I

LAWRENCE M. ADELMAN, ESQ. SBN 59058

LAW OFFICES OF LA WRENCE M. ADELMAN
2 5850 Canoga Avenue, Suite, 400

sup~JtIIK~~
Woodland Hills, CA 91367-6554
3 Phone: 818-992-8005
Fax: 818-710-3844
4
Attorney for Defendant Russell Bloom, etc. MAY 282010
5
John A. ~ :I~.nEx0S<4JI1'8 OffIcer/Cieri<
6 ~ (lhl~l~ ~~~
AMBEM UlFLEUR-C UlVTON
7
8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

9 LOS ANGELES CENTRAL DISTRICT

10

II CIRGADYNE INCORPORATED, dba Liquor) CASE NO. BC436121

License Specialists, )
12 ) ANSWER TO COMPLAINT BY
) DEFENDANT RUSSELL BLOOM, AN
13 Plaintiff, ) INDIVIDUAL, DBA CA LIQUOR LICENSE

~
SPECIALISTS, NATIONWIDE LIQUOR
14 vs. LICENSE SPECIALITS AND ABC LICENSE

~
SPECIALISTS
15 RUSSELL BLOOM, an individual, dba CA
) Assigned to the Honorable Yvette M.
16 Liquor License Specialists and Nationwide Palazuelos, Department 28

17

18
Liquor License Specialists and ABC License
Specialists and DOES 1-10,

Defendants.
l
)

19 1 - - - - - - - - - - - - - - - - ~
20 COMES NOW, defendant RUSSELL B L j ' an individual, doing business as CA
21
Liquor License Specialists, Nationwide Liquor License Specialists and ABC License Specialist
22
("Defendant") who for himself and for no other defendants hereby answers and otherwise
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responds to the unverified complaint (the "Complaint") of plaintiff CI~~~

24
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25 INCORPORATED, doing business as Liquor License Specialists ("Plaintifr'~ ~ ffll~ws:1:: .... F;

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GENERAL DENIAL C)
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. J I. Pursuant to the provisions of Code of Civil Procedure 431.30(d) I;tefllndan
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1

ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.


hereby denies, each and every allegation of the Complaint to the full extent any allegation(s

2 thereof, conjunctively and/or disjunctively, singularly and/or in the plural, allege(s) any act, failur
3
to act, conduct, law violation, claim, cause of action, damage, remedy, fact, event, happening
4
occurrence, transaction, writing, document, representation, misrepresentation, presentation
5

6 statement, advertisement, deceit, fraud, defamation, oppression, malice, omission, and/or an

7 assertion, whatsoever, or at all, concerning or relating to Defendant.

8
II
9
AFFIRMATIVE DEFENSES
10
2. First Affirmative Defense - General Demurrer - All Causes of Action. As
II
12 first affirmative and separate defense to the Complaint and to each cause of action therei

13 contained Defendant alleges that each and every allegation therein contained fails to state fact
14
sufficient to constitute a cause of action against Defendant.
IS
3. Second Affirmative Defense - Statute of Limitations - All Causes of Action. A
16
a second affirmative and separate defense to the Complaint and to each cause of action therei
17

18 contained Defendant alleges that each and/or every allegation therein contained is barred by th

19 applicable statute of limitations.

20
4. Third Affirmative Defense - Laches - All Causes of Action. As a thir
21
affirmative and separate defense to the Complaint and to each cause of action therein containe
22
23 Defendant alleges that each and/or every allegation therein contained is barred by the equitabl

24 doctrine of laches because Plaintiff has waited an unreasonable period of time to file and prosecut

25 the Complaint and/or the causes of action therein contained, which unreasonable delay has cause
26
witnesses and evidence required by Defendant to successfully defend against the allegations of th
27
Complaint and/or said causes of action to disappear and become unavailable to Defendant, thereb
28,
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

 1

causing prejudice to Defendant in prosecuting a defense.

2 5. Fourth Affirmative Defense - Estoppel - All Causes of Action. As a fourt
3
affirmative and separate defense to the Complaint and/or to each cause of action therein containe
4
Defendant asserts that by virtue of Plaintiffs past actions and behavior with respect to the subjec
5
6 matter of the Complaint and/or said causes of action, Plaintiff is now estopped to assert and/o

7 prosecute the same against Defendant.

