ANSWER AND CROSSCLAIM - OF DEF MELVIN BOND, W/ JURY DEMAND AND CERT OF SERVICE

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‘COMMON PLEAS COURT

2008 NOY - :

IN THE COURT OF COMMON PLEAS OY-6 AMIO:SI
MEDINA COUNTY, OHIO . PILED

KATHY FORTHEY

MEDINA COUNTY

ALLISON VITAS, ) CASE NO. 08 CIV 1945 chen GF’ esuRTs
) ATS
Plaintiff, ) JUDGE KIMBLER
)
-vs- )
) ANSWER AND CROSS-CLAIM
MELVIN BOND, et al. ) OF DEFENDANT, MELVIN BOND
)
Defendants. ) Jury Demand Endorsed Hereon

Defendant, Melvin Bond, for his Answer to the Plaintiff’s Complaint states as

follows:
FIRST DEFENSE
1. Plaintiff's Complaint fails to state a claim against this Defendant upon
which relief can be granted.
SECOND DEFENSE

2. Plaintiff has failed to join necessary and/or indispensable parties
pursuant to Rules 19 and 19.1 of the Ohio Rules of Civil Procedure.
THIRD DEFENSE
3. Any injuries and/or damages allegedly sustained by the Plaintiff were

caused by her own negligence and/or failure to mitigate damages.‘copy

FOURTH DEFENSE
4, Any injuries and/or damages allegedly sustained by the Plaintiff were

caused by the intervening and/or…