Answer: 19 CV 007607

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osentin County Ohio Clerk of Courts of the Common Pleas- 2019 Oct 09 12:13 PM-19CV007607

IN THE FRANKLIN COUNTY COURT OF COMMON PLEAS

FRANKLIN COUNTY, OHIO
SHANEVA WILIAMS, Case No.: 19-CV-007607
Plaintiff, Judge Richard Frye
vs.

WORKERS’ COMPENSATION

DOUGLAS RILEY, et al.,
(BWC No. 17-219351)

)
)
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} ANSWER OF OHIO BUREAU OF
)
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} (BWC Ref. No. BWS-6293)

Defendants.

Defendant, Ohio Bureau of Workers’ Compensation (“BWC”), by and through the Ohio
Attorney General acting through Special Counsel duly appointed as provided in section 109.08
of the Ohio Revised code, answers the numbered paragraphs of Plaintiff's Complaint as follows:

COUNTI

1, The BWC lacks sufficient information to form a basis as to the truth or falsity of
the allegations of Paragraph 1 of the Complaint.

2 The BWC lacks sufficient information to form a basis as to the truth or falsity of
the allegations of Paragraph 2 of the Complaint

3. The BWC lacks sufficient information to form a basis as to the truth or falsity of
the allegations of Paragraph 3 of the Complaint.

4. The BWC lacks sufficient information to form a basis as to the truth or falsity of
the allegations of Paragraph 4 of the Complaint.

5. The BWC lacks sufficient information to form a basis as to the truth or falsity of
the allegations of Paragraph 5 of the Complaint.

6 The BWC lacks sufficient information to form a basis as to the truth or falsity of
the allegations of Paragraph 6 of the Complaint.

7 The BWC lacks sufficient information to form a basis as to the truth or falsity of

the allegations of Paragraph 7 of the Complaint.OE875 -

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oseenetin County Ohio Clerk of Courts of the Common Pleas- 2019 Oct 09 12:13 PM-19CV007607

8 The BWC lacks sufficient information to form a basis as to the truth or falsity of
the allegations of Paragraph 8 of the Complaint.

9 The BWC admits that Ms. Williams suffered injury. The BWC lacks sufficient
information to form a basis as to the truth or falsity of the remaining allegations of Paragraph 9
of the Complaint.

8. The BWC admits that Ms. Williams required medical care. The BWC lacks
sufficient information to form a basis as to the truth or falsity of the remaining allegations of
Paragraph 8 of the Complaint.

9. The BWC admits that Ms. Williams lost wages. The BWC lacks sufficient

information to form a basis as to the truth or falsity of the remaining allegations of Paragraph 9

of the Complaint.
COUNT
10. The BWC restates the foregoing responses, as if fully re-stated herein.
11 The BWC admits that Ms. Williams was in the course and scope of her

employment at the time of the crash. The BWC denies the remaining allegations of Paragraph

11 of the Complaint.

12. Denied.
13. Denied.
14. Denied.

15. Admitted.

16. Denied.
17. Denied
18 Denied

WHEREFORE, the BWC, as statutory subrogee pursuant to O.R.C. §4123.93 ef seq.,

requests that its liens be accorded their rightful priority. As of October 1, 2019, said liens totalOE875 -

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‘ranklin County Ohio Clerk of Courts of the Common Pleas- 2019 Oct 09 12:13 PM-19CV007607

$40,068.97 (which includes $14,622.67 in medical payments and $25,846.30 in compensation);

pursuant to O.R.C. §4123.93(D), the BWC also asserts a claim for estimated future costs of the

Plaintiff's claim, calculated as of October 1, 2019 at $33,436.03, but which may increase, and

which constitute additional sums to which the BWC is entitled and to which it has a subrogation

interest.

Respectfully Submitted,
DAVE YOST
OHIO ATTORNEY GENERAL

/s/ Edward T. Saadi

Edward T. Saadi, Esq. (#0075775)
EDWARD T. SAADI, LLC

970 Windham Ct., Ste. 7
Boardman, OH 44512

(330) 782-1954

(330) 266-7489 (fax)

Edwar ol.com,

Special Counsel Appointed by Ohio
Attorney General Dave YostOE875 -

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oseenetin County Ohio Clerk of Courts of the Common Pleas- 2019 Oct 09 12:13 PM-19CV007607

CERTIFICATE OF SERVICE

A copy of the foregoing ANSWER OF OHIO BUREAU OF WORKERS’
COMPENSATION was served this 9" day of October, 2019 by ordinary United States mail,
postage prepaid to

Grant A. Goodman, Esq.
1360 W. Ninth St., Ste. 410
Cleveland, OH 44113

Douglas Riley
2826 St. Elmo Ave., NE
Canton, OH 44714

Douglas Riley

201 Rose Lane St., SW
Apt. 103

North Canton, OH 44720

Respectfully Submitted,

DAVE YOST
OHIO ATTORNEY GENERAL

/s/ Edward T. Saadi

Edward T. Saadi, Esq. (#0075775)
EDWARD T. SAADI, LLC

970 Windham Court, Suite 7
Boardman, OH 44512

(330) 782-1954

(330) 266-7489 (fax)
EdwardSaadi(@aol com

Special Counsel Appointed by Ohio
Attorney General Dave Yost