Free Answer to Complaint - District Court of Delaware - Delaware

Case 1 :05-cv—OO243-SLR Document 2 Filed O4/29/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF DELAWARE
ESTATE OF THELMA J. MARR, and )
ELLIS D. MARR, AS ADMINISTRATOR)
OF TI-IE ESTATE OF THELMA J. MARR)
And individually, ) C.A. No. D5-243
)
Plaintiffs, )
)
v. )
)
STONEBRJDGE LIFE INSURANCE )
COMPANY, a foreign corporation, )
)
Defendant. )

1. Admitted.
2. Admitted.
3. Denied as stated.
4. Denied as stated.
5. Admitted.
6. Denied.
7. Denied.
S. Admitted.
9. Admitted.
FIRST AFFIRMATIVE DEFENSE
The Complaint fails to state a claim upon which relief may be granted.

Case 1:05-cv—O0243-SLR Document 2 Filed O4/29/2005 Page 2 of 2
SECOND AFFIRMATIVE DEFENSE
Plaintiffs have failed to follow the terms and conditions of the subject
Stonebridge Life Insurance policy.
THIRD AFFIRMATIVE DEFENSE
Pl:-1intiffs’ complaint is barred under the doctrine of estoppel.
FORTH AFFIRMATIVE DEFENSE
Plaintiffs’ complaint is barred under the doctrine of waiver.
FIFTH AFFIRMATIVE DEFENSE
Plaintiffs’ complaint is barred under the doctrine of release.
WHEREFORE, Defendant, Stonebridge Life Insurance Company, demands
judgment be entered in its favor and against Plaintiffs, plus interest and cost of suit.
MORGAN SHELSBY dt LEONI
ls! Michael I. Logullo
MICHAEL I. LOGULLO
[email protected]
131 Continental Drive, Suite 206
Newark, Delaware 19713
(302) 454-7430
Attorney for Defendant,
Stonebridge Life Insurance Company
DATE: April 29, 2005