8
6. Fifth Affirmative Defense - Failure to Mitigate Damages - All Causes 0

9
Action. As a fifth affirmative and separate defense to the Complaint and/or to each cause of actio
10
therein contained Defendant asserts that Plaintiff has failed to take reasonable and available step
11

12 to avoid, reduce and/or mitigate Plaintiffs alleged damages and losses as alleged in the Complain

13 and/or each of the causes of action therein contained, and should, therefore, be barred an
14
restrained from recovering any and/or all of such otherwise avoidable damages from Defendant.
15
7. Sixth Affirmative Defense - Unclean Hands - All Causes of Action. As a sixt
16
affirmative and separate defense to the Complaint and/or to each cause of action therein containe
17
18 Defendant asserts that by virtue of Plaintiffs past actions and behavior with respect to the subjec

19 matter of the Complaint and/or said causes of action, Plaintiff is guilty of unclean hands wit
20
respect to such subject matter and should, therefore, be barred from any and/or all recovery wit
21
respect thereto from Defendant.
22

23 8. Seventh Affirmative Defense - Waiver - All Causes of Action. As a sevent

24 affirmative and separate defense to the Complaint and/or to each cause of action therein containe
25 Defendant asserts that Plaintiff has heretofore waived and given up its right to assert the rights
26
remedies, claims, allegations, damages and expenses therein contained against Defendant.
27
9. Eighth Affirmative Defense - Lack of Standing - Failure to Suffer Injury i
2&, .

ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

1

Fact - First, Second and Third Causes of Action. As an eighth affirmative and separate defens

2 to the first, second and/or third causes of action of the Complaint Defendant asserts that Plaintif
3
lacks standing to assert the claims and causes of action contained in the first, second and/or thir
4
causes of action because Plaintiff has not suffered injury in fact as a result of the claims and cause
5
6 of actions alleged against Defendant.

7 10. Ninth Affirmative Defense - Lack of Standing - Failure to Lose Money 0

8
Property - First, Second and Third Causes of Action. As a ninth affirmative and separat
9
defense to the first, second and/or third causes of action of the Complaint Defendant asserts tha
10
Plaintiff lacks standing to assert the claims and causes of action contained in the first, secon
11
12 and/or third causes of action because Plaintiff has not lost money or property as a result of th

13 claims and causes of action alleged against Defendant.

14
11. Tenth Affirmative Defense - Lack of Standing - Lack of Causation - First
15
Second and Third Causes of Action. As a tenth affirmative and separate defense to the first
16
second and/or third causes of action of the Complaint Defendant asserts that Plaintiff lack
17

18 standing to assert the claims and causes of action contained in the first, second and/or third cause

19 of action because all alleged injuries and damages alleged by Plaintiff are not the result of any 0

20
Defendant's alleged actions.
21
12. Eleventh Affirmative Defense - Defendant's Alleged Acts Not Unlawful- First
22
23 Second and Third Causes of Action. As an eleventh affirmative and separate defense to the first

24 second and/or third causes of action of the Complaint Defendant asserts that the alleged actions b
25 Defendant upon which the claims and causes of action contained in the first, second and/or thir
26
causes of action are based are not unlawful because applicable federal and California trademark
27
service mark and trade name law allow Defendant to use the trade names, service marks, domai
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

 1

names and/or website designations allegedly violated because such trade names, service marks,

2 domain names and/or website designations are descriptive of services and/or geographi
3
designations, and/or are generic terms which are not subject to protection under applicable law an
4
are not the subject of trademark, service mark and/or trade name registration and/or protection b
5
6 Plaintiff under either federal or California state law.

7 13. Twelfth Affirmative Defense - Defendant's Alleged Acts Not Unfair - First
8
Second and Third Causes of Action. As a twelfth affirmative and separate defense to the first
9
second and/or third causes of action of the Complaint Defendant asserts that the alleged actions b
10
Defendant upon which the claims and causes of action contained in the first, second and/or thir
II

12 causes of action are based are not unfair because the utility of Defendant's acts in utilizin

13 unregistered terms descriptive of services and/or of geographic designations and/or generic term
14
that are not the subject of trademark, service mark and/or trade name registration and/or protectio
15
by Plaintiff under federal and/or California trademark, trade name and/or service mark law,
16
outweighs any alleged detriment caused thereby.
17
18 14. Thirteenth Affirmative Defense - Defendant's Alleged Acts Not Deceptive

