC";@){dDdN~(1tmkv&9-o{
-";7JJY&lTG5ZH`l.+yUuwh
oQ"J< _[VBexUNVe}6NU9Bc- iYJldI=x0_. /O /Layout
HK The Defendants Answer to the Complaint - United States Courts /A <<
/Pg 5 0 R
Effective immediately we have updated our refund policy! This Note does not address specific issues regarding answers in . H\j0~ Some claims, however, like a quiet title claim does require that the complaint be verified. /BaseEncoding /WinAnsiEncoding
endobj
endcodespacerange (2) A statement of any new matter constituting a defense. /Type /Font
/P 8 0 R
/A <<
<90> <90> <2022> California Deposition and Discovery Practice. /LastChar 255
Document collections are now available as non-refundable purchase items with new pricing. Effective: January 1, 2007. /Placement /Block
/Widths [ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 340 360 419 0 0 0 0 239 320 320 0 0 340 360 340 0 661 661 661 660 660 660 659 660 660 659 340 340 0 0 0 661 0 720 721 740 780 720 680 780 821 400 640 800 640 940 740 800 660 800 780 660 701 740 720 940 780 699 640 300 0 300 0 0 400 581 600 580 639 580 379 580 680 361 339 660 340 1000 679 620 640 620 459 520 460 661 600 800 601 620 560 319 0 320 0 0 600 ]
It is verified by the plaintiff or their attorney and may come attached with exhibits. end /Placement /Block
<<
This Standard Clause contains integrated notes with important explanations and drafting tips, including when a party must verify a pleading or discovery response and who may sign a verification. 39
endobj 1363 0 obj
<>/Filter/FlateDecode/ID[<8F9674A30833FC4CA32D7919421B9748><959A51EE2E10CE419C6A731736045E27>]/Index[1335 47]/Info 1334 0 R/Length 132/Prev 247024/Root 1336 0 R/Size 1382/Type/XRef/W[1 3 1]>>stream
286 0 obj
<>stream
/FirstChar 0
/Pg 5 0 R
endstream
endobj
startxref
%%EOF
Some of the forms, such as the form for a generic complaint, apply to different types of cases. <80> <80> <20AC> However, if a tenant wants to have a jury trial, the tenant must file a verified answer with a jury demand. /P 8 0 R
>>
Please bear with us as the download emails don't seem to be getting sent out as quickly right now. xZr83-I!6SS%vKdMRl$3_d'*S
tn_.VgI6g_r6/Y+/N#"nE+.NQ` ^$\8&LxZ"` <00> <00> <0000> This can be done without needing to have the document notarized. What is the difference between a law and an agreement? Click the on our main page to search for what you are looking for. 20 0 obj
Cross-Defendant Juanita Eyherabide hereby answers the Cross-Complaint which has been filed as of the date of this answer, specifically those pleadings of Antelope Valley East-Kern Water 1089.5). xU]TGD!aS?x4d;$ fE!yX}Ns&d]:uNw5s /K 21
<>
<<
/P 8 0 R
Quiet Title Complaint Example. /Pg 5 0 R
The sample complaint on which this preview is based . A verified complaint is a complaint that has been verified by the plaintiff or their attorney verifying that the facts stated in the complaint are true. Pre-production / Production / Post-production. SAMPLE Use the samples to help you complete the packet of blank forms. <8D> <8D> <2022> b. Answering paragraph 19, CIPA admits the allegations thereof. (b) This section shall become operative on January 1, 1999, unless a statute that becomes effective on or . /CMapName /Times-BoldOPBaseFont1 def <8C> <8C> <0152> Interpreter Request . ?7p/.>`q8ib,rjROTJ=sQm1btN!GGU]B0NRS>W
4ZK9z>. Set Aside A Fraudulent Transfer. VERIFED ANSWER WITH AFFIRlVlATIVE DEFENSES The Respondents respectfully submit the within Verified Answer on a Pro Se basis to the compiailll dated April 1. 34 0 obj
x+-534R0 BsKk A 15 0 obj
<82> <82> <201A> /K 10
<<
<00A0> /Type /Encoding
>>
by Practical Law Litigation. The download manager is not working as well as usual. The property being levied upon is held until the determination of the plaintiff's claim. Disclaimer: These codes may not be the most recent version. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.
