UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

CURT MARCEILLE, )
)
Plaintiff, ) CIVIL ACTION
v. )
) NO. __________
KENNETH GALVIN, )
)
Defendant. )

ANSWER TO COMPLAINT

Comes now the Defendant, KENNETH GALVIN, in answer to the action from Plaintiff

for relief:

The Defendant, KENNETH GALVIN, admits this is an action for negligence.

1. The Defendant admits that Plaintiff, CURT MARCEILLE, asserts he is a resident of

Cook County according to knowledge.

2. Defendant, KENNETH GALVIN, admits he is a resident of Marathon County.

3. Paragraph four states Plaintiff operated a vehicle headed east on Washington Street at

Dearborn Street, which Defendant admits.

4. In answer to paragraph 5, the Defendant admits he was travelling northbound on

Dearborn in the same intersection.

5. Defendant admits at that time the two vehicles collided.

6. In answer to paragraph 7, the Defendant admits he had a duty to exercise care while

operating his vehicle. Defendant admits that he did so.

7. Defendant does not admit to the breaches alleged in paragraph 8. Defendant denies

his actions were the cause of the collision and resulting damage to the Plaintiff’s

vehicle.

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 8. Defendant has no knowledge of the Plaintiff’s damages.

9. The Defendant admits this court has jurisdiction over the parties due to diversity of

citizenship.

10. In answer to paragraph 10, the Defendant lacks sufficient knowledge to either admit

or deny the Plaintiff has seventy-five thousand dollars in damages.

Dated: January 14th, 2009

By: _________________________
SARAH SEALY
Attorney Code: 5678
123 Assistance Way
Chicago, IL 60604
(312) 123-4567

Attorney for the Defendant

KENNETH GALVIN

Answer

CERTIFICATE OF SERVICE

The undersigned declares as follows:

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            On January 14th, 2009, I, Curt Marceille, by and through my attorney, served the
foregoing Answer to the Complaint at Law for the action of Negligence on the Plaintiff’s
attorney of record in this action:

Earl E. Riser
Attorney for Plaintiff
Attorney Code: 1234
1620 S. Michigan Ave.
Chicago, IL 60616
(312) 566-0678

by placing a true copy enclosed in an envelope for mailing to the above address on the date
shown above to be deposited with the United States Postal Service that same day in the ordinary
course of business.

            I declare under penalty of perjury under the laws of the United States of America that the
above is true and correct.

            Executed on January 14th, 2009

                                                                        ________________________________________

                                                                                                Kenneth Galvin

SARAH SEALY
Attorney Code: 5678
123 Assistance Way
Chicago, IL 60604
(312) 123-4567

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