Free Answer to Complaint - District Court of Connecticut - Connecticut

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I UNITED STATES DISTRICT COURT
I — DISTRICT OF CONNECTICQIIIN JAN 2 3 ID 3: 5 5 I
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I BRL°*NKEN¥*lEDY· I ‘·1:I,I?III=IiII%I. CI. I
_ Plalnuftl : 3:03CVl O38(RNC) I
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· KEVIN FOLEY, : January 23, 2004 I
Defendants. ;
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ANSWER
I ` - The defendant, Kevin Foley, hereby responds to the allegations of the plaintiffs
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I complaint as follows:
I 1. As to paragraph 1, the defendant has insufficient knowledge upon which
to form a belief and therefore denies the same and leaves the plaintiff to his proof
2. Paragraphs 2, 3 and 4 are admitted.
3. As to paragraphs 5, 6 and 7, the defendant has insufficient knowledge
upon which to form a belief and therefore denies the same and leaves the plaintiff to his i
proof. I
4. Paragraph 8 is denied insofar as it alleges that the defendant refhsed to I
comply with repeated demands and became agitated and belligerent. As to the
I remaining allegations in paragraph 8, the defendant has insufficient knowledge upon I
which to form a belief and therefore denies the same and leaves the plaintiff to his proof
5. Paragraph 9 is denied insofar as it alleges when the defendant refused to I
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I comply with repeated demands. As to the remaining allegations in paragraph 9, the ' I
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1 I defendant has insufficient knowledge upon which to form a belief and therefore denies 1
I the same and leaves the plaintiff to his proof 1
6. As to paragraph 10, the defendant has insufficient knowledge upon which 1
to form a belief and therefore denies the same and leaves the plaintiff to his proof
counr ONE: 1
T 1. The defendant hereby incorporates his responses to paragraphs 1-10 of the
previous section as his corresponding responses to paragraphs 1-10 of Count One as if
fully set forth herein.
2. Paragraphs ll and 12 are denied.
3. Paragraph 13 is denied insofar as it alleges as a direct and proximate result
- of the negligence and carelessness of defendant. As to the remaining allegations in
· paragraph 13, the defendant has insufficient knowledge upon which to form a beliefand
therefore denies the same and leaves the plaintiff to his proof
4. Paragraphs 14, 15, and 16 are denied insofar as they allege as a further 1
n result of the negligence and carelessness of defendant. As to the remaining allegations in I
paragraphs 14, 15 and 16, the defendant has insufficient knowledge upon which to fonn a
A belief and therefore denies the same and leaves the plaintiff to his proof I
I COUNT TWO:
1. The defendant hereby incorporates his responses to paragraphs 1-10 of the l
first section as his corresponding responses to paragraphs l-10 of Count Two as if fully
set forth herein. _
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· 2. Paragraphs 11 and 12 are denied.
3. Paragraph 13 is denied insofar as it alleges as a direct and proximate result I
of the intentional, wanton and/or recklessness of defendant. As to the remaining {
allegations in paragraph 13, the defendant has insufficient knowledge upon which to form
a belief and therefore denies the same and leaves the plaintiff to his proof J
4. Paragraphs 14, 15 and 16 are denied insofar as they allege as a further H
{ result of the intentional, wanton and/or recklessness of the defendant. As to the l
remaining allegations in paragraphs 14, 15 and 16, the defendant has insufficient i
_ knowledge upon which to form a belief and therefore denies the same and leaves the `
plaintiff to his proof. ·
Respectfully submitted,

Rya P. Barry ·
Moukawsher & Walsh, LLC
— 21 Oak Street, Suite 209 A
Hartford, CT 06106 i E
Tele. No: (860) 549-8440
Fax N0: (860) 549-8440
Email: [email protected]
Fed. Bar Id: et 21683 -
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This is to certify that a copy of the foregoing was mailed, postage prepaid, on thisggj
day of January 2004, to the following counsel of record: {
J eftrey L. Ment {
Rome, McGuigan & Sabanosh {
One State Street . {
Hartford, cr 06103
(860) 549-1000 {
Wn {
Ry P. Barry {
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