On January 10, 2018 a
Motion-Secondary
was filed
in the District Court of Oklahoma County.
Preview
it ni HN FILED IN Bia Riet beluick
OKLAHOMA COUNTY
IN THE DISTRICT COURT OF OKLAHOMA COUNTY FEB 26 2018
STATE OF OKLAHOMA
RICK WARREN
) COURT CLERK
Southwestern Bell Telephone Company ) Se
d/b/a AT&T Oklahoma )
Plaintiff )
)
v. ) No. CS-2018-249
)
Chad Michael Niemyer )
Defendant, J
DEFENDANT’S RESPONSE TO PETITION
COMES NOW Chad Niemyer, by and through his attorney, John T. Poling and
submits this Response to Plaintiff's Petition. In support of the Petitioner’s Response, he
states to-wit:
1, Defendant disputes all of Plaintiff's allegations and demand strict proof thereof.
2. Defendant or defendant’s crew was not responsible to alleged damage.
Statements in Support
The alleged amount requested by Plaintiff is not due Plaintiff as said amounts are not
owed by Defendant to Plaintiff. Defendant was not the only company or contractor located
on the jobsite. The location in question was open to a number of individuals including the
general contractor who could have and more than likely caused the damage. Upon completion
of Defendants work, the property of Plaintiff was still intact.
Therefore, for reasons stated above, Defendant, Chad Niemyer, does ask this Court to
deny Plaintiff's Petition and grant unto him all costs associated with this case, including
attorney fees, and other remedies as the Court deems right.
Respecffully submit,
DM
pin T. Poling OBA:
105 Greenway Dr.
Oklahoma City, OK 73127
(405) 264-6167 Telephone
Attorney for the RespondentCERTIFICATE OF SERVICE
The undersigned certifies that on the 26th day of January, 2018, a copy of the foregoing
Response was mailed to the attorney of record for the above styled case by United States Postal
Service, first-class, postage paid at the following address:
Lori A. Sander
3934 NW 36" St
Oklahoma City, Oklahoma 73112
Oklahoma City, OK 73127
(405) 264-6167 Telephone
Attorney for the RespondentVERIFICATION
STATE OF OKLAHOMA
SS:
COUNTY OF OKLAHOMA
Chad Michael Niemyer, being first duly sworn upon this oath, deposes and states:
That he is the Defendant above named; that he has read the forgoing Response and
understands the contents thereof; that the statemgnts and allegations contained therein are
true and correct.
i
—_—
2 ee dab
Subscribed and sworn to before me this 2k day of. Say Acic?» 2018
KARYL PAXSON / i
Nota pic Sat ofOkanoma Mona how)
Commission Number 12007931 5
My Commission Expires Aug 21, 2020 Notary ‘Public
My Commission Expires:
Document Filed Date
February 26, 2018
Case Filing Date
January 10, 2018
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it ni HN FILED IN Bia Riet beluick OKLAHOMA COUNTY IN THE DISTRICT COURT OF OKLAHOMA COUNTY FEB 26 2018 STATE OF OKLAHOMA RICK WARREN ) COURT CLERK Southwestern Bell Telephone Company ) Se d/b/a AT&T Oklahoma ) Plaintiff ) ) v. ) No. CS-2018-249 ) Chad Michael Niemyer ) Defendant, J DEFENDANT’S RESPONSE TO PETITION COMES NOW Chad Niemyer, by and through his attorney, John T. Poling and submits this Response to Plaintiff's Petition. In support of the Petitioner’s Response, he states to-wit: 1, Defendant disputes all of Plaintiff's allegations and demand strict proof thereof. 2. Defendant or defendant’s crew was not responsible to alleged damage. Statements in Support The alleged amount requested by Plaintiff is not due Plaintiff as said amounts are not owed by Defendant to Plaintiff. Defendant was not the only company or contractor located on the jobsite. The location in question was open to a number of individuals including the general contractor who could have and more than likely caused the damage. Upon completion of Defendants work, the property of Plaintiff was still intact. Therefore, for reasons stated above, Defendant, Chad Niemyer, does ask this Court to deny Plaintiff's Petition and grant unto him all costs associated with this case, including attorney fees, and other remedies as the Court deems right. Respecffully submit, DM pin T. Poling OBA: 105 Greenway Dr. Oklahoma City, OK 73127 (405) 264-6167 Telephone Attorney for the RespondentCERTIFICATE OF SERVICE The undersigned certifies that on the 26th day of January, 2018, a copy of the foregoing Response was mailed to the attorney of record for the above styled case by United States Postal Service, first-class, postage paid at the following address: Lori A. Sander 3934 NW 36" St Oklahoma City, Oklahoma 73112 Oklahoma City, OK 73127 (405) 264-6167 Telephone Attorney for the RespondentVERIFICATION STATE OF OKLAHOMA SS: COUNTY OF OKLAHOMA Chad Michael Niemyer, being first duly sworn upon this oath, deposes and states: That he is the Defendant above named; that he has read the forgoing Response and understands the contents thereof; that the statemgnts and allegations contained therein are true and correct. i —_— 2 ee dab Subscribed and sworn to before me this 2k day of. Say Acic?» 2018 KARYL PAXSON / i Nota pic Sat ofOkanoma Mona how) Commission Number 12007931 5 My Commission Expires Aug 21, 2020 Notary ‘Public My Commission Expires: