On January 19, 2022 a
Answer
was filed
involving a dispute between
Thomas, Marcus,
and
Dallas Movers South Llc,
Hamrick, Noah L.,
Pioneer Truck Leasing,
Sia Transportation Inc.,
Sia Transportation Inc. Dba Two Men And A Truck,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
3/17/2022 4:55 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
CAUSE NO. DC-22-00781
MARCUS THOMAS IN THE DISTRICT COURT
§§§§§§§§§§§§§
PLAINTIFF,
VS.
lOlSTJUDICIAL DISTRICT
NOAH HAMRICK, SIA
TRANSPORTATION INC. DBA TWO
MEN AND A TRUCK, PIONEER TRUCK
LEASING, AND DALLAS MOVERS
SOUTH LLC
DEFENDANTS. DALLAS COUNTY, TEXAS
DEFENDANTS NOAH HAMRICK, SIA TRANSPORTATION INC. DBA TWO MEN
AND A TRUCK’S ORIGINAL ANSWER TO PLAINTIFF’S ORIGINAL
PETITION AND DEMAND FOR JURY TRIAL
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Noah Hamrick and SIA Transportation Inc. d/b/a Two Men and a Truck,
Defendants in the above-styled and numbered cause, and file this, their Original Answer to
Plaintiffs Original Petition and Demand for Jury Trial, and would respectfully show the Court
the following:
I.
GENERAL DENIAL
Defendants generally deny each and every, all and singular, the material allegations
contained in the Plaintiff’s Original Petition and, being allegations of fact, demand that the
Plaintiff be required to prove such allegations by a preponderance of the evidence if the Plaintiff
can so do.
II.
DEMAND FOR JURY TRIAL
Defendants hereby demand a trial by jury and submit the appropriate jury fee.
DEFENDANTS’ ORIGINAL ANSWER T0 PLAINTIFF’S ORIGINAL PETITION AND DEMAND FOR JURY TRIAL -PAGE l
III.
Defendants request Level III Discovery Plan.
WHEREFORE, PREMISES CONSIDERED, Defendants pray that Plaintiff takes
nothing by this suit; and that Defendants go hence Without delay and recover all costs expended
in Defendants’ behalf. Praying fiirther, Defendants pray for such other and further relief, either
at law or in equity, to which Defendants may be justly entitled.
Respectfully submitted,
CHAMBLEE RYAN, P.C.
MBL
By:
William H. Chamblee
State Bar No. 04086100
wchamblee@cr.law
Amos D. Pettis
State Bar No. 24027730
2777 Stemmons Freeway, Suite 1257
Dallas, Texas 75207
(214) 905-2003
(214) 905 -12 1 3 (Facsimile)
ATTORNEY FOR DEFENDANTS
NOAH HAMRICK AND SIA TRANSPORTATION INC.,
D/B/A Two MEN AND A TRUCK
CERTIFICATE OF SERVICE
I do hereby certify that on March 17, 2022 a true and correct copy of the above and
foregoing document has been served Via the court’s e-flle/e-service system to all counsel of
record.
MM»
William H. Chamblee
DEFENDANTS’ ORIGINAL ANSWER T0 PLAINTIFF’S ORIGINAL PETITION AND DEMAND FOR JURY TRIAL -PAGE 2
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Envelope ID: 62720906
Status as of 3/18/2022 9:29 AM CST
Associated Case Party: MARCUS THOMAS
Name BarNumber Email TimestampSubmitted Status
Felipe B.Link flink@linklawpc.com 3/17/2022 4:55:37 PM SENT
Sara Link sara@linklawpc.com 3/17/2022 4:55:37 PM SENT
Link & Associates E-Fling service e-filing@linklawpc.com 3/17/2022 4:55:37 PM SENT
Lizeth G.Becerra lbecerra@linklawpc.com 3/17/2022 4:55:37 PM SENT
Adrian Vela adrian@linklawpc.com 3/17/2022 4:55:37 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
JASON MCGILBERRY service@linklawpc.com 3/17/2022 4:55:37 PM SENT
JASON MCGILBERRY JMCGILBERRY@LINKLAWPC.COM 3/17/2022 4:55:37 PM ERROR
Associated Case Party: NOAHL. HAMRICK
Name BarNumber Email TimestampSubmitted Status
Rhonda Braun rbraun@cr.law 3/17/2022 4:55:37 PM SENT
Amos Pettis apettis@cr.law 3/17/2022 4:55:37 PM SENT
