Equal Employment Opportunity Commission v. Aaron Rents, Inc.

Filing 11

ANSWER to 7 Amended Complaint by Aaron Rents, Inc..(Rhode, Shari)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,

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Plaintiff,
and
ASHLEY ALFORD,
Plaintiff-Intervenor,
v.
AARON RENTS, INC. d/b/a AARON
SALES AND LEASE OWNERSHIP,
RICHARD MOORE, AND BRAD MARKIN,
Defendants.

CIVIL ACTION NO.
3:08-cv-00683-MJR-DGW

DEFENDANT AARON RENTS, INC.’S ANSWER TO PLAINTIFF-INTERVENOR
ASHLEY ALFORD’S FIRST AMENDED COMPLAINT IN INTERVENTION
COMES NOW Defendant Aaron Rents, Inc. (“Aarons”), by its
undersigned counsel, and pursuant to Rule 12(a) of the Federal
Rules

of

Civil

Procedure,

hereby

submits

its

Answer

to

Plaintiff/Intervenor Ashley Alford’s First Amended Complaint in
Intervention (“Plaintiff-Intervenor’s Complaint”) as follows:
PARTIES
1.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

Aarons

in

Paragraph

states

that

1

of

it

is

without knowledge or information sufficient to form a belief as
to Plaintiff-Intervenor Ashley Alford’s (“Plaintiff-Intervenor”)

residence

and/or

citizenship,

and

therefore,

denies

same.

Except as specifically stated herein, the remaining allegations
contained in Paragraph 1 of Plaintiff-Intervenor’s Complaint are
denied.
2.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

in

Aarons

admits

Complaint,

Paragraph
that

2

it

is

of
a

Georgia corporation with its principal place of business located
at 309 East Paces Ferry Road, N.E., Atlanta, Georgia 30305.
Except

as

specifically

admitted

herein,

the

remaining

allegations contained in Paragraph 2 of Plaintiff-Intervenor’s
Complaint are denied.
3.
Answering the allegations contained in Paragraph 3 of the
Plaintiff-Intervenor’s

Complaint,

Aarons

admits

that

it

is

a

corporation, duly registered to conduct business in the State of
Illinois and does conduct business in the State of Illinois,
including St. Clair County, Illinois.
admitted

herein,

the

remaining

Except as specifically

allegations

contained

in

Paragraph 3 of Plaintiff-Intervenor’s Complaint are denied.
4.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

Aarons

in

Paragraph

states

that

4

of

it

is

without knowledge or information sufficient to form a belief as

- 2 -

to Defendant Richard Moore’s residence and/or citizenship at all
times

relevant

to

Plaintiff-Intervenor’s

therefore, denies same.

Complaint,

and

Except as specifically stated herein,

the remaining allegations contained in Paragraph 4 of PlaintiffIntervenor’s Complaint are denied.
5.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

Aarons

in

Paragraph

states

that

5

of

it

is

without knowledge or information sufficient to form a belief as
to Defendant Brad Martin’s residence and/or citizenship at all
times

relevant

to

Plaintiff-Intervenor’s

therefore, denies same.

Complaint,

and

Except as specifically stated herein,

the remaining allegations contained in Paragraph 5 of PlaintiffIntervenor’s Complaint are denied.
GENERAL ALLEGATIONS
6.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

Aarons

in

Paragraph

admits

it

6

of

is

a

corporation doing business as Aaron’s Sales and Lease Ownership.
Except

as

specifically

admitted

herein,

the

remaining

allegations contained in Paragraph 6 of Plaintiff-Intervenor’s
Complaint are denied.

- 3 -

7.
Answering

the

allegations

Plaintiff-Intervenor’s
operates

a

Heights,

store

St.

specifically

Complaint,

located

Clair

contained

at

admitted

Paragraph

Aarons

2035

County,

in

admits

West

Highway

Illinois,

herein,

the

62208.
remaining

it

7

owns

50,

of
and

Fairview

Except

as

allegations

contained in Paragraph 7 of Plaintiff-Intervenor’s Complaint are
denied.
8.
Answering

the

allegations

contained

in

Paragraph

8

of

Plaintiff-Intervenor’s Complaint, Aarons admits that Defendant
Richard Moore was employed by Aarons as a General Manager at the
store

located

at

2035

West

Highway

50,

Fairview

Heights,

Illinois, 62208 from on or about September 7, 2005 through on or
about

November

20,

2006,

but

was

suspended

pending

an

investigation effective from October 13, 2006 through November
20, 2006.

Except as specifically admitted herein, the remaining

allegations contained in Paragraph 8 of Plaintiff-Intervenor’s
Complaint are denied.
9.
Answering

the

allegations

contained

in

Paragraph

9

of

Plaintiff-Intervenor’s Complaint, Aarons admits that PlaintiffIntervenor

was

employed

by

Aarons

as

a

Customer

Service

Representative at the store located at 2035 West Highway 50,

- 4 -

Fairview Heights, Illinois, 62208 from on or about October 31,
2005 through on or about April 9, 2007.
admitted

herein,

the

remaining

Except as specifically

allegations

contained

in

Paragraph 9 of Plaintiff-Intervenor’s Complaint are denied.
10.
Aarons denies the allegations contained in Paragraph 10 of
Plaintiff-Intervenor’s Complaint.
11.
Aarons denies the allegations contained in Paragraph 11 of
Plaintiff-Intervenor’s Complaint.
12.
Aarons denies the allegations contained in Paragraph 12 of
Plaintiff-Intervenor’s Complaint.
13.
Aarons denies the allegations contained in Paragraph 13 of
Plaintiff-Intervenor’s Complaint.
14.
Aarons denies the allegations contained in Paragraph 14 of
Plaintiff-Intervenor’s Complaint.
15.
Aarons denies the allegations contained in Paragraph 15 of
Plaintiff-Intervenor’s Complaint.

