In the 17th District Court of the State of California
In and for the County of Los Angeles

Nathaniel J. Clark
Plaintiff

Vs.

Ruben Denton
Defendant

Answer of defendant to plaintiffs amended complaint.

The defendant in the above entitled action, for answer to the amended complaint of plaintiff, in said action, the said amended complaint having been served and filed before answer to the original complaint herein;

Denies, on information and belief, that at given times between the first day of August 1875, and the first day of December 1875, the plaintiff loaned or advanced to D. C. Scott and J. G. Baker the sum of $1505 in gold coin or other currency of the United States, to be used in and about the Star Oil Works, or that he loaned or advanced any other sum of money whatever for that purpose or that said plaintiff ever, at any time, loaned or advanced to said Scott and Baker the sum of $1505 or any other sum whatever, or for any purpose whatever, except as hereinafter admitted.

Denies that plaintiff ever advanced or loaned to said Scott and Baker any money whatever for the purpose of purchasing of supplies and fixtures for the Star Oil Works or for the purpose of manufacturing oil, or for the purpose of carrying on the business of the Star Oil Works in the County of Los Angeles, except the sum of $200 which said defendant, at the request of said Scott and Baker paid to plaintiff.

Denies that the note of D. G. Scott set out in the complaint for $250, was for the use of Scott and Baker or that the sum or the partial thereof or any part thereof was used or expended for, in, or about, the business of the Star Oil Works, or in the purchases of supplies therefore, but avers the fact to be that the said sum of money was loaned by plaintiff to said Scott on his private and individual account.

Denies that plaintiff loaned or advanced to said Scott and Baker on the 11th day of October 1875, or at any other time, the sum of $425 in gold or other currency of the United States, or any other sum for the purpose of carrying on the business of the said Star Oil Works, or for any other purpose whatever.

Denies that on the 18th day of October 1875, the said plaintiff advanced or loaned to the said Scott and Baker the sum of $130 in gold coin or other currency of the United States, or any other sum of money whatever, to be used in and about the business of the said Star Oil Works, or for the purchase of supplies, items for, or for any other purpose whatever.

Denies that on the 20th day of October 1875, or at any other time, plaintiff loaned or advanced to said Scott and Baker, the sum of $150 in gold coin or other currency of the United States, or any other sum whatever, for the purpose of carrying on the business of the said Star Oil Works, or for the purchase of supplies, items for, or for any other purpose whatever.

Denies that on the 25th day of October 1875, or at any other time, the said plaintiff loaned or advanced to the said Scott and Baker the sum of $350, in gold coin or other currency of the United States, or any other sum whatever, for the purpose of carrying on the business of said Star Oil Works, or of purchasing supplies, times for, or for any other purpose whatever.

Denies on his own knowledge that subsequent to the advances and loans alleged in plaintiff’s complaint, or at any other time, he, the said defendant, agreed by contract in writing or otherwise with said Scott and Baker, or with the said plaintiff, to pay to plaintiffs for, or on account of said Scott and Baker, or for as an account of the business of the said Star Oil Works, or for an account of supplies or material furnished, to said Scott and Baker [?] the sum of $1505 in gold coin or any other currency of the U.S. or any other sum of money whatever, except Star issue of $200 and interest in gold coin which defendant duly paid to plaintiff.

Denies that he, the said defendant, agreed, contracted, or promised in writing, or otherwise, on or about the 22d day of March 1876, or at any other time, to and with said Scott and Baker or that he contracted, agreed, or promised, to the said plaintiff in writing or otherwise, on the said date, or at any other time, to pay to said plaintiff for, or an account of, said Scott and Baker, or on account of the said Star Oil Works, the sum of $250 in gold coin or other currency of the United States, set out in plaintiff’s complaint, as a promissory note from D.G. Scott to plaintiff, or any other sum whatever, or that he on the said date, or at any other time, agreed with, contracted, or promised in writing or other means, the said Scott and Baker, or the plaintiff herein, to pay plaintiff the sum of $425 in gold coin or other currency of the United States, or the sum of $130 in gold coin or other currency of the United States, or the sum of $150 in gold coin or other currency of the United States, or the sum of $350 in gold coin or other currency of the United States.

Denis that he, the said defendant, on the said 22d day of March 1876 or at any other time, contracted, agreed, or promised in writing or otherwise to, and with, the said Scott and Baker, or with the said plaintiff, to pay any or either of the said, several sums of money hereinabove set forth, to the said plaintiff, on account of the said Scott and Baker, or the said Star Oil Works, or any part thereof.

Denies that the said defendant ever, at any time, or place, agreed, contracted, or promised in writing or otherwise to pay any debt, or debts, of the said Scott and Baker, or that he ever assumed, by agreement or contract in writing or otherwise, to pay any or either of the several sums of money hereinbefore set forth for the said Scott and Baker, to the said plaintiff, or to any other persons whatever, or any sum or sums of money whatever.

Wherefore defendant, having fully answered, prays judgment of the said action, that the same be dismissed, and for the costs of suit in this behalf expended.

Whiting & King
Defendant’s attorneys

Filed October 11, 1876