Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-01013-SRU

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Filed 12/03/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARSHALL AVIATION, LLC VS. AIG AVIATION, INC. , THE INSURANCE COMPANY OF THE STATE OF PENNSYLVANIA, MJ AVIATION, LLC, LJ AVIATION, LLC, and LOUIS PUGLIESE, JR. : : : : : : : : : CIVIL ACTION NO. 303CV1013 (SRU)

DECEMBER 1, 2004

PLAINTIFF'S REPLY TO DEFENDANTS MJ AVIATION, LLC AND LOUIS PUGLIESE, JR.'S AFFIRMATIVE DEFENSES AND COUNTERCLAIM REPLY TO SPECIAL DEFENSES: FIRST AFFIRMATIVE DEFENSE: Denied. SECOND AFFIRMATIVE DEFENSE: Denied. THIRD AFFIRMATIVE DEFENSE: Denied. REPLY TO COUNTERCLAIM 1. As to the allegations contained in Paragraph 1, the Plaintiff/Counterclaim

Defendant is without knowledge or information thereof sufficient to form a belief as to

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the truth of said allegations and, therefore, leaves the Defendants/Counterclaim Plaintiffs to its proof. 2. The Plaintiff/Counterclaim Defendant admits that it alleged in its Complaint that a

reverse polarity condition damaged the aircraft's electronics and avionics and leaves the Defendants/Counterclaim Plaintiffs to their proof on the remainder. 3. 4. 5. The allegations contained in Paragraph 3 are denied. The allegations contained in Paragraph 4 are admitted. As to the allegations contained in Paragraph 5, the Plaintiff/Counterclaim

Defendant is without knowledge or information thereof sufficient to form a belief as to the truth of said allegations and, therefore, leaves the Defendants/Counterclaim Plaintiffs to its proof. 6. As to the allegations contained in Paragraph 6, the Plaintiff/Counterclaim

Defendant is without knowledge or information thereof sufficient to form a belief as to the truth of said allegations and, therefore, leaves the Defendants/Counterclaim Plaintiffs to its proof. 7. As to the allegations contained in Paragraph 7, the Plaintiff/Counterclaim

Defendant is without knowledge or information thereof sufficient to form a belief as to

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the truth of said allegations and, therefore, leaves the Defendants/Counterclaim Plaintiffs to its proof. 8. The allegations contained in Paragraph 8 are denied.

PLAINTIFF/COUNTERCLAIM DEFENDANT MARSHALL AVIATION, LLC

ROBERT J. O'BRIEN JONATHAN E. SNYDER Gordon, Muir and Foley, LLP 10 Columbus Boulevard Hartford, CT 06106 (860) 525-5361 Federal Bar No. ct05489 Federal Bar No. ct22572 Email: ro'[email protected] Email: [email protected]

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CERTIFICATION

I hereby certify that a copy of the foregoing was mailed, first class, postage prepaid mail, on December 1, 2004, to:

Steven R. Arnold, Esq. Stanger & Arnold, LLP 29 South Main Street, Suite 325 West Hartford, CT 06107 Eric P. Smith, Esq. Lynch, Traub, Keefe & Errante, P.C. 52 Trumbull Street P.O. Box 1612 New Haven, CT 06506-1612 Richard J. Kenny, Esq. Kenny, O'Keefe & Usseglio, PC 21 Oak Street, #208 Hartford, CT 06106-8002

JONATHAN E. SNYDER

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