APPENDIX 11
| Jurisdiction | Colorado |
| DISTRICT COURT, ANY COUNTY, COLORADO | ▲ COURT USE ONLY ▲ |
| PLAINTIFF: HOMEOWNER DEFENDANTS: DEFENDANT, MR. DEFENDANT, ENGINEER, CIVIL ENGINEER, DEVELOPER, ETC. CROSS-CLAIMANTS: DEFENDANT and MR. DEFENDANT CROSS-CLAIM DEFENDANTS: ENGINEER/DESIGN PROFESSIONAL, DEVELOPER, MR. DEVELOPER AND SUBCONTRACTORS | |
| Case Number: xx CV xxx Division: X | |
| COUNSEL FOR DEFENDANTS/CROSS-CLAIMANTS: Lawyer ALL CAPS LAW FIRM, P.C. Address Phone | |
| DEFENDANTS' ANSWER TO FIRST AMENDED COMPLAINT, CROSS-CLAIMS AND JURY DEMAND | |
Defendant and Mr. Defendant, by and through their attorneys, the law firm of ALL CAPS LAW FIRM, hereby state the following for their Answer to Plaintiff's First Amended Complaint and Jury Demand:
1. The first sentence of Paragraph 1 is denied for lack of information or belief. The second and third sentences of Paragraph 1 are admitted.
2. Admitted.
3. Denied for lack of information or belief.
4. Admitted.
5. With respect to the allegations contained in Paragraph 5, Def admits that it owned only those duties imposed under Colorado law and denies the allegations contained in Paragraph 5 to the extent it is inconsistent with those duties. Def admits that certain work on the project was performed by subcontractors.
6. With respect to the allegations contained in the first sentence of Paragraph 6, Mr. Def admits that he was an officer and employee of Def and generally denies the remaining allegations contained in the first sentence to the extent they allege Mr. Def acted wrongfully in any respect related to this matter. Mr. Def specifically denies that he developed, marketed or sold the subject house. With respect to the allegations contained in the second sentence of Paragraph 6, Mr. Def admits the implication that all work he performed in relation to the house were performed in his capacity of an employee of Def, but denies the remaining allegations contained in the second sentence of Paragraph 6.
7. Denied.
8. Admitted that Def was the architect for the subject project and provided architectural design services in that role. Def admits that it owed only those duties imposed on architects under Colorado law and denies the allegations contained in Paragraph 8 to the extent they assert duties beyond those imposed under Colorado law. The remaining allegations contained in Paragraph 8 are denied.
9. The first sentence of Paragraph 9 is denied to the extent it alleges Mr. Def retained Engineer to perform work on the subject project, denied for lack of information or belief to the extent it asserts that Def retained Engineer and admitted to the extent it alleges that Engineer performed structural engineering for the subject project. All remaining allegations contained in Paragraph 9 are denied for lack of information or belief.
10. The first sentence of Paragraph 10 is denied to the extent it asserts that Def. or Mr. Def retained Civil Eng. and to the extent that it asserts Civil Eng. performed civil investigations or observations on the project. The second sentence of Paragraph 10 is denied for lack of information or belief.
11. Admitted upon information and belief.
12. Admitted upon information and belief.
13. Admitted upon information and belief.
14. Def and Mr. Def object to Paragraph 14 of the Complaint as it violates the requirement of C.R.C.P. 8(e)(1) that "Each averment of a pleading shall be simple, concise, and direct." Without waiving their objection, Def and Mr. Def deny the allegations contained in Paragraph 14.
15. Def and Mr. Def object to Paragraph 15 of the Complaint as it violates the requirement of C.R.C.P. 8(e)(1) that "Each averment of a pleading shall be simple, concise, and direct." Without waiving their objection, Def and Mr. Def deny the allegations contained in Paragraph 15.
16. Def and Mr. Def object to Paragraph 16 of the Complaint as it violates the requirement of C.R.C.P. 8(e)(1) that "Each averment of a pleading shall be simple, concise, and direct." Without waiving their objection, Def and Mr. Def deny the allegations contained in Paragraph 16.
17. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
18. Denied for lack of information or belief.
19. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
20. Denied for lack of information or belief.
21. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
22. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
23. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
24. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
25. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
26. Denied as to Def and Mr. Def. Denied for lack of information and belief as to all other parties.
27. Def and Mr. Def object to Paragraph 27 of the Complaint as it violates the requirement of...
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