Claims Against The City Of Marksville example essay topic

692 words
CIVIL SUIT NUMBER 2002-4187 A BRYAN JOSEPH MAYEUX, ET UX 12 TH JUDICIAL DISTRICT COURT vs. PARISH OF AVOYELLES LAMBERT'S CONTRACTORS, INC., ET AL STATE OF LOUISIANA FILED: DY. CLK. ANSWER NOW INTO COURT through undersigned counsel comes THE CITY OF MARKSVILLE and for Answer to the Second Supplemental and Amending Petition of Bryan Joseph Mayeux and Amy Lemoine Mayeux with respect represents: 1. Except to admit that the CITY OF MARKSVILLE is a political subdivision of the State of Louisiana which may be served through its Mayor, Honorable Richard R. Michel, the remaining allegations of Paragraph 1 are denied for lack of sufficient knowledge or information to justify a belief as to their truth.

2. The allegations of Paragraph 2 as they relate to the CITY OF MARKSVILLE are denied; the remaining allegations are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 3. The allegations of Paragraph 3 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 4. The allegations of Paragraph 4 are denied for lack of sufficient knowledge or information to justify a belief as to their truth.

5. The allegations of Paragraph 5 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 6. The allegations of Paragraph 6 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 7. The allegations of Paragraph 7 are denied for lack of sufficient knowledge or information to justify a belief as to their truth.

8. The allegations of Paragraph 8 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 9. The allegations of Paragraph 9 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 10. The allegations of Paragraph 10 as they relate to the CITY OF MARKSVILLE are denied; the remaining allegations are denied for lack of sufficient knowledge or information to justify a belief as to their truth.

11. The allegations of Paragraph 11 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 12. The allegations of Paragraph 12 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 13. The allegations of Paragraph 13 are denied for lack of sufficient knowledge or information to justify a belief as to their truth.

14. The allegations of Paragraph 14 are denied for lack of sufficient knowledge or information to justify a belief as to their truth. 15. FURTHER ANSWERING, the CITY OF MARKSVILLE shows that the claims against the CITY OF MARKSVILLE have prescribed by virtue of the one year prescription provided for by Louisiana Law; further, the CITY OF MARKSVILLE shows that if the plaintiffs have been damaged, which is denied, then the damages are a result of the acts or omissions of other parties for whom the CITY OF MARKSVILLE is not responsible. WHEREFORE the CITY OF MARKSVILLE prays that this answer be deemed good and sufficient and after proceedings duly had that there be judgment rendered herein in favor of the CITY OF MARKSVILLE and against the plaintiffs dismissing their claims against the CITY OF MARKSVILLE with prejudice and at their costs.

CERTIFICATE OF SERVICE This will certify that I have served a copy of the above and foregoing Answer has been served upon: Mr. Tristan Knoll P.O. Box 426 Marksville, Louisiana 71351 Attorney for Bryan Joseph Mayeux and Amy Lemoine Mayeux Mr. Michael D. His lop P.O. Box 11590 Alexandria, Louisiana 71315-1590 Attorney for Tim Lambert and Lambert Contractors, Inc. Ms. Debra C. Eldredge Senior Attorney P.O. Box 94245 Baton Rouge, Louisiana 70804-9245 Attorney for State, DOT by placing it in the U.S. Mails, properly addressed and postage pre-paid prior to filing. Marksville, Louisiana this day of October, 2003.