Defendant admits only so much of Paragraph 1 of the Complalint that alleges that Scott E Williams

Person is Donn Schulman

the attorney
Filing: for the Plaintiff in this action and that this Court has jurisdiction over this action.
Address (if not protected):the4501
Defendant denies remaining allegations
North 13th Place of Paragraph 1 of the Complaint.
City, State, Zip Code: Phoenix, AZ 85014
Telephone: 602-762-3976
Email Address: donn.schulman@yahoo.com For Clerk’s Use Only
ATLAS Number:
Representing [X ] Self, or [ ] Attorney for
Lawyer’s Bar Number:

MARICOPA COUNTY
SUPERIOR COURTSUPERIOR COURT
OF ARIZONA
MARICOPAIN COUNTY,
MARICOPAARIZONA
COUNTY
IN COUNTY

Good DayDAY
GOOD Holdings LLC LLC
HOLDINGS Case Number:
CV2023-003212
CV2023-003212
Name of Plaintiff(s)

ANSWER
Donn Schulman
DONN SCHULMAN

Name of Defendant(s)

For Defendant’s Answer to Plaintiff’s Complaint, Defendant, Donn

Donn Schulman
Schulman ,
admits, denies, and alleges as follows:

1. The allegations in paragraph ONE in the Complaint, I: [ ] ADMIT as true, [ ] Deny, [X] State I
RESPONSE TO ALLEGATIONS
have insufficient information to determine whether true or false.
1. Defendant admits only so much of Paragraph 1 of the Complaint that alleges that Scott E Williams
2. The allegations
is the attorney in paragraph
for the Plaintiff TWO
in this in the
action andComplaint abouthas
that this Court the jurisdiction ADMIT
parties, I: [ ]over as true,
this action.
Defendant denies the remaining allegations of Paragraph 1 of the Complaint.
[X] Deny, [ ] State I have insufficient information to determine whether true or false.

2. Defendant
3. denies the
The allegations allegationsTHREE
in paragraph of Paragraph
in the 2Complaint,
of the Complaint.
I: [X] ADMIT as true, [ ] Deny, [ ]
State I have insufficient information to determine whether true or false.
3. Defendant admits that the Premises are located within the judicial precinct of this Court and there
is authority for the filing of this action outside the precinct where the Premises are located.
4. The allegations in paragraph FOUR in the Complaint, I: [ ] ADMIT as true, [X] Deny, [ ]
4. Defendant have insufficient
State I admits information
only so much to determine
of Paragraph whether
4 alleging Deed true
was or false.
incorporated herein. Defendant
denies the remaining allegations of Paragraph 4 of Complaint.
5. The allegations in paragraph FIVE in the Complaint, I: [ ] ADMIT as true, [X] Deny, [ ] State
5. Defendant denies the allegations of Paragraph 5 of the Complaint.
I have insufficient information to determine whether true or false.
6. The allegations
6. Defendant in paragraph
neither admits SIXthe
or denies in allegations
the Complaint, I: [ ] ADMIT
of Paragraph 6 dueastotrue, [X] Deny,
insufficient [ ] State I
information
have insufficient
to determine whether trueinformation
or false. to determine whether true or false.

Arizona Supreme Court Page 1 of 4 CVC31f-122917

 X

CV2023-003212
Case Number: CV2023-003212

7. Defendant admits only so much of Paragraph 7 of the Complaint that alleges Defendants are residents
of the County
7. where this
The allegations action is filed.
in paragraph SEVEN Defendants deny the I:
in the Complaint, remaining allegations
[ ] ADMIT as true, of
[X ]Paragraph
Deny, [ ] 7 of
the Complaint.
State I have insufficient information to determine whether true or false.

8. Defendant denies the allegations of Paragraph 8 of the Complaint.

8. The allegations in paragraph EIGHT in the Complaint, I: [ ] ADMIT as true, [X] Deny, [ ]
State I have insufficient information to determine whether true or false.
9. Defendant denies the allegations of Paragraph 9 f the Complalint.

9. The allegations in paragraph NINE in the Complaint, I: [ ] ADMIT as true, [X] Deny, [ ] State
I have insufficient information to determine whether true or false.
AFFIRMATIVE DEFENSES

10. The allegations in paragraph TEN in the Complaint, I: [ ] ADMIT as true, [ ] Deny, [ ] State I
1. Plaintiffs claims are barred in whole or in part because the Plaintiff did not follow the steps in the
have insufficient
"formal" eviction information
process required to determine
by State whether
law to evict true or false.
the previous owner, Defendant Donn Schulman,
of a property purchased at a foreclosure sale.
(If you need more space, add an attachment labeled “Statement of Facts and Breach,” and continue
2. Plaintiff's
consecutive claims are barred in whole or in part for failure to state a claim for which relief can be
numbering.)
granted.

Defendant’s GENERAL DENIAL: Defendant denies anything stated in the Complaint that Defendant has
3. Plaintiff's claims are barred in whole or in part because the Defendant, Donn Schulman, was not served
thenot specifically admitted, qualified, or denied.
summons.

