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Answering an unverified complaint in California

by Stan Burman

Answering an unverified complaint in California.

Answering an unverified complaint in California is the topic of this blog post. 

Answering an unverified complaint should be done within 30 calendar days from the date that you were served unless the plaintiff or their attorney has granted you an extension of time.

Most civil complaints in California are not verified unless a particular statute or code provides otherwise, although any plaintiff may choose to verify their complaint if they want.

Although I will be referring to an answer to an unverified complaint the same principles discussed here also apply to cross-complaints.

However I have to stress that any answer to a complaint or cross-complaint filed by a governmental entity must be verified regardless of whether the complaint or cross-complaint is verified. See Code of Civil Procedure § 446.

If a complaint is not verified you can answer with a general denial pursuant to Code of Civil Procedure § 431.30(b) and generally deny all of the allegations of the complaint. However you should also be sure to include specific affirmative defenses that are tailored to the individual case. This is due to the fact that an answer that contains nothing but "boilerplate" affirmative defenses is vulnerable to a demurrer on the grounds that the answer fails to state facts sufficient to state any defenses to the complaint.

In the case of FPI Development, Inc vs. A1 Nakashima, (1991) 231 Cal.App.3d 367, 384, a California Court of Appeal held that the affirmative defenses pled 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. Because conclusory allegations are not admitted by demurrer, and because conclusory allegations have no pleading value, conclusory and "boilerplate" affirmative defenses are insufficient.

I want to stress again that if you include only “boilerplate” affirmative defenses you run the risk of the plaintiff filing a demurrer to your answer.

Sample answer to an unverified complaint in California for sale.

Attorneys or parties in California who wish to view a portion of a sample answer to an unverified complaint for sale by the author can see below.

Sample Answer to Unverified Complaint for California by Stan Burman on Scribd

 

Over 300 sample legal documents for California and Federal litigation for sale.

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The author of this blog post, Stan Burman, 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.

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DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. 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.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

 

 

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