v1996-64

50

Fred w . rooicr

Aiid for answer to plainti

of action, and as and for a thii

rate defense thereto, this answe

leges :

That from the time said w

plaintiff's yard and/or on his

knew and appreciated, or, in tl

nary care, should have known ai

said wire constituted an obsta

might trip, stumble or fall.

That during all of said time, i

the time of the alleged accident, '

reasonable exertion and no expe

fling expense, have removed said

property, and knew, or, in the e

care, should have known said f

That in the exercise of reasoi

gence, plaintiff could have, by i

said wire removed, avoided anc

injury and/or damage to his p

fendant alleges that plaintiff's i

due to and proximately caused

remove or have said wire remov

And for fui'ther answer to plai

of action and as and for a four

rate defense to said second ca

answering defendant alleges:

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archive.org Volume Name: govuscourtsca9briefs1996

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

Document Link: http://archive.org/stream/govuscourtsca9briefs1996#page/n63/mode/1up

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