United States District Court Central District of California: Answer (Corrected) of Greg Diamond, Albert v. Williams 1

Case 8:18-cv-00448-CJC-JDE Document 146 Filed 07/23/18 Page 1 of 15 Page ID #:690
1 Gregory A. Diamond, SBN 256598

LAW OFFICE OF GREGORY A DIAMOND
2 920 Steele Drive
Brea, CA, 92821
3 Telephone (714) 782-4734
Email: gad20@columbia.edu
4 Defendant filing in pro per
5
UNITED STATES DISTRICT COURT
6
CENTRAL DISTRICT OF CALIFORNIA
7
LENORE ALBERT, an individual; ) CASE NO. 8:18−cv−00448−CJC−JDE
8 Plaintiff(s), )
) ANSWER OF GREG DIAMOND
9 v. )
) 1. 42 USC 1983
10 ANTHONY TROY WILLIAMS, an individual; ) 2. Defamation
COMMON LAW OFFICES OF AMERICA; ) 3. False Light
11 GEORGE OLIVO, an individual; SHERI MOODY, ) 4. Extortion
an individual; VALERIE LOPEZ, an individual; ) 5. RICO Violations
12 CYNTHIA L. BROWN, an individual; SHERRY ) 6. UCL 17200
HERNANDEZ, an individual; MONICA JONES, an )
13 individual; PAM RAGLAND, an individual; )
CITIBANK, N.A.; GREG DIAMOND, an individual; )
14 BILLIE RENE POWERS, an individual; WILLIAM )
WAGENER, an individual; KARIN HUFFER, an )
15
individual; MARY SMITH, an individual; JOANNE )
16 KENNEDY, an individual; DEVIN LUCAS, an )
individual; ORANGE COUNTY SUPERIOR )
17 COURT; STATE BAR EMPLOYEE, an individual; )
STATE BAR OF CALIFORNIA; TIMOTHY BYER, )
18 an individual; ALEX HACKERT, an individual; )
HON. YVETTE ROLAND, an individual; )
19 MARICRUZ FARFAN, an individual; CAITLIN )
ELEN-MORIN, an individual; STEVE BALLARD, )
20 an individual; CATHERINE OLSEN, an individual; )
NIRA WOODS, an individual; and DOES 1 through )
21 50, inclusive, )
)
22 Defendants. )
_____________________________________________ ______________________________________
23
24
25 Paragraph 1 is denied.
26 Paragraphs 2-13 are denied based on lack of information.
27 Paragraph 14 is admitted.
Answer (Corrected) of Greg Diamond, Albert v. Williams

1
1 Paragraphs 36-40 are denied as applied to Mr. Diamond; denied based on lack of information as to other
2 defendants.
3 Paragraph 41 is denied as applied to Mr. Diamond (and specifically denying that his admitted opposition
4 to Plaintiff's runs for political office constituted “interfering”); denied based on lack of information as to
5 other defendants.
6 Paragraphs 42-43 are denied as applied to Mr. Diamond; denied based on lack of information as to other
7 defendants.
8 Paragraphs 44-50 are denied as to any implication that “Occupy Fights Foreclosures” (1) was part of a
9 “nationwide” (or any other illegal) conspiracy, (2) was involved in “racketeering” within the meaning of
10 RICO or the Organized Crime Control Act, (3) was engaged in violence to person or property, (4) in any
11 meaningful way constituted a “family” organization under the above laws pertaining to crime “families,”
12 (5) was in any way a “racketeering enterprise” under the meaning of the aforementioned laws, or (6)
13 worked as a “conduit” to or through the other organizations described; denied as to all allegations made
14 against the Orange Juice Blog engaging in improper activity; denied as applied to Mr. Diamond except to
15 admit that he did help run Orange Juice Blog; denied based on lack of information as to other defendants.
16 Paragraph 51 is denied based on lack of information.
19 Paragraph 60 is denied as applied to Mr. Diamond; denied based on lack of information as to other
20 defendants.
22 Paragraphs 63-69 are denied.
24 Paragraph 84 is denied as applied to Mr. Diamond; denied based on lack of information as to other
25 defendants.
28 ///

