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COURT OF COMMON PLEAS

MONTGOMERY COUNTY, OHIO

__________________________________________________
______________________, et al. )
Plaintiffs, )
vs. ) Case No. _____
______________________, et al. ) (Judge ___________________)
Defendants ) ANSWER OF DEFENDANT
) ___________________ INDUSTRIES
)
__________________________________________________

1. Defendant ___________________ Industries is without knowledge or information sufficient to

form a belief as to the truth of the allegations in paragraphs 1 through 12 of the Complaint and,
therefore, denies same.

2. In response to paragraph 13, ___________________ Industries incorporates, as if fully restated,

its response set forth in paragraph 1.

3. ___________________ Industries is without knowledge or information sufficient to form a belief

as to the truth of the allegations in paragraphs 14 through 18 of the Complaint and, therefore, denies
same.

4. In response to paragraph 19, ___________________ Industries incorporates, as if fully restated,

its responses set forth in paragraphs 1 through 3.

5. ___________________ Industries denies the allegations in paragraphs 20 through 22 of the

Complaint.

6. ___________________ Industries admits the allegations in the first two sentences of paragraph
23, but denies the allegations in the third sentence of paragraph 23.

7. Plaintiffs' Complaint fails to state a claim upon which relief can be granted.

8. Plaintiffs' injuries were caused in whole or in part by acts or omissions of persons, entities or
natural conditions over which ___________________ Industries had or has no responsibility or
control and not by any acts or omissions of ___________________ Industries.

9. The acts or omissions over which ___________________ Industries had or has no control were
an intervening cause of Plaintiffs' injuries and constitute a complete defense and bar to Plaintiffs'
claims against ___________________ Industries.

10. One or more of Plaintiffs were negligent and such negligence was the direct and proximate
cause of their injuries.
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11. Plaintiffs knowingly and voluntarily assumed the risk of the activity in which they were
involved.

12. Plaintiffs' claims are barred by the statute of limitations.

WHEREFORE, ___________________ Industries demands that the Complaint be dismissed with

prejudice at Plaintiffs' costs, an award of attorney fees and all other relief, legal or equitable, to
which it is entitled.

Respectfully Submitted,

______________________

______________________

[name and address of attorney for Defendant]

Attorney for Defendant

This is to certify that a copy of the foregoing Answer has been sent by regular mail, postage
prepaid, to all counsel of record this _____[date] day of ____________________, 20_____[month
and year].

______________________

[signature of attorney for Defendant]

[printed name of attorney for Defendant]