One of three defendants in a Madison County personal injury case responded to the plaintiff's document production request.
The lawsuit involves plaintiff Judith Simmons who says she walked through a door at Faith Countryside Homes, a retirement community in Highland, where she fell into a four-foot hole and injured both lower extremities.
Faith Countryside Homes, Kane Mechanical and Maul Excavating are defendants in the case filed last year.
The defendants are accused of failing to take reasonable steps to guard against the hazard they created, including failure to prevent entry into the door or post any warning of the hazard inside.
The plaintiff suffered permanent pain, mental anguish, disability and disfigurement, has been prevented from tending to her duties, has lost wages, past, present, and future and has incurred and become liable for large sums of money in hospital, medical and related expenses, past, present and future, all to her damage in a substantial amount.
According to the complaint, Kane and Maul were named as defendants because they were engaged in plumbing work at Faith Countryside Homes.
Kane Mechanical filed the certificate of service regarding the production request. The filing also indicates it answered Simmons' questions.
All three defendants claim Simmons caused her injuries due to her own negligence and failure to keep a careful lookout as the hole and trench area were an open condition.
Simmons seeks a judgment of more than $75,000. She is represented by Thomas Keefe Jr. and Charles Hamilton, both of Belleville.
Maul Excavating is represented by Daniel Price of Centralia.
Faith Countryside Homes is represented by Michael McDonald Jr.
Madison County Chief Judge Ann Callis is assigned to the case.
The case is number 11-L-579.