2
1 Paragraph 91 is denied based on lack of information; and denied in part regarding in its history and
2 characterization of the Occupy movement, which as presented in material respects does not match Mr.
3 Diamond's personal experience as a participant therein, nor the historical record of the genesis of the
4 movement in Manhattan's Zuccotti Park or the weeks and months following, to the unlikely extent that
5 this difference in recollection is relevant to the claims at hand.
6 Paragraph 92 is denied in part, admitted in part, and in part denied based on lack of information. Mr.
7 Diamond does not recall George Olivo’s and Vern Nelson’s roles in creating Occupy Irvine; he admits
8 that he played some role in creating it, although not from the very beginning, and that he and Mr. Olivo,
9 among many others, participated in it. He is not certain whether Mr. Nelson would be described as a
10 “participant.” He admits that he and Mr. Nelson assisted in it, but is not certain whether Mr. Olivo's
11 actions constituted “assistance.” He denies that Occupy Irvine was “unplanned.”
12 Paragraph 93 is admitted.
14 Paragraph 98 is admitted in part, denied in part (the article in question was apparently published on
15 December 27, 2011); and denied in part based on lack of information (Mr. Diamond does not know
16 whether Plaintiff was aware of the story in advance; there would have been no need to contact her based
17 on the information at hand, given that Trang Che did not identify Plaintiff or anyone else as her lawyer,
18 nor did she appear to believe, given the notice of foreclosure, that she was then being actively represented
19 at all; Mr. Diamond notes that Plaintiff is neither mentioned nor anonymously maligned in the story.)
20 Paragraph 99 is admitted in part and denied in part: each of those paragraphs does appear in Vern
21 Nelson's story, but their juxtaposition and removal from context here gives a false impression. In any
22 event, Mr. Diamond did not write or adopt those paragraphs.
23 Paragraph 100 is denied in part (the story apparently appeared after the point when Plaintiff claims to
24 have contacted Joe Roberts regarding defamation, no defamation appears in the article as available, if it
25 contained defamation at some point then Vern Nelson responded to a request for correction without Mr.
26 Diamond's knowledge or involvement); denied for lack of information in part (Mr. Diamond does not
27 know whether Plaintiff contacted Roberts), and denied due to the ambiguity of the phrase “working on
28 Trang Che's legal case.” Regarding the latter, Mr. Diamond admits that he offered no legal representation

3
1 of her in any legal proceeding. As Occupy Orange County's “Civic Liaison,” his role was (1) trying to
2 help find her an attorney with relevant expertise (a roster of which Occupy was trying to assemble for
3 situations involving legally dubious foreclosures), which he surmised she did not have based on her
4 statements, which did not include reference to any abortive or continuing suit filed by Plaintiff; (2)
5 represent (in a non-legal capacity) the interests of Occupy in its dealing with government institutions
6 such as police and sheriffs, such as those who were expected to come to evict Trang Che, to ensure a
7 peaceful and lawful interaction; and (3) to aid Occupy in its public relations campaign to publicly
8 embarrass financial institutions who were foreclosing homes without going through proper procedures
9 (such as by using “auto-pens” rather than reviewing individual loans) in order to encourage them to take
10 promised steps to work with homeowners to maximize the likelihood of their being able to stay in their
11 homes. These activities involved both legal and non-legal skills; Mr. Diamond does not recall ever
12 asserting that Trang Che was his “client” and frankly does not understand how any of the above defames
13 Plaintiff. On re-reading the comments to the article, Mr. Diamond recognizes that the intermediaries with
14 whom he was collaborating to find Trang Che an attorney may have been intending to direct her
15 (redundantly, but they wouldn't have known that) to Joe Roberts rather than to Plaintiff, but his
16 recollection has until that review been that she was the only attorney doing such work in Orange County
17 at the time, and that at the time he had a positive opinion of her and her work based on others' reports.
19 Paragraph 102 is denied based on lack of information as to who wrote the December 31 comment to
20 which Mr. Diamond replied that same evening, but he believes that it was Joe Roberts; he admits to
21 having written the comment seeking to learn how to defend victims of unlawful disclosure. (Mr.
22 Diamond does not recall contacting him.)
25 Paragraph 105 is denied. Mr. Diamond did try to put Trang Che in touch with a foreclosure lawyer,
26 through one or more intermediaries who were keeping track of them, not knowing that she had already
27 been involved (by Plaintiff's admission) with both Plaintiff and Joe Roberts. He recalls being told that
28 Trang Che was later represented by Plaintiff and on that basis has asserted that he – not directly, but

