Sander Equipment Product Liability Answer 3

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Answer to Plaintiff's Complaint at Law

NOW COMES the Defendant, ROCKWELL/DELTA and PORTER-CABLE CORPORATION, a Minnesota Corporation, by and through its attorneys, SEGAL, McCAMBRIDGE, SINGER & MAHONEY, LTD., and answers the complaint at law as follows:

1. Neither admits nor denies the allegations contained in Paragraph 1, as these Defendants do not have sufficient knowledge upon which to base their answer.

2. Admits the allegations contained in Paragraph 2 and further states that Defendant, Porter-Cable is not a proper Defendant in this lawsuit as the product in question was not a Porter-Cable product.

3. Admits that Porter-Cable distributes products but denies each and every additional allegation in Paragraph 3 and further states that Porter-Cable did not distribute the product allegedly involved in this lawsuit.

4. Denies each and every allegation contained in Paragraph 4.

5. Neither admits nor denies the allegations contained in Paragraph 5, as these Defendants do not have sufficient knowledge upon which to base their answer.

6. Neither admits nor denies the allegations contained in Paragraph 6, as these Defendants do not have sufficient knowledge upon which to base their answer.

7. Based on information and belief the product identified as serial #EK8886, model number 31-710, asset number 1745 was a product manufactured by Rockwell/Delta but this Defendant does not have sufficient upon which to base its answer that was the sander involved in the injury to Mr. Riemma.

8. Neither admits nor denies the allegations contained in Paragraph 8, as these Defendants do not have sufficient knowledge upon which to base their answer.

STRICT PRODUCT LIABILITY

9. These Defendants reallege their answers to Paragraphs 1 through 7 as its answers to Paragraph 9.

10. These Defendants admit only that the Rockwell/Delta designed, manufactured, and placed into the stream of commerce a certain corer sander identified as serial #EK8886, model number 31-710, asset number 1745 but does not have sufficient knowledge upon which to base its answer regarding whether that sander was involved in the instant accident.

11. Admits only those duties upon this Defendant imposed by law and states at all times these Defendants acted in accordance with said duties.

12. Denies each and every allegation contained in Paragraph 12, specifically denying sub-paragraphs 12(a) through 12(d)

13. Denies each and every allegation contained in Paragraph 13.

14. Denies each and every allegation contained in Paragraph 14.

15. Denies each and every allegation contained in Paragraph 15.

WHEREFORE, Defendants deny that Plaintiff is entitled to judgment against any of the Defendants in any sum whatsoever.

NEGLIGENCE

16. This Defendant realleges its answers to Paragraphs 1 through 8 as its answers to Paragraph 16.

17. Admits only those duties imposed upon these Defendants by law and states at all times these Defendants acted in accordance with said duties.

18. Denies each and every allegation contained in Paragraph 18, specifically denying sub-paragraphs 18(a) through 18(c).

19. Denies each and every allegation contained in Paragraph 19.

20. Denies each and every allegation contained in Paragraph 20.

21. Denies each and every allegation contained in Paragraph 21.

WHEREFORE, Defendants deny that Plaintiff is entitled to judgment against any of these Defendants in any sum whatsoever.

LOSS OF CONSORTIUM

22. Defendants reallege its answer to Paragraph 1 through 8 as its answer to Paragraph 22.

23. Neither admits nor denies the allegations contained in Paragraph 23 as these Defendants do not have sufficient knowledge upon which to base their answer.

24. Denies each and every allegation contained in Paragraph 24.

25. Denies each and every allegation contained in Paragraph 25.

WHEREFORE, Defendants deny that Plaintiff, CONNIE RIEMMA is entitled to judgment against any of these Defendants in any sum whatsoever.

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