(Source:  FACE Intel website)
 
 
KOUROSH KENNETH HAMIDI
7349 CROSS DRIVE
CITRUS HEIGHTS, CA 95610
In Propia Persona
 
EDNDOSRED
NOV 12, 1998
By P. Allen , Deputy
 
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SACRAMENTO
INTEL CORPORATION,     Case No. 98AS05067
Plaintiff,
vs.     ANSWER TO COMPLAINT
 
KOUROSH KENNETH HAMIDI and  
FACE - Intel, a purported California
nonprofit organization,
Defendant,
I. Defendant KOUROSH KENNETH HAMIDI, on behalf of himself and Defendant FACE-INTEL, a California non-profit organization,(hereinafter "Defendants") answering plaintiff's unverified complaint herein, deny each and every allegation of said complaint pursuant to the provisions of Code of Civil Procedure Section 431.30(d).
FIRST AFFIRMATIVE DEFENSE
2. The complaint and each cause of action therein, fails to state facts sufficient to constitute a cause of action against Defendants.
SECOND AFFIRMATIVE DEFENSE
3. Defendants allege that, at all times relevant to the complaint, each acted in good faith and in furtherance of their first amendment rights under the United States Constitution and the California State Constitution.
THIRD AFFIRMATIVE DEFENSE
4. Defendants allege that plaintiff consented to and/or ratified the acts of Defendants after full disclosure of all the pertinent facts and potential consequences.
FOURTH AFFIRMATIVE DEFENSE
5. To the extent that plaintiff ever had a right to the relief prayed for in the complaint, plaintiff has waived such right.
FIFTH AFFIRMATIVE DEFENSE
6. To the extent that plaintiff ever had a right to the relief prayed for in the complaint, plaintiff is estopped from recovering such relief because of plaintiff's actions.
SIXTH AFFIRMATIVE DEFENSE
7. To the extent that plaintiff ever suffered the damages alleged in the complaint, those damages should be reduced because of plaintiff's failure to mitigate damages.
SEVENTH AFFIRMATIVE DEFENSE
8. Defendants allege that if plaintiff sustained any of the damages alleged in the complaint. such damages were proximately caused, wholly or partly, by plaintiff's own negligence
EIGHTH AFFIRMATIVE DEFENSE
9. Defendants allege that plaintiff was negligent, and otherwise at fault, with regard to the events alleged in the complaint.- and such negligence and fault is the proximate cause of any liabilities or damages plaintiff may incur. Accordingly, plaintiff's recovery, if any, should be precluded or reduced in proportion to it's negligence and fault.
NINTH AFFIRMATIVE DEFENSE
10. Defendants allege that the damages, if any, suffered by plaintiff were proximately caused in whole or in part by the wrongful and/or negligent acts, conduct or omissions of other parties, including, plaintiff, co-defendants herein and third parties, and not by any wrongdoing or negligence on the part of Defendants.
TENTH AFFIRMATIVE DEFENSE
11. While denying any liability to plaintiff or to any other party, by reason of anything alleged in the complaint, Defendants allege that in the event judgment is entered against Defendants in this action, they are entitled to have that liability or judgment apportioned among themselves, plaintiff and co-defendants herein in accordance with each party's comparative negligence or fault as determined at trial.
ELEVENTH AFFIRMATIVE DEFENSE
12. Defendants allege that any reimbursement, from whatever source, to plaintiff for the damages alleged must be applied against any liability of Defendants.
TWELFTH AFFIRMATIVE DEFENSE
13. Defendants allege that plaintiff lacks clean hands with respect to the allegations made in this complaint, and is therefore not entitled to any relief .
THIRTEENTH AFFIRMATIVE DEFENSE
14. Defendants allege that the relief requested by plaintiff would constitute a prior restraint on freedom of speech in violation of the United States Constitution and the California State Constitution and should thereby be denied.

WHEREFORE, KOUROSH KENNETH HAMIDI AND FACE-INTEL, pray as follows:

I . That plaintiff takes nothing by their complaint against these answering Defendants.

2. For costs of suit herein, and

3. For such other costs and further relief as the court may deem just and proper.
 
 

Dated:     November 4, 1998

 (Sigend by Kourosh Kenneth Hamidi)

KOUROSH KENNETH HAMIDI