Plaintiff’s motion for judgment on ...








PLAINTIFF’S MOTION FOR JUDGMENT ON THE PLEADINGS AS TO THE ANSWER BY DEFENDANTS ______________________________.
Plaintiff, ________________________ hereby moves this Court for judgment on the pleadings as to defendant’s Answer to the complaint of plaintiff as a whole as well as to the 1
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affirmative defenses in defendant’s answer to the complaint of plaintiff as follows:
THE ANSWER OF DEFENDANTS AS A WHOLE
1. Plaintiff hereby moves this Court for judgment on the pleadings as to the entiretyof defendant’s Answer on the grounds that the complaint of plaintiff and each cause of actioncontained therein states facts sufficient to constitute a cause of action against defendants anddefendant’s Answer as a whole fails to state sufficient facts to constitute a defense to the complaint,or to any of the causes of action therein.
Cal. Civ. Proc. Code
§ 438(c).
FIRST AFFIRMATIVE DEFENSE
2. The first affirmative defense that the complaint fails to state a cause of action againstany Defendant, as pled in Defendants Answer (“Answer”) on file herein, fails to state sufficient factsto constitute a defense to the Complaint, or to any of the causes of action therein.
Cal. Civ. Proc.Code
§ 438(c).3. The complaint of plaintiff and each cause of action contained therein states factssufficient to constitute a cause of action against defendants.
Cal. Civ. Proc. Code
§ 438(c). (WestSupp. 2008).
SECOND AFFIRMATIVE DEFENSE
4. The second affirmative defense that the Complaint, and each cause of action therein, is barred by the applicable statute of limitations, as pled in Defendant’s Answer on file herein, fails to
- 3 -NOTICE OF MOTION AND MOTION FOR JUDGMENT ON THE PLEADINGS

              Plaintiff’s motion for judgment on ...              Plaintiff’s motion for judgment on ...
 
 
 
 
 
 
 
 
 


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2012 CA 007990 B: HICKMAN, DERIAN DOUGLAS Vs. INTERNAL REVENUE SERVICE Case Type: Civil II File Date: 10/10/2012 Status: Closed Status Date: 10/10/2012 Disposition: Dismissed-By Court Disposition Date: 01/16/2013 Party NameParty Alias(es)Party TypeAttorney(s) HICKMAN, DERIAN DOUGLAS PLAINTIFF PRO SE INTERNAL REVENUE SERVICE Defendant Docket DateDescriptionMessages 01/23/2013 Order Filed Order Denying Motion to Reopen Case Filed. Signed by Judge L. Cordero on 1/23/2013. submitted 01/23/2013 19:16. atm 01/23/2013 Order Denying Motion to Vacate Order of Dismissal Entered on the Docket ORDER DENYING MOTION TO REOPEN CASE, signed by J. Cordero, efiled, eserved, docketed and copies mailed to pro se parties on 1/23/13. rsk. 19:15 01/17/2013 Miscellaneous Docket Copy of Motion to Reopen Case Filed was Mailed to Defendant's.rp 01/17/2013 Motion Filed: Motion to Reopen Case Filed. Attorney: PRO SE (999999) DERIAN DOUGLAS HICKMAN (PLAINTIFF); 01/16/2013 Order Sua Sponte to/for: Entered on Docket Order of Dismissal Signed by Judge Cordero on 1/16/13. Submitted 01/16/2013 18:22. MLL. 01/16/2013 Dismissed by Court Dismissed by Court 01/16/2013 Event Resulted: Event Resulted: The following event: Initial Scheduling Conference-60 scheduled for 01/18/2013 at 9:30 am has been resulted as follows: Result: Event Cancelled Judge: CORDERO, LAURA A Location: Courtroom A-50 01/16/2013 Order Sua Sponte to/for: Entered on Docket Order Sua Sponte to/for: Order Dismissing Complaint, signed by J. Cordero, efiled, eserved, docketed and copies mailed to pro se parties on 1/16/13. rsk. 18:21 12/27/2012 Proof of Service Proof of Service Method : Service Issued Issued : 10/11/2012 Service : Summons Issued Served : 12/18/2012 Return : 12/27/2012 On : INTERNAL REVENUE SERVICE Signed By : CHARLES CHRISTOPHER Reason : Proof of Service Comment : Tracking #: 5000124501 12/27/2012 Affidavit of Service of Summons & Complaint on Affidavit of Service of Summons & Complaint on INTERNAL REVENUE SERVICE (Defendant); 11/06/2012 Certified Mail Receipt of Questionable Service of Final Notice of Acknowledgment Filed Certified Mail Receipt of Questionable Service of Final Notice of Acknowledgment Filed on behalf of defendant Internal Revenue Service 11/5/2012 green card stamp Logistics and Support Services. vlp INTERNAL REVENUE SERVICE (Defendant); 11/01/2012 Final Notice of Acknowledgment mailed to deft(s) on: Final Notice of Acknowledgment of Receipt of Summons, Complaint Initial Order and Addendum mailed to defendant Internal Revenue Service on November 1, 2012 by the clerk pursuant to SCR 4 (c)(4). vlp INTERNAL REVENUE SERVICE (Defendant); 10/11/2012 Complaint Summons and I.O. with Acknowledgment Form mailed to Deft(s) Complaint Summons and I.O. with Acknowledgment Form mailed to Deft(s) by the Clerk Pursuant to SCR 54-II this date: 10/11/12. MLL. INTERNAL REVENUE SERVICE (Defendant); 10/11/2012 Complaint Summons and I.O. with Acknowledgment Form mailed to Deft(s) Complaint Summons and I.O. with Acknowledgment Form mailed to Deft(s) by the Clerk Pursuant to SCR 54-II this date: 10/11/12. MLL. INTERNAL REVENUE SERVICE (Defendant); 10/11/2012 Service Issued Issue Date: 10/11/2012 Service: Summons Issued Method: Service Issued Cost Per: $ INTERNAL REVENUE SERVICE 1100 4th Street, SW WASHINGTON, DC 20024 Tracking No: 5000124501 INTERNAL REVENUE SERVICE 500 North Capitol Street,NW WASHINGTON, DC 20001 Tracking No: 5000124502 10/10/2012 Additional Summons Additional Summons 10/10/2012 Order Granting Motion to Proceed In Forma Pauperis Entered on the Docket Order Granting Motion to Proceed In Forma Pauperis Entered on the Docket 10/10/12 signed by J/Eilperin 10/10/2012 Motion to Proceed In Forma Pauperis Filed Motion to Proceed In Forma Pauperis Filed Attorney: PRO SE (999999) 10/10/2012 Event Scheduled Event Scheduled Event: Initial Scheduling Conference-60 Date: 01/18/2013 Time: 9:30 am Judge: CORDERO, LAURA A Location: Courtroom A-50 10/10/2012 Complaint for Fraud Filed Complaint for Fraud Filed Attorney: PRO SE (999999) D
 

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