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JURISDICTION AND VENUE
16.
Answering

the

allegations

contained

in

Paragraph

16

of

Plaintiff-Intervenor’s Complaint, Aarons states that Paragraph
16 is a mere statement of jurisdiction to which a responsive
pleading

is

neither

necessary

nor

proper.

To

the

extent

a

response is warranted, the allegations contained in Paragraph 16
are denied.
17.
Answering

the

allegations

contained

in

Paragraph

17

of

Plaintiff-Intervenor’s Complaint, Aarons states that Paragraph
17 is a mere statement of jurisdiction to which a responsive
pleading

is

neither

necessary

nor

proper.

To

the

extent

a

response is warranted, the allegations contained in Paragraph 17
are denied.
18.
Answering

the

allegations

contained

in

Paragraph

18

of

Plaintiff-Intervenor’s Complaint, Aarons states that Paragraph
18 is a mere statement of jurisdiction to which a responsive
pleading

is

neither

necessary

nor

proper.

To

the

extent

a

response is warranted, the allegations contained in Paragraph 18
are denied.

- 6 -

19.
Answering

the

allegations

Plaintiff-Intervenor’s
committed
District

any
of

contained

Complaint,

unlawful
Illinois

Aarons

employment
against

in

Paragraph

denies

practices

that

in

the

19
it

of
has

Southern

Plaintiff-Intervenor.

Further

answering Paragraph 19, Aarons states that Paragraph 19 is a
mere statement of jurisdiction to which a responsive pleading is
neither

necessary

nor

proper.

To

the

extent

a

response

is

warranted, the allegations contained in Paragraph 19 are denied.
20.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

in

Aarons

Paragraph

states

20

that

of
the

allegations in Paragraph 20 are a mere statement of venue to
which a responsive pleading is neither necessary nor proper.

To

the extent a response is warranted, the allegations contained in
Paragraph 20 are denied.
COUNT I – COMMON LAW ASSAULT
Aarons states that Count I - Common Law Assault does not
allege claims against Aarons, and therefore, requires no answer
from Aarons.
however,

To the extent that any such response is warranted,

Aarons

responds

as

follows

to

each

of

individually

numbered paragraphs in Plaintiff-Intervenor’s Complaint.

- 7 -

21.
Answering Paragraph 21 of Plaintiff-Intervenor’s Complaint,
Aarons realleges and incorporates by reference, as if fully set
forth

herein,

its

Affirmative

Defenses

and

its

responses

to

Paragraphs 1 through 20 of Plaintiff-Intervenor’s Complaint.
22.
Aarons denies the allegations contained in Paragraph 22 of
Plaintiff-Intervenor’s Complaint.
23.
Aarons denies the allegations contained in Paragraph 23 of
Plaintiff-Intervenor’s Complaint.
24.
Aarons denies the allegations contained in Paragraph 24 of
Plaintiff-Intervenor’s Complaint.
25.
Aarons denies the allegations contained in Paragraph 25 of
Plaintiff-Intervenor’s Complaint.
26.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

Aarons

in

Paragraph

states

that

26

of

it

is

without knowledge or information sufficient to form a belief as
to whether Plaintiff-Intervenor had previously been referred to
as “Trixie” or “Trix,” and therefore, denies same.

- 8 -

Except as

specifically

admitted

herein,

the

remaining

allegations

contained in Paragraph 26 are denied.
27.
Aarons denies the allegations contained in Paragraph 27 of
Plaintiff-Intervenor’s Complaint.
28.
Aarons denies the allegations contained in Paragraph 28 of
Plaintiff-Intervenor’s Complaint.
29.
Aarons denies the allegations contained in Paragraph 29 of
Plaintiff-Intervenor’s Complaint.
30.
Aarons denies the allegations contained in Paragraph 28 of
Plaintiff-Intervenor’s Complaint.
31.
Aarons denies the allegations contained in Paragraph 31 of
Plaintiff-Intervenor’s Complaint.
32.
Aarons denies the allegations contained in Paragraph 32 of
Plaintiff-Intervenor’s Complaint.
33.
Aarons denies the allegations contained in Paragraph 33 of
Plaintiff-Intervenor’s Complaint.

- 9 -

34.
Aarons denies the allegations contained in Paragraph 34 of
Plaintiff-Intervenor’s Complaint.
35.
Aarons denies the allegations contained in Paragraph 35 of
Plaintiff-Intervenor’s Complaint.
36.
Aarons denies the allegations contained in Paragraph 36 of
Plaintiff/Intervenor’s Complaint.
37.
Aarons denies the allegations contained in Paragraph 37 of
Plaintiff-Intervenor’s Complaint.
38.
Aarons denies the allegations contained in Paragraph 38 of
Plaintiff-Intervenor’s Complaint.
39.
Aarons denies the allegations contained in Paragraph 39 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 39 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.

- 10 -

COUNT II – COMMON LAW BATTERY
Aarons states that Count II - Common Law Battery does not
allege claims against Aarons, and therefore, requires no answer
from Aarons.
however,

To the extent that any such response is warranted,

Aarons

responds

as

follows

to

each

of

individually

numbered paragraphs in Plaintiff-Intervenor’s Complaint.
40.
Answering Paragraph 40 of Plaintiff-Intervenor’s Complaint,
Aarons realleges and incorporates by reference, as if fully set
forth

herein,

its

Affirmative

Defenses

and

its

responses

to

Paragraphs 1 through 39 of Plaintiff-Intervenor’s Complaint.
41.
Aarons denies the allegations contained in Paragraph 41 of
Plaintiff-Intervenor’s Complaint.
42.
Aarons denies the allegations contained in Paragraph 42 of
Plaintiff-Intervenor’s Complaint.
43.
Aarons denies the allegations contained in Paragraph 43 of
Plaintiff-Intervenor’s Complaint.
44.
Aarons denies the allegations contained in Paragraph 44 of
Plaintiff-Intervenor’s Complaint.