19 Fraudulent, and/or Likely to Mislead - First, Second and Third Causes of Action. As
20
thirteenth affirmative and separate defense to the first, second and/or third causes of action of th
21
Complaint Defendant asserts that the alleged actions by Defendant upon which the claims an
22
23 causes of action contained in the first, second and/or third causes of action are based are no

24 deceptive, fraudulent and/or likely to mislead because reasonable persons are unlikely to b
25 mislead as to the truth of the alleged statements and/or acts of Defendant.
26
15. Fourteenth Affirmative Defense - Defendant's Alleged Acts Constitut
27
"Puffing" - First, Second and Third Causes of Action. As a fourteenth affirmative and separat
28,
-,1

ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.


defense to the first, second and/or third causes of action of the Complaint Defendant asserts th

2 alleged actions by Defendant upon which the claims and causes of action contained in the first
3
second and/or third causes of action are based are not deceptive, fraudulent and/or likely t
4
mislead because reasonable persons are unlikely to be mislead as to the truth of the allege
5
6 statements and/or acts of Defendant in that they constitute "puffing" by Defendant as to the natur

7 and quality of Defendant's services.

8 16. Fifteenth Affirmative Defense - Registration of Fictitious Business Name(s) a
9
County Level Does Not Give Plaintiff Standing to Sue for Violation of Business an
10
Professions Code Sections 17200 and/or 17500 - First, Second and Third Causes of Action
II
12 As a fifteenth affirmative and separate defense to the first, second and/or third causes of action 0

13 the Complaint Defendant asserts that the alleged filing of a fictitious business name statement b
14
Plaintiff for a trade name at the county level, without concurrently registering the subject fictitiou
IS
business name as a national federal and/or statewide California trademark, service mark and/o
16
trade name under applicable federal and/or California law, does not give Plaintiff standing to su
17
18 for infringement of Plaintiff's alleged trade name on either a national federal and/or statewid

19 California basis because fictitious business name registration at the county level is designed t
20
give public notice of the correct person or entity using a fictitious business name for service 0
21
process and litigation purposes, while the national federal and statewide California laws fo
22
23 trademark, service mark and/or trade name registration are designed to afford a commercia

24 monopoly on the use of a specific trademark, service mark and/or trade name, provided th
25 requirements for registration of a specific trademark, service mark and/or trade name are firs
26
satisfied at the national federal and/or statewide California level.
27
17. Sixteenth Affirmative Defense - Plaintiff's Request for a Tempora
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.


Restraining Order, Preliminary Injunction and/or Permanent Injunction Violate th
2 Commerce Clause of the United States Constitution - First, Second and Third Causes 0

3
Action. As a sixteenth affirmative and separate defense to the first, second and/or third causes 0
4
action of the Complaint Defendant alleges the scope of the temporary restraining order,
5
6 preliminary injunction and/or permanent injunction requested by Plaintiff in connection with th

7 first, second and/or third causes of action of the Complaint violate the Commerce Clause found i
8 the United States Constitution in that they constitute a request that a court of the State 0

9
California issue an order affecting, controlling, regulating and burdening interstate commerc
10
because the order would limit Defendant's activities outside of California and among the severa
11
12 states, an effect that is reserved to the federal government under the foregoing provision of th

13 United States Constitution.

14
18. Seventeenth Affirmative Defense - Plaintiff's Request for a Tempora
IS
Restraining Order, Preliminary Injunction and/or Permanent Injunction
16
Supremacy Clause of the United States Constitution - First, Second and Third Causes 0
17
18 Action. As a seventeenth affirmative and separate defense to the first, second and/or third cause

19 of action of the Complaint Defendant alleges the scope of the temporary restraining order
20
preliminary injunction and/or permanent injunction requested by Plaintiff in connection with th
21
first, second and/or third causes of action of the Complaint violate the Supremacy Clause of th
22
23 United States Constitution in that they constitute a request that a court of the State of Californi

24 issue an order in violation of federal trademark law and the regulations of the Patent an
25 Trademark Office of the United States which prohibit a federal or state court from affording
26
commercial monopoly to any person or entity based on a trademark, service mark and/or trad
27
name that is descriptive of services and/or of a geographic designation, and/or is otherwis
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

 I

comprised of generic words or phrases.

