Read the Facts:

Parties:

1. K., minor by her Parents and guardians, Janice Knowles and Steven Knowles, 1243 Asbury Ave., Bennington Vermont
2. Ronald Clemmons, 24 Logan Street, Albany, NY
3. Lower Council School District, 701 Wilkes Rd., Albany, NY
4. Bud Smith and Ace Trucking, 2501 Industrial Hwy, Center Bridge, NY

Ronald Clemmons, a 69 year old licensed bus driver was employed by Lower Council School District.

Bud Smith was a licensed dump truck driver working for Ace Trucking.

On Oct. 21, 2017, Mr. Clemmons picked up 44 children for a field trip. B.K., was a minor on that bus.

At approximately 10:30 am, that same day, Defendant Bud Smith failed to stop at a stop sign and entered the intersection at SR-30A and SR-7 when he collided with the truck.

As a result of the accident, B.K., minor was injured requiring surgery and hospitalization and other medical treatment, damages in excess of $75,000.

At approximately 10:30 am on October 21, 2017, plantiff boarded a school bus for a scheduled field trip which consisted of forty-four children and eigh adults. The school bus was driven by defendant Ronald Clemmons who was employed for the Lower Council School District. The bus was traveling north on SR-30A going approximately 15 and 25 mph as it approached the intersection with SR-7. The north and south bound traffic on SR-30A was controlled by multiple warning signs and flashing indicators all implying to stop. Defendant Clemmons, who was lloking for SR-7, saw the posted stop sign and slowed down but did not completely hault the bus which then entered the intersection. Upon entering the intersection the bus was struck on the right side behind the real axel by a dump truck which was operated by Defendant Bud Smith who was employed by Ace Trucking Company. Defendant Smith was driving the dump truck with utility trailer, owned and operated by Defendant Ace. Defendant Smith was traveling about 45 mph westbound on SR-7. East and westbound traffic on SR-7 at the intersection with SR-30A was controlled by flashing yellow intersection control beacons.Plaintiff is filing this complaint against Defendant Clemmons because he was negligent when he failed to stop the school bus at a stop sign. Plantiff is filing this complaint against Defendant Smith for being negligent in the operation and control of a dump truck driving too fast for conditions while approaching an intersection with flashing yellow lights. The platiff is filing suit against the school because plantiff believes that the school failed to properly supervise, control and direct its employee Defendant Clemmons. Finally plantiff is filing suit against Defendant Ace because the company was negligent in failing to inspect and correct mechanical deficiences to the brake system, the air hose linking the truck and trailer, permitting use of a dump truck to pull a trailer, allowing its driver to operate a vehicle not designed to pull a trailer, and failed to properly suprvise and train employee Smith concerning the rules of the road.

Four reasons of negligence caused by all four defendants is what resulted in this plantiff enduring damages and having to seek relief. First, as a result of Defendant School's negligence in employing and supervising Defendant Clemmons the collosion on October 21, 2017 occurred causing the plantiff to suffer in a multitude of ways. Secondly, the plantiff was injured when the impact of the dump truck with the school bus occurred so she was thrown about the interior of the school bus striking her head and shoulder on the side and roof of the bus resulting in a fractured skill and fractured vertebra C3 and 4, contusions and abrasions suffering damages. Thirdly, Defendant Smith was negligent in the operation and control of a dump truck driving too fast for conditions while approaching an intersection with flashing yellow lights. Fourthly Defendants Ace's negligence, caused the dump truck to stike the school bus in which the plantiff was a passenger. Plantiff endured: surgical treatment and repair of a fractured skull, placement of a halo brace upon her head and shoulders for stabilization and healing of vertebra fractures as C3 and 4, physical therapy to rehabilitate and restore the normal use of her head and neck, medical expenses related to the treatement and rehabilitation for the injuries sustained, time lost from school while hospitlized and unable to attend school, arranging and paying for private tutors to come to her home for missed school instruction, inability to participate in soccer or Daisy Scouts, and any other damges wil be established at the trial of this matter. Against each of the four defendants the plaintiff is reqesting the Honorable court to enter judgment in her favor against the defandants in an amount exceeding $75,000 plus interest, costs, attorneys fees and such other relief as deemed equitable.

