UNITED STATES DISTRICT COURT

for the
District of Vermont
Civil Division

SPENCER FLANNIGAN : Civil Action No.

Plaintiff, :

:
v.
:
LASSITER CENTRAL CLINIC OF
VERMONT, a corporation : ANSWER FOR DAMAGES
DR. BETHANY RANDALL, an
individual :

Defendants. :
____________________________

Answer to First Count

Defendants, Lassiter Central Clinic of Vermont and Bethany Randall, answer as follows:
1. Defendants admit in part and deny in part, the allegations of Paragraphs 1.
2. Defendants admit the allegations of Paragraph 2 of the complaint.

Answer to Second Count

3. In answer to Paragraph 3 of Count Two of the complaint, defendants admit in
part, and deny in part.
4. Defendants deny each and every allegation contained in Paragraphs 4 and 5 of
the complaint.
5. In answer to Paragraph 6 of Count Two of the complaint, defendants admit in
part and deny in part.
6. Defendants deny each and every allegation contained in Paragraph 7 of the
complaint.
7. Defendants admit in part and deny in part, Paragraph 8 of the complaint.
 Wherefore defendants pray that:
1. The Court enter judgement dismissing the complaint;
2. The defendants be awarded costs incurred herein; and
3. The defendants be awarded further relief as the Court sees just.

Dated: November 18, 2017

Respectfully submitted,

___________________________
William Radcliffe, Esq.
Reeves, Allyn, and Cain
500 Hospital Dr.
Berlin, Vermont 05602
wradcliffe@RAC.com
(802) 759-3246

Certificate of Service

I, William Radcliffe, attorney for defendants, do certify that a true and accurate
copy of the Answer was served on Roger Hutchinson, attorney for Plaintiff, at 124 Sue
Rd. Berlin, Vermont 05602 by ordinary mail, on November 19, 2017.

___________________________
William Radcliffe, Esq.