Document 4MdZ7EegqMDKLyaZpQnoeVZR
IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO
DALE J. RIGSBY, Plaintiff,
-vsTHE BABCOCK & WILCOX COMPANY, et al.,
Defendants.
) CASE NO. CV 87 07 2396
)
) JUDGE CARROLL
)
)
)
)
) ) ANSWER OF DEFENDANT THE
) BABCOCK & WILCOXCOMPANY
) TO PLAINTIFF*S COMPLAINT
Comes now the Defendant, The Babcock & Wilcox Company, and
for its Answer to Plaintiff's Complaint, avers and states as
follows:
1. Defendant admits that the Plaintiff was an employee of
The Babcock & Wilcox Company from October 30, 1961 through
December 31, 1984.
Defendant denies each and every other
allegation contained in Paragraph 1 of Plaintiff's Complaint.
2. The
allegations contained
in Paragraph
2 of
Plaintiff's Complaint are denied for want of knowledge.
3. The
allegations contained
in Paragraph
3 of
Plaintiff's Complaint are denied.
4. The
allegations contained
in Paragraph
4 of
Plaintiff's Complaint are denied for want of knowledge.
5. The
allegations contained
in Paragraph
5 of
Plaintiff's Complaint are denied for want of knowledge.
OTHER DEFENSES 6. The Plaintiff is not in compliance with the requirements as set forth in 2317.48 of the Ohio Revised Code
which requires interrogatories relating to the subject matter
of the discovery, as are necessary to procure the discovery
sought.
7. When the Plaintiff complies with O.R.C.2317.48 and
provides specific discovery requests, this Defendant will
comply as required by statute and pursuant to the Civil Rules.
WHEREFORE, Plaintiff, having fully answered, prays that
this Court not allow the Plaintiff to obtain discovery from
this Defendant
O.R.C.2317.48.
until
such
time
that
Plaintiff
complies with
ROETZEL & ANDRESS
j
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El.iizza4beth A. Nocera l^
Ronald S. Kopp
75 East Market Street
Akron, Ohio 44308
(216) 376-2700
ATTORNEYS FOR DEFENDANT THE BABCOCK & WILCOX COMPANY
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing Answer of Defendant The Babcock & Wilcox Company to Plaintiff's Complaint has been forwarded via regular U.S. Mail, postage prepaid, to A. Russell Smith, 503 Society Bldg., Akron, Ohio 44308 and to Stephen J. Brown, 211 South Court St., Medina, Ohio' 44256, Attorneys for Plaintiff, on this 31st day of August, 1987.
__ ,__
Elizabeth A. No
ra
2- -
220 MARKET AVENUE. SOUTH SUITE 770
CANTON. OHIO 44702 (216) 455-2700
1127 EUCLID AVENUE SUITE 364
CLEVELAND, OHIO 44115 (216) 696-7716
TELE*: 296257 EXEC STE
(216) 376-2700
CABLE: WATANO TELECOPIER: (216) 376 -4577
August 31, 1987
37 WEST BROAO STREET
SUITE aoo
COLUMBUS, OHIO 43215 (614) 463-9770
TELECOPIER: (614)463-9792
JA. Russell Smith, Esq. 503 Society Building Akron, Ohio 44308
Stephen J. Brown, Esq. 211 South Court St. Medina, Ohio 44256
Re: Dale J. Rigsby v. The Babcock & Wilcox Company
Gentlemen:
Enclosed please find copy of the Answer of Defendant The Babcock & Wilcox Company to Plaintiff's Complaint, which I have caused to be filed in reference to the above-captioned action.
Sincerely,
ROETZEL & ANDRESS
EAN/slr 05125/103 Enclosure
Betty Nocera