Answer 3 - doctors answer to plaintiffs complaint in med mal suit

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Defendant, Syed Mohsin, M.D.'s Answer to Plaintiff's Complaint

Respectfully submitted, Mary C. O'Connor, Foran Glennon Palandech & Ponzi PC.

NOW COMES the Defendant, SYED MOHSIN, M.D., incorrectly sued herein as SYED MOSHIN, M.D., by and through his attorneys, MARY C. O'CONNOR, KATHERINE E. BEAUMONT and FORAN GLENNON PALANDECH & PONZI PC, and as and for his answer to Plaintiff's Complaint, states as follows:

COUNT I: Dr. Waicosky - Medical Negligence - Wrongful Death

1-12. The allegations of Count I, paragraphs 1 through 12 inclusive, are not directed at this answering Defendant and accordingly this Defendant makes no answer thereto. To the extent the allegations of Count I are directed to this Defendant, those allegations are denied.

COUNT II: Dr. Moshin[sic] - Medical Negligence - Wrongful Death

2. This answering Defendant admits the allegations of paragraph 2.

3. This answering Defendant objects to the allegations of paragraph 3 as vague, and accordingly makes no answer thereto.

4. This answering Defendant denies the allegations of paragraph 4.

5. This answering Defendant admits the allegations of paragraph 5.

6. This answering Defendant denies the allegations of paragraph 6.

7. This answering Defendant denies the allegations of paragraph 7 and admits only those duties imposed upon him by law.

8. This answering Defendant denies the allegations of paragraph 8, subparts (a) through (h) inclusive.

9. This answering Defendant denies the allegations of paragraph 9.

10. This answering Defendant has insufficient knowledge with which to answer the allegations of paragraph 10 and accordingly makes no answer thereto.

11. This answering Defendant has insufficient knowledge with which to answer the allegations of paragraph 11 and accordingly makes no answer thereto.

12. This answering Defendant admits that an attorney's affidavit is attached to the instant Complaint but makes no answer to the legal conclusion as to its sufficiency pursuant to 735 ILCS 5/2-622.

COUNT III: LCM - Medical Malpractice -Agency - Waicosky -Wrongful Death

1-13. The allegations of Count III, paragraphs 1 through 13 inclusive, are not directed at this answering Defendant and accordingly this Defendant makes no answer thereto. To the extent the allegations of Count III are directed to this Defendant, those allegations are denied.

COUNT IV: LCM - Medical Malpractice - Agency - Moshin[sic] - Wrongful Death

1-14. The allegations of Count IV, paragraphs 1 through 14 inclusive, are not directed at this answering Defendant and accordingly this Defendant makes no answer thereto. To the extent the allegations of Count IV are directed to this Defendant, those allegations are denied.

WHEREFORE, Defendant, SYED MOHSIN, M.D., incorrectly sued herein as SYED MOSHIN, M.D., prays for judgment in his favor and against Plaintiff and for costs so wrongfully sustained.

Respectfully submitted.

<<signature>>

MARY C. O'CONNOR

FORAN GLENNON PALANDECH & PONZI PC

STATE OF ILLINOIS )

) SS:

COUNTY OF COOK )

MARY C. O'CONNOR, being first duly sworn on oath, deposes and says that she is a member of the law firm of Foran Glennon Palandech & Ponzi PC, attorneys for Defendant herein; that she is charged with the preparation of the Answer to Plaintiff's Complaint at Law; that she has knowledge of the statements contained in the Answer regarding insufficient knowledge and that said statements regarding insufficient knowledge are true and correct to the best of her knowledge.

<<signature>>

MARY C. O'CONNOR

SUBSCRIBED AND SWORN TO before me this 17th day of December, 2004

<<signature>>

Notary Public

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