/P 4 0 R
A person verifying a pleading need not swear to the truth or his or her belief in the truth of the matters stated therein but may, instead, assert the truth or his or her belief in the truth of those matters "under penalty of perjury.". >>
This blog post will discuss answering a verified complaint in California. >>
SUPREME COURT Manila. /Differences [ 1 /.null 2 /.null 3 /.null 4 /.null 5 /.null 6 /.null 7 /.null 8 /.null 11 /.null 12 /.null 14 /.null 15 /.null 16 /.null 17 /.null 18 /.null 19 /.null 20 /.null 21 /.null 22 /.null 23 /.null 24 /.null 25 /.null 26 /.null 27 /.null 28 /.null 29 /.null 30 /.null 31 /.null ]
KFC 995 .G674. CCP 2030.310 (a), 2030.410. endobj
CqA0t9 d6sOKC$}Z:0n AAupa'H)f /Placement /Block
/P 8 0 R
Superior Court of California, County of Contra Costa. /A <<
/FirstChar 0
23. G.R. 1 defendants pqrs corporation, tom adams, kenny adams and paul roberts's notice of hearing and demurrer to plaintiff's first amended complaint 36 0 obj
<20> <7E> <0020> >>
/S /P
The term "pleading paper" is often used to describe the format of a document that is filed with the Court when a pre-made form is not available. /CMapType 2 def /CIDInit /ProcSet findresource begin 3. district, public agency, or public corporation, in his or her official capacity, is plaintiff, the answer shall be verified, unless an admission of the truth of the complaint might subject the party to a criminal prosecution, or, unless a county . <<
/K 0
<98> <98> <02DC> x0D@(M0tS@ ]R 7bFiA/>stream
A General Denial is a type of answer filed in response to a complaint. 446. endobj
Business Disputes: Causes, Effects, Solutions. <85> <85> <2026>
/CMapType 2 def D E C I S I O N. LEONARDO-DE CASTRO, J.: For review under Rule 45 of the Rules of Court is the Decision 1 dated November 17, 2005 and the Resolution 2 dated November 16, 2006 of the Court Appeals in CA-G.R. /Encoding <<
California that the foregoing is true and correct. <88> <88> <02C6> 238 0 obj
<>
endobj
<7D> <7D> <007D> /Placement /Block
/Pg 5 0 R
Make 2 Copies of the Answer. /S /P
<99> <99> <2122> submits this Verified Shareholder Derivative Complaint (the "Complaint") against defendants named herein. <<
<8C> <8C> <0152> <90> <90> <2022> /O /Layout
263 0 obj
<>/Filter/FlateDecode/ID[<6F91244A77F804641FBF2D7AB20B59B4><04AA19A82420B74A9122BFAAEEFFA4F1>]/Index[238 49]/Info 237 0 R/Length 109/Prev 567362/Root 239 0 R/Size 287/Type/XRef/W[1 2 1]>>stream
762 0 obj
<>stream
A verified complaint also forces the defendant to respond to the lawsuit with a verified answer. /P 8 0 R
/S /P
/P 8 0 R
California law also states that any answer to a complaint filed by a governmental entity must be verified. California Civil Writ Practice, CEB Practice Guide, 4th Ed., April 2012. . Go to. a. /O /Layout
hRPW5?B&M@2I )V[7F "VHWfiS1EHqhm3RtVy3= v.>0vz);{4_$hx9[)w!~p EhS1q7bZi M&UHV+%FLlX9J
miv\K}a\> S?K:%sbkS*oq^U /Pg 5 0 R
Defendant admits the allegations of paragraph 2. /O /Layout
Appointment Of Rents Receiver. 609 0 obj
<>/Filter/FlateDecode/ID[]/Index[580 92]/Info 579 0 R/Length 132/Prev 344734/Root 581 0 R/Size 672/Type/XRef/W[1 3 1]>>stream
This may, in turn, make the defendant less trustworthy in the eyes of the jury and you can have a stronger hold throughout the case. <8F> <8F> <2022> Forcing a verified complaint when you do not have all the evidence can be very costly without any benefit. Responses to requests for production are due within thirty (30) days (five (5) days in unlawful detainer actions) if the requests were personally served, thirty-five (35) days if the requests were served by mail, and thirty (30) days plus two (2) court days if the requests were served by express mail or facsimile or electronically. To the extent the allegations in paragraph 1 of Hugh's Verified Complaint constitute legal argument or legal conclusions, no answer is required. <88> <88> <02C6> /K 1
The sample requests that the entire answer be stricken as it is not verified, or in the alternative that all of the affirmative defenses contained in the answer should be stricken as they contain only immaterial allegations. /CIDSystemInfo CV No. endstream
