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Dear Mr. Mattox:
Enclosed are Piedmont-Jenter’s answers to the three interrogatories in the Caddy-Seuter v. Fillmore and Piedmont-Jenter suit.
In all cases, we believe we are not liable for the damage because the operators of the equipment were not wearing appropriate safety gear and were not following approved standard operating procedures when the injuries occurred.
Please review these answers and inform me when you set the plaintiff’s deposition and the doctors’ depositions.
Sincerely,
Harold P. Steward
Vice President
Enc: Interrogative #1
Interrogative #2
Interrogative #3
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