Free Answer to Counterclaim - District Court of Delaware - Delaware

Case 1 :08-cv—00089-GIVIS Document 6 Filed 02/29/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
JOSEPH KNOPF, i Case N0.: 08-0089
Plaintiff, )
v. g JURY TRIAL DEMANDED
WILLIAM GONZALEZ, TRANSCO g
INC., and MCLANE COMPANY, INC., )
Defendants. g
PLAINTIFF’S RESPONSE TO DEFENDANTS’ COUNTERCLAIM
11 [sic]. As to defendants’ Ninth separate defense, it is admitted that this Court
lacks personal jurisdiction over defendants since diversity of citizenship has not been
established. The averments contained in the remaining separate defenses are denied.
l2 [sic]. Admitted.
13 [sic]. It is denied that the tractor trailer was owned by defendant McClane
Company. The balance of the allegations contained in paragraph 13 are admitted.
14 [sic]. Denied.
15 [sic]. Plaintiff is without sufficient information to admit or deny the allegations
contained in paragraph 15. Any damage to the trailer or loss of use of the tractor-trailer
was caused by the negligence of defendant William Gonzalez, any negligence on the part
of plaintiff is denied.

Case 1:08-cv—00089-G|\/IS Document 6 Filed 02/29/2008 Page 2 of 2
WHEREFORE, plaintiff respectfully requests that the counterclaim of defendant
McClane Company, Inc. be denied and that judgment be entered in plaintiffs favor.
MO A S, LLP
VIN G. HE L .D. 430)
16 Polly Drummond Hil oad
Newark, Delaware 19711
(302) 368-4200
Email: [email protected]
Attomeys for Plaintiff
Dated: Q {g/ {Org

Case 1:O8—cv-00089-GI\/IS Document 6-2 Filed O2/29/2008 Page 1 of 1
CERTIFICATE OF SERVICE
I, Kevin G. Healy, hereby certify that on this Qmy of February, 2008, two
true and correct copies of the attached document were served on the following
individual(s) via first class mail:
Delia Ann Clark, Esq.
Rawle & Henderson
300 Delaware Ave., Suite 1015
Wilmington, DE 19801
MO JA LLP
,»/
/
VIN G. HEALY ( /. #2 0)
16 Polly Drummond Hill ad
Newark, Delaware 1971
(302) 368-4200
Email: [email protected]
Attorneys for Plaintiff
KGH/113196-0001/1697049/1

Case 1:08-cv-00089-GMS

Document 6

Filed 02/29/2008

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Case 1:08-cv-00089-GMS

Document 6

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Case 1:08-cv-00089-GMS

Document 6-2

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