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1.) Fill the form in which is the four images attached to this. "The Defendant's Answer To The Complaint"

2.) You can pick which Defendant- Ronald Clemmons, Lower Council School District, Bud Smith/Ace Trucking who you are Answering for.

3. Again, this is a Federal Form. Please read form carefully in section B:Presenting Defenses to the Claim of Reliefyou just fill out the numbered sections that apply to your Defendant. For example, if you claim your Defendant never got served with the lawsuit, then you would answer #4 why the service was insufficient; or if venue is improper answer # 3 and so on.

4. In Section C:Asserting Affirmative Defenses to the Claims of Relief-you are objecting to the Claim of Relief (facts stated in complaint), you are to state Plaintiff's claim and then fill out any areas that you believe bar the Plaintiff's claim. For example, if you claim Statute of Limitations (Laches) then you would fill out #11, Contributory Negligence claims you would fill out #4.

5. You only need to fill out what applies.Counterclaim is not required, but if want to try- go ahead.

6. Please include your affirmative defenses in your Answer to the Complaint. List of affirmative defenses from Federal Rules of Civil Procedure - Rule 8 (c) https://www.law.cornell.edu/rules/frcp/rule_8

Looking forward to seeing who helps assist me with this so I can rate the tutor. I appreciate the hard work.