- 11 -

45.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

Aarons

in

Paragraph

states

that

45

of

it

is

without knowledge or information sufficient to form a belief as
to whether Plaintiff-Intervenor had previously been referred to
as “Trixie” or “Trix,” and therefore, denies same.

Except as

specifically stated herein, the remaining allegations contained
in Paragraph 45 are denied.
46.
Aarons denies the allegations contained in Paragraph 46 of
Plaintiff-Intervenor’s Complaint.
47.
Aarons denies the allegations contained in Paragraph 47 of
Plaintiff-Intervenor’s Complaint.
48.
Aarons denies the allegations contained in Paragraph 48 of
Plaintiff-Intervenor’s Complaint.
49.
Aarons denies the allegations contained in Paragraph 49 of
Plaintiff-Intervenor’s Complaint.
50.
Aarons denies the allegations contained in Paragraph 50 of
Plaintiff-Intervenor’s Complaint.

- 12 -

51.
Aarons denies the allegations contained in Paragraph 51 of
Plaintiff-Intervenor’s Complaint.
52.
Aarons denies the allegations contained in Paragraph 52 of
Plaintiff-Intervenor’s Complaint.
53.
Aarons denies the allegations contained in Paragraph 53 of
Plaintiff-Intervenor’s Complaint.
54.
Aarons denies the allegations contained in Paragraph 54 of
Plaintiff-Intervenor’s Complaint.
55.
Aarons denies the allegations contained in Paragraph 55 of
Plaintiff-Intervenor’s Complaint.
56.
Aarons denies the allegations contained in Paragraph 56 of
Plaintiff-Intervenor’s Complaint.
57.
Aarons denies the allegations contained in Paragraph 57 of
Plaintiff-Intervenor’s Complaint.
58.
Aarons denies the allegations contained in Paragraph 58 of
Plaintiff-Intervenor’s Complaint.

- 13 -

59.
Aarons denies the allegations contained in Paragraph 59 of
Plaintiff-Intervenor’s Complaint.
60.
Aarons denies the allegations contained in Paragraph 60 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 60 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT III – NEGLIGENT HIRING
61.
Answering Paragraph 61 of Plaintiff-Intervenor’s Complaint,
Aarons realleges and incorporates by reference, as if fully set
forth

herein,

its

Affirmative

Defenses

and

its

responses

to

Paragraphs 1 through 60 of Plaintiff-Intervenor’s Complaint.
62.
Answering Paragraph 62 of Plaintiff-Intervenor’s Complaint,
Aarons states that Paragraph 62 calls for a legal conclusion to
which a responsive pleading is neither necessary nor proper.

To

the extent a response is warranted, Aarons admits that it has
complied with any legal obligations that it has with regard to
the hiring and training of individuals.

- 14 -

Except as specifically

stated herein, Aarons denies the remaining allegations contained
in Paragraph 61 of Plaintiff-Intervenor’s Complaint.
63.
Answering Paragraph 63 of Plaintiff-Intervenor’s Complaint,
Aarons states that Paragraph 63 calls for a legal conclusion to
which a responsive pleading is neither necessary nor proper.

To

the extent a response is warranted, Aarons admits that it has
complied with any legal obligations that it has with regard to
conducting
candidates.
the

background

checks

and

interviewing

supervisory

Except as specifically stated herein, Aarons denies

remaining

allegations

contained

in

Paragraph

61

of

Plaintiff-Intervenor’s Complaint.
64.
Answering Paragraph 64 of Plaintiff-Intervenor’s Complaint,
Aarons states that Paragraph 64 calls for a legal conclusion to
which a responsive pleading is neither necessary nor proper.

To

the extent a response is warranted, Aarons admits that it has
complied with any legal obligations that it has with regard to
the

hiring

herein,

of

Aarons

individuals.
denies

the

Except

remaining

as

specifically

allegations

stated

contained

in

Paragraph 64 of Plaintiff-Intervenor’s Complaint.
65.
Answering Paragraph 65 of Plaintiff-Intervenor’s Complaint,
Aarons states that Paragraph 65 calls for a legal conclusion to

- 15 -

which a responsive pleading is neither necessary nor proper.

To

the extent a response is warranted, Aarons admits that it has
complied with any legal obligations that it has with regard to
the

hiring

herein,

of

Aarons

individuals.
denies

the

Except

remaining

as

specifically

allegations

stated

contained

in

Paragraph 65 of Plaintiff-Intervenor’s Complaint.
66.
Aarons denies the allegations contained in Paragraph 66 of
Plaintiff-Intervenor’s

Complaint,

including

subparagraphs

(a)

through (d).
67.
Aarons denies the allegations contained in Paragraph 67 of
Plaintiff-Intervenor’s Complaint.
68.
Aarons denies the allegations contained in Paragraph 68 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 68 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT IV – NEGLIGENT RETENTION
69.
Answering Paragraph 69 of Plaintiff-Intervenor’s Complaint,
Aarons realleges and incorporates by reference, as if fully set

- 16 -

forth

herein,

its

Affirmative

Defenses

and

its

responses

to

Paragraphs 1 through 69 of Plaintiff-Intervenor’s Complaint.
70.
Aarons denies the allegations contained in Paragraph 70 of
Plaintiff-Intervenor’s Complaint.
71.
Aarons denies the allegations contained in Paragraph 71 of
Plaintiff-Intervenor’s Complaint.
72.
Aarons denies the allegations contained in Paragraph 72 of
Plaintiff-Intervenor’s Complaint.
73.
Aarons denies the allegations contained in Paragraph 73 of
Plaintiff-Intervenor’s Complaint.
74.
Aarons denies the allegations contained in Paragraph 74 of
Plaintiff-Intervenor’s Complaint.
75.
Aarons denies the allegations contained in Paragraph 75 of
Plaintiff-Intervenor’s Complaint.
76.
Aarons denies the allegations contained in Paragraph 76 of
Plaintiff-Intervenor’s Complaint.

