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IN THE UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF TENNESSEE


NASHVILLE DIVISION
MARCIA RICHARDSON and
JAME RICHARDSON,
Plaintiffs,
v.
CONTEMPORARY SERVICES
CORPORATION,
Defendant.

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Case No.: 3:12-1278

ANSWER
Defendant, Contemporary Services Corporation (CSC), answers the complaint as
follows, the numbers below corresponding with those in the complaint:
1.

Admitted, on information and belief.

2.

Admitted, on information and belief.

3.

Admitted.

4.

Admitted, on information and belief.

5.

Admitted.

6.

Admitted.

7.

Admitted.

8.

Denied, and strict proof thereof is demanded.

9.

CSC is without sufficient information to either admit or deny the allegation set

forth in paragraph 9 of the Complaint, and denies that said allegations are relevant to this
proceeding.

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10.

CSC denies that it was throwing out property belonging to fans. CSC admits

that, because of the size of the bags in question and at the direction of Tennessee Football, Inc.
d/b/a Tennessee Titans, CSC did not permit Ms. Richardson and other fans to enter LP Field with
Titans grocery bags in their possession. CSC denies that Ms. Richardson was refused entry in
line at Gate 7.
11.

CSC admits the allegations set forth in paragraph 11 of the Complaint, except for

the allegation that Ms. Richardson was ever hassled. CSC denies this allegation.
12.

Denied, and strict proof thereof is demanded.

13.

Denied, and strict proof thereof is demanded.

14.

CSC is without sufficient information to either admit or deny the allegations set

forth in paragraph 14 of the Complaint, except that it admits that it called medical staff to tend to
Ms. Richardson and admits that it offered an ambulance to transport Ms. Richardson to a
hospital.
15.

CSC is without sufficient information to either admit or deny the allegations set

forth in paragraph 15 of the Complaint.


16.

CSC is without sufficient information to either admit or deny the allegations set

forth in paragraph 16 of the Complaint.


17.

CSC is without sufficient information to either admit or deny the allegations set

forth in paragraph 17 of the Complaint.


18.

CSC is without sufficient information to either admit or deny the allegations set

forth in paragraph 18 of the Complaint.


19.

Denied, and strict proof thereof is demanded.

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20.

The allegations set forth in paragraph 20 of the Complaint require no response

from CSC.
21.

Denied, and strict proof thereof is demanded.

22.

The allegations set forth in paragraph 22 of the Complaint require no response

from CSC.
23.

Denied, and strict proof thereof is demanded.

24.

The allegations set forth in paragraph 24of the Complaint require no response

from CSC.
25.

Denied, and strict proof thereof is demanded.

26.

The allegations set forth in paragraph 26 of the Complaint require no response

from CSC.
27.

Denied, and strict proof thereof is demanded.

28.

The allegations set forth in paragraph 28 of the Complaint require no response

from CSC.
29.

Denied, and strict proof thereof is demanded.

30.

Denied, and strict proof thereof is demanded.

31.

The allegations set forth in paragraph 31 of the Complaint require no response

from CSC.
32.

Denied, and strict proof thereof is demanded.

Having now answered the individually numbered paragraphs of plaintiffs Complaint,


CSC states that it is not liable to plaintiffs under any theory of law, for the amount sued for or for
any amount. All allegations in the plaintiffs Complaint not herein admitted, explained or denied
are hereby denied.

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AFFIRMATIVE DEFENSES
1.

The plaintiffs Complaint fails to state a claim for which relief can be granted.

2.

Pursuant to the doctrine of comparative fault, CSC asserts that the plaintiffs

damages, if any, were caused by others, including but not limited to plaintiff, Marcia Richardson
and Tennessee Football, Inc. d/b/a Tennessee Titans. Tennessee Football, Inc. may be served
with process through its registered agent, CT Corporation System, whose address is 800 South
Gay Street, Suite 2021, Knoxville, Tennessee, 37929-9710.
Defendant, CSC reserves leave herein to plead such further and additional defenses as it
may have after further investigation into the facts of this case. Any allegations of the complaint
not heretofore admitted, explained, or denied, are here and now denied.
WHEREFORE, CSC prays for judgment dismissing this action with prejudice, for its
costs and expenses in this action.
Respectfully submitted this _____ day of ____________________________, 2013.

/s/ Christopher D. Cravens


Christopher D. Cravens, BPR No. 015171
Burrow & Cravens, P.C.
1700 Hayes Street, Suite 202
Nashville, Tennessee 37203
chrisdcravens@bellsouth.net
615-252-2502
Attorney for Contemporary Services
Corporation
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and accurate copy of the foregoing has been
served, via the method(s) indicated below, on all counsel:
( ) Hand ( ) Mail (

) Fax ( ) Fed. Ex. ( ) E-mail ( X ) Electronic

Kenneth R. Jones, Jr.

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William B. Hawkins, III


Jones Hawkins & Farmer, PLC
150 Fourth Avenue North, Suite 1820
Nashville, Tennessee 37219
Attorneys for James and Marcia Richardson
This _____ day of _________________________________, 2013.

/s/ Christopher D. Cravens

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