State Farm General Insurance Company vs City of Carmel-By-The-Sea: OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT

ABSTRACT: RE: SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants. Case No.: 16CV002381 OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT On March 7, 2017, Ashley Stander, Law Offices of Geordan Goebel, Attorneys for Plaintiff, submitted to the Superior Court of California, County of Monterey, OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT. 1. ANY VALIDLY PLED CLAIM DEFEATS A DEMURRER. 2. PLAINTIFFS' THIRD AMENDED COMPLAINT SETS FORTH SUFFICIENT FACTS TO STATE ALL THREE CAUSES OF ACTION. A. The City's Violation of its Own Code Section Proximately Caused the Damages as Allege Herein. B. The City's Exercise of Dominion and Control over Trees within its Limits Prevented Property Owners from Rectifying Dangerous Condition of Property. C. Inverse Condemnation
3. CONCLUSION. The TAC sets forth sufficient facts to establish causes of action against the City. The demurrer should be overrruled.
The OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT document copy is embedded.

16cv002381 Opposition to Demurrer to Third Amended Complaint 3-7-2017 by L. A. Paterson on Scribd

SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY
STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants.
Case No.: 16CV002381
OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT