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`DOCKET NO: HHD-CV22-6162157-S
`
`NANCY RICHENS, ET AL.
`
`V.
`
`TRAVELERS HOME AND MARINE
`INSURANCE COMPANY, ET AL.
`
`: SUPERIOR COURT
`
`
`:
`J.D. OF HARTFORD
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`
`:
`AT HARTFORD
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`: MARCH 14, 2023
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`FIRST COUNT:
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`ANSWER
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`The Defendants do not respond to the allegations contained in this Count as they are not
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`directed towards them.
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`SECOND COUNT:
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`1.
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`2.
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`3.
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`Paragraph 1 is admitted.
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`Paragraph 2 is admitted.
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`As to paragraph 3, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`4.
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`As to paragraph 4, the defendant admits that a collision occurred. As to the
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`remaining allegations contained in this paragraph, the defendant has insufficient knowledge upon
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`which to form a belief and leaves the plaintiff to his burden of proof.
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`5.
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`As to paragraph 5, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`HANKS, OLSEN & SHEEHAN
`538 PRESTON AVENUE, SUITE 305, MERIDEN, CT 06450 (203) 427-2160 (866) 540-7599
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`6.
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`As to paragraph 6, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`7.
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`As to paragraph 7, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`8.
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`As to paragraph 8, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`9.
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`As to paragraph 9, the defendant has insufficient knowledge upon which to form
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`a belief and leaves the plaintiff to his burden of proof.
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`10.
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`As to paragraph 10, the defendant has insufficient knowledge upon which to form
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`a belief and leaves the plaintiff to his burden of proof.
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`THIRD COUNT:
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`1-10. Paragraphs 1 through 10 of the Second Count are hereby incorporated as
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`paragraphs 1 through 10 of Third Count.
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`11.
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`12.
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`13.
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`14.
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`Paragraph 11 is admitted.
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`Paragraph 12 is admitted.
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`Paragraph 13 is denied.
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`Paragraph 14 is denied.
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`FOURTH COUNT:
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`HANKS, OLSEN & SHEEHAN
`538 PRESTON AVENUE, SUITE 305, MERIDEN, CT 06450 (203) 427-2160 (866) 540-7599
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`The Defendants do not respond to the allegations contained in this Count as they are not
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`directed towards them.
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`FIFTH COUNT:
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`1.
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`2.
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`3.
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`Paragraph 1 is admitted.
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`Paragraph 2 is admitted.
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`As to paragraph 3, the defendant has insufficient knowledge upon which to form a
`
`belief and leaves the plaintiff to his burden of proof.
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`4.
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`As to paragraph 4, the defendant admits that a collision occurred. As to the
`
`remaining allegations contained in this paragraph, the defendant has insufficient knowledge upon
`
`which to form a belief and leaves the plaintiff to his burden of proof.
`
`5.
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`As to paragraph 5, the defendant has insufficient knowledge upon which to form a
`
`belief and leaves the plaintiff to his burden of proof.
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`6.
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`As to paragraph 6, the defendant has insufficient knowledge upon which to form a
`
`belief and leaves the plaintiff to his burden of proof.
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`7.
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`As to paragraph 7, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`8.
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`As to paragraph 8, the defendant has insufficient knowledge upon which to form a
`
`belief and leaves the plaintiff to his burden of proof.
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`HANKS, OLSEN & SHEEHAN
`538 PRESTON AVENUE, SUITE 305, MERIDEN, CT 06450 (203) 427-2160 (866) 540-7599
`
`
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`
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`9.
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`As to paragraph 9, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`SIXTH COUNT:
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`1-9.
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`Paragraphs 1 through 9 of the Fifth Count are hereby incorporated as paragraphs 1
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`through 9 of the Sixth Count.
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`10.
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`11.
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`12.
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`13.
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`Paragraph 10 is admitted.
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`Paragraph 11 is admitted.
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`Paragraph 12 is denied.
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`Paragraph 13 is denied.
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`SEVENTH COUNT:
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`The Defendants do not respond to the allegations contained in this Count as they are not
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`directed towards them.
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`EIGHTH COUNT:
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`The Defendants do not respond to the allegations contained in this Count as they are not
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`directed towards them.
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`NINTH COUNT:
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`HANKS, OLSEN & SHEEHAN
`538 PRESTON AVENUE, SUITE 305, MERIDEN, CT 06450 (203) 427-2160 (866) 540-7599
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`1-10. Paragraphs 1 through 10 of the Second Count are hereby incorporated as
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`paragraphs 1 through 10 of the Ninth Count.
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`
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`11.
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`12.
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`Paragraph 11 is admitted.
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`As to paragraph 12, the defendant has insufficient knowledge upon which to form
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`a belief and leaves the plaintiff to his burden of proof.
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`TENTH COUNT:
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`1-6.
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`Paragraphs 1 through 6 of the Second Count are hereby incorporated as
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`paragraphs 1 through 6 of the Tenth Count.
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`7.
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`8.
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`Paragraph 7 is admitted.
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`As to paragraph 8, the defendant admits that the plaintiff was present at the scene
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`of the accident. As to the remaining allegations contained in this paragraph, the defendant has
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`insufficient knowledge upon which to form a belief and leaves the plaintiff to his burden of
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`proof.
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`
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`9.
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`As to paragraph 9, the defendant has insufficient knowledge upon which to form a
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`belief and leaves the plaintiff to his burden of proof.
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`
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`10.
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`As to paragraph 10, the defendant has insufficient knowledge upon which to form
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`a belief and leaves the plaintiff to his burden of proof.
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`HANKS, OLSEN & SHEEHAN
`538 PRESTON AVENUE, SUITE 305, MERIDEN, CT 06450 (203) 427-2160 (866) 540-7599
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`The Defendants,
`ADDYSON L. STOUDT AND LIZA M.
`STOUDT
`
`
`
`
`By:
`Mark J. Sheehan, Esq.
`Hanks, Olsen & Sheehan
`538 Preston Avenue, Suite 305
`Meriden, CT 06450
`Tel: (203) 427-2160
`Juris No.: 419471
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`
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`HANKS, OLSEN & SHEEHAN
`538 PRESTON AVENUE, SUITE 305, MERIDEN, CT 06450 (203) 427-2160 (866) 540-7599
`
`
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` CERTIFICATION
`
`
`I certify that a copy of this document was or will immediately be mailed or delivered
`electronically or non-electronically on March 14, 2023, to all counsel and self-represented parties
`of record and that written consent for electronic delivery was received from all counsel and self-
`represented parties of record who were or will immediately be electronically served.
`Name and address of each party and attorney that copy was or will immediately be mailed
`or delivered to:
`Christopher J. Flood, Esq.
`The Flood Law Firm, LLC
`190 Washington Street
`Middletown, CT 06457
`
`Cynthia Ann Jaworski, Esq.
`Law Offices of Cynthia M. Garraty
`PO Box 2903
`Hartford, CT 06104
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`____________________________________
`Mark J. Sheehan, Esq.
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`HANKS, OLSEN & SHEEHAN
`538 PRESTON AVENUE, SUITE 305, MERIDEN, CT 06450 (203) 427-2160 (866) 540-7599
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