On January 26, 2005 a
Answer
was filed
in the District Court of Oklahoma County.
Preview
IAD MT
ae FILED IN THE DISTRICT COURT
OKLAHOMA COUNTY, OKLA.
IN THE DISTRICT COURT OF OKLAHOMA COUNTY yy
STATE OF OKLAHOMA
PATRICIA AK
SOUTHBank, by
Plaintiff,
Case No. CJ 2005-666
vs.
GLORY O. PETERS, et al.,
Defendants.
ANSWER_OF DEFENDANT, BROOK MAYFIELD CUSTOM HOMES Lic TO
THIRD PARTY PETITION OF HILL & COMPANY, LTD.
COMES NOW the Defendant, Brook Mayfield Custom Homes, LLC
(“Mayfield”), and for its response to the third party claims of
the Hill & Company, Ltd. (“Hill”), alleges and states as follows:
3. Denied.
4, Denied.
5. Admitted. 1
ADDITIONAL DEFENSES
1. Hill has failed to state a claim against Mayfield upon
which relief may be granted.
2. Hill’s claims are barred, in whole or in part, by the
doctrines of estoppel, laches, waiver and/or unclean hands.
3. Mayfield reserves the right to assert additional
defenses determined through discovery.
WHEREFORE, Mayfield respectfully requests that the Court
enter judgment in his favor and against Hill & Company, Ltd. on
its Third Party Petition, and that the Court award Mayfield hiscosts and reasonable attorney's fees and any other relief to
which he might prove himself entitled.
By:
Respectfully Submitted,
DUNN SWAN & CUNNINGHAM
CTell I. Cunningvam III, OBA #2093
2800 Oklahoma Téwer
210 Park Avenue
Oklahoma City, Oklahoma 73102
(405) 235-8318
Attorneys for Defendant, Brook Mayfield
Custom Homes, LicCERTIFICATE OF SERVICE
that on the @@ aay of
The undersigned certifies
Wa , 2005, a true and correct copy of the above
foregoing Answer to Third Party Claims was mailed, postage
prepaid, to:
Donald K. Funnell, Esq.
1200 Robinson Renaissance
119 N. Robinson
Oklahoma City, OK 73102
Jim Vogt, Esq.
120 North Robinson, Suite 2200
Okiahoma City, OK 73102
Cynthia Rowe D'antonio, Esq.
4200 PERIMETER CENTER DRIVE
SUITE 140 OKLAHOMA CITY, OK
73112
Bret D. Davis, Esq.
LAMUN, MOCK, CUNNYNGHAM & DAVIS
5900 NW GRAND BOULEVARD
OKLAHOMA CITY, OK 73118-1295
Kenneth Dewbre, Esq.
2220 SHADOWLAKE DR
OKC, OK 73159
CLLIG 4
Document Filed Date
March 22, 2005
Case Filing Date
January 26, 2005
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IAD MT ae FILED IN THE DISTRICT COURT OKLAHOMA COUNTY, OKLA. IN THE DISTRICT COURT OF OKLAHOMA COUNTY yy STATE OF OKLAHOMA PATRICIA AK SOUTHBank, by Plaintiff, Case No. CJ 2005-666 vs. GLORY O. PETERS, et al., Defendants. ANSWER_OF DEFENDANT, BROOK MAYFIELD CUSTOM HOMES Lic TO THIRD PARTY PETITION OF HILL & COMPANY, LTD. COMES NOW the Defendant, Brook Mayfield Custom Homes, LLC (“Mayfield”), and for its response to the third party claims of the Hill & Company, Ltd. (“Hill”), alleges and states as follows: 3. Denied. 4, Denied. 5. Admitted. 1 ADDITIONAL DEFENSES 1. Hill has failed to state a claim against Mayfield upon which relief may be granted. 2. Hill’s claims are barred, in whole or in part, by the doctrines of estoppel, laches, waiver and/or unclean hands. 3. Mayfield reserves the right to assert additional defenses determined through discovery. WHEREFORE, Mayfield respectfully requests that the Court enter judgment in his favor and against Hill & Company, Ltd. on its Third Party Petition, and that the Court award Mayfield hiscosts and reasonable attorney's fees and any other relief to which he might prove himself entitled. By: Respectfully Submitted, DUNN SWAN & CUNNINGHAM CTell I. Cunningvam III, OBA #2093 2800 Oklahoma Téwer 210 Park Avenue Oklahoma City, Oklahoma 73102 (405) 235-8318 Attorneys for Defendant, Brook Mayfield Custom Homes, LicCERTIFICATE OF SERVICE that on the @@ aay of The undersigned certifies Wa , 2005, a true and correct copy of the above foregoing Answer to Third Party Claims was mailed, postage prepaid, to: Donald K. Funnell, Esq. 1200 Robinson Renaissance 119 N. Robinson Oklahoma City, OK 73102 Jim Vogt, Esq. 120 North Robinson, Suite 2200 Okiahoma City, OK 73102 Cynthia Rowe D'antonio, Esq. 4200 PERIMETER CENTER DRIVE SUITE 140 OKLAHOMA CITY, OK 73112 Bret D. Davis, Esq. LAMUN, MOCK, CUNNYNGHAM & DAVIS 5900 NW GRAND BOULEVARD OKLAHOMA CITY, OK 73118-1295 Kenneth Dewbre, Esq. 2220 SHADOWLAKE DR OKC, OK 73159 CLLIG 4