v1996-58

44

Fred W. Pooler i

carelessly and negligently walk ii

property, resulting in his tripping

on or over said wire, and this def

any damage oi- injury that pla:

reason of said fall was due to i

aforesaid negligence of the plaint

And for further answer to Plai

of Action and as and for a Secoi

fense thereto, this answering Dei

That from the time the wire re

tiff's complaint, was placed in pi

up to and including the time of t

therein, (a period of approximat

plaintiif knew and appreciated, '

of ordinary care, should have 1

ciated that said wire constitutec

which plaintiff might trip, stum

That during all of said time, u

the time of the alleged accident, p

reasonable exertion and no ex- 4^

trifling expense, have removed

removed from his property, anc

exercise of ordinary care, shouk

fact.

That, notwithstanding said fa

careless and negligent disregard

himself, carelessly and negligentl;

to remain on his property for a

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archive.org Volume Name: govuscourtsca9briefs1996

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

Document Link: http://archive.org/stream/govuscourtsca9briefs1996#page/n57/mode/1up

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