2 19. Eighteenth Affirmative Defense - Plaintiff's Request for a Tempora
3
Restraining Order, Preliminary Injunction and/or Permanent Injunction based on Coun
4
Registration of a Fictitious Business Name Violate the Intent of the State of Californi
5
6 Trademark and Service Mark Law to Occupy the Entire Field of Trademark, Service Mar

7 and Trade Name Registration and Enforcement - First, Second and Third Causes of Action
8 As an eighteenth affinnative and separate defense to the first second and/or third causes of actio
9
of the Complaint Defendant alleges the remedy of a temporary restraining order, preliminar
10
injunction and/or pennanent injunction requested by Plaintiff in connection with the first, secon
II

12 and/or third causes of action of the Complaint are not available to Plaintiff because they are base

13 on Plaintiffs alleged filing of a fictitious business name statement on the county level and woul
14
thereby violate and invade the scope and intent of California's trademark and service mark law t
15
occupy the entire field of trademark, service mark and/or trade name regulation on a statewid
16
basis, and which trademark and service mark law incorporates the federal laws and regulation
17

18 concerning the non-registration and/or enforcement in the State of California of a trademark

19 service mark and/or trade name that is descriptive of services and/or of a geographic designation
20
and/or is otherwise comprised of generic words or phrases.
21
20. Nineteenth Affirmative Defense - Plaintiff's Request for a Tempora
22
23 Restraining Order, Preliminary Injunction and/or Permanent Injunction Should Be Denie

24 because Plaintiff's Alleged Injuries are Not Irreparable - First, Second and Third Causes 0

25 Action. As a nineteenth affinnative and separate defense to the first, second and/or third causes 0

26
action of the Complaint Defendant alleges the remedy of a temporary restraining order
27
preliminary injunction and/or pennanent injunction requested by Plaintiff in connection with th
28,
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!-.....

ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

1

first, second and third causes of action under the Complaint are not available to Plaintiff becaus

2 the alleged acts by Defendant have not and will not inflict legally and/or equitably cognizabl
3
irreparable injury on Plaintiff because Plaintiff has no legal and/or equitable claim or right t
4
prevent Defendant from utilizing the trademark, service mark, trade name, domain name and/o
5
6 website designation that would be the subject of the requested temporary restraining order

7 preliminary injunction and/or permanent injunction requested by Plaintiff because Plaintiff'

8
alleged trademark, service mark, trade name, domain name and/or website designation constitut
9
unregistered trademarks, service marks and/or trade names that are descriptive and/or generic i
10
nature.
11
12 21. Twentieth Affirmative Defense - Justification or Privilege - First, Second an

13 Third Causes of Action. As a twentieth affirmative and separate defense to the first, secon
14
and/or third causes of action of the Complaint Defendant alleges Defendant was justified and/o
15
privileged in taking all of the actions alleged to have been taken by Defendant with respect to th
16
subject matter of the first, second and/or third causes of action of the Complaint because th
17

18 trademarks, service marks, trade names, domain names and/or website designations upon whic

19 Plaintiff bases its first, second and/or third causes of action against Defendant are descriptive 0

20
services and/or of geographic designations and/or generic terms not creating ownership rights tha
21
are legally and/or equitably cognizable and enforceable against Defendant under the laws of th
22
23 United States or the State of California, and/or do not involve activities likely to mislead

24 reasonable person.

25 22. Twenty-First Affirmative Defense - Compensatory Damages Not Recoverabl

26
- First, Second and Third Causes of Action. As a twenty-first affirmative and separate defens
27
to the first, second and/or third causes of action of the Complaint Defendant alleges Plaintiff is no
28,
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

 I

entitled to recover compensatory damages from Defendant under the first, second and/or thir

2 causes of action of the Complaint because such relief or remedy is not legally and/or equitabl
3
cognizable or permitted under the laws of the State of California either because the law prohibit
4
such recovery outright and/or because Plaintiff is seeking to enforce an unregistered trademark
5
6 service mark and/or trade name and compensatory damages are only recoverable for the violatio

7 ofregistered trademarks, service marks and/or trade names.

8 Twenty-Second Affirmative Defense - Plaintiff's Request for a Tempora
23.
9
Restraining Order, Preliminary Injunction and/or Permanent Injunction Should Be Denie
10
because Plaintiff has Adequate Remedy at Law - First, Second and Third Causes of Action.
II

12 As a twenty-second affirmative and separate defense to the first, second and/or third causes 0

13 action of the Complaint Defendant alleges the remedy of a temporary restraining order,
14
preliminary injunction and/or permanent injunction requested by Plaintiff in connection with th
15
first, second and third causes of action under the Complaint are not available to Plaintiff becaus
16
Plaintiff seeks compensatory damages resulting from the alleged acts by Defendant specified i
17

18 the first, second and third causes of action and compensatory damages will afford Plaintiff with

19 complete and adequate remedy at law.

