Answer

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                          (FILED: BRONX COUNTY CLERK 0272472014 Aapaenaapean cpanel

NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 02/24/2014

LA203-022440666-0002 20005/14E, DGM/js
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX.
segne ERNE RSET Ree ern pee en ene xX
JACQUELINE AVILAS,

Plaintiff,

VERIFIED ANSWER
-against-
Index No. 20005/14E

FRANK BARCIA,

Defendant
Ca OX

Defendant, FRANK BARCIA, by his attorneys MARTYN, TOHER, MARTYN & ROSSI,
ESQS., answering the Complaint of the plaintiff herein alleges:

de Denies any knowledge or information sufficient to form a belief as to each and every
allegation contained in paragraphs designated “1”, “2”, “4” and “5” of the Complaint.

2. Denies each and every allegation contained in paragraph designated “6”, “7”, “8”,
“9” and “10” of the Complaint.

AND FOR A FIRST AFFIRMATIVE D! SE

Bt ‘That whatever injuries and damages the plaintiff may have sustained as alleged in the
Complaint herein were caused, in whole or in part by the culpable conduct of the plaintiff, in…