endobj
243 0 obj
<>stream
Complete Answer Form (front and back), including title of case and case number. /S /P
<<
In many jurisdictions, a complaint does not need to be verified unless a rule or statute . n.n/b{qHe`'g0Mgl,59[~s{x7cqXd 2 Hy{KR/v d+%ZDPZH/rT'o4$`=27}D~
Fk}H
<=m@FF/_:o6;f2^2)>vWtkG 0
Broker for Fraud. 5 0 obj
>>
I want to stress that failure to file a verified answer when one is required will subject the answer to a motion to strike on the grounds that it is not verified. /A <<
Fill out my Wufoo form!Fill out my Wufoo form! >>
But the other grounds for challenging the sufficiency of the answer must be raised by demurrer, or are automatically waived. /K 2
Answering an unverified complaint in California is the topic of this blog post. STATE OF CALIFORNIA, COUNTY OF ORANGE I have read the foregoing_____ _____and know its contents. <00> <00> <0000> QQ*OXB;JT* r%*EX Consider using a verified complaint to your advantage if you have evidence of all your claims. The author is is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. How to prepare to pitch to a bank for a commercial loan? Note that this rule only applies to unlimited civil cases, where the demand of the complaint exceeds $25,000.00. /Pg 5 0 R
%%EOF
CSL denies the allegations in Complaint paragraph 22. 4. The second ground clearly authorizes striking an unverified answer to a verified complaint.
If you need an interpreter, please complete the form below and submit it to any Filing Window or courtroom. /BaseFont /Times-Bold
Western University admits that Hugh was employed in the County of Los Angeles, State of California within this judicial <<
/O /Layout
<89> <89> <2030> March 5, 2021 | Structure Law Group, LLP. ^;y]*ZLFQU2Eil+SWS|.lOi%e @W,~6v.UHtehG
>>
VERIFICATION FORM No. >>
Hj`L E
The Sample Answer, which is one form of Respose, to a ADA Lawsuit, Busienss, or Real Estate Lawsuit filed in a California Superior Court, or in the case of an ADA lawsuit, filed in part in Federal District Court for ADA claims. 2 Verification of Pleading (Code Civ. <7F> <7F> <2022> That means that the complaint itself will be limited as you can only include the facts that you know at that time and not the facts that you still need to prove are true. When filing a lawsuit in California, the original complaint may be either verified or unverified. >>
Except when otherwise specifically required by law or rule, pleadings need not be under oath, verified or accompanied by affidavit. <<
What is a verified answer California? /Pg 5 0 R
California. Description General Denial Form California. stream >>
/Placement /Block
endobj
>>
>>
A California Court of Appeal ruled in the case of FPI Development, Inc vs. A1 Nakashima, (1991) 231 Cal.App.3d 367, 384 that the affirmative defenses alleged in an answer to a complaint must be pled in the same fashion, and with the same specificity, as a cause of action in a complaint. /A <<
A positive side of using a verified complaint is that the defendant has to submit a verification of the answers. endobj
/O /Layout
<9E> <9E> <017E> 22. 1335 0 obj
<>
endobj
Plaintiff's information and belief is based upon, among other things . /S /P
endstream
endobj
765 0 obj
<>stream
/CIDInit /ProcSet findresource begin /Ordering (UCS) endstream
/K 11
There are some cons to consider when using a verified complaint. Disputes concerning General Denials arise based on whether the plaintiff filed a verified or unverified complaint. The real estate attorneys at Talkov Law are well versed in a variety of real estate issues, including quiet title actions. Search Instructions. <84> <84> <201E> begincmap Defendant generally denies each statement of the complaint. (1) The general or specific denial of the material allegations of the complaint controverted by the defendant. CA Corp and Individual combined answer. /S /P
<0D> <0D> <000D> /CMapType 2 def endstream
endobj
