v1996-62

48

Fred W. Pooler i

and up to and including the tin

alleged therein, (a period of ap

months) plaintiff knew and appi

exercise of ordinary care, shoulc

appreciated that said wire const

over which plaintiff might trip, i

That during all of said time, u

the time of the alleged accident, p

reasonable exertion and no exf

trifling expense, have removed

removed from his property, and

exercise of ordinary care, shoulc

fact.

That, notwithstanding said fa

careless and negligent disregard

himself, carelessly and negligently^

to remain on his property for a

mately seven months, and with (

gent disregard for the safety o

or about the 20th day of June, 19

carelessly and negligently walk ir

property, resulting in his tripping

on or over said wire, and this def

any damage ot' injury that pla

reason of said fall was due to j

aforesaid negligence of the plaim

And for further answer to plaii

of action, and as and for a sec(

fense thereto, this answering defe

---

archive.org Volume Name: govuscourtsca9briefs1996

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

Document Link: http://archive.org/stream/govuscourtsca9briefs1996#page/n61/mode/1up

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