4
1 through intermediaries – was among those who had made that referral. Mr. Diamond does not recall ever
2 thinking, let alone telling anyone, that Plaintiff had “botched” Trang Che's case. To the extent that she
3 did so and he had knowledge about it at one time, which he does not presume, it would have been years
4 before a year before a year prior to the filing of this action. Mr. Diamond's understanding of Plaintiff
5 having “botched” legal proceedings is based almost entirely on his reading of the State Bar complaints
6 filed against Plaintiff, her alleged (and to Mr. Diamond's sensibility, unthinkable and scandalous) non-
7 cooperation with the investigations, and their conclusions, which were ratified by the State Supreme
8 Court and a District Court Judge.) Mr. Diamond did hear other reports from figures who knew Plaintiff
9 about he supposedly blowing deadlines and such, but he did not research them and never formed a firm
10 opinion about their veracity. They did suffice to stop him from making any additional referrals to her, out
11 of caution.
12 As to sub-paragraphs 105(a), 105(b), and 105(c), Mr. Diamond admits to writing material at least
13 substantially similar to each. The reference in paragraph 105(a) to a “powerful man” was to California
14 Democratic Party Chair Eric Bauman. (Any reference to Tony Rackauckas would not have been
15 “history.”) Mr. Diamond's statement in paragraph 105(b) about the California Supreme Court's order
16 regarding her suspension was based on his reading of the docket in her disciplinary case and his
17 understanding of the default result if it did not take up her appeal. His opinion about those “foolish
18 enough to have made arrangements with her” was based on reading the charges against her by former
19 clients and noting her apparent refusal to cooperate in the State Bar investigation. Regarding Mr.
20 Diamond's reference in 105(c) to “poor Trang Che” – “poor” referring only to the fact that her condo was
21 foreclosed, not to his evaluation of the value of Plaintiff's actions. Mr. Diamond based on his recollection
22 of the referral on his conversations with intermediaries; he still believes that she was likely the object of
23 his referral through them, whether she eventually took the case through them or not. He recalls giving out
24 Plaintiff's contact information to people facing foreclosure on at least a few occasions subsequent to that
25 as well, until the negative hearsay about her led him to stop. As a political citizen-journalist covering
26 Orange County election races, Mr. Diamond absolutely was interested in knowing more about the quality
27 of Plaintiff's representations of foreclosure clients, especially given the Bar complaints about her.
28 Paragraph 106 is denied. Mr. Diamond was not aware of that opinion at the time.

5
1 Paragraph 107 is denied based on lack of information, except for the ambiguous statement that Mr.
2 Diamond has “denied the assault.” Mr. Diamond has always lacked sufficient information to determine
3 whether an assault took place and, if so, what the attending circumstances were.
4 Paragraph 108 is denied. The term “powerful man” in Paragraph 105(a) was not a reference to Tony
5 Rackauckas. Mr. Diamond did wonder, given Plaintiff's history, whether she was intentionally taking a
6 similar role in this election (given that she was attacking and undermining both of Mr. Rackauckas's
7 candidate), perhaps in the hope of some reward, like the appointment she did receive from Mr. Bauman.
8 He does not know whether she had an arrangement with Mr. Rackauckas and does not recall ever stating
9 that she did. She did objectively “help” him, whether or not he wanted her to, by splitting the Democratic
10 vote with Mr. Murdock and by suing Mr. Spitzer during the primary campaign (and again now.)
11 Paragraph 109 is denied based on lack of information and in Plaintiff's apparent misunderstanding of the
12 word “assisted.” One can be of objective “help” to someone, such as by splitting the vote with an
13 opponent, without an explicit quid pro quo.
14 Paragraph 110 is denied based on lack of information. Trang Che stated that she was facing eviction from
15 her condo. Mr. Diamond does not recall being aware being told or otherwise knowing that she had
16 already had a lawyer. At her request, through an intermediary, he tried to put her in touch with what he
17 was told was the sole lawyer in Orange County who was working at halting foreclosures, whom he later
18 came to believe was Plaintiff because she fit that description. If Plaintiff already had her case at the time
19 when activists were staying with her to stave off foreclosure, Mr. Diamond was not aware of it.
21 Paragraph 112 is denied; as ambiguously phrased, this paragraph may be taken to ask Mr. Diamond to
22 agree that the statements were untrue and placing her in a false light, which he denies.
23 Paragraph 113 is admitted. Mr. Diamond presumes from its wording that this is not an allegation against
24 him.
25 Paragraph 114 is denied based on lack of information. Mr. Diamond did not participate in the production
26 of that article and was under the impression that Plaintiff was suspended for refusing to cooperate in
27 investigation of client complaints. He presumes that this is not an allegation against him.