766 0 obj
<>stream
<>
Note that the author is NOT an attorney and no guarantee or warranty is provided. /Placement /Block
September 1, 2019] ANSWERUNLAWFUL DETAINER Page 2 of 2 UD-105 (Each defendant for whom this answer is filed must be named in item 1 and must sign this answer unless his or her attorney signs.) 12 dict begin endobj
<< /Length 6 0 R
/Filter /FlateDecode
>>
stream
endcmap endobj
19. /FirstChar 0
Mostly, an answer includes the defendant's counterclaims (allegations or claims . endobj
/K 17
150 0 obj<>
endobj
152 0 obj<>/Font<>>>/Contents 153 0 R/CropBox[0 0 612 792]/Parent 146 0 R>>
endobj
153 0 obj<>stream
>>
/O /Layout
>>
/Pg 5 0 R
@Du:AMD0nr}tDu=Z9 Ir-%DxQm*[y\zRcWW4|u3^ z4j
Free Preview Pld C 010 Form. endobj
Please check official sources. SUPERIOR COURT OF CALIFORNIA, COUNTY OF. /S /P
/P 8 0 R
/P 8 0 R
B. /O /Layout
w-HT`J ' b4$u; 7.s^uu}[\S;PY~
MopUkfxHrIj]0\t{^ecYp&qV!%#d_L.KanR~5W/xg
/Encoding <<
[8O338E D%pP]^\9l?v,BwoIhl kdq}PWze\2@ssriMr)b`QnO?19{/`pz4uC/lEZ".w"^zFUu Y(/}I2Z{Zk_W6_cBWXf;;"@R+7,En6Gatg0!/C^Z+6{|;/vQ4Hv#=50-q7 /6?]>F||;j>cL:ZDk9};}6q.Ng6RDs[19_f%I'*[1c^(hDba6p6RO over . 40 0 obj
If you are filing an answer to the complaint then you can use form PLD-050 to answer the credit card lawsuit if it is an unverified complaint or it is a verified complaint and the amount that you are being sued for is less than $25,000 from the credit card company. >>
5. >>
Wrongful death/product liability. >>
In law, an answer refers to a defendant's first formal written statement to a plaintiff's initial petition or complaint.This opening written statement will admit or deny the allegations, or demand more information about the claims of wrongdoing. This sample motion to strike an answer to a complaint for California is made pursuant to Sections 435-437 of the Code of Civil Procedure. seq require specific statements in your response. endobj
Read your Answer, making sure all blanks are filled in, and to confirm that all of the statements are true. /Placement /Block
If the plaintiff makes statements to their attorney under oath before a full investigation has been performed, the plaintiff may also end up being guilty of perjury.
/A <<
/Pg 5 0 R
endobj
>>
8 0 obj
Representing Yourself (Pro Se)? Sample Answer to Verified Complaint for California by Stan Burman on Scribd, To view more information on over 300 sample legal documents for California and Federal litigation visit:https://legaldocspro.myshopify.com/products. <00A0>
9-10-111. /Length1 48416
Ameriquest Mortgage Company, et al., brought in the United States District Court for the Central District of California. /ToUnicode 39 0 R
3 0 obj
The sample answer on which this preview is based has been revised and updated in May 2018, is 16 pages and includes brief instructions, over twenty five generic affirmative defenses, a verification, and a proof of service by mail. All forms provided by US Legal Forms, the nations leading legal forms publisher. Sec. It also briefly covers points to consider when amending or responding to an answer. <8F> <8F> <2022> >>
B. /K 18
endbfrange When filing a lawsuit in California, the original complaint may be either verified or unverified. /Supplement 0 /P 37 0 R
<0D> <0D> <000D> >>
Nk|MRiK-M)y[d+Od+Od+Od+OT+OT- 0KEtAqEBu6EAuTHv6:8hAq,"tMS5jt#q^{=8}Vijjt=qMm*CDmF5;j!CLVp[iR)g8ZCl.U .fFP#jtY:4aFB*N.bG'{ /S /P
A verified complaint is a verification of the facts that have been stated in a complaint as truth. 1 begincodespacerange /A <<
(('vJhno|S%kB)#YHB@dJoegWF\pd4Wz;\nV5Z9ef _2'H
0
<8E> <8E> <017D> /S /P
You can receive 10 free gifts just for subscribing. <<
35 0 obj
/O /Layout
The verification also needs to be signed by the defendant or their attorneys stating they have read the answers and that everything is correct to the best of their knowledge. >>
General Denial: A General Denial is a non-specific form which denies the claims of the Plaintiff, in general. Verified Complaint. They are currently arriving within 30 minutes of purchase. /Subtype /TrueType
