Motion-Secondary: WHITNEY, RANDALL (DBA TITAN TECHNICAL TRAINING) vs. ROWAN COMPANIES INC

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                §        IN THE DISTRICT COURT
                  D/B/A TITAN TECHNICAL TRAINING AND                             §
                  A/K/A TITAN TECHNICAL TRAINING LLC                             §
                                                                                 §
                                                                                 §        OF HARRIS COUNTY, TEXAS
                                                                                 §
                                                                                 §
                  ROWAN COMPANIES,                                               §
                                                                                 §        190    JUDICIAL DISTRICT



                       A/K/A TITAN TECHNICAL TRAINING LLC’S RESPONSE TO DEFENDANT’S
                           REPLY MEMORANDUM ON TRADITIONAL MOTION FOR SUMMARY
                          JUDGMENT BASED ON PLAINTIFF’S LACK OF CAPACITY, OR IN THE



                           COMES NOW, RANDALL WHTINEY D/B/A TITAN TECHNICAL TRAINING AND

                  A/K/A    TITAN     TECHNICAL         TRAINING        LLC’s,   hereinafter    referred  to as  Plaintiff,  who   files

                  this his response to ROWAN COMPANIES, INC.’s, hereinafter referred to as Defendant, Reply

                  Memorandum         on  Traditional    Motion    for  Summary       Judgment     Based    on  Plaintiff’s   Lack   of

                  Capacity, or in the Alternative, Plea to the Jurisdiction, and in support thereof respectfully shows



                  1.       On May 19, 2017, the eve of the hearing on Defendant’s Motion for Summary Judgment,

                  Defendant filed a Reply Memorandum on Traditional Motion for Summary Judgment Based on

                  Plaintiff’s Lack of Capacity, or in the Alternative, Plea to the Jurisdiction. Defendant’s Reply

                  Memorandum, should be stricken, as it was untimely filed by Defendant.

                  2.       Further, on the first page of Defendant’s Reply Memorandum, Defendant unethically and

                  strategically   included   a  footnote   number    one   (1), making    defaming     and  accusatory    statements

                  about   Plaintiff’s  character   and   the  invoices   he  submitted    to the  Defendant,    therein   defrauding
                                                                                 D/B/A

                                                                                 TRAINING