4. Palintiff's claims are barred in whole DEFENSESor in part because the Plaintiff is claiming the Defendant, Donn
and DENIALS
Schulman, and the tenant, Defendant Arianne Burchett, owe the Plaintiff the tenant's past due rent, in an
amount not consistent with the tenant's lease, which the tenant is current and the rent prepaid to July 1, 2023.
A. Defendant alleges that the claims for relief stated in the Complaint are, or may be, barred by reason
5. Plaintiff's
of claims
(check are
any barred in whole or in part due to Plaintiff making false statements as to the
that apply):
marital status of the Defendants and making false accusations as to Defendants committing judicial acts to
benefit the marital property, which are untrue and damaging to the credibility of the Defendants, which the
Plaintiff has
[X]not provided
Lack proofjurisdiction
of personal to support the accusations. [ ] Failure of consideration
[ ] Lack of subject matter jurisdiction [X ] Fraud
[X] Insufficient service of process
6. Plaintiff's claims are barred in whole or in part due to the false[X ] Illegality
statement in the "Written Notice of
Surrender and[X] Failure to statethea notice
Possession", claim upon
prior towhich [X] Plaintiff
the eviction, that the Laches purchased the property at a
trustee sale, which
reliefiscan
false, and for which the trustee sale is the direct
be granted result of a foreclosure that Defendant is
[ ] License
currently pursuing legal action to prove wrongful.
[ ] Accord and satisfaction [ ] Payment
7. Plaintiff's
[ claims are barred
] Arbitration in whole or in part due to the Plaintiff
and award not acknowledging the current tenant's
[ ] Release
lease, which Plaintiff and Plaintiff's
[ ] Assumption of risk attorney were provided prior[ ] Reshearing
to the judicataon March 15, 2023, and
informed of in December 2022 by tenant, and without performing due diligence as to the status of the lease,
[ ] Contributory
continued with moving forward negligence
and filing an illegal eviction. [ ] Statute of Frauds
[ ] Duress [ ] Statute of Limitations
8. Plainfiff's claims are barred in whole or in part due to the Plaintiff not performing due diligence in an
[ ] Estoppel
effort to contact the previous owner/landlord, Defendant Donn Schulman, [ ] Waiverwith Notice of Sale or Notice of
[ ] Other
New Ownership, Defenses
or by are listed
any other means, andtoexplained below.
inform the Defendant of new ownership and where to forward
rent payments, or to obtain information regarding tenants on the property, or any other matters in regards to
the property, Misrepresentation,
prior to the "Written Notice
failure to joinofanSurrender and party,
indespensible Possession" and prior to the eviction.
misconduct.

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 CV2023-003212
Case Number: CV2023-0032122

B. Defendant reserves the right to amend this Answer at a later time to assert any matter constituting an
avoidance or affirmative defense including, without limitation, those affirmative defenses set forth in
Rule 8(d), Arizona Rules of Civil Procedure, as discovery shows to be applicable.

REQUESTS to the COURT

WHEREFORE, having fully defended, Defendant requests that Plaintiff’s Complaint be dismissed,
that Plaintiff take nothing, and that Defendant be awarded the costs and expenses incurred herein,
including such other and further relief as the Court may deem just and proper.

4-13-2023
Date Signature of Defendant/Defendant’s Attorney

9. Defendant reserves the right to assert further affirmative defenses as they become
evident through discovery investigation.

10. All actions taken by Defendant with respect to Plaintiff were supported by
legitimate business reasons.
PRAYER

WHEREFORE, PREMISES CONSIDERED, Defendant prays that the above answers be

deemed good and sufficient and all claims by Plaintiff against Defendants be dismissed, with
prejudice, and such other and further relief, legal and equitable, including attorney’s fees, be
awarded Defendants.

Dated: April 26, 2023

Respectfully submitted,

Donn Schulman
4501 North 13th Place
Phoenix, AZ 85014
602-739-3976\

Arizona Supreme Court Page 3 of 4 CVC31f-122917

 Case Number: CV2023-003212

CERTIFICATE OF SERVICE:

The following page must be completed and attached to the LAST page of your Answer:

[X ] I filed the ORIGINAL of the Answer with the Clerk of the Superior Court in Maricopa County
on: 4-13-2023 (Month/Date/Year)

[X] I mailed/delivered a COPY of the answer to the Judicial Officer assigned to my case on:
4-13-2023 (Month/Date/Year)

Judge (or Commissioner): Commissioner Mary Cronin

(Judicial Officer assigned to your case)

[X] I mailed/delivered a COPY of the Answer to the Plaintiff (or the Plaintiff’s Attorney if Plaintiff is
represented by an attorney) on: 4-13-2023 (Month/Date/Year)

Name of Plaintiff /Plaintiff’s attorney: Scott E. Williams #012417, ZONA LAW GROUP P.C.

Address: 7701 East Indian School Road, Suite J

City, State, Zip Code: Scottsdale, AZ 85251-4041

(You must mail a copy of all documents to the Plaintiff and his/her lawyer)

By signing below, I state to the Court, under penalty of law, that the information stated on these
pages is true and correct to the best of my knowledge and belief.

I further state that I have filed/mailed the attached document(s) as shown above. I understand
that if I do not file/mail the attached document(s) as shown above, the Judge in my case will not
read the attached document.

4-13-2023
Date Signature of Defendant/Defendant’s Attorney

Arizona Supreme Court Page 4 of 4 CVC31f-122917