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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY YMIN CHEN and QINGMIAN LI, Plaintiffs, v. HASSAN ABDI ELMI, J.B. HUNT TRANSPORT, INC., Defendants. : : : : : : : : : : : C.A. No.

JURY TRIAL DEMANDED

DISCLOSURE STATEMENT FORM Please check one box: The nongovernmental corporate party, , in the above listed civil action does not have any parent corporation and publicly held corporation that owns 10% or more of its stock. The nongovernmental corporate party, J.B Hunt Transport, Inc. in the above listed civil action has the following parent corporation(s) and publicly held corporation(s) that owns 10% or more of its stock: J.B. Hunt Transport Services, Inc.

Date: JANUARY 24, 2007

Signature: Counsel for: Defendant, J.B. Hunt Transport Inc.

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IN THE UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY YIMIN CHEN and QINGMIAN LI, Plaintiffs, v. HASSAN ABDI ELMI, J.B. HUNT TRANSPORT, INC., JOHN DOES 1-10 and ABC CORPORATION 1-10, Defendants. : : : CIVIL ACTION NO.:2:07-00456 (KSH) : : : : JURY TRIAL DEMANDED : :

DEFENDANT'S ANSWER TO PLAINTIFFS' COMPLAINT Defendant, J. B. Hunt Transport, Inc., by and through its counsel, Rawle & Henderson
LLP,

hereby answers plaintiffs' Complaint as follows: FIRST COUNT 1. Admitted in part; denied in part. Answering defendant admits only that on August

4, 2005, plaintiff, Yimin Chen, drove a motor vehicle on US Route 95 northbound in New castle County, Delaware. The remaining averments contained in paragraph 1 of the First Count of the Complaint are denied and strict proof thereof is demanded at trial. By way of further answer, paragraph 1 of the First Count of the Complaint contains conclusions of law to which no responsive pleading is required. 2. Admitted in part; denied in part. Answering defendant admits only that on August

4, 2005, defendant Elmi drove a motor vehicle owned by defendant, J.B. Hunt Transport, Inc., on US Route 95 northbound in New Castle County, Delaware. The remaining averments contained in paragraph 2 of the First Count of the Complaint are denied and strict proof thereof is demanded at trial. By way of further answer, paragraph 2 of the First Count of the Complaint contains conclusions of law to which no responsive pleading is required.

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3.

Denied. Answering defendant denies any negligence or carelessness and demands

strict proof thereof at trial. By way of further answer, the averments contained in paragraph 3 of the First Count of the Complaint are conclusions of law to which no response is required. 4. Denied. Answering defendant denies any negligence or carelessness and demands

strict proof thereof at trial. Answering defendant has insufficient knowledge or information upon which to form a belief as to the truth of the remaining averments contained in paragraph 4 of the First Count of the Complaint, and therefore, said averments are denied. By way of further answer, paragraph 4 of the First Count of the Complaint contains conclusions of law to which no response is required. WHEREFORE, answering defendant, J. B. Hunt Transport, Inc., demands judgment in its favor and against the plaintiff, Yimin Chen, dismissing plaintiff's Complaint with prejudice together with an award of costs and disbursements incurred by answering defendant, including attorneys' fees together with such other relief in favor of said defendant as this Honorable Court shall deem appropriate. SECOND COUNT 1. Answering defendant incorporates by reference its answers to all paragraphs in

the First Count of the Complaint as though the same were set forth fully herein. 2. Admitted in part; denied in part. Answering defendant admits only that on August

4, 2005, plaintiff, Qingmian Li, was an occupant of a motor vehicle driven by plaintiff, Yimin Chen. The remaining averment contained in paragraph 2 of the Second Count of the Complaint is a conclusion of law to which no responsive pleading is required, and therefore, said averment is denied.

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3.

