v1996-60

Document Title Page

46

Fred W. Pooler i

said wire removed, avoided andy

injury and/or damage to his pei

fendant alleges that plaintiff's h

due to and proximately caused b)

move or have said wire removed

vVnd for further answer to pla

of action and as and for a fourtl

rate defense to said first cause of c

ing defendant alleges:

That from the time said reel:

unwound and spread and envelo

way, said wire was in plain view o

ing all of the time that he was w;

up to and including the time th

entangled in said wire and that i

less and negligent disregard for

self, carelessly and negligently h

he was walking and carelessl_^

walked into and allowed his f

tangled in said wire in broad da

his tripping and/or stumbling an^

said wire and this defendant alh

age or injury that plaintiff sust.

said fall was due to and cause(

negligence of the plaintiff.

As and for its answer to plai

of action set forth in his compla

  1. Admits the allegations of

II thereof.


archive.org Volume Name: govuscourtsca9briefs1996

Volume: http://archive.org/stream/govuscourtsca9briefs1996

Document Link: http://archive.org/stream/govuscourtsca9briefs1996#page/n59/mode/1up

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