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g g FLOYD CIRCUIT COURT. i
w. J. Elliott, Plaintiff.
;é Against // Answer. g
;% Chesapeake & Ohio Railway Company, Defendant. %
5% The defendant, Chesapeake & Ohio Railway Company, for it
g: answer and defense to plaintiff's petition herein, says that k
ii it is untrue and it denies that on the ____day of _____l9l4, if
g: or other date, Without any fault on the part of plaintiff's 4;
§:‘ driver or while he was exercising all or any necessary or g;
%: proper care or attention in driving plaintiff's said horse, E
%;E_ i that the defendant, or its agents or servants or employees g
a, i so or at all negligently or carelessly operated one of its @
£3 trains of cars or engines in such close proximity to plain- .
;fi; tiff's said horse or buggy, or that it operated the same so i
fig or at all negligently or carelessly or in such a reckless or g
3? unnecessary manner by throwing from its engine steam or water g
g; in unnecessary large quantities or by making violent or une ?
5g necessary noises that plaintiff's said horse became thereby ?
i: frightened or run over a steep embankment or into Big 3
3? Sandy River, or thereby greatly injyred his said horse or g
a% tearing up or demolishing said buggy. That it has no knowl- g
$5 edge or information sufficient upon which to found a belief ?
g: as to Whether or not said horse was so frightened or damaged %
a; that he was with great difficulty extricated from the river 5
ff or prevnted from being drowned, and therefore denies said %
g; avemments. Denies that the damages to said horse are reason- f
g? ably $ 50.00, or other sum or mnount over or above $ 25.00; V
i} denies that the buggy was almost completely destroyed or ?