MJB Bixby Construction Co. Lawsuits

[Ayatollahgondola]

This is from El Dorado County

Defendants allege that if they did not perform the tc.'fmS and conditions of any part of any
contract with plainuft: it was because such penormance was prevented. by plaintiff.

Defendants allege that the claim for mechanic's lien is willfUlly overstated and that
defendal1ts have performed all obligations owing on their part to be perfonncd, including
pay:menr for work.
Defendants allege that there are valid offsets, counter~c]aims and back charges against
j plaimitfsubstantially in excess of the amount sought by Plaintiff
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23 I TWENTY-SECONP AFF]RMATJV~ DEFEN~
24 i Defendants allege that plaintiff materially breached the contract referred to in the
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25 , Complaint by failing to perfcnn diligently and in a workmanlike manner the renns and
26 i conditions ofthe Contract and its obligations thereunder therehy excusing any purported
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27 I bn:aches of me Contract by defendants, and each of "them
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MARTY AND