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2. It denies Paragraphs 2 and 3.
FIRST DEFENSE TO FIFTH COUNT.
1. It repeats its answers to Paragraphs 1 to
6 inclusive of the first count.
2. It denies Paragraphs 2 to 7 inclusive.
FIRST DEFENSE TO SIXTH COUNT.
1. It repeats its answers to the fifth count.
2. It denies Paragraphs 2 and 3.
SECOND DEFENSE TO EACH COUNT.
The plaintiff did not suffer any injury or
sustain any loss by reason of any negligence on the part of the
defendant or any of its agents or servants.
THIRD DEFENSE TO EACH COUNT.
The plaintiff did not suffer the injuries or
sustain the losses alleged.
FOURTH DEFENSE TO EACH COUNT.
The plaintiff was guilty of contributory neg-
ligence in failing to exercise that degree of care and caution
for her own safety which was reasonably necessary under the
circumstances.
FIFTH DEFENSE TO EACH COUNT.
The plaintiff, by voluntarily entering into the
employ of the defendants as alleged, under the circumstances
which existed at the time, assumed the risk of any injury which
she might or did suffer.
SIXTH DEFENSE TO EAcH COUNT.
The plaintiff assumed the risks of the in-
juries, if any, which she received and therefore cannot re-
-2-
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Document data
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- Core
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- Type
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Context sent to Scholar
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"ocrText": "2. It denies Paragraphs 2 and 3.\nFIRST DEFENSE TO FIFTH COUNT.\n1. It repeats its answers to Paragraphs 1 to\n6 inclusive of the first count.\n2. It denies Paragraphs 2 to 7 inclusive.\nFIRST DEFENSE TO SIXTH COUNT.\n1. It repeats its answers to the fifth count.\n2. It denies Paragraphs 2 and 3.\nSECOND DEFENSE TO EACH COUNT.\nThe plaintiff did not suffer any injury or\nsustain any loss by reason of any negligence on the part of the\ndefendant or any of its agents or servants.\nTHIRD DEFENSE TO EACH COUNT.\nThe plaintiff did not suffer the injuries or\nsustain the losses alleged.\nFOURTH DEFENSE TO EACH COUNT.\nThe plaintiff was guilty of contributory neg-\nligence in failing to exercise that degree of care and caution\nfor her own safety which was reasonably necessary under the\ncircumstances.\nFIFTH DEFENSE TO EACH COUNT.\nThe plaintiff, by voluntarily entering into the\nemploy of the defendants as alleged, under the circumstances\nwhich existed at the time, assumed the risk of any injury which\nshe might or did suffer.\nSIXTH DEFENSE TO EAcH COUNT.\nThe plaintiff assumed the risks of the in-\njuries, if any, which she received and therefore cannot re-\n-2-"
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