- 17 -

77.
Aarons denies the allegations contained in Paragraph 77 of
Plaintiff-Intervenor’s Complaint.
78.
Aarons denies the allegations contained in Paragraph 78 of
Plaintiff-Intervenor’s Complaint.
79.
Aarons denies the allegations contained in Paragraph 79 of
Plaintiff-Intervenor’s Complaint.
80.
Aarons denies the allegations contained in Paragraph 80 of
Plaintiff-Intervenor’s Complaint.
81.
Answering Paragraph 81 of Plaintiff-Intervenor’s Complaint,
Aarons states that Paragraph 81 calls for a legal conclusion to
which a responsive pleading is neither necessary nor proper.

To

the extent a response is warranted, Aarons admits that it has
complied with any legal obligations that it has with regard to
ensuring that employees are fit for their position.

Except as

specifically

remaining

stated

herein,

Aarons

denies

the

allegations contained in Paragraph 81 of Plaintiff-Intervenor’s
Complaint.

- 18 -

82.
Aarons denies the allegations contained in Paragraph 82 of
Plaintiff-Intervenor’s

Complaint,

including

subparagraphs

(a)

through (d).
83.
Aarons denies the allegations contained in Paragraph 83 of
Plaintiff-Intervenor’s Complaint.
84.
Aarons denies the allegations contained in Paragraph 84 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 84 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT V – NEGLIGENT SUPERVISION
85.
Answering Paragraph 85 of Plaintiff-Intervenor’s Complaint,
Aarons realleges and incorporates by reference, as if fully set
forth

herein,

its

Affirmative

Defenses

and

its

responses

to

Paragraphs 1 through 84 of Plaintiff-Intervenor’s Complaint.
86.
Aarons denies the allegations contained in Paragraph 86 of
Plaintiff-Intervenor’s Complaint.

- 19 -

87.
Aarons denies the allegations contained in Paragraph 87 of
Plaintiff-Intervenor’s Complaint.
88.
Aarons denies the allegations contained in Paragraph 88 of
Plaintiff-Intervenor’s Complaint.
89.
Aarons denies the allegations contained in Paragraph 89 of
Plaintiff-Intervenor’s Complaint.
90.
Aarons denies the allegations contained in Paragraph 90 of
Plaintiff-Intervenor’s Complaint.
91.
Aarons denies the allegations contained in Paragraph 91 of
Plaintiff-Intervenor’s Complaint.
92.
Answering Paragraph 92 of Plaintiff-Intervenor’s Complaint,
Aarons states that Paragraph 92 calls for a legal conclusion to
which a responsive pleading is neither necessary nor proper.

To

the extent a response is warranted, Aarons admits that it has
complied with any legal obligations that it has with regard to
supervising employees.

Except as specifically stated herein,

Aarons denies the remaining allegations contained in Paragraph
92 of Plaintiff-Intervenor’s Complaint.

- 20 -

93.
Aarons denies the allegations contained in Paragraph 93 of
Plaintiff-Intervenor’s

Complaint,

including

subparagraphs

(a)

through (d).
94.
Aarons denies the allegations contained in Paragraph 94 of
Plaintiff-Intervenor’s Complaint.
95.
Aarons denies the allegations contained in Paragraph 95 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 95 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT VI – NEGLIGENT INVESTIGATING OF A SEXUAL HARASSMENT CLAIM
96.
Answering Paragraph 96 of Plaintiff-Intervenor’s Complaint,
Aarons realleges and incorporates by reference, as if fully set
forth

herein,

its

Affirmative

Defenses

and

its

responses

to

Paragraphs 1 through 95 of Plaintiff-Intervenor’s Complaint.
97.
Aarons denies the allegations contained in Paragraph 97 of
Plaintiff-Intervenor’s Complaint.

- 21 -

98.
Aarons denies the allegations contained in Paragraph 98 of
Plaintiff-Intervenor’s Complaint.
99.
Aarons denies the allegations contained in Paragraph 99 of
Plaintiff-Intervenor’s Complaint.
100.
Aarons denies the allegations contained in Paragraph 100 of
Plaintiff-Intervenor’s Complaint.
101.
Aarons denies the allegations contained in Paragraph 101 of
Plaintiff-Intervenor’s Complaint.
102.
Aarons denies the allegations contained in Paragraph 102 of
Plaintiff-Intervenor’s Complaint.
103.
Aarons denies the allegations contained in Paragraph 103 of
Plaintiff-Intervenor’s Complaint.
104.
Aarons denies the allegations contained in Paragraph 104 of
Plaintiff-Intervenor’s Complaint.
105.
Answering

Paragraph

105

of

Plaintiff-Intervenor’s

Complaint, Aarons states that Paragraph 105 calls for a legal

- 22 -

conclusion to which a responsive pleading is neither necessary
nor

proper.

To

the

extent

a

response

is

warranted,

Aarons

admits that it has complied with any legal obligations that it
has

with

harassment.
the

regard

to

investigating

allegations

of

sexual

Except as specifically stated herein, Aarons denies

remaining

allegations

contained

in

Paragraph

105

of

Plaintiff-Intervenor’s Complaint.
106.
Aarons denies the allegations contained in Paragraph 106 of
Plaintiff-Intervenor’s

Complaint,

including

subparagraphs

(a)

through (i).
107.
Aarons denies the allegations contained in Paragraph 107 of
Plaintiff-Intervenor’s Complaint.
108.
Aarons denies the allegations contained in Paragraph 108 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 108 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.

- 23 -

COUNT VII – NEGLIGENT REPAIR
109.
Answering

Paragraph

109

of

Plaintiff-Intervenor’s

Complaint, Aarons realleges and incorporates by reference, as if
fully

set

forth

herein,

its

Affirmative

Defenses

and

its

responses to Paragraphs 1 through 108 of Plaintiff-Intervenor’s
Complaint.
110.
Aarons denies the allegations contained in Paragraph 110 of
Plaintiff-Intervenor’s Complaint.
111.
Aarons denies the allegations contained in Paragraph 111 of
Plaintiff-Intervenor’s Complaint.
112.
Aarons denies the allegations contained in Paragraph 112 of
Plaintiff-Intervenor’s Complaint.
113.
Aarons denies the allegations contained in Paragraph 113 of
Plaintiff-Intervenor’s Complaint.
114.
Aarons denies the allegations contained in Paragraph 114 of
Plaintiff-Intervenor’s Complaint.

