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pleadings test_answer

13 further the defendant says that the second

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13. Further, the defendant says that the second plaintiff intentionally struck her repeatedly while she was chained to a gate at the site. 14. The defendant refers to and repeats the allegations in paragraph 3 of the Statement of Claim and admitted in the Defence and says that the actions of the second plaintiff referred to in paragraph 12 were performed both in the second plaintiff’s individual capacity and in his capacity as managing director of the first plaintiff, or in the alternative, in his individual capacity only, or in the alternative, in his capacity as managing director of the first plaintiff only. 15. By reason of the second plaintiff’s actions referred to in paragraph 12, the defendant suffered loss and damage, particulars of which will be provided subsequently. 16. The actions of the second plaintiff on his own behalf and/or on behalf of the first defendant described in paragraph 12 were calculated and/or likely to cause serious physical harm to the defendant and/or to intimidate the defendant into refraining from protesting against the plaintiffs in the future. [also open to counterclaim for false imprisonment and possibly other causes of action] AND THE DEFENDANT COUNTERCLAIMS: A. Damages; B. Aggravated and/or exemplary damages; C. Costs. Dated: 19 January 2009 [signed]
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Solicitors for the defendant
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13 Further the defendant says that the second plaintiff...

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