6
1 Paragraph 117 is denied based on the term “aided and abetted Vern Nelson...” Mr. Diamond commented
2 only minimally on Mr. Nelson's article – and did so because there was something that he wanted to say
3 for its own sake, not for the purpose of driving the article higher in the Google rankings as alleged. Mr.
4 Diamond lacks information on whether commenting on an article even has that effect.
6 Paragraph 131 is denied because Mr. Diamond has not verified Plaintiff's transcription of this comment.
8 Paragraph 134-35 are denied, in part because “Can you be DA if your law license is suspended?” is not a
9 statement, but a question, and Mr. Diamond was sincerely interested in the answer to it.
12 Paragraph 142 is denied with the exception of the statement that Mr. Diamond has seen that the
13 California Bar's web page does state something like that Plaintiff has no prior administrative actions
14 against her, which Mr. Diamond understands to be irrelevant to whether she was listed as suspended.
15 Paragraph 143 is denied based on the ambiguous terms “adopted the statements of Vern Nelson,” and
16 denied with respect to the existence of there being any defamation to aid and abet.
17 Paragraph 144 is denied on the basis that these were not “false blog postings” requiring correction. Mr.
18 Diamond acted in reliance of the published conclusions of the State Bar of California regarding Plaintiff's
19 suspension from practice, which has since been retracted, reinstated, retroactively reversed, and now
20 appears to be again in force.
25 Paragraphs 184-196 are denied as applied to Mr. Diamond; denied based on lack of information as to
26 other defendants.

7
2 Paragraph 202 is denied based on lack of information and due to the uncertain meaning of “posted on the
3 phone of Lenore Albert.”
5 Paragraph 204 is denied based on lack of information and the meaning of “never directly threatened”.
6 Mr. Diamond has seen a published copy of the letter that Plaintiff sent to another lawyer in the course of
7 a dispute (about discovery, he vaguely recalls) where she wrote that if he didn't meet her demands “I will
8 have you all decapitated, and force your children to take your decapitated heads to school as part of show
9 and tell.” Mr. Diamond considers any distinction between this “merely” contingent threat and any “direct
10 threat” to be splitting hairs. (Specifically, neck hairs.)
11 Paragraph 205 is admitted as to Mr. Diamond insofar as it refers solely to a physical copy of the letter
12 being delivered to Mr. Diamond; denied based on lack of information as to other defendants.
14 Paragraph 214-215 are denied based on lack of information.
15 Paragraph 216 is denied as to Mr. Diamond; denied based on lack of information as to other defendants.
17 Paragraphs 218-222 are denied as to Mr. Diamond; denied based on lack of information as to other
18 defendants.
21 defendants.
28 defendants.

8
5 defendants.
6 Paragraphs 303-308 are denied as to Mr. Diamond; denied based on lack of information.
9 Paragraphs 345-346 are admitted based on secondhand knowledge; but to the extent that “enterprise” is
10 intended to mean something like “a predicate enterprise for a RICO suit” they are denied based on lack of
11 information and specifically denied with respect to Mr. Diamond's involvement with them.
13 Paragraphs 360-388 is denied as to Mr. Diamond; denied based on lack of information as to other
14 defendants.
19 defendants.
21 defendants.
23 defendants.
26 defendants.
27 Except as expressly admitted here, Mr. Diamond denies all allegations in the Complaint.
28 Mr. Diamond denies any basis for any of the remedies listed in the prayer for relief.

