Free Answer to Third Party Complaint - District Court of Connecticut - Connecticut

l — Case 3:03-cv-01013-SRU Document 54 Filed 06/24Z2004 Page 1 of 4 `jg
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i UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MARSHALL AVIATION, LLC 1 CIVIL ACTION NO.
v. 303CVl0l3 (SRU)
AIG AVIATION, INC. and
THE INSURANCE COMPANY OF :
THE STATE OF PENNSYLVANIA :
MJ AVIATION, LLC, LJ AVIATION, LLC
and LOUIS PUGLIESE, JR. 1 JUNE 23, 2004
ANSWER AND SPECIAL DEFENSES OF THIRD-·PARTY DEFENDANTS, I
LJ AVIATION, LLC AND LOUISE PUGLIESE, JR.
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1. As to the allegations contained in paragraphs 1, 2, 3, 6 and 7, these third—party
defendants have insufficient knowledge or information upon which to form a belief and therefore
deny the same and leave the third-party plaintiffs to their proof
2. Paragraph 4 is admitted.
3. Paragraph 5 is admitted insofar as it alleges that third-party defendant, Louis
Pugliese, Jr. is a resident of Connecticut and an employee of LJ Aviation, LLC. The remainder of
said paragraph is denied.

. Case 3:03-cv-010635SRU Document 54 Filed 06/24/$004 Page 2 of 4 l
4 Paragraph 8 is denied with respect to the third—party defendant, LJ Aviation, LLC
and admitted with respect to the third-party defendant, MJ Aviation, LLC.
5. Paragraph 9 is admitted insofar as it alleges that the third—party defendant was an
employee of the third-party defendant, MJ Aviation, LLC. The remainder of said paragraph is
denied.
6. Paragraph 10 is admitted insofar as it alleges an annual inspection on or about
November 14, 2002. The remainder of said paragraph is denied.
7. Paragraphs ll, 12, 13 and 14 are denied.
FIRST SPECIAL DEFENSE j
The third—party complaint fails to state a claim upon which relief may be granted.
SECOND SPECIAL DEFENSE
The defendants and third-party plaintiffs and/or any party or parties whose rights are
claimed to be subrogated to the defendants and third-party plaintiffs, have failed to mitigate their
damages.
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THE DEFENDANTS, \
LJ AVIATI , LLC AND LOUIS PUGLIESE, JR. !
B .
Ric d J. Kenny
F ul Bar N0. ct0431 1
Kenny, O’Keefe & Usseglio, P.C.
Their Attorneys
21 Oak Street, Ste. 208
J Hartford, CT 06106
(860) 246-2700
(860) 246-6480
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CERTIFICATION l
I hereby certify that a copy of the foregoing was mailed; postage prepaid this 23rd day of I
June, 2004 to the following:
Robert J. O’Brien, Esq.
Jonathan Snyder, Esq.
Gordon, Muir & Foley, LLP
10 Columbus Boulevard I
Hartford, CT 06106
Steven E. Arnold, Esq.
Peter Van Dyke, Esq.
Stanger & Arnold, LLP
29 South Main Street
West Hartford, CT 06107
Eric P. Smith, Esq.
Lynch, Traub, Keefe and Errante
52 Trumbull Street
P.O. Box 1612
New Haven, CT 06506-1612 f,//.
//
ich? J. Kenny 1
K y, O’Keefe & Usseglio, P.C.
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