ANSWER TO REVISED SUBSTITUTED COMPLAINT

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                          DOCKET NO.: UWY-CV21-6060768-S                            :       SUPERIOR COURT

ELIZABETH STEWART, ET AL.                                 :       J.D. OF WATERBURY

VS.                                                       :       AT WATERBURY

SAINT MARY’S HOSPITAL, INC., ET AL                        :       MARCH 8, 2023

                  ANSWER TO REVISED SUBSTITUTED COMPLAINT

       Defendants, Saint Mary’s Hospital, Inc., Trinity Health of New England Corporation, Inc.

and Mark Stevens, PA (collectively, “the Trinity defendants”), hereby respond to plaintiffs’

Substituted Complaint, dated December 16, 2022, as follows:

FIRST COUNT: (as to St. Mary’s Hospital)

       1.      Defendant lacks knowledge or information sufficient to form a belief as to the

truth of the allegations contained in paragraph 1 and, therefore, leaves plaintiff to her proof.

       2.      Defendant lacks knowledge or information sufficient to form a belief as to the

truth of the allegations conta…