9
1 AFFIRMATIVE DEFENSES
2 By way of affirmative defenses to the allegations of the complaints herein, Defendant Gregory A.
3 Diamond alleges as follows:
4 FIRST AFFIRMATIVE DEFENSE
5 1. Plaintiff's Complaint as a whole, and each purported cause of action alleged therein, fails to state
6 facts sufficient to constitute a claim against Defendant upon which relief can be granted
7 SECOND AFFIRMATIVE DEFENSE
8 2. Any recovery by Plaintiff is barred because her process was defective (as she listed an incorrect
9 address for her on her summons).
10 THIRD AFFIRMATIVE DEFENSE
11 3. Any recovery on Plaintiff's Complaint, or any purported cause of action alleged therein, is barred
12 by the failure to add a necessary party. Defendant was served this complaint on the last permissible day
13 and has been informed by putative co-Defendant Vern Nelson that he was never served Mr. Diamond has
14 since learned from Plaintiff that, of the dozens of Plaintiff’s listed in this case, only he and Ms. Nira
15 Woods, whom he does not know, were served, rendering her purported intention to prove the elements of
16 a RICO claim involving Mr. Diamond and these other Defendants obviously inoperative.
17 FOURTH AFFIRMATIVE DEFENSE
19 under the equitable doctrines of consent, waiver, estoppel, laches, and/or unclean hands.
20 FIFTH AFFIRMATIVE DEFENSE
22 by the doctrine of in pari delicto, in that Plaintiff's own role in facilitating the alleged predicate actions –
23 which Defendant is informed and believes have not been successfully challenged in any successful
24 adjudication favoring Plaintiff on the underlying merits – far exceed any contribution alleged of
25 Defendant in causing her alleged injuries.
26 SIXTH AFFIRMATIVE DEFENSE
28 in that Plaintiff's alleged injuries or damages, if any, were not caused by acts or omissions of Defendant.

10
1 SEVENTH AFFIRMATIVE DEFENSE
3 by any injuries incurred by Plaintiff’s being caused by other Defendants rather than Mr. Diamond.
4 EIGHTH AFFIRMATIVE DEFENSE
6 in that any flaws in Defendant's statements were de minimus, especially as compared to Plaintiff's own
7 role in their publication
8 NINTH AFFIRMATIVE DEFENSE
10 by the applicable statute of limitation.
11 TENTH AFFIRMATIVE DEFENSE
13 based on the doctrine of preemption of state law by federal law.
14 ELEVENTH AFFIRMATIVE DEFENSE
16 by Defendant’s failure to exhaust administrative remedies.
17 TWELTH AFFIRMATIVE DEFENSE
19 in that Defendant was lawfully exercising his First Amendment right to freedom of speech under the
20 Constitution of the United States.
21 THIRTEENTH AFFIRMATIVE DEFENSE
23 in that Defendant was lawfully exercising his First Amendment right to freedom of the press under the
24 Constitution of the United States.
25 FOURTEENTH AFFIRMATIVE DEFENSE
27 in that Defendant was lawfully exercising his First Amendment right to freedom of speech under the
28 Constitution of the State of California.

11
1 FIFTEENTH AFFIRMATIVE DEFENSE
3 in that Defendant was lawfully exercising his First Amendment right to freedom of the press under the
4 Constitution of the State of California.
5 SIXTEENTH AFFIRMATIVE DEFENSE
7 in that Defendant's statements were true.
8 SEVENTEENTH AFFIRMATIVE DEFENSE
10 in that Defendant reasonably believed his statements to be true, especially given that she was a public
11 figure.
12 EIGHTEENTH AFFIRMATIVE DEFENSE
14 in that Defendant's statements were made in reasonable reliance on public assertions by reliable
15 governmental sources, including the State Bar and the State Supreme Court.
16 NINETEENTH AFFIRMATIVE DEFENSE
18 in that Defendant's statements were opinion.
19 TWENTIETH AFFIRMATIVE DEFENSE
21 in that Defendant's statements were reasonable extrapolations based on available evidence.
22 TWENTY-FIRST AFFIRMATIVE DEFENSE
24 in that any deficiencies in Defendant's statements were due to excusable fragility of memory.
25 TWENTY-SECOND AFFIRMATIVE DEFENSE
27 in that any demands by Plaintiff for retraction of Defendant's statements were unaccompanied by the
28 specific ways in which they were inaccurate and persuasive evidence that they were inaccurate.

