v1996-74

Document Title Page

60

Fred W. Pooler v

(Testimony of Fred W. Pooler.)

Mr. GUNN: May I interrupt

fact that this stipulation will prec

tion to the witness I feel that ^

time interpose our formal objec

duction of any testimony, and I

enumerate the grounds.

Comes now the defendant and

troduetion of any evidence on

that the first cause of action ii

sufficient to constitute a cause of

defendant: second, that it disclo

a matter of law, that plaintiff as

injury from falling or tripping

allowing it to remain in his yar

approximately seven months anc

therefrom or to a place where 1

tripped or fallen over it: third, t

its face that plaintiff, as a matter

of contributory negligence, barri

not removing the wire from his

where he would not have fallen

seven months and in not looki

stepping and in failing to exercisi

it discloses on its face that th(

omissions of the defendant were

cause of plaintiff's injuries: fifth

face that plaintiff could have a

quences of defendant's alleged i

wrongful act or omission by ei

gence and reasonable care for


archive.org Volume Name: govuscourtsca9briefs1996

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