20
24. Twenty-Third Affirmative Defense - No Substantial Similarity betwee
21
Plaintiff's Alleged Trade Name and Defendant's Alleged Trade Names - First, Second an
22
23 Third Causes of action. As a twenty-third affirmative and separate defense to the first, secon

24 and/or third causes of action of the Complaint Defendant alleges that there is no substantia
25 similarity between Plaintiffs alleged trade name and Defendant's alleged trade names.
26
25. Twenty-Fourth Affirmative Defense - No Substantial Copying andlo
27
Verbatim Copying of Plaintiff's Website by Defendant in Defendant's Website - First
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

 1

Second and Third Causes of Action. As a twenty-fourth affirmative and separate defense to th

2 first, second and/or third causes of action of the Complaint Defendant alleges that there is n
3
substantial and/or verbatim copying by Defendant of Plaintiffs website in Defendant's website.
4
26. Twenty-Fifth Affirmative Defense - No Substantial Similarity and/or Identica
5

6 Design and/or Overall Feel between Defendant's Website and Plaintiff's Website - First

7 Second and Third Causes of Action. As a twenty-fifth affirmative and separate defense to th
8
first, second and/or third causes of action of the Complaint Defendant alleges there is n
9
substantial similarity and/or identical design and/or overall feel between Defendant's website an
10
Plaintiffs website.
11
12 27. Twenty-Sixth Affirmative Defense - Plaintiff's Claims Concerning Its Websit

13 Cannot be Heard in the Superior Court of California because Such Claims Involv
14
Copyright Issues and/or Rights Equivalent to Copyright that are Preempted by the Federa
15
Copyright Act and are the Exclusive Jurisdiction of the United States District Court - First
16
Second and Third Causes of Action. As a twenty-sixth affirmative and separate defense to th
17

18 first, second and/or third causes of action of the Complaint Defendant alleges the claims an

19 causes of action asserted by Plaintiff against Defendant in Plaintiffs first, second and/or thir
20
causes of action concerning Plaintiffs website and Defendant's website cannot be heard in th
21
Superior Court of California because they are claims and causes of action involving issues 0
22
23 copyright protection and/or of rights equivalent to copyright that are preempted by the federa

24 Copyright Act and are the exclusive jurisdiction of the United States District Court.
25 28. Twenty-Seventh Affirmative Defense - Plaintiff's Claims Concerning
26
Website Cannot be Enforced in the Superior Court of California or in the United State
27
District Court because the Copyright in Plaintiff's Website is Not Registered with th
,28
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

1

Copyright Office of the Library of Commerce, thereby Preventing Plaintiff from Assertin

2 Copyright Claim related Issues in either the Superior Court of California or in the Unite
3
States District Court - First, Second and Third Causes of Action. As a twenty-sevent
4
affirmative and separate defense to the first, second and/or third causes of action of the Complain
5
6 Defendant asserts that Plaintiffs website related claims involving Defendant's website involv

7 copyright issues that cannot be enforced against Defendant in either the Superior Court 0

8
California or in the United States District Court because the alleged copyright in Plaintiff
9
website is not currently registered at the Copyright Office of the Library of Congress whic
10
registration is a condition precedent to the enforcement of a copyright claim against an allege
11
12 infringer in court.

13 29. Twenty-Eighth Affirmative Defense - Plaintifrs Claims Concerning It

14
Website cannot Be Enforced in the Superior Court of California or in the United State
15
District Court because They Involve Copyright Issues and/or Rights Equivalent t
16
Copyright of Enforcement of Titles or Names Not Subject to Copyright Protection under th
17
18 Federal Copyright Act - First, Second and Third Causes of Action. As a twenty-eight

19 affirmative and separate defense to the first, second and/or third causes of action of the Complain
20
Defendant alleges that Plaintiffs website related claims involving Defendant's website involv
21
issues of copyright protection and/or of rights equivalent to copyright that are preempted by th
22
23 federal Copyright Act and that cannot be enforced against Defendant in the Superior Court 0