12
1 TWENTY-THIRD AFFIRMATIVE DEFENSE
3 in that any demands by Plaintiff for retraction of Defendant's statements were undercut by Plaintiff's
4 demonstrated lack of credibility as a witness.
5 TWENTY-FOURTH AFFIRMATIVE DEFENSE
7 in that Defendant's statements and/or actions were protected by absolute and/or qualified privilege.
8 TWENTY-FIFTH AFFIRMATIVE DEFENSE
10 in that in any instances where clarification or retraction of statements was necessary to avoid
11 impermissible levels of inaccuracy under the law, Defendant made such changes.
12 TWENTY-SIXTH AFFIRMATIVE DEFENSE
14 in that Plaintiff consented to the publication and republication of her disciplinary record as a term of
15 becoming a member of the Bar and/or candidate for office.
16 TWENTY-SEVENTH AFFIRMATIVE DEFENSE
18 in that Plaintiff's Complaint misstates the legal standards required for liability.
19 TWENTY-EIGHTH AFFIRMATIVE DEFENSE
21 in that Plaintiff's fails to provide sufficient evidence that Defendant engaged in actions satisfying the
22 elements required to prove liability for the tort of defamation, particularly given her status as a public
23 figure and (2) Defendant's role covering Orange County elections, including the 2018 primary.
24 TWENTY-NINTH AFFIRMATIVE DEFENSE
27 elements required to prove liability for the tort of false light, particularly given (1) her status as a public
28 figure and (2) Defendant's role covering Orange County elections, including the 2018 primary in which

13
1 she was taking part – to which making even a contingent threat, and even a supposedly “joking” threat
2 (if that is part of her contention) to decapitate opposing legal counsel in a contentious adversary
3 proceeding is relevant to her fitness for office.
4 THIRTIETH AFFIRMATIVE DEFENSE
6 or reduced based on the doctrine of comparative negligence.
7 THIRTY-FIRST AFFIRMATIVE DEFENSE
9 by issue preclusion, in that Plaintiff's the issue of whether she was suspended by operation of an order by
10 the California Supreme Court has already been considered by a California Superior Court judge, who
11 made factual findings that she was in fact suspended, leading him to remove her ballot designation as an
12 attorney, although he allowed her to remain on the ballot in her race. That the suspension of her license
13 was later reversed by the Bar Court – apparently out of concern that her argument that the penalties and
14 other sums that she may owe could be discharged in her recent bankruptcy, a fight that they could avoid
15 by either bringing new charges against her for moral turpitude based on forgery (which they have) or by
16 waiting until her personal bankruptcy was converted to a Chapter 7 (which it has.) Plaintiff is now again
17 suspended. The Superior Court ruling remains in place even during her appeal – which, given the
18 proximity of the upcoming election, is presumably already moot. Plaintiff should be estopped from
19 making claims contrary to the Superior court’s well-documented findings of fact.
20 THIRTY-SECOND AFFIRMATIVE DEFENSE
22 by claim preclusion, in that Plaintiff's claims that she was not suspended by operation of an order by the
23 California Supreme Court have already been considered by a California Superior Court judge, who made
24 factual findings that she was in fact suspended, leading him to remove her ballot designation as an
25 attorney, although he allowed her to remain on the ballot in her race. That the suspension of her license
26 was later reversed by the Bar Court – apparently out of concern that her argument that the penalties and
27 other sums that she may owe could be discharged in her recent bankruptcy, a fight that they could avoid
28 by either bringing new charges against her for moral turpitude based on forgery (which they have) or by

14
1 waiting until her personal bankruptcy was converted to a Chapter 7 (which it has.) Plaintiff is now again
2 suspended. The Superior Court ruling remains in place even during her appeal – which is presumably
3 already moot. Plaintiff should be estopped from making claims contrary to the Superior court’s well-
4 documented adjudication of this claim.
5 THIRTY-THIRD AFFIRMATIVE DEFENSE
8 elements required to prove a violation of RICO.
9 THIRTY-FOURTH AFFIRMATIVE DEFENSE
12 elements required to prove liability for the tort of tortious interference with prospective economic
13 advantage, particularly given her status as a public figure.
14 THIRTY-FIFTH AFFIRMATIVE DEFENSE
17 elements required to prove liability for any other cause of action listed in the complaint but not noted
18 above, particularly given her status as a public figure.
19 THIRTY-SIXTH AFFIRMATIVE DEFENSE
20 36. As a general defense, any recovery on Plaintiff's Complaint, or any purported cause of action
21 alleged therein, is barred in that Plaintiff's accusations of fact (based on “information and belief,” without
22 sufficiently likely evidentiary support, throughout this unverified complaint) are false, inaccurate, and/or
23 scurrilous, including without restriction as noted in the responses to each paragraph appearing above.
24
25 Dated: July 23, 2018 LAW OFFICE OF GREGORY A DIAMOND
26
By /s/ Gregory Diamond
27 GREGORY A. DIAMOND, ESQ.
28 Defendant pro per