Admitted in part; denied in part. Answering defendant admits only that on August

4, 2005, defendant Elmi drove a motor vehicle owned by defendant, J.B. Hunt Transport, Inc., on US Route 95 northbound in New Castle County, Delaware. The remaining averments contained in paragraph 3 of the Second Count of the Complaint are denied and strict proof thereof is demanded at trial. By way of further answer, paragraph 3 of the Second Count of the Complaint contains conclusions of law to which no responsive pleading is required. 4. Denied. Answering defendant denies any negligence or carelessness and demand

strict proof thereof at trial. By way of further answer, the averments contained in paragraph 4 of the Second Count of the Complaint are conclusions of law to which no response is required. 5. Denied. Answering defendant denies any negligence or carelessness and demand

strict proof thereof at trial. Answering defendant has insufficient knowledge or information upon which to form a belief as to the truth of the remaining averments contained in paragraph 5 of the Second Count of the Complaint, and therefore, said averments are denied. By way of further answer, paragraph 5 of the Second Count of the Complaint contains conclusions of law to which no response is required. WHEREFORE, answering defendant, J. B. Hunt Transport, Inc., demands judgment in its favor and against the plaintiff, Qingmian Li, dismissing plaintiffs' Complaint with prejudice together with an award of costs and disbursements incurred by answering defendant, including attorneys' fees together with such other relief in favor of said defendant as this Honorable Court shall deem appropriate. THIRD COUNT 1. Answering defendant incorporates by reference its answers to all paragraphs in

the First and Second Counts of the Complaint as though the same were set forth fully herein.

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2.

Admitted in part; denied in part. Answering defendant admits only that on August

4, 2005, defendant Elmi drove a motor vehicle owned by his employer, defendant, J.B. Hunt Transport, Inc. Answering defendant denies any negligence and demand strict proof thereof at trial. By way of further answer, paragraph 2 of the Third Count of the Complaint contains conclusions of law to which no responsive pleading is required. 3 Denied. Answering defendant denies any negligence or carelessness and demand

strict proof thereof at trial. Answering defendant has insufficient knowledge or information upon which to form a belief as to the truth of the remaining averments contained in paragraph 3 of the Third Count of the Complaint, and therefore, said averments are denied. By way of further answer, paragraph 3 of the Third Count of the Complaint contains conclusions of law to which no response is required. WHEREFORE, answering defendant, J. B. Hunt Transport, Inc., demands judgment in its favor and against the plaintiffs dismissing plaintiffs' Complaint with prejudice together with an award of costs and disbursements incurred by answering defendant, including attorneys' fees together with such other relief in favor of said defendant as this Honorable Court shall deem appropriate. FOURTH COUNT 1. Answering defendant incorporates by reference its answers to all paragraphs in

the First, Second and Third Counts of the Complaint as though the same were set forth fully herein. 2. Denied. The averments contained in paragraph 2 of the Fourth Count of the

Complaint are addressed to a defendant other than answering defendant herein. By way of further answer, this defendant has insufficient knowledge or information upon which to form a

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belief as to the truth of the averments contained in paragraph 2 of the Fourth Count of the Complaint, and therefore, said averments are denied. 3. Denied. The averments contained in paragraph 3 of the Fourth Count of the

Complaint are addressed to a defendant other than answering defendant herein. By way of further answer, this defendant has insufficient knowledge or information upon which to form a belief as to the truth of the averments contained in paragraph 3 of the Fourth Count of the Complaint, and therefore, said averments are denied. WHEREFORE, answering defendant, J. B. Hunt Transport, Inc., demands judgment in its favor and against the plaintiffs, dismissing plaintiffs' Complaint with prejudice together with an award of costs and disbursements incurred by answering defendant, including attorneys' fees together with such other relief in favor of said defendant as this Honorable Court shall deem appropriate. FIFTH COUNT 1. Answering defendant incorporates by reference its answers to all paragraphs in

the First, Second, Third and Fourth Counts of the Complaint as though the same were set forth fully herein. 2. Denied. The averments contained in paragraph 2 of the Fifth Count of the

Complaint are addressed to a defendant other than answering defendant herein. By way of further answer, this defendant has insufficient knowledge or information upon which to form a belief as to the truth of the averments contained in paragraph 2 of the Fifth Count of the Complaint, and therefore, said averments are denied. 3. Denied. The averments contained in paragraph 3 of the Fifth Count of the

Complaint are addressed to a defendant other than answering defendant herein. By way of