- 24 -

115.
Aarons denies the allegations contained in Paragraph 115 of
Plaintiff-Intervenor’s Complaint.
116.
Aarons denies the allegations contained in Paragraph 116 of
Plaintiff-Intervenor’s Complaint.
117.
Aarons denies the allegations contained in Paragraph 117 of
Plaintiff-Intervenor’s Complaint.
118.
Aarons denies the allegations contained in Paragraph 118 of
Plaintiff-Intervenor’s Complaint.
119.
Answering

Paragraph

119

of

Plaintiff-Intervenor’s

Complaint, Aarons states that Paragraph 119 calls for a legal
conclusion to which a responsive pleading is neither necessary
nor

proper.

To

the

extent

a

response

is

warranted,

Aarons

admits that it has complied with any legal obligations that it
has

with

Except

as

regard

to

maintaining

specifically

a

stated

safe

working

herein,

Aarons

environment.
denies

the

remaining allegations contained in Paragraph 119 of PlaintiffIntervenor’s Complaint.

- 25 -

120.
Aarons denies the allegations contained in Paragraph 120 of
Plaintiff-Intervenor’s

Complaint,

including

subparagraph

(a)

through (b).
121.
Aarons denies the allegations contained in Paragraph 121 of
Plaintiff-Intervenor’s Complaint.
122.
Aarons denies the allegations contained in Paragraph 122 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 122 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT VIII – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
123.
Answering

Paragraph

123

of

Plaintiff-Intervenor’s

Complaint, Aarons realleges and incorporates by reference, as if
fully

set

forth

herein,

its

Affirmative

Defenses

and

its

responses to Paragraphs 1 through 122 of Plaintiff-Intervenor’s
Complaint.
124.
Aarons denies the allegations contained in Paragraph 124 of
Plaintiff-Intervenor’s Complaint.

- 26 -

125.
Aarons denies the allegations contained in Paragraph 125 of
Plaintiff-Intervenor’s Complaint.
126.
Aarons denies the allegations contained in Paragraph 126 of
Plaintiff-Intervenor’s Complaint.
127.
Aarons denies the allegations contained in Paragraph 127 of
Plaintiff-Intervenor’s Complaint.
128.
Aarons denies the allegations contained in Paragraph 128 of
Plaintiff-Intervenor’s Complaint.
129.
Aarons denies the allegations contained in Paragraph 129 of
Plaintiff-Intervenor’s Complaint.
130.
Aarons denies the allegations contained in Paragraph 130 of
Plaintiff-Intervenor’s Complaint.
131.
Aarons denies the allegations contained in Paragraph 131 of
Plaintiff-Intervenor’s Complaint.
132.
Aarons denies the allegations contained in Paragraph 132 of
Plaintiff-Intervenor’s Complaint.

- 27 -

133.
Aarons denies the allegations contained in Paragraph 133 of
Plaintiff-Intervenor’s Complaint.
134.
Aarons denies the allegations contained in Paragraph 134 of
Plaintiff-Intervenor’s Complaint.
135.
Aarons denies the allegations contained in Paragraph 135 of
Plaintiff-Intervenor’s Complaint.
136.
Aarons denies the allegations contained in Paragraph 136 of
Plaintiff-Intervenor’s Complaint.
137.
Aarons denies the allegations contained in Paragraph 137 of
Plaintiff-Intervenor’s Complaint.
138.
Aarons denies the allegations contained in Paragraph 138 of
Plaintiff-Intervenor’s Complaint.
139.
Aarons denies the allegations contained in Paragraph 139 of
Plaintiff-Intervenor’s Complaint.
140.
Aarons denies the allegations contained in Paragraph 140 of
Plaintiff-Intervenor’s Complaint.

- 28 -

141.
Aarons denies the allegations contained in Paragraph 141 of
Plaintiff-Intervenor’s Complaint.
142.
Aarons denies the allegations contained in Paragraph 142 of
Plaintiff-Intervenor’s Complaint.
143.
Aarons denies the allegations contained in Paragraph 143 of
Plaintiff-Intervenor’s Complaint.
144.
Aarons denies the allegations contained in Paragraph 144 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 144 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT IX – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
Aarons states that Count IX – Intentional Infliction of
Emotional Distress does not allege claims against Aarons, and
therefore, requires no answer from Aarons.
any

such

follows

response
to

each

is
of

warranted,

however,

individually

Plaintiff-Intervenor’s Complaint.

- 29 -

To the extent that
Aarons

numbered

responds

paragraphs

as
in

145.
Answering

Paragraph

145

of

Plaintiff-Intervenor’s

Complaint, Aarons realleges and incorporates by reference, as if
fully

set

forth

herein,

its

Affirmative

Defenses

and

its

responses to Paragraphs 1 through 144 of Plaintiff-Intervenor’s
Complaint.
146.
Aarons denies the allegations contained in Paragraph 146 of
Plaintiff-Intervenor’s Complaint.
147.
Aarons denies the allegations contained in Paragraph 147 of
Plaintiff-Intervenor’s Complaint.
148.
Aarons denies the allegations contained in Paragraph 148 of
Plaintiff-Intervenor’s Complaint.
149.
Aarons denies the allegations contained in Paragraph 149 of
Plaintiff-Intervenor’s Complaint.
150.
Aarons denies the allegations contained in Paragraph 150 of
Plaintiff-Intervenor’s Complaint.
151.
Aarons denies the allegations contained in Paragraph 151 of
Plaintiff-Intervenor’s Complaint.