/Supplement 0 29 0 obj
87pq>F'l~xsD+^$jEbC&B?o{1@c4m~JARgiyt7YeeUP~6Z oWCpnI?y14bcM tJ4VGG=lJ ********************************* 1. XVV7Jg:GZ;84? The effect of a General Denial is to, "put in issue the material allegations of the complaint." (FPI Development, Inc. v. Nakashima (1991) 231 Cal.App.3d 367, 383.) /Placement /Block
Plaintiff has known Smith since approximately 1996. /A <<
Be careful to use the form that fits your case and the type of pleading you want to file. >>
/P 4 0 R
>>
/K 8
%PDF-1.5
%
/Differences [ 1 /.null 2 /.null 3 /.null 4 /.null 5 /.null 6 /.null 7 /.null 8 /.null 11 /.null 12 /.null 14 /.null 15 /.null 16 /.null 17 /.null 18 /.null 19 /.null 20 /.null 21 /.null 22 /.null 23 /.null 24 /.null 25 /.null 26 /.null 27 /.null 28 /.null 29 /.null 30 /.null 31 /.null ]
/S /P
/CMapName /BookmanOldStyle-BoldOPExtFont0 def 30 0 obj
Defendant is without sufficient information to admit or deny the allegations contained in Paragraphs [] of the Complaint and, therefore, deny . What laws can be overridden by contracts? In California, if you are answering the verified complaint, every single paragraph must be answered with denial or . <002D> /K 15
(CCP 431.30(b)(1)). But you'll be able to use the amended one. << Start a house sample answer verified partition results in the If the lawsuit involves a verified complaint from a third party collecting on . /A <<
1 0 obj
855-598-3258. /Pg 5 0 R
%PDF-1.6
%
/CIDInit /ProcSet findresource begin /S /P
9701 Wilshire Boulevard #1000 Beverly Hills,CA90212 Phone: (855) 598-3258 Secondary phone: (310) 651-3065 Email: DoronEghbali@lawadvocategroup.com, Law Advocate Group, LLP., Attorneys in Beverly Hills & Los Angeles |. View PLD-C-010 AnswerContract form. This is easy enough to accomplish through a simple verification. /Ordering (UCS) /Differences [ 0 /.null 1 /.null 2 /.null 3 /.null 4 /.null 5 /.null 6 /.null 7 /.null 8 /.null 9 /.null 10 /.null 11 /.null 12 /.null 13 /.null 14 /.null 15 /.null 16 /.null 17 /.null 18 /.null 19 /.null 20 /.null 21 /.null 22 /.null 23 /.null 24 /.null 25 /.null 26 /.null 27 /.null 28 /.null 29 /.null 30 /.null 31 /.null 35 /.null 36 /.null 37 /.null 38 /.null 42 /.null 43 /.null 47 /.null 60 /.null 61 /.null 62 /.null 64 /.null 92 /.null 94 /.null 95 /.null 124 /.null 126 /.null 127 /.null 128 /section ]
Related forms. /Registry (Times-RomanOPBaseFont0) 43. (He was at my wedding, I married his cousin) /P 8 0 R
I. Respondent denies the allegations as sel fanh within paragraph "1" of the Complaint.
Defendant denies the allegations of paragraph 1. These rules only apply in unlimited civil cases in which the demand of the complaint exceeds $25,000.00. /CMapName /Times-RomanOPBaseFont0 def >>
32 0 obj
Usually, at the time of filing the complaint, not all of the facts about the legal claim has been discovered. <<
Then, count the number of pages in your final Answer.
ccp 446 ccp verification discovery when is a verified complaint required verification ccp 446 and 2015.5 los angeles verified complaint california sample attorney verification california verification of an answer to a complaint is mandatory. /Pg 5 0 R
All forms provided by US Legal Forms, the nations leading legal forms publisher. <<
21 0 obj
/K 14
endobj
Divide the consent sample answer verified partition california states that email address is also states that your business and is a plaintiff. sufficient to enable it to answer, and basing its denial on that ground, denies the allegations of paragraph 18. eN&:X*ZdD%F 3*2et$)op7WW!2Wl,U@j9!6\!s$z%?Q8TDP+=:1gH BkC^~Im`g"K{RFg
:fSHv?F:\e#A{K?Tqe/W.KByPp8"],omFP1r(p++5y*h?|h{J{ydB-UP06/iB:)y
6JrOIQt(#Utb_V]!z5ke uNCM_SJ0*@}x* }:]>^tY^8M|~x}-yr;I5]^%0] EokY=LPTQgI the allegations in Complaint paragraph 21. 0
/Pg 5 0 R
How are disputes settled between partners in business? << !vAjf_g\Ljgj]{&*aaYmE7J8trk3Ua'CVblt8"v)xnP'E:c4r2!8H]Roha: +$'l$0YBjupf Defendant's request for sanctions in the amount of $500 against Plaintiff and his counsel is GRANTED.