DISTRICT COURT, COUNTY of DENVER, COLORADO, ruled in favor of defendant and third party plaintiff. Plaintiff, Worst Deal, Inc., alleged slippery tile company's vinyl floor tile caused her injuries. Slippery's attorney, Rip U. Awff, filed an ANSWER and third party complaint.
DISTRICT COURT, COUNTY of DENVER, COLORADO, ruled in favor of defendant and third party plaintiff. Plaintiff, Worst Deal, Inc., alleged slippery tile company's vinyl floor tile caused her injuries. Slippery's attorney, Rip U. Awff, filed an ANSWER and third party complaint.
DISTRICT COURT, COUNTY of DENVER, COLORADO, ruled in favor of defendant and third party plaintiff. Plaintiff, Worst Deal, Inc., alleged slippery tile company's vinyl floor tile caused her injuries. Slippery's attorney, Rip U. Awff, filed an ANSWER and third party complaint.
Defendant and Third Party Plaintiff: Worst Deal, Inc.,
v.
Third Party Defendant: Slippery Tile Company, Inc.
COURT USE ONLY Rip U. Awff Attorney for Defendant 430 Herald Square, Suite 1022 Denver, CO 80203
303-555-3333 FAX: 303-522-3333 counsel@ripawff.com Registration #: 1444 Case Number: 07CV1002
Div.: 10 Ctrm.: 2
ANSWER AND THIRD PARTY COMPLAINT
The defendant, and third party plaintiff, Worst Deal, Inc., by and through its counsel, Rip U. Awf, for its Answer and Third Party Complaint states and alleges as follows:
1. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegation contained in paragraph 1 of the Complaint, and therefore, denies this allegation.
2. Defendant admits the allegation contained in paragraph 2 of the plaintiff's Complaint.
3. Defendant denies the allegations contained in paragraphs 3, 4, 5, 6, 7, 8, 9, 10, and 11 of the plaintiff's Complaint.
4. All other allegations of the plaintiff's Complaint that are not specifically admitted are denied.
AFFIRMATIVE DEFENSES
5. The Complaint fails to state a claim upon which relief can be granted.
6. The plaintiff's own negligence contributed or caused his injuries.
THIRD PARTY COMPLAINT
1. Third party defendant, Slippery Tile Company, Inc., is incorporated to do business in Colorado, with its principal place of business located at 1400 Industrial Avenue, Denver, Colorado 80201, and third party defendant's registered agent is Jan Jones, who can be served with process at the same address. 2. On October 12, 20__, Worst Deal, Inc., purchased vinyl floor tile from Slippery Tile Company, Inc., for installation at the store located at 150 North Accident Way.
3. In deciding to purchase the vinyl floor tile, Worst Deal, Inc., relied on written and oral warranties and representations that the vinyl floor tile, which was manufactured by Slippery Tile Company, Inc., was "skid proof" and "safe even when wet."
4. On October 12, 20__, Worst Deal, Inc., paid $25,000.00 to Slippery Tile Company, Inc., for the purchase and installation of the vinyl floor tile, which was subsequently installed on October 19, 20__.
5. On December 30, 20__, Kelley Klutz, the plaintiff in this action, allegedly slipped and fell on tile sold and installed by Slippery Tile Company, Inc.
6. Worst Deal, Inc., has been served with a Complaint for damages allegedly incurred by Kelley Klutz, and a copy of this Complaint is attached hereto as exhibit "A".
7. This process should have been served upon Slippery Tile Company, Inc., for its negligence and strict liability in selling and installing defective floor tile.
8. Any damages claimed by the plaintiff are a direct and proximate result of the negligence of Slippery Tile Company, Inc., and should any damages be assessed against Worst Deal, Inc., Worst Deal, Inc., is entitled to judgment against Slippery Tile Company, Inc., in that same amount.
WHEREFORE, the defendant and third party plaintiff prays that the plaintiff recover nothing by reason of his Complaint, that the plaintiff's Complaint be dismissed, and that the third party plaintiff receive judgment from third party defendant for all sums that may be adjudged against the defendant in favor of the plaintiff.
Defendant's Address: 150 North Accident Way Denver, Colorado 80213 Respectfully submitted,
___________________________________ Rip U. Awff, #1444 Attorney for Defendant and Third Party Plaintiff
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing Answer and Third Party Complaint was served this ____ day of _____________, 20__, by placing them in the United States mail, first class postage prepaid, addressed as follows:
Ima Gogetter Candice Corporate Attorney for Plaintiff Attorney for Third Party Defendant 511 Law Office Lane 123 Business Boulevard, Suite A Denver, Colorado 80203 Denver, CO 80220
LEASE BASIC RENTAL AGREEMENT or RESIDENTIAL LEASE This Rental Agreement or Residential Lease Shall Evidence the Complete Terms and Conditions Under Which the Parties Whose Signatures Appear Below Have Agreed
LEASE BASIC RENTAL AGREEMENT or RESIDENTIAL LEASE This Rental Agreement or Residential Lease Shall Evidence the Complete Terms and Conditions Under Which the Parties Whose Signatures Appear Below Have Agreed