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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVANIA
`
`:
`ROXANNE WEST, p/n/g, on behalf of
`:
`S.W., an incapacitated person,
`
`:
`
`
`
`Plaintiff,
`
`:
`
`
`
`
`
`
`:
`
`
`v.
`
`
`
`:
`
`
`
`
`
`
`:
`PITTSBURGH PUBLIC SCHOOLS;
`:
`A.J. MYERS & SONS, INC.;
`
`:
`JOHN DOE 1; JOHN DOE 2;
`
`:
`JOHN DOE 3; JOHN DOE 4;
`
`:
`JOHN DOE 5; XYZ CORPORATION 1
`:
`XYZ CORPORATION 2; XYZ
`
`CORPORATION 3, XYZ CORPORATION :
`4, AND XYZ CORPORATION 5, (John
`:
`Does 1-5 and XYZ Corporations 1-5 are
`:
`fictitious names),
`
`
`
`:
`
`
`
`Defendants.
`
`:
`
`
`No. GD 22-002376
`
`
`
`
`
`
`
`
`
`PLAINTIFF’S REPLY TO NEW MATTER OF
` DEFENDANT AJ MEYERS & SON, INC.
`
`AND NOW, comes the Plaintiff, by and through her undersigned counsel, hereby responds to the new
`
`matter of Defendant AJ Meyers & Son, Inc.:
`
`
`
`1. – 5. Denied. Denied as a conclusion of law to which no responsive pleading is
`
`required by the Pennsylvania Rules of Civil Procedure. To the extent an answer is required, after
`
`reasonable investigation, Plaintiff is without the knowledge or information sufficient to form a
`
`belief as to the truth of the averments contained in these paragraphs. Accordingly, strict proof
`
`thereof is demanded at the time of trial.
`
`
`
`
`
`
`
`

`

`Respectfully submitted,
`
`MORGAN & MORGAN, P.A.
`
`
`BY:
`ALAN J. BOROWSKY, ESQUIRE
`Attorney for Plaintiff
`
`Dated: November 18, 2022
`
`
`
`
`
`

`

`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVANIA
`
`:
`ROXANNE WEST, p/n/g, on behalf of
`:
`S.W., an incapacitated person,
`
`:
`
`
`
`Plaintiff,
`
`:
`
`
`
`
`
`
`:
`
`
`v.
`
`
`
`:
`
`
`
`
`
`
`:
`PITTSBURGH PUBLIC SCHOOLS;
`:
`A.J. MYERS & SONS, INC.;
`
`:
`JOHN DOE 1; JOHN DOE 2;
`
`:
`JOHN DOE 3; JOHN DOE 4;
`
`:
`JOHN DOE 5; XYZ CORPORATION 1
`:
`XYZ CORPORATION 2; XYZ
`
`CORPORATION 3, XYZ CORPORATION :
`4, AND XYZ CORPORATION 5, (John
`:
`Does 1-5 and XYZ Corporations 1-5 are
`:
`fictitious names),
`
`
`
`:
`
`
`
`Defendants.
`
`:
`
`No. GD 22-002376
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`I, Alan J. Borowsky, Esquire, hereby certify that I have served a true and correct copy of
`
`Plaintiffs’ Motion to Compel Production of Documents via e-mail, to counsel for Defendants as follows:
`
`Michael C. Hamilton, Esq.
`Weber Gallagher
`4 PPG Place, 5th Floor
`Pittsburgh, PA 15222
`mhamilton@wglaw.com
`
`Jaime N. Doherty, Esq.
`GRB Law
`525 William Penn Place, Suite 3110
`Pittsburgh, PA 15219
`jdoherty@grblaw.com
`
`
`
`Dated: November 18, 2022
`
`
`
`MORGAN & MORGAN, P.A.
`
`
`BY:
`ALAN J. BOROWSKY, ESQUIRE
`
`
`
`
`
`
`

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