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ANSWER
Defendant, Contemporary Services Corporation (CSC), answers the complaint as
follows, the numbers below corresponding with those in the complaint:
1.
2.
3.
Admitted.
4.
5.
Admitted.
6.
Admitted.
7.
Admitted.
8.
9.
CSC is without sufficient information to either admit or deny the allegation set
forth in paragraph 9 of the Complaint, and denies that said allegations are relevant to this
proceeding.
10.
CSC denies that it was throwing out property belonging to fans. CSC admits
that, because of the size of the bags in question and at the direction of Tennessee Football, Inc.
d/b/a Tennessee Titans, CSC did not permit Ms. Richardson and other fans to enter LP Field with
Titans grocery bags in their possession. CSC denies that Ms. Richardson was refused entry in
line at Gate 7.
11.
CSC admits the allegations set forth in paragraph 11 of the Complaint, except for
the allegation that Ms. Richardson was ever hassled. CSC denies this allegation.
12.
13.
14.
CSC is without sufficient information to either admit or deny the allegations set
forth in paragraph 14 of the Complaint, except that it admits that it called medical staff to tend to
Ms. Richardson and admits that it offered an ambulance to transport Ms. Richardson to a
hospital.
15.
CSC is without sufficient information to either admit or deny the allegations set
CSC is without sufficient information to either admit or deny the allegations set
CSC is without sufficient information to either admit or deny the allegations set
CSC is without sufficient information to either admit or deny the allegations set
20.
from CSC.
21.
22.
from CSC.
23.
24.
The allegations set forth in paragraph 24of the Complaint require no response
from CSC.
25.
26.
from CSC.
27.
28.
from CSC.
29.
30.
31.
from CSC.
32.
AFFIRMATIVE DEFENSES
1.
The plaintiffs Complaint fails to state a claim for which relief can be granted.
2.
Pursuant to the doctrine of comparative fault, CSC asserts that the plaintiffs
damages, if any, were caused by others, including but not limited to plaintiff, Marcia Richardson
and Tennessee Football, Inc. d/b/a Tennessee Titans. Tennessee Football, Inc. may be served
with process through its registered agent, CT Corporation System, whose address is 800 South
Gay Street, Suite 2021, Knoxville, Tennessee, 37929-9710.
Defendant, CSC reserves leave herein to plead such further and additional defenses as it
may have after further investigation into the facts of this case. Any allegations of the complaint
not heretofore admitted, explained, or denied, are here and now denied.
WHEREFORE, CSC prays for judgment dismissing this action with prejudice, for its
costs and expenses in this action.
Respectfully submitted this _____ day of ____________________________, 2013.