provide a supplemental discovery for the Ipana case below is the attachment along with the remaining details that wasn't in photo .

NEW MATTER 11. Plaintiff is barred from bringing this action because the applicable statute of limitations had expired prior to the institution of suit. 12. The alleged negligence of the defendant was not the proximate cause of the alleged accident or plaintiff's injuries. 13. At all times material to this cause of action, plaintiff failed to exercise the proper care and precaution required of an ordinary and prudent person under the circumstances and, therefore, her claims should be barred or should be mitigated by her comparative negligence. 14. Plaintiff's negligence, carelessness, and recklessness was an intervening and superceding cause of her injuries. 15. Plaintiff assumed the risk of injury. WHEREFORE, Defendant demands judgment in its favor.

Plaintiff, V. SHIGLEY'S SUPERMARKE:T, INC. Defendant. | ; Case No. 10-7575 DEFENDANT'S ANSWER TO CIVIL ACTION COMPLAINT _ . Denied. Defendant is without sufficient information to form a belief as to the truth and veracity of this allegation and, therefore, same is denied. Admitted. . Denied. Defendant is without sufficient information to form a belief as to the truth and veracity of this allegation and, therefore, same 1s denied. Denied as a conclusion of law. Denied as a conclusion of law. Denied as a conclusion of law. Denied. Defendant is without sufficient information to form a belief as to the truth and veracity of this allegation and, therefore, same is denied. 8. Denied. Defendant 1s without sufficient information to form a belief as to the truth and veracity of this allegation and, therefore, same is denied. 9. Denied. Defendant is without sufficient information to form a belief as to the truth and veracity of this allegation and, therefore, same is denied. 10. Denied. Defendant 1s without sufficient information to form a belief as to the truth and veracity of this allegation and, therefore, same is denied. WHEREFORE, Defendant demands judgment in its favor. w =1 o oh s NEW MATTER 11. Plaintiff is barred from bringing this action because the applicable statute of limitations had expired prior to the institution of suit. 12. The alleged negligence of the defendant was not the proximate cause of the alleged accident or plaintiff's injuries. 13. At all times material to this cause of action, plaintiff failed to exercise the proper care and precaution required of an ordinary and prudent person under the circumstances and, therefore, her claims should be barred or should be et e ; |