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Roger Wittenberg responds to a civil lawsuit.
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Save Answer to Complaint For Later Filing # 50812602 E-Filed 01/05/2017 01:59:02 PM
IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY
CASENO.: 16012590 -AF
FLORIDA BAR NO.: 651583
ELOISA SMITH as Personal Representative
of the Estate of JOHN GERALD SMITH, deceased
Plaintiff,
: Oo
ROGER WITTENBERG ©
Defendant
COMES NOW the Defendant, ROGER SNBERG, by and through her undersigned
counsel, and hereby files this her okies
1, Each and Every all Plaintiff's Complaint is hereby separately and
severally denied and striot pr a
OFA The aa |OHN GERALD SMITH caused and/or contributed to the
tiff's Complaint and states as follows
injuries that he sust a therefore, any award rendered to him should be reduced by the
amount of his ¢ or the Plaintiff should not be entitled to recover at all.
& Bose sMaris as Personal Representative of the Estate of JOHN GERALD
SMAfEEL Shot emttied to recover as damages in tis ease any amount which represents medical
expenses, lost wages, and death benefits paid or payable from personal injury protection
insurance coverage or any other collateral source.
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/05/2017 01:59:02 PM 4, ‘The Plaintiffs’ damages, if any, were caused by the negligence of third patties, the
City of Delray Beach, the Florida Department of Transportation and the construction company
who will be identified through discovery who put up a tarp around fencing blocking the view of
the intersection, and/or any and all other thitd parties which discovery may reveal; hence the
Plaintiffs cannot recover from this Defendant, for his damages, if any, against this Hefendant
should be limited to the degree that their negligence contributed to the em
§768.81(3), Florida Statutes,
WHEREFORE, this Defendant demands trial by jury ofall inne or right,
1 HEREBY CERTIFY that a true and correct may above and foregoing was
furnished by electronic mail this 5" day of January, 201 ce Garcia, Esq. Searcy, Denney,
Scarola Barnhart & Shipley, PA 2139 Palm ee |, West Palm Beach, FL 33409,
ROBB, MASON, COULOMBE,
BU & CHARBONNET
9501 Wiles Road, Suite 207
aa,
