v1996-60
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
- 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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