William HChamblee wchamblee@cr.law 3/17/2022 4:55:37 PM SENT
Document Filed Date
March 17, 2022
Case Filing Date
January 19, 2022
Category
MOTOR VEHICLE ACCIDENT
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FILED 3/17/2022 4:55 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY CAUSE NO. DC-22-00781 MARCUS THOMAS IN THE DISTRICT COURT §§§§§§§§§§§§§ PLAINTIFF, VS. lOlSTJUDICIAL DISTRICT NOAH HAMRICK, SIA TRANSPORTATION INC. DBA TWO MEN AND A TRUCK, PIONEER TRUCK LEASING, AND DALLAS MOVERS SOUTH LLC DEFENDANTS. DALLAS COUNTY, TEXAS DEFENDANTS NOAH HAMRICK, SIA TRANSPORTATION INC. DBA TWO MEN AND A TRUCK’S ORIGINAL ANSWER TO PLAINTIFF’S ORIGINAL PETITION AND DEMAND FOR JURY TRIAL TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, Noah Hamrick and SIA Transportation Inc. d/b/a Two Men and a Truck, Defendants in the above-styled and numbered cause, and file this, their Original Answer to Plaintiffs Original Petition and Demand for Jury Trial, and would respectfully show the Court the following: I. GENERAL DENIAL Defendants generally deny each and every, all and singular, the material allegations contained in the Plaintiff’s Original Petition and, being allegations of fact, demand that the Plaintiff be required to prove such allegations by a preponderance of the evidence if the Plaintiff can so do. II. DEMAND FOR JURY TRIAL Defendants hereby demand a trial by jury and submit the appropriate jury fee. DEFENDANTS’ ORIGINAL ANSWER T0 PLAINTIFF’S ORIGINAL PETITION AND DEMAND FOR JURY TRIAL -PAGE l III. Defendants request Level III Discovery Plan. WHEREFORE, PREMISES CONSIDERED, Defendants pray that Plaintiff takes nothing by this suit; and that Defendants go hence Without delay and recover all costs expended in Defendants’ behalf. Praying fiirther, Defendants pray for such other and further relief, either at law or in equity, to which Defendants may be justly entitled. Respectfully submitted, CHAMBLEE RYAN, P.C. MBL By: William H. Chamblee State Bar No. 04086100 wchamblee@cr.law Amos D. Pettis State Bar No. 24027730 2777 Stemmons Freeway, Suite 1257 Dallas, Texas 75207 (214) 905-2003 (214) 905 -12 1 3 (Facsimile) ATTORNEY FOR DEFENDANTS NOAH HAMRICK AND SIA TRANSPORTATION INC., D/B/A Two MEN AND A TRUCK CERTIFICATE OF SERVICE I do hereby certify that on March 17, 2022 a true and correct copy of the above and foregoing document has been served Via the court’s e-flle/e-service system to all counsel of record. MM» William H. Chamblee DEFENDANTS’ ORIGINAL ANSWER T0 PLAINTIFF’S ORIGINAL PETITION AND DEMAND FOR JURY TRIAL -PAGE 2 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Envelope ID: 62720906 Status as of 3/18/2022 9:29 AM CST Associated Case Party: MARCUS THOMAS Name BarNumber Email TimestampSubmitted Status Felipe B.Link flink@linklawpc.com 3/17/2022 4:55:37 PM SENT Sara Link sara@linklawpc.com 3/17/2022 4:55:37 PM SENT Link & Associates E-Fling service e-filing@linklawpc.com 3/17/2022 4:55:37 PM SENT Lizeth G.Becerra lbecerra@linklawpc.com 3/17/2022 4:55:37 PM SENT Adrian Vela adrian@linklawpc.com 3/17/2022 4:55:37 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status JASON MCGILBERRY service@linklawpc.com 3/17/2022 4:55:37 PM SENT JASON MCGILBERRY JMCGILBERRY@LINKLAWPC.COM 3/17/2022 4:55:37 PM ERROR Associated Case Party: NOAHL. HAMRICK Name BarNumber Email TimestampSubmitted Status Rhonda Braun rbraun@cr.law 3/17/2022 4:55:37 PM SENT Amos Pettis apettis@cr.law 3/17/2022 4:55:37 PM SENT William HChamblee wchamblee@cr.law 3/17/2022 4:55:37 PM SENT