1 Siddu Navaneetha

39005 Lochmoor Dr
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Cleveland, OH 44139
3 7657147243
siddun11@gmail.com
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF OHIO

7 Case No.: 06071999

8 LOGAN LOVELL,
9 Plaintiff,
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vs.
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PAT SAINSBURY,
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Defendant
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ANSWER TO COMPLAINT

16 Defendant, PAT SAINSBURY, answers the complaint of Plaintiff, LOGAN LOVELL, in

17 this action as follows:

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1. The allegations contained in this paragraph are admitted.
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2. The allegations contained in this paragraph are admitted.
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3. The defendant denies that there is any cause of action in this case, either based in
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22 Cleveland, OH or any other area in this state.

23 4. The allegations contained in this paragraph are admitted.

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5. The allegations contained in this paragraph are admitted.
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6. The allegations contained in this paragraph are admitted.
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7. The allegations contained in this paragraph are admitted.
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28 8. The allegations contained in this paragraph are admitted.

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 1 9. The defendant is without information as to the plaintiff’s actions and therefore denies
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the contentions of paragraph 9.
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10. The allegations contained in this paragraph are admitted.
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11. The defendant has no information about the extent of the plaintiff’s injuries and
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6 therefore denies the contentions of paragraph 11.

7 12. The defendant has no information about the extent of the plaintiff’s injuries and
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therefore denies the contentions of paragraph 12.
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13. Denied.
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14. Denied.
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12 15. Denied.

13 16. Denied.
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17. Denied.
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18. Denied.
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18 DEFENDANT’S PRAYER FOR RELIEF

19 WHEREFORE, Defendant prays for the following relief:

20 1. Deny any compensation to the plaintiff.
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2. Grant no award of damages to the plaintiff.
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3. Make no award of costs to the plaintiff or plaintiff’s attorney.
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4. Dismiss the plaintiff’s action for failure to state a ground upon which relief may be

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26 5. Grant the defendant’s prayer for relief contained in Defendant’s Counter-claim, set out
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below.
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 1 6. Award the defendant a jury trial on all triable issues.
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7. Award the defendant any and all damages, compensation and other relief that justice may
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demand.
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So submitted, this the 5th day of March, 2020.
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6 I declare under penalty of perjury under the law of the State of Ohio that the foregoing is

7 true and correct.

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Saul Goodman
22320-20
13 Attorney for Defendant, Pat Sainsbury
39706 Lockmore Dr
14 Cleveland, OH 44139
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Telephone: (765) 714-7243

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CERTIFICATE OF SERVICE
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 1 I hereby certify that a true and accurate copy of the foregoing document
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has been served upon:

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Pat Sainsbury
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9500 Arthur Dr

8 Cleveland OH 44139

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by placing the same, postage prepaid in the United States Mail on this the 13 th
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day of February, 2020.
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________________________
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39005 Lochmoor Dr
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Cleveland OH 44139
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