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 MARICO
SUPERIOR COURT
COUNTY OF ARIZONA
SUPERIOR COURT
MARICOPA
IN COUNTY, ARIZONA
IN MARICOPA COUNTY
COUNTY

GOOD
Good DayDAY HOLDINGS
Holdings LLC LLC CV2023-003212
CV2023-003212
Case Number:
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

RESPONSE ONE TOin the Complaint, I: [ ] ADMIT as true, [ ] Deny, [X] State I
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
is the attorney for the Plaintiff in this action and that this Court has jurisdiction over this action.
2.
DefendantThedenies
allegations in paragraph
the remaining TWO inof
allegations theParagraph
Complaint1 about
of thethe parties, I: [ ] ADMIT as true,
Complaint.
[X] Deny, [ ] State I have insufficient information to determine whether true or false.
2. Defendant denies the allegations of Paragraph 2 of the Complaint.
3. The allegations in paragraph THREE in the Complaint, I: [X] ADMIT as true, [ ] Deny, [ ]
3. Defendant
State Iadmits that the Premises
have insufficient are located
information withint whether
to determine the judicial
true precinct
or false. of this Court and there
is authority for the filing of theis 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 admits only so much of Paragraph 4 alleging Deed was incorporated herein. Defendant
State
denies the I have insufficient
remaining allegationsinformation
of Paragraphto4 determine whether true or false.
of Complaint.

5.5.Defendant denies thein

The allegations allegations
paragraphof Paragraph
FIVE 5 of the Complaint.
in the Complaint, I: [ ] ADMIT as true, [X] Deny, [ ] State
I have insufficient information to determine whether true or false.
6.6.Defendant denies the allegations of Paragraph 6 of the Complaint.
The allegations in paragraph SIX in the Complaint, I: [ ] ADMIT as true, [X] Deny, [ ] State I
have insufficient information to determine whether true or false.

Arizona Supreme Court Page 1 of 4 CVC31f-122917

 X

CV2023-003212
Case Number: CV2023-003212

7. Defendant
7. admits only
The allegations so much of
in paragraph Paragraph
SEVEN in the7Complaint,
of the Complaint that alleges
I: [ ] ADMIT Defendants
as true, [X ] Deny,are
[ ]residents
of the County wehre this action is filed. Defendants deny the remaining allegations.of Paragraph 7 of
State I have insufficient information to determine whether true or false.
the Complaint.

8. The allegations
8. Degendat denies theinallegations EIGHT
paragraph of in the8 Complaint,
Paragraph I: [ ] ADMIT as true, [X] Deny, [ ]
of the Complalint.
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.

10. AFFIRMATIVE
The allegations in paragraph TEN in the DEFENSES
Complaint, I: [ ] ADMIT as true, [ ] Deny, [ ] State I
have insufficient information to determine whether true or false.
1. Plaintiff's claims are barred in whole or in part due to Plaintiff filing an illegal eviction against
Defendant, Arianne Burchett, the tenant at 1332 East Campbell Avenue, Phoenix, AZ 85014, who has a
(Iflease
valid you that
needbegan
more on
space, add an
February 1, attachment labeled
2021, and ends “Statement
on March of Facts
31, 2024, whoand Breach,”
is current on and continue
the rent, that was
prepaid on November 1,
consecutive numbering.) 2022,, up to July 1, 2023, and who has not violated the lease in any way.

2. Plaintiffs
Defendant’sclaims are barred
GENERAL in wholeDefendant
DENIAL: or in partdenies
due toanything
Plaintiffstated
making theComplaint
in the false accusation on two line
that Defendant has
items in the Complaint that Defendant Arianne Burchett and Defendant Donn Schulman are married,
not specifically
providing no proofadmitted, qualified, which
of this accusation, or denied.
is misleading,making this
false accusation two separate times in the Complaint, with no proof,s,
making these false accusations incorrectDEFENSES accusationsand
that DENIALS
both Defendants are performing acts that are unclear,
benefit the marital property, with no proof, which is misleading
3. Palintiff's claims are barred in whole or in part because of improper and false.
notice and improper procedure for
a formal eviction required after a foreclosure sale.
A. Defendant alleges that the claims for relief stated in the Complaint are, or may be, barred by reason
of (check any that apply):
5. Plaintiff's claims are barred in whole or in part because the eviction the result of a trustee sale that
was the result of a wrongful foreclosure that the Plaintiff is in the process of pursuing legal action.
[X] Lack of personal jurisdiction [ ] Failure of consideration
[ ] Lack of subject matter jurisdiction [X ] Fraud
7. Plaintiff's claims are barred in whole or in part because of Defendant requests that Plaintiff provide defendant
that defendant[X] allegedly
Insufficient service of process
owes. [X] Illegality
[X] Failure to state a claim upon which [X] Laches
8. relief can be granted [ ] License
4. Palintiff claims are barred
[ ] Accord and in whole or in part due to Defendant was
satisfaction [ ]not properly served summons.
Payment
[ ] Arbitration and award [ ] Release
5. Plaintiff's claims are barred in whole or in part due to
[ ] Assumption of risk [ ] Res judicata
[ ] Contributory negligence [ ] Statute of Frauds
[ ] Duress [ ] Statute of Limitations
[ ] Estoppel [ ] Waiver
[ ] Other Defenses are listed and explained below.

Misrepresentation, failure to join an indespensible party, misconduct.

Arizona Supreme Court Page 2 of 4 CVC31f-122917

Defendant denies anything stated in the Complaint that DXefemdant has not specifically admitted, qualified, or denied.

CV2023-003212
Case Number: CV2023-0032122

SUMMARY
Defendant denies the allegations contained within the Summary of the Complaint.
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

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