Pro Se 3 (Rev. 12/16) The Defendant's Answer to the Complaint UNITED STATES DISTRICT COURT for the District of Division Case No. (to be filled in by the Clerk's Office) Plaintiff(s) Write the full name of each plaintiff who is filing this complaint. If the names of all the plaintiffs cannot fit in the space above, Jury Trial: (check one) Yes No please write "see attached" in the space and attach an additional page with the full list of names.) -V- Defendant(s) (Write the full name of each defendant who is being sued. If the names of all the defendants cannot fit in the space above, please write "see attached" in the space and attach an additional page with the full list of names.) THE DEFENDANT'S ANSWER TO THE COMPLAINT I. The Parties Filing This Answer to the Complaint Provide the information below for each defendant filing this answer or other response to the allegations in the plaintiff's complaint. Attach additional pages if needed. Name Street Address City and County State and Zip Code Telephone Number E-mail Address II. The Answer and Defenses to the Complaint A. Answering the Claims for Relief On a separate page or pages, write a short and plain statement of the answer to the allegations in the complaint. Number the paragraphs. The answer should correspond to each paragraph in the complaint, with paragraph 1 of the answer corresponding to paragraph 1 of the complaint, etc. For each paragraph in the complaint, state whether: the defendant admits the allegations in that paragraph; denies the allegations; lacks sufficient knowledge to admit or deny the allegations; or admits certain allegations but denies, or lacks sufficient knowledge to admit or deny, the rest. Page 1 of 7Pro Se 3 (Rev. 12/16) The Defendant's Answer to the Complaint Pro Se 3 (Rev. 12/16) The Defendant's Answer to the Complaint B. Presenting Defenses to the Claims for Relief a. If the basis for subject-matter jurisdiction is diversity of citizenship, state the effect of Write a short and plain statement identifying the defenses to the claims, using one or more of the adding the other party: following alternatives that apply The other party is a citizen of the State of (name) Or is a citizen of (foreign nation) The amount of The court does not have subject-matter jurisdiction over the claims because (briefly explain why there is no federal-question jurisdiction or diversity of citizenship jurisdiction; see the complaint form for more damages sought from this other party is (specify the amount) information) J . If the claim by this other party is based on an alleged violation of a federal constitutional or statutory right, state the basis: 2. The court does not have personal jurisdiction over the defendant because (briefly explain) C. Asserting Affirmative Defenses to the Claims for Relief Identify an affirmative defense or avoidance that provides a basis for the defendant to avoid liability for 3. The venue where the court is located is improper for this case because (briefly explain) one or more of the plaintiff's claims even if the basis for the claim is met. Any affirmative defense or avoidance must be identified in the answer. Include any of the following that apply, as well as any others that may apply. The plaintiff's claim for (specify the claim) 4 The defendant was served but the process-the form of the summons-was insufficient because (briefly explain) is barred by (identify one or more of the following that apply): 1 . Accord and satisfaction (briefly explain) 5. The manner of serving the defendant with the summons and complaint was insufficient because (briefly explain) 2. Arbitration and award (briefly explain) 5 The complaint fails to state a claim upon which relief can be granted because (briefly explain why the facts alleged, even if true, are not enough to show the plaintiff's right to recover) 3. Assumption of risk (briefly explain) 7. Another party (name) needs to be joined (added) 4. Contributory or comparative negligence of the plaintiff (briefly explain) in the case. The reason is (briefly explain why joining another party is required) 5. Duress (briefly explain) Page 2 of 7 Page 3 of 7Pro Se 3 (Rev. 12/16) The Defendant's Answer to the Complain Pro Se 3 (Rev. 12/16) The Defendant's Answer to the Complaint 16. Statute of frauds (briefly explain) 6. Estoppel (briefly explain) 17. Statute of limitations (briefly explain) 7. Failure of consideration (briefly explain) 18. Waiver (briefly explain) 8. Fraud (briefly explain) 19. Other (briefly explain) 9. Illegality (briefly explain) D. Asserting Claims Against the Plaintiff (Counterclaim) or Against Another Defendant (Cross-Claim) 10. Injury by fellow employee (briefly explain) For either a counterclaim against the plaintiff or a cross-claim against another defendant, state briefly the facts showing why the defendant asserting the counterclaim or cross-claim is entitled to the damages or other relief sought. Do not make legal arguments. State how each opposing party was involved and what each did that caused the defendant harm or violated the defendant's rights, including the dates and 11. Laches (Delay) (briefly explain) places of that involvement or conduct. If more than one counterclaim or cross-claim is asserted, number each claim and write a short and plain statement of each claim in a separate paragraph. Attach additional pages if needed. 1 . The defendant has the following claim against the plaintiff (specify the claim and explain it; 12. License (briefly explain) include a further statement of jurisdiction, if needed): 13. Payment (briefly explain) 2. The defendant has the following claim against one or more of the other defendants (specify the claim and explain it; include a further statement of jurisdiction, if needed): 14. Release (briefly explain) 3. State briefly and precisely what damages or other relief the party asserting a counterclaim or cross-claim asks the court to order. Do not make legal arguments. Include any basis for 15. Res judicata (briefly explain) claiming that the wrongs alleged are continuing at the present time. Include the amounts of any actual damages claimed for the acts alleged and the basis for these amounts. Include any punitive or exemplary damages claimed, the amounts, and the reasons that are alleged to entitle the party to actual or punitive money damages. Page 4 of 7 Page 5 of 7Pro Se 3 (Rev. 12/16) The Defendant's Answer to the Complaint Pro Se 3 (Rev. 12/16) The Defendant's Answer to the Complaint The defendant asserting the counterclaim or cross-claim against (specify who the claim is Telephone Number against) alleges that the following E-mail Address injury or damages resulted (specify): b. The defendant seeks the following damages or other relief (specify): III. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information, and belief that this answer: (1) is not being presented for an improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and (4) the answer otherwise complies with the requirements of Rule 11. A. For Parties Without an Attorney I agree to provide the Clerk's Office with any changes to my address where case-related papers may be served. I understand that my failure to keep a current address on file with the Clerk's Office may result in the dismissal of my case. Date of signing: Signature of Defendant Printed Name of Defendant B. For Attorneys Date of signing: Signature of Attorney Printed Name of Attorney Bar Number Name of Law Firm Street Address State and Zip Code Page 6 of 7 Page 7 of 7