Plaintiff's Response to Defendant's Joint Motion for Partial Traditional and Partial No Evidence Summary Judgment

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Angela Claiborne                                                 IN THE DISTRICT COURT             OF

        Plaintiff

Vv                                                               HARRIS COUNTY,           TEXAS

APTVC, LLC
        Defendant                                                 190    JUDICIAL DISTRICT

     PLAINTIFF’S RESPONSE TO DEFENDANTS’ JOINT MOTION FOR PARTIAL
        TRADITIONAL AND PARTIAL NO EVIDENCE SUMMARY JUDGMENT

        The Court should deny Defendants APTVC, LLC and Gatesco, Inc.’s (collectively

“Defendants”) Motion For Partial Traditional And Partial No Evidence Summary Judgment

                               ffs negligence claims only,      because the ceiling of an apartment

Plaintiff rented from Defendants          collapsed and fell on her, causing injuries.         While that

fact alone is reason enough to deny Defendants’ Motion, the Motion should also be denied



                Defendants owed their tenant duties of reasonable care, in…