24 California or in the United Stated District Court because the alleged issues of copyright protectio
25 and/or of rights equivalent to copyright involve the enforcement of titles or names that are no
26
subject to copyright protection under the federal Copyright Act.
27
30. Twenty-Ninth Affirmative Defense - Truth - Fourth Cause of Action. As

ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

1

twenty-ninth affirmative and separate defense to the fourth cause of action of the Complain

2 Defendant alleges the statements alleged in the fourth cause of action to have been made b
3
Defendant concerning Plaintiff are truthful.
4
31. Thirtieth Affirmative Defense - Lack of Publication - Fourth Cause of Action.
5
6 As a thirtieth affirmative and separate defense to the fourth cause of action of the Complain

7 Defendant alleges none of the statements alleged in the fourth cause of action to have been mad
8
by Defendant concerning Plaintiff were published to a legally cognizable or significant person 0

9
entity.
10
32. Thirty-First Affirmative Defense - Privilege - Fourth Cause of Action. As
11
12 thirty-first affirmative and separate defense to the fourth cause of action of the Complain

13 Defendant alleges Defendant was privileged in making the statements alleged in the fourth caus
14
of action to have been made by Defendant concerning Plaintiff because they were made in goo
15
faith, without malice, and involved the business of acting as a finder for alcoholic beverag
16
licenses, a business in which Defendant and Plaintiff participated and were made to persons wh
17

18 were interested in selling and/or acquiring an alcoholic beverage license.

19 33. Thirty-Second Affirmative Defense - Punitive and Exemplary Damages No

20
Recoverable due to Lack of Malice, Oppression or Fraud - Fourth Cause of Action. As
21
thirty-second affirmative and separate defense to the fourth cause of action of the Complain
22

23 Defendant asserts that Plaintiff is precluded from recovering punitive or exemplary damages fro

24 Defendant because Defendant is not guilty of malice, oppression or fraud under Civil Cod

25 Section 3294.
26
III
27
PRAYER FOR RELIEF
28,
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

 I

WHEREFORE, Defendant prays judgment against Plaintiff under the Complaint a
2 follows:
3
A. That Plaintiff take nothing against Defendant by way of the Complaint and/or b
4
way of any cause of action therein contained.
5
6 B. That Defendant be awarded reasonable attorney's fees by virtue of applicabl

7 statutory provisions, including, but not limited to Code of Civil Procedure 1032, 1033 and/o
8
1033.5.
9
C. That Defendant be awarded Defendant's costs of suit herein incurred.
10
D. That Defendant be awarded such other and further relief as the court deems just an
II
12 proper.

13
14 La ence . de man, Attorney for endant Russell
Boom, individually and doing business as CA Liquor
15 License Specialists, Nationwide Liquor License Specialists
and ABC License Specialists
16
17
18
19
20
21

22
23

24
25
26
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ANSWER TO COMPLAINT BY DEFENDANT RUSSELL BLOOM, ETC.

I

PROOF OF SERVICE BY MAIL (CCP 1013 (a), 2015.5)
2 STATE OF CALIFORNIA )

3 COUNTY OF LOS ANGELES)

4 I am a citizen of the United States and a resident of Los Angeles County, California. I a
5 over the age of eighteen years and I am not a party to this action. My business address is 585
6 Canoga Avenue, Suite 400, Woodland Hills, California 91367-6554.
7 On May ~, 2010, I served the within document(s) entitled ANWER TO COMPLAIN
8 BY DEFENDANT RUSSELL BLOOM, ETC., CASE NO. BC436121, on the interested parties i
9 this action, by placing a true copy thereof enclosed in a sealed envelope, with postage thereon full
10 prepaid, addressed as follows:
II Rick A. Blake, Esq.
Law Offices of Rick A. Blake
12 2107 North Broadway, Suite 106
13 Santa Ana, CA 92706

14 I am readily familiar with the practice of this office for collecting and processm

15 correspondence for mailing. Under that practice, the above-described document(s) would b

16 deposited with the U.S. Postal Service on the same day as the document(s) were enclosed in thei

17 envelope(s). I am aware that on motion of the party served, service is presumed invalid if the posta

18 collection date or postage meter date is more than one day after the date of mailing set forth in thi

19 declaration.

20 I declare under penalty of perjury under the laws of the State of California that the foregoin

21 is true and correct.

22 Executed on thisM~dayof May, 2010, at WO')'\J"'1Ji"I

23

24

25

26

27
28 ,

, .
PROOF OF SERVICE BY MAIL