State of California
In the County Court
In & for the County of Los Angeles

Andrew J. Kraszynski
Plaintiff

Vs.

The Los Angeles Petroleum Refining Company
Defendant

ANSWER

Now comes the above named defendant and for answer to the complaint herein filed – denies that the said plaintiff on the 10th day of April 1874, or at any other time, was the owner of the premises in the complaint described, or entitled to the possession thereof. And for further answer, the said defendant denies that they on the 10th day of April, 1874, or at any other time, were occupying the premises in said complaint described or any portion thereof, as tenant at will of said Plaintiff, or in any other manner as tenant, or under, said plaintiff.

And for further answer defendant alleges that on the 24th day of October, 1873, one Adam Malezewski was the owner of the premises in complaint described and on that day, for value received, did sell the said premises to wit, the said two acres described in the complaint, as being occupied by defendant, and demanded by plaintiff, in his said complaint, and did give his certain contract under seal and in writing, duly executed by him, to execute and deliver all necessary deeds for said two acres to said corporation, the defendant herein; under which said contract this defendant entered upon said two acres and proceeded to erect large furnaces and other works for the purpose of refining crude petroleum. That on the 6th day of August, 1872, the said Malezewski leased the said premises in complaint described, including the said two acres, to one O. P. Robbins for 3 years from the said 6th day of August, 1872, and on the 21st day of July, 1873, the said Robbins assigned and transferred the said lease to one Peter Jorgenson and A. J. Krazynski, the plaintiff herein, and that the only interest the said plaintiff has, or ever had, in said premises is, and was, by virtue of said lease and assignment; that on the said 24th of October, 1873, and prior to the execution of said contract to convey, the said two acres from the said Adam Malezewski to this defendant, the said plaintiff and the said Peter Jorgenson surrendered their lease to the said two acres to the said Adam Malezewski for a valuable consideration.

And for a further answer defendant avers that prior to said purchase by defendant from Malezewski and the entry of defendant into possession of the said two acres, the said Peter Jorgenson and plaintiff represented to defendant that they had surrendered their lease, as to the two acres, demanded in the complaint to said Adam Malezewski for the purpose of enabling the defendant to erect certain oil refining works thereon, and upon the consideration that the erection of said oil refining works would be of great advantage to said Jorgenson and said plaintiff, in their hotel and store business in which they were then and there engaged, on lands adjoining and near the said two acres; that defendant relying upon such representations of said Jorgenson and plaintiff, entered upon said two acres and erected large and valuable works for refining petroleum at the cost of three thousand dollars and upwards.

And further answering defendant, denies that plaintiff has suffered damages in the sum of one thousand dollars, or any other sum, by the occupancy or detention of said two acres, or by the erection of said works thereon, by this defendant; but defendant avers that plaintiff has been benefitted in his hotel and store business by the erection of said works and use thereof by defendant, in the sum of one thousand dollars and upwards.

Wherefore defendant prays to be dismissed hence with its costs and disbursements herein expended.

J.E. Howard & Sons
& Ganahl & McDaniel
Attorneys for Defendant

Filed May 19, 1874