Module #4 Assignment - Answer
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Ivy Tech Community College, Indianapolis *
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Course
202
Subject
Law
Date
Feb 20, 2024
Type
docx
Pages
3
Uploaded by cesiaeves
STATE OF INDIANA
)
IN THE LITIGATION COUNTY SUPERIOR COURT NO. 5
) SS:
COUNTY OF LITIGATION
)
CAUSE NO.: 64D05-1602-CT-000086
)
RICHARD HART and
)
MERCURY PARCEL
)
SERVICE, INC.,
)
Defendants,
)
)
)
v.
)
)
ANN FORRESTER and
)
WILLIAM FORRESTER,
)
Plaintiffs,
)
_____________________________________________________________________________________
DEFENDANT’S ANSWER AND COUNTERCLAIM
Comes now the Defendant, Richard Hart, by and through his undersigned attorney, Keanu
Reeves, hereby answers the Plaintiffs' Complaint as follows:
COUNT I: NEGLIGENCE
1.
Denied that Defendant drove vehicle negligently.
2.
Admitted.
3.
Defendant denies the allegations in paragraph 3 of the Complaint as Defendant lacks sufficient knowledge or information to form a belief as to the truth of said allegations.
4.
Defendant denies the remaining allegations in paragraph 4 of the Complaint as Defendant
lacks sufficient knowledge or information to form a belief as to the truth of said allegations.
FIRST AFFIRMATIVE DEFENSE
Lack of Subject Matter Jurisdiction: Defendant asserts that this court lacks subject matter jurisdiction over certain claims asserted in the Complaint.
COUNT II: LOSS OF CONSORTIUM
1.
Defendant denies the remaining allegations in paragraph 1of the Complaint as Defendant lacks sufficient knowledge or information to form a belief as to the truth of said allegations.
2.
Defendant denies the remaining allegations in paragraph 2 of the Complaint as Defendant
lacks sufficient knowledge or information to form a belief as to the truth of said allegations.
3.
Defendant denies the remaining allegations in paragraph 3 of the Complaint as Defendant
lacks sufficient knowledge or information to form a belief as to the truth of said allegations.
FIRST COUNTERCLAIM: CONTRIBUTION
Defendant asserts that Plaintiff, Ann Forrester, was partly responsible for the accident described in the Complaint. Defendant alleges that Plaintiff's actions or omissions contributed to the occurrence of the accident, thereby causing or contributing to the damages suffered by Plaintiff. Defendant seeks contribution from Plaintiff for any proportionate fault attributable to her actions or omissions.
SECOND COUNTERCLAIM: INDEMNIFICATION
Defendant asserts that Plaintiff, Ann Forrester, is obligated to indemnify Defendant for any damages, costs, or expenses incurred by Defendant as a result of Plaintiff's actions or omissions leading to the accident described in the Complaint. Defendant alleges that Plaintiff's conduct constituted a breach of duty owed to Defendant, thereby triggering Plaintiff's obligation to indemnify Defendant against any adverse consequences arising from such breach.
REQUEST FOR TRIAL BY JURY
WHEREFORE, Defendant demands a trial by jury, requests the dismissal of Plaintiffs' Complaint, and requests judgment to be entered in favor of Defendant for costs and disbursements by jury pursuant to Indiana Trial Rule 38.
CERTIFICATE OF SERVICE
I hereby certify that on the 30th day of April 2016, I mailed a copy of this Answer to the plaintiffs, Ann and William Forrester’s attorney, Cesia G. Eves, by ordinary mail.
Dated:________________
by: /s/_Keanau Reeves
____
Keanu Reeves, Esq, #3355449
Reeves, Beeves, and Deeves Law.
345 Buckeye Ln
Columbus, OH 43215
Phone: 614-123-4567
Fax: 614-183-6738
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