15

United States District Court Central District of California: Answer (Corrected) of Greg Diamond, Albert v. Williams 1

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United States District Court Central District of California: Answer (Corrected) of Greg Diamond, Albert v. Williams 1

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Case 8:18-cv-00448-CJC-JDE Document 146 Filed 07/23/18 Page 1 of 15 Page ID #:690

1 Gregory A. Diamond, SBN 256598

26 Paragraphs 2-13 are denied based on lack of information.

28 Paragraphs 15-35 are denied based on lack of information.

Answer (Corrected) of Greg Diamond, Albert v. Williams

16 Paragraph 51 is denied based on lack of information.

18 Paragraphs 53-59 are denied based on lack of information.

21 Paragraphs 61-62 are denied based on lack of information.

22 Paragraphs 63-69 are denied.

23 Paragraphs 70-83 are denied based on lack of information.

26 Paragraphs 85-88 are denied based on lack of information.

27 Paragraphs 89-90 are denied.

Answer (Corrected) of Greg Diamond, Albert v. Williams

5 this difference in recollection is relevant to the claims at hand.

11 actions constituted “assistance.” He denies that Occupy Irvine was “unplanned.”

13 Paragraphs 94-97 are denied based on lack of information.

22 event, Mr. Diamond did not write or adopt those paragraphs.

Answer (Corrected) of Greg Diamond, Albert v. Williams

18 Paragraph 101 is denied based on lack of information.

22 Diamond does not recall contacting him.)

23 Paragraph 103 is denied based on lack of information.

24 Paragraph 104 is denied based on lack of information.

Answer (Corrected) of Greg Diamond, Albert v. Williams

Answer (Corrected) of Greg Diamond, Albert v. Williams

13 opponent, without an explicit quid pro quo.

20 Paragraph 111 is denied based on lack of information.

28 Paragraphs 115-116 are denied based on lack of information.

Answer (Corrected) of Greg Diamond, Albert v. Williams

5 Paragraphs 118-130 are denied based on lack of information.

7 Paragraphs 132-33 are denied based on lack of information.

10 Paragraphs 136-139 are denied based on lack of information.

11 Paragraphs 140-141 are denied.

20 appears to be again in force.

21 Paragraph 145 is denied based on lack of information.

22 Paragraphs 146-152 are denied.

23 Paragraphs 153-172 are denied based on lack of information.

24 Paragraphs 173-183 are denied based on lack of information.

27 Paragraphs 197-199 are denied.

28 Paragraph 200 is denied based on lack of information.

Answer (Corrected) of Greg Diamond, Albert v. Williams

1 Paragraph 201 is denied.

3 phone of Lenore Albert.”

4 Paragraph 203 is denied based on lack of information.

10 threat” to be splitting hairs. (Specifically, neck hairs.)

13 Paragraphs 206-213 are denied.

14 Paragraph 214-215 are denied based on lack of information.

16 Paragraph 217 is denied based on lack of information.

19 Paragraphs 223-224 are denied based on lack of information.

22 Paragraph 229 is denied based on lack of information.

24 Paragraphs 231-239 are denied based on lack of information.

26 Paragraph 241 is denied based on lack of information.

Answer (Corrected) of Greg Diamond, Albert v. Williams

1 Paragraphs 250-268 are denied based on lack of information.

2 Paragraphs 269-285 are denied based on lack of information.

3 Paragraphs 286-298 are denied based on lack of information.

12 Paragraphs 347-359 are denied based on lack of information.

15 Paragraph 389 is denied based on lack of information.

17 Paragraph 391 is denied based on lack of information.

24 Paragraphs 404-413 are denied based on lack of information.

Answer (Corrected) of Greg Diamond, Albert v. Williams

3 Diamond alleges as follows:

4 FIRST AFFIRMATIVE DEFENSE

7 SECOND AFFIRMATIVE DEFENSE