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Seymour Responds

Seymour Responds

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Published by ValleyIndyDotOrg
Seymour Responds
Seymour Responds

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Published by: ValleyIndyDotOrg on Jul 16, 2014
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07/16/2014

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NO: AAN-CV-14-6015474-S : SUPERIOR COURT  ANGELA BORELLI, ADMINISTRATRIX : OF THE ESTATE OF BRANDON : GIORDANO : J.D. OF ANSONIA/MILFORD v. : AT MILFORD OFFICER ANTHONY RENALDI, : OFFICER MICHAEL JASMIN, : SERGEANT WILLIAM KING AND : TOWN OF SEYMOUR : MAY 6, 2014
ANSWER AND SPECIAL DEFENSES COUNT ONE Negligence as to defendants Anthony Renaldi and Michael Jasmin)
1-3. As to paragraphs 1, 2 and 3, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion about the truth of the matters contained therein and, therefore, leaves the plaintiff to her burden of proof. 4. Paragraph 4 is admitted. 5. As to paragraph 5, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion about the truth of the matters contained therein and, therefore, leaves the plaintiff to her burden of proof. 6-8. Paragraphs 6, 7 and 8 are admitted. 9-10. As to paragraphs 9 and 10, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion about the truth of the matters contained therein and, therefore, leaves the plaintiff to her burden of proof.
 
 
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11. Paragraph 11 is admitted. 12. That portion of paragraph 12 which states: “At said time and place, defendant Officer Renaldi turned his police cruiser around and attempted to “catch up” to the silver Ford Mustang” is admitted. As to the remainder of paragraph 12, it is denied. 13-21. Paragraphs 13, 14, 15, 16, 17, 18, 19, 20 and 21 are denied. 22. That portion of paragraph 22 which states: “As a direct and proximate result of the defendants’ negligence and the aforementioned collision” is denied. As to the remainder of paragraph 22, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion and, therefore, leaves the plaintiff to her burden of proof. 23. That portion of paragraph 23 which states: “As a direct and proximate result of the defendants’ negligence” is denied. As to the remainder of paragraph 23, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion and, therefore, leaves the plaintiff to her burden of proof. 24. That portion of paragraph 24 which states: “As a direct and proximate result of the aforementioned negligence of the defendants” is denied. As to the remainder of paragraph 24, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion and, therefore, leaves the plaintiff to her burden of proof. 25. That portion of paragraph 25 which states: “As a direct and proximate result of the aforementioned negligence of the defendants” is denied. As to the remainder of paragraph 25, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion and, therefore, leaves the plaintiff
 
 
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to her burden of proof.
COUNT TWO Negligence as to defendant William King)
1-20. The answers to paragraphs 1 through 20 of the First Count are hereby incorporated and made the answers to paragraphs 1 through 20 of this Second Count, as if fully set forth herein. 21-22. As to paragraphs 21 and 22, this defendant does not have sufficient knowledge or information upon which to base a belief or opinion about the truth of the matters contained therein and, therefore, leaves the plaintiff to her burden of proof. 23. Paragraph 23 is denied. 24-27. The answers to paragraphs 22 through 25 of the First Count are hereby incorporated and made the answers to paragraphs 22 through 25 of this Second Count, as if fully set forth herein.
COUNT THREE Liability as to Town of Seymour pursuant to C.G.S. § 52-557n)
1-25. The answers to paragraphs 1 through 25 of the First Count are hereby incorporated and made the answers to paragraphs 1 through 25 of this Third Count, as if fully set forth herein. 26-52. The answers to paragraphs 1 through 27 of the Second Count are hereby incorporated and made the answers to paragraphs 26 through 52 of this Third Count, as if fully set forth herein. 53. Paragraph 53 is denied.

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