- 30 -

152.
Aarons denies the allegations contained in Paragraph 152 of
Plaintiff-Intervenor’s Complaint.
153.
Aarons denies the allegations contained in Paragraph 153 of
Plaintiff-Intervenor’s Complaint.
154.
Aarons denies the allegations contained in Paragraph 154 of
Plaintiff-Intervenor’s Complaint.
155.
Aarons denies the allegations contained in Paragraph 155 of
Plaintiff-Intervenor’s Complaint.
156.
Aarons denies the allegations contained in Paragraph 156 of
Plaintiff-Intervenor’s Complaint.
157.
Aarons denies the allegations contained in Paragraph 157 of
Plaintiff-Intervenor’s Complaint.
158.
Aarons denies the allegations contained in Paragraph 158 of
Plaintiff-Intervenor’s Complaint.
159.
Aarons denies the allegations contained in Paragraph 159 of
Plaintiff-Intervenor’s Complaint.

- 31 -

160.
Aarons denies the allegations contained in Paragraph 160 of
Plaintiff-Intervenor’s Complaint.
161.
Aarons denies the allegations contained in Paragraph 161 of
Plaintiff-Intervenor’s Complaint.
162.
Aarons denies the allegations contained in Paragraph 162 of
Plaintiff-Intervenor’s Complaint.
163.
Aarons denies the allegations contained in Paragraph 163 of
Plaintiff-Intervenor’s Complaint.
164.
Aarons denies the allegations contained in Paragraph 164 of
Plaintiff-Intervenor’s Complaint.
165.
Aarons denies the allegations contained in Paragraph 165 of
Plaintiff-Intervenor’s Complaint.
166.
Aarons denies the allegations contained in Paragraph 166 of
Plaintiff-Intervenor’s Complaint.
167.
Aarons denies the allegations contained in Paragraph 165 of
Plaintiff-Intervenor’s Complaint.

- 32 -

Answering

the

WHEREFORE

clause

immediately

following

Paragraph 167 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT X – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
168.
Answering

Paragraph

168

of

Plaintiff-Intervenor’s

Complaint, Aarons realleges and incorporates by reference, as if
fully

set

forth

herein,

its

Affirmative

Defenses

and

its

responses to Paragraphs 1 through 167 of Plaintiff-Intervenor’s
Complaint.
169.
Aarons denies the allegations contained in Paragraph 169 of
Plaintiff-Intervenor’s Complaint.
170.
Aarons denies the allegations contained in Paragraph 170 of
Plaintiff-Intervenor’s Complaint.
171.
Aarons denies the allegations contained in Paragraph 171 of
Plaintiff-Intervenor’s Complaint.
172.
Aarons denies the allegations contained in Paragraph 172 of
Plaintiff-Intervenor’s Complaint.

- 33 -

173.
Aarons denies the allegations contained in Paragraph 173 of
Plaintiff-Intervenor’s Complaint.
174.
Aarons denies the allegations contained in Paragraph 174 of
Plaintiff-Intervenor’s Complaint.
175.
Aarons denies the allegations contained in Paragraph 175 of
Plaintiff-Intervenor’s Complaint.
176.
Aarons denies the allegations contained in Paragraph 176 of
Plaintiff-Intervenor’s Complaint.
177.
Aarons denies the allegations contained in Paragraph 177 of
Plaintiff-Intervenor’s Complaint.
178.
Aarons denies the allegations contained in Paragraph 178 of
Plaintiff-Intervenor’s Complaint.
179.
Aarons denies the allegations contained in Paragraph 179 of
Plaintiff-Intervenor’s Complaint.
180.
Aarons denies the allegations contained in Paragraph 180 of
Plaintiff-Intervenor’s Complaint.

- 34 -

181.
Aarons denies the allegations contained in Paragraph 181 of
Plaintiff-Intervenor’s Complaint.
182.
Aarons denies the allegations contained in Paragraph 182 of
Plaintiff-Intervenor’s Complaint.
183.
Aarons denies the allegations contained in Paragraph 183 of
Plaintiff-Intervenor’s Complaint.
184.
Aarons denies the allegations contained in Paragraph 184 of
Plaintiff-Intervenor’s Complaint.
185.
Aarons denies the allegations contained in Paragraph 185 of
Plaintiff-Intervenor’s Complaint.
186.
Aarons denies the allegations contained in Paragraph 186 of
Plaintiff-Intervenor’s Complaint.
187.
Aarons denies the allegations contained in Paragraph 187 of
Plaintiff-Intervenor’s Complaint.
188.
Aarons denies the allegations contained in Paragraph 188 of
Plaintiff-Intervenor’s Complaint.

- 35 -

189.
Aarons denies the allegations contained in Paragraph 189 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 189 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT XI – RETALIATION
190.
Answering

Paragraph

190

of

Plaintiff-Intervenor’s

Complaint, Aarons realleges and incorporates by reference, as if
fully

set

forth

herein,

its

Affirmative

Defenses

and

its

responses to Paragraphs 1 through 189 of Plaintiff-Intervenor’s
Complaint.
191.
Answering

the

allegations

Plaintiff-Intervenor’s

contained

Complaint,

Aarons

in

Paragraph

states

that

191

of

it

is

without knowledge or information sufficient to form a belief as
to

whether

Plaintiff-Intervenor

was

attending

college

at

the

time she began working for Aarons in or about October 2005, and
therefore, denies same.

Except as specifically stated herein,

the remaining allegations contained in Paragraph 191 are denied.

- 36 -

192.
Aarons denies the allegations contained in Paragraph 192 of
Plaintiff-Intervenor’s Complaint.
193.
Aarons denies the allegations contained in Paragraph 193 of
Plaintiff-Intervenor’s Complaint.
194.
Aarons denies the allegations contained in Paragraph 194 of
Plaintiff-Intervenor’s Complaint.
195.
Aarons denies the allegations contained in Paragraph 195 of
Plaintiff-Intervenor’s Complaint.
196.
Answering

the

allegations

contained

in

Paragraph

196

of

Plaintiff-Intervenor’s Complaint, Aarons admits that PlaintiffIntervenor

filed

a

charge

of

discrimination

with

the

Equal

Employment Opportunity Commission on or about February 15, 2007,
the language of which speaks for itself.

