1 William James. Palmer, Jr.

, as BENEFICIARY
Intestate heir of ESTATE OF WILLIAM
2
PALMER, aka WILLIAM JAMES PALMER
3 P.O. Box 641984
Los Angeles, CA 90064
4
310-663-4811
5

7 SUPERIOR COURT OF CALIFORNIA

8 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
9

10

11 BLALOCK HOME INVESTMENTS, LLC, a ) CASE NO. 21STCV16388

Limited Liability Corporation )
12 Plaintiff, )
vs ) VERIFIED ANSWER
13 )
WILLIAM J. PALMER, JR. aka )
14 WILLIAM JAMES PALMER, JR.; ) JURY TRIAL DEMANDED
DAVON GREGORY; ROBERT WHITFIELD; )
15 The testate and intestate heirs of William )
Palmer, Sr., deceased, and all persons claiming )
16
by, through, or under such decedent; )
17 ALL PERSONS UNKNOWN, CLAIMING )
ANY LEGAL OR EQUITABLE RIGHT,
)
18 TITLE, ESTATE, LIEN, OR INTEREST IN Date: August 11, 2021
)
THE PROPERTY DESCRIBED IN THE Time: 8:30am
)
19 COMPLAINT ADVERSE TO PLAINTIFF’S Dept. 40
TITLE, OR ANY CLOUD ON PLAINTIFF’S
)
20 ) Judge: Hon. David Sotelo
TITLE THERETO; and DOES 1 through 10,
inclusive, )
21 Defendants )
22 _______________________________________ )

23

24
ANSWER
25

26 DEFENDANT does not have sufficient information or knowledge to admit or

27
deny Paragraphs 1, 6, 7 and 8, and on that basis DENIES.
28

1
1 DEFENDANT denies the allegations in Paragraph 6 and 10, 11, 12, 13, on the

2 basis that orders obtained by fraud are void on their face, and therefore cannot pass
3
chain of title. Evidence which was not allowed to be presented in the probate case
4

5 referenced, due to the premature termination of proceedings does override the

6 ADMITTED FRAUD of Ivy Evette Johnson, NOR does it preclude such evidence being
7
presented in this matter to demonstrate the fraud, beyond all doubt.
8

9 DEFENDANT denies the allegations in Paragraph 15, on the basis that that
10
PLAINNTIFF is not a bonafide purchaser for value.
11

12 DEFENDANT denies all allegations in the FIRST CAUSUE OF ACTION

13

14 DEFENDANT denies all allegations in the SECOND CAUUSE OF ACTION on

15 the basis that the April 2019 QUIT CLAIM deed is not a wild deed.
16

17 DEFENDANT denies that PLAINNTIFF is entitled to any of the relief prayed

18 for on the basis that title was obtained by fraud.
19

20 AFFIRMAMTIVE DEFENSES
21
ESTOPPEL
22

23 PLAINTIFF attempts to parley statements made by LOS ANGELES SUPERIOR

24
COURT into evidence in support of their claim, however such statements are not
25

26 reflected in the evidence presented to the court nor are they conclusive as to
27 DEFENDANTS’ knowledge sufficient to defend his interest as required by law.
28

2
1 Evidence that DEFENDANT did not possess such knowledge has never been produced.

2
FRAUD
3

4 Ivy Evette Johnson used fraud and identity theft to obtain administrator rights to
5
the estate of WILLIAM JAMES PALMER (DECEDENT), and has ADMITTED to
6

7 such fraud. Evidence in the record shows that BLALOCK HOME INVESTMENTS,
8 LLC was a party to this fraud, in that they did not obtain the property for value, and
9
have never show any evidence to refute that they purchased the SUBJECT PORPERTY
10

11 at a fair market value price.

12
UNCLEAN HANDS
13

14 PLAINNTIFF damages are due to PLAINTIFFS own conduct, and the Conduct
15
of Its Agents, Representatives, and Consultants, to which PLAINTIFF acquiesced.
16

17 ADEQUATE WARNING AND FAILURE TO MITIGATE DAMAGES

18

19 PLAINTIFF had multiple adequate warnings that the SUBJECT PROPERTY

20 was stolen, and chose not to mitigate damages when he discovered that the SELLER
21
was in breach and had passed stolen property. PLAINTIFF’S own negligence in
22

23 addressing the breach of contract of the SELLER and their inability to explain such
24 breach, following PLAINTIFF being warned by DEFENDANT that the property was
25
stolen, gave ample notice to PLAINTIFF sufficient to mitigate damages, by cancelling
26

27 the contract, and receiving a full refund of his consideration.

