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LAW OFFICES

BROENING OBERG WOODS & WILSON

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PROFESSIONAL CORPORATION POST OFFICE BOX PHOENIX, ARIZONA

20527 85036 (602) 271-7700

Sarah L. Barnes (020362)

slb@bowwlaw_com
Attorneys for Defendant

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IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA

NO. CV2012-090514 Plaintiff, vs. SULLIVAN MOTOR COMPANY, INC., et_ a!., Defendant.
In response to Plaintiffs Complaint, Defendant, through counsel undersigned, (Honorable John Ditsworth) ANSWER

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denies, admits and alleges as follows:

1.

In response to

1 of the Complaint, the Defendant does not have sufficient

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information to admit or deny the allegations stated therein and therefore those allegations are denied.

2.
3.

Defendant admits the allegations in ~ 2 of the Complaint. Defendant denies the allegations in ~ 3 of the Complaint. In response to
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4.

4-5, Defendant admits only that jurisdiction and venue are proper,

and they deny any remaining express or implied allegations therein.

5.
6.

Paragraph 6 of the Complaint does not require a response. Defendant denies the allegations in~~ 7-28 of the Complaint.

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7.

Paragraphs 29-31 of the Complaint do not require a response, as the statutes

and decisions referenced speak for themselves; to the extent any allegations are implied therein, Defendant denies the same.

8.

Defendant denies the allegations

in~~

32-44 of the Complaint.

GENERAL DENIAL & AFFIRMATIVE DEFENSES

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9.

Defendant denies and every other allegation of the Complaint not specifically

admitted herein, and denies that Plaintiff is entitled to any of the relief sought in his prayer for relief. 10. As affirmative defenses to the claims set forth in the Complaint, the Defendant

alleges as follows:
a.

Failure to state a claim upon which relief may be granted; Comparative Fault; Waiver/Release; and, Estoppel.

b.
c. d.

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Defendant reserves the right to assert such further affirmative defenses as may be supported by matters discovered hereafter. WHEREFORE having fully answered Plaintiffs Complaint, Defendant prays that it be dismissed; that Plaintiff take nothing thereby; that Defendant be discharged with its lawful costs herein incurred; and for such other and further relief as the Court deems just and proper. RESPECTFULLY SUBMITTED this 15th day ofMay, 2012. BROENING OBERG WOODS & WILSON, P.C.

23 24 25 26 By s/ Sarah L. Barnes Sarah L. Barnes Post Office Box 20527 Phoenix, Arizona 85036 Counsel for Defendant 2

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On this 15th day of May, 2012, the foregoing was electronically transmitted to the ClerK's Office using the CMIECF System for filing and copy mailed to:

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sf Kathy Lake
S:\RMM\Sullivan re Harris\Pieadings\Answer.doc
29135.017

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