Except as specifically

stated herein, the remaining allegations contained in Paragraph
196 are denied.
197.
Answering

the

allegations

contained

in

Paragraph

197

of

Plaintiff-Intervenor’s Complaint, Aarons admits that PlaintiffIntervenor

filed

a

charge

of

discrimination

- 37 -

with

the

Equal

Employment Opportunity Commission on or about February 15, 2007,
the language of which speaks for itself.

Except as specifically

stated herein, the remaining allegations contained in Paragraph
197 are denied.
198.
Aarons denies the allegations contained in Paragraph 198 of
Plaintiff-Intervenor’s Complaint.
199.
Aarons denies the allegations contained in Paragraph 199 of
Plaintiff-Intervenor’s Complaint.
200.
Aarons denies the allegations contained in Paragraph 200 of
Plaintiff-Intervenor’s Complaint.
201.
Aarons denies the allegations contained in Paragraph 201 of
Plaintiff-Intervenor’s Complaint.
Answering

the

WHEREFORE

clause

immediately

following

Paragraph 201 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
COUNT XII – SEXUAL HARASSMENT
202.
Answering

Paragraph

202

of

Plaintiff-Intervenor’s

Complaint, Aarons realleges and incorporates by reference, as if

- 38 -

fully

set

forth

herein,

its

Affirmative

Defenses

and

its

responses to Paragraphs 1 through 201 of Plaintiff-Intervenor’s
Complaint.
203.
Answering

the

allegations

contained

in

Paragraph

203

of

Plaintiff-Intervenor’s Complaint, Aarons states that Paragraph
203

is

a

mere

statement

of

Plaintiff’s

claims

to

responsive pleading is neither necessary nor proper.

which

a

To the

extent a response is warranted, the allegations contained in
Paragraph 203 are denied.
204.
Aarons denies the allegations contained in Paragraph 204 of
Plaintiff-Intervenor’s Complaint.
205.
Answering

the

allegations

contained

in

Paragraph

205

of

Plaintiff-Intervenor’s Complaint, Aarons states that Paragraph
205 states a legal conclusion to which a responsive pleading is
neither

necessary

warranted,

the

nor

proper.

allegations

To

the

contained

extent
in

a

response

Paragraph

205

is
are

denied.
206.
Answering

the

allegations

contained

in

Paragraph

206

of

Plaintiff-Intervenor’s Complaint, Aarons admits that more than
thirty days elapsed between the filing of Ashley Alford’s charge

- 39 -

of

discrimination

with

the

Equal

Employment

Opportunity

Commission and the institution of this lawsuit by the Equal
Employment Opportunity Commission.

Further answering, Aarons

denies that all conditions precedent to the institution of this
lawsuit have been fulfilled, as Plaintiff’s allegations herein
are

beyond

the

discrimination.

scope

of

the

allegations

in

the

charge

of

Additionally, some of the allegations in the

charge of discrimination occurred more than 300 days prior to
the

filing

of

the

charge

of

discrimination.

Except

as

specifically stated herein, the remaining allegations contained
in Paragraph 206 of Plaintiff-Intervenor’s Complaint are denied.
207.
Aarons denies the allegations contained in Paragraph 207 of
Plaintiff-Intervenor’s

Complaint,

including

subparagraph

(a)

through (c).
208.
Aarons denies the allegations contained in Paragraph 208 of
Plaintiff-Intervenor’s Complaint.
209.
Aarons denies the allegations contained in Paragraph 209 of
Plaintiff-Intervenor’s Complaint.
210.
Aarons denies the allegations contained in Paragraph 210 of
Plaintiff-Intervenor’s Complaint.

- 40 -

Answering

the

WHEREFORE

clause

immediately

following

Paragraph 210 of Plaintiff-Intervenor’s Complaint, Aarons denies
that Plaintiff-Intervenor is entitled to the relief requested
therein or any relief at all.
FIRST AFFIRMATIVE DEFENSE
Plaintiff-Intervenor’s Complaint, or parts thereof, fails
to state a claim upon which relief can be granted.
SECOND AFFIRMATIVE DEFENSE
Plaintiff-Intervenor’s claims are barred by the doctrines
of consent, waiver, estoppel, justification, laches, license,
unclean

hands,

after-acquired

evidence,

and/or

accord

and

satisfaction.
THIRD AFFIRMATIVE DEFENSE
Aarons has complied with all applicable Federal and State
laws and regulations and has acted in good faith at all times
relevant

hereto.

Aarons

has

not

intentionally

or

willfully

violated Plaintiff-Intervenor’s rights in any manner or acted
maliciously

or

with

reckless

indifference

with

respect

Plaintiff-Intervenor or any aspect of her employment.
time

has

Aarons

acted

with

any

intent

to

injure

to

At no

Plaintiff-

Intervenor.
FOURTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor is not entitled to recover damages,
including compensatory or punitive, under any facts or theories

- 41 -

set forth in the Complaint.

Furthermore, Plaintiff-Intervenor

is not entitled to any of the relief, equitable, declaratory, or
legal, requested in Plaintiff-Intervenor’s Complaint.
FIFTH AFFIRMATIVE DEFENSE
All or part of Plaintiff-Intervenor’s Complaint is barred
by Plaintiff-Intervenor’s failure to follow Aarons’ effective
Non-Discrimination and Sexual Harassment Policy of which she had
full knowledge.
to

prevent

Specifically, Aarons exercised reasonable care

and

correct

promptly

any

unlawfully

harassing

behavior and Plaintiff-Intervenor unreasonably failed to take
advantage of any preventive or corrective opportunities provided
by Aarons or to avoid harm otherwise.
SIXTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor cannot establish a causal connection
between any damages as alleged and any improper conduct on the
part of Aarons.
SEVENTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor’s Complaint may be barred, in whole or
in part, by Aarons having promptly and effectively remediated
any

and

all

conduct

reported

by

Plaintiff-Intervenor

as

discriminatory and/or retaliatory.
EIGHTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor’s Complaint may be barred, in whole or
in part, by the applicable limitations periods.