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further answer, this defendant has insufficient knowledge or information upon which to form a belief as to the truth of the averments contained in paragraph 3 of the Fifth Count of the Complaint, and therefore, said averments are denied. WHEREFORE, defendant, J. B. Hunt Transport, Inc., demands judgment in its favor and against the plaintiffs, dismissing plaintiffs' Complaint with prejudice together with an award of costs and disbursements incurred by answering defendant, including attorneys' fees together with such other relief in favor of said defendant as this Honorable Court shall deem appropriate. AFFIRMATIVE DEFENSES FIRST DEFENSE Plaintiffs' Complaint fails to state a claim upon which relief can be granted. SECOND DEFENSE Answering defendant did not breach any duty owed to plaintiffs. THIRD DEFENSE Answering defendant avers that plaintiffs were guilty of contributory negligence. FOURTH DEFENSE The injuries or damages sustained by plaintiffs, if any, were not actually or proximately caused by an act or omission on the part of the answering defendant. FIFTH DEFENSE Plaintiffs' claims are barred or reduced in accordance with the applicable comparative negligence act. SIXTH DEFENSE Plaintiffs' injuries and damages, if any, were caused in whole or in part by the intervening and superseding acts of third parties over whom answering defendant had no control.

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SEVENTH DEFENSE Answering defendant, at all relevant times, acted with due care and complied with all requirements of applicable law. EIGHTH DEFENSE Plaintiffs' claims are barred by the doctrines of res judicata, collateral estoppel, waiver and/or the entire controversy doctrine. NINTH DEFENSE Plaintiffs have failed to satisfy the requirements of the New Jersey Automobile Reparation Reform Act, N.J.S.A. 39:6A-1-35, and pursuant thereto, plaintiffs' claims are limited or barred in their entirety. TENTH DEFENSE Plaintiffs' claims are limited or barred in accordance with N.J.S.A. 39:6A-1 et seq. and/or any other applicable law regarding tort option selection. ELEVENTH DEFENSE Plaintiffs have failed to mitigate their damages, if any. TWELFTH DEFENSE Answering defendant was confronted with a sudden emergency and exercised all reasonable care under the circumstances. THIRTEENTH DEFENSE Answering defendant is entitled to a credit/set off for any expenses paid by insurance or other third parties who are claimed as damages by the plaintiffs. FOURTEENTH DEFENSE Pursuant to N.J.S.A. 2A:15-59-1, answering defendant demands all reasonable counsel fees and court costs to the extent that this is a frivolous law-suit. FIFTEENTH DEFENSE Plaintiffs' claims are barred under the Doctrine of Avoidable Consequences.

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SIXTEENTH DEFENSE This Court lacks jurisdiction over this defendant by reason of insufficiency of process and reserves the right to move at or before trial for a dismissal of the Complaint on the ground of lack of jurisdiction because of insufficiency of process and/or service. SEVENTEENTH DEFENSE Answering defendant asserts all defenses available to it pursuant to the terms of the applicable No-Fault Statute. EIGHTEENTH DEFENSE Answering defendant adopts and incorporates by reference as if the same were set forth at length herein, all other affirmative defenses which have been or will be asserted by any other party in this action, except those which may contain allegations of liability against this defendant, to the extent that such defenses are applicable to said defendant. NINETEENTH DEFENSE This Court lacks in personam jurisdiction over a defendant and answering defendant reserves the right to move at or before trial for a dismissal of the Complaint on the ground of lack of personal jurisdiction and because this party is an indispensable party. WHEREFORE, defendant, J. B. Hunt Transport, Inc., demands judgment in its favor and against the plaintiffs, dismissing plaintiffs' Complaint with prejudice together with an award of costs and disbursements incurred by answering defendant, including attorneys' fees together with such other relief in favor of said defendant as this Honorable Court shall deem appropriate.

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RESERVATION OF DEFENSES Answering defendant reserves the right to assert any of the defenses, objections and/or claims that are or may in the future be warranted against any and all parties presently named and/or in the future to be named in the underlying controversy.

RAWLE & HENDERSON LLP

By: Jon Michael Dumont 1609 Delia A. Clark, Esq. 6736 Attorneys for Defendants 40 Lake Center Executive Park 401 Route 73 North, Suite 200 Marlton, NJ 08053 (856) 797-8910 Attorneys for Defendant, J.B. Hunt Transport, Inc. Dated: February 7, 2007

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CERTIFICATE OF SERVICE It is hereby certified that a true and correct copy of the within-captioned Answer filed electronically was served electronically and via first-class mail, postage prepaid to:

George F. Hendricks Hendricks & Hendricks 73 Patterson Street New Brunswick, NJ 108901.

RAWLE & HENDERSON LLP

By:

______________ Jon Michael Dumont Delia A. Clark Attorneys for Defendant, J.B. Hunt Transport, Inc.

Dated: January 31, 2007

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