28

3
1 NO ADEQUATE REMEDY/CONTRARY TO PUBLIC POLICY

2
While PLAINTIFF has multiple adequate remedies available to mitigate his
3

4 damages, including but not limited to title insurance, and breach of contract against the

5 seller, DEFENDANT has not adequate remedy to theft of property to which it is

6
UNDISPUTED he is the sole know heir. DEFENDANT did not enter into any contract
7

8 or agreement with any person to dispose of his property. Leaving DEFENDANT

9 without remedy is, or should be CONTRARY TO PUBLIC POLICY.
10

11 IMPOSSIBILITY/UNDUE BURDEN
12
Cali. Civ. Code §3531 simply states “The law never requires impossibilities.”
13

14 It would be impossible for DEFENDANT to prove they did not know something,
15
PLAINNTIFF is asking the COURT to hold DEFENDANT to an impossible standard
16

17 of retroactive “should have, could have, would have” in reaction of what IVY EVETTE
18 JOHNSON was attempting to do, which was OBVIOUS on it’s face in that she lied
19
about her very identity, and the identity of multiple other parties to present a diluted
20

21 picture of DEFENDANTS interest in the SUBJECT PROPERTY.

22
UNCONSTITUTIONAL
23

24 To quiet title in the name of PLAINNTIFFF would constitute an unconstitutional

25
seizure of DEFENDANTS property, since PLAINTIFF ADMITS he hold title due to
26

27 the actions of a GOVERNMENT ENTITY, the Los Angeles Superior Court,

28

4
1 PROBATE division.

2
PPRAYER FOR RELIEF
3

4 WHEREFORE, DEFENDANT requests that:

5

6 Judgment that the estate of WILLIAM PALMER, AKA WILLIAM JAMES

7 PALMER is the true and correct owner of 100% of the real property located at 807 East
8
103rd Place, Los Angeles, CA 90002 (“SUBJECT PROPERTY”).
9

10 2. Judgment declaring Westminster Title Company Inc. is liable for any damages
11
suffered by the PLAINTIFF if the transaction was the result of fraud unknow to him.
12

13 Judgement that IVY EVETTE JOHNSON never had any interest in the
14
SUBJECT PROPERTY described herein, AND
15

16 Judgement that GOLDEN RULE LENDING, LLC never had any interest in the
17
SUBJECT PROPERTY described herein;
18

19 Judgment that PLAINTIFF BLALOCK HOME INVESTMENTS, LLC, have no

20
right, title, estate, claim, lien, or interest in or to the SUBJECT PROPERTY whatsoever;
21

22 For costs and attorneys’ fees as allowed by law; AND

23

24 For such other relief as the court deems just and proper.
25
Dated: July 14, 2021
26

27 By:___________________________
28 William James Palmer, Jr. as Beneficiary intestate heir of
the ESTATE of William
5
Palmer aka William James Palmer
1 PROOF OF SERVICE
2 CASE #21STCV16388
3
I, Marina J Boyd, am a resident of Los Angeles County, state of California. I am over the age
4
of 18 and not a party to this action. My business address is P.O. Box 641984, Los Angeles, California
5 90064.

6
On Thursday, July 15, 2021, I served
7

8
1) WILLIAM JAMES PALMER, JR. NOTICE OF REMOVAL TO FEDERAL COURT
9 2) CERTIFICATION AND NOTICE OF INTERESTED PARTIES

10

11 (X) ELECTRONICALLY as follows: I caused such documents to be served via e-mail to the

12 following e-mail addresses designated by the parties:

13
Robert O. Whitfield, III, DEFENDANT Vanessa H. Widener, Esq. (SBN #203967)
14 roknowsre@gmail.com Anderson, McPharlin & Conners LLP
vhw@amclaw.com
15 Lisa (assistant) lmg@amclaw.com
16 William James Palmer, Jr
c/o prosewestand@gmail.com
17

18 I declare under penalty of perjury under the laws of the State of California that the above is
19 true and correct.
20

21 15th day of July 2021 at Los Angeles, California.

Executed this _____
22

23

24 ____________________________
Signature
25

26 Marina Boyd
____________________________
27 Print Name
28