- 42 -

NINTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor’s Complaint may be barred, in whole or
in part, by Plaintiff-Intervenor’s failure to notify Aarons of
any conduct which she found objectionable.
TENTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor

has

failed

to

mitigate

her

alleged

damages as required by law.
ELEVENTH AFFIRMATIVE DEFENSE
Any

damages

that

Plaintiff-Intervenor

suffered

were

the

direct and proximate result of her own actions or inactions,
including, but not limited to, her own negligence or assumption
of the relevant risks.
TWELFTH AFFIRMATIVE DEFENSE
Any injuries or damages alleged by Plaintiff-Intervenor, if
any,

were

the

result

of

new,

independent,

intervening,

or

superseding causes that are unrelated to any conduct of Aarons,
and as a result, any action on the part of Aarons was not the
proximate or producing cause of any alleged injuries or damages
Plaintiff-Intervenor claims to have suffered.
THIRTEENTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor’s Complaint is barred or reduced by
the

fact

that

Plaintiff-Intervenor

consented

to,

welcomed,

and/or voluntarily participated in any conduct complained of in
this action.

- 43 -

FOURTEENTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor did not exercise due caution and care
with respect to the matters alleged in the Complaint and if, in
fact, Plaintiff-Intervenor suffered any damage or injury, she
contributed in whole or in part to such damage or injury, and,
therefore, any remedy or recovery to which Plaintiff-Intervenor
might

otherwise

be

entitled

must

be

denied

or

reduced

accordingly.
FIFTEENTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor

is

not

entitled

to

recover

damages

under any facts or theories set forth in the Complaint.

SIXTEENTH AFFIRMATIVE DEFENSE
To the extent any employee, manager, supervisor, director
or officer of Aarons engaged in any unlawful conduct as alleged
in Plaintiff-Intervenor’s Complaint, such actions were outside
the

scope

and

course

of

their

employment

and

were

not

in

furtherance of Aarons’ business.
SEVENTEENTH AFFIRMATIVE DEFENSE
Any

discriminatory

employment

decisions

by

Aarons’

managerial agents were contrary to Aarons’ good-faith efforts to
comply

with

Title

VII

of

the

Civil

amended.

- 44 -

Rights

Act

of

1964,

as

EIGHTEENTH AFFIRMATIVE DEFENSE
Plaintiff-Intervenor’s Complaint in Intervention is subject
to dismissal due to insufficiency of process and/or service of
process.
NINETEENTH AFFIRMATIVE DEFENSE
Defendant

is

not

liable

to

Plaintiff-Intervenor

on

her

claims of assault and battery because Plaintiff-Intervenor led
Defendant
alleged

to

reasonably

contact

by

believe

Defendant

that
and

she

the

consented

alleged

to

contact

the
by

Defendant was the same or was substantially similar to that
consented to by Plaintiff-Intervenor.
TWENTIETH AFFIRMATIVE DEFENSE
Aarons hereby reserves the right to amend this Answer or
add additional affirmative defenses, or to withdraw affirmative
defenses,

after

reasonable

opportunity

for

appropriate

discovery.
WHEREFORE,

having

fully

answered

the

allegations

in

Plaintiff-Intervenor’s Complaint, Aarons requests that the Court
enter an order dismissing the Plaintiff-Intervenor’s Complaint
in its entirety with prejudice, awarding Aarons its costs and
expenses,

including

reasonable

attorneys’

fees,

and

Aarons other relief as this Court deems just and proper.

- 45 -

awarding

Respectfully submitted, this 1st day of December 2008.

s/Alisa P. Cleek_____________
Alisa P. Cleek – Lead Counsel
Georgia Bar No. 581063
(Pro hac vice pending)
s/Elliott M. Friedman________
Elliott M. Friedman
Georgia Bar No. 277566
(Pro hac vice pending)
ELARBEE, THOMPSON, SAPP & WILSON, LLP
229 Peachtree Street, NE
800 International Tower
Atlanta, Georgia 30303
Phone:[phone]
Fax: [phone]
Email: [e-mail]
[e-mail]

s/Shari R. Rhode____________
Shari R. Rhode
Illinois Bar No. 02324598
s/Kristen Glasford__________
Kristen Glasford
Illinois Bar No. 06281800
RHODE & JACKSON, P.C.
1405 West Main Street
Carbondale, Illinois 62901
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendant Aaron Rents, Inc.

- 46 -

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,
Plaintiff,
and
ASHLEY ALFORD,
Plaintiff-Intervenor,
v.
AARON RENTS, INC. d/b/a AARON
SALES AND LEASE OWNERSHIP,
RICHARD MOORE, AND BRAD MARKIN,
Defendants.

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

CIVIL ACTION NO.
3:08-cv-00683-MJR-DGW

CERTIFICATE OF SERVICE
I hereby certify that on December 1, 2008, I electronically
filed

the

foregoing

DEFENDANT

AARON

RENTS,

INC.’S

ANSWER

TO

PLAINTIFF-INTERVENOR ASHLEY ALFORD’S FIRST AMENDED COMPLAINT IN
INTERVENTION with the Clerk of Court using the CM/ECF system
which will automatically send notification of such filing to the
following:
Barbara A. Seely
Jan Shelly
Judy L. Cates
s/Shari R. Rhode____________
Shari R. Rhode
Illinois Bar No. 02324598

RHODE & JACKSON, P.C.
1405 West Main Street
Carbondale, Illinois 62901
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant Aaron Rents, Inc.

-2-