On October 14, 2021 a
Answer
was filed
involving a dispute between
Tinsman, Divya,
and
Couch, Thomas,
State Farm Mutual Automobile Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
11/11/2021 11:20 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
CAUSE NO. DC-21-15195
DIVYA TINSMAN; § 1N THE DISTRICT COURT
Plaintiff §
§
vs. § DALLAS COUNTY, TEXAS
§
STATE FARM MUTUAL AUTOMOBILE §
INSURANCE COMPANY; AND THOMAS §
COUCH; §
Defendants. § 298TH JUDICIAL DISTRICT
DEFENDAN TS’ ORIGINAL ANSWER
COME NOW, State Farm Mutual Automobile Insurance Company and Thomas Couch,
Defendants in the above styled and numbered cause and file their Original Answer to the
Plaintiff‘s Original Petition and in support thereof would respectfully represent and Show unto
the Court the following:
I.
Defendants deny each and every, all and singular, the material allegations contained in
Plaintiffs Original Petition and demand strict proof thereof.
II.
Defendants demand a trial by jury.
III.
REQUIRED DISCLOSURES
Pursuant to Texas Rule of Civil Procedure 194, you are required to disclose, within 30 days
of the filing of this answer, the information and material described in Rule 194.
WHEREFORE, PREMISES CONSIDERED, Defendants pray that upon final trial and
hearing hereof, that no recovery be had from Defendants, but that Defendants go hence without
DEFENDANTS’ ORIGINAL ANSWER PAGE 1
day and recover their costs, and for such other and further relief to which Defendants may be
justly entitled and will ever pray.
Respectfiilly submitted,
WALTERS, BALIDO & CRAIN, L.L.P.
CARLOS A. BALIDO
State Bar No. 01631230
Meadow Park Tower, Suite 1500
10440 North Central Expressway
Dallas, TX 75231
Tel: 214-749-4805
Fax: 214-760-1670
balidoedocsnotifications@wbclawfirrncom
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing document has been served
on all parties of record, in compliance with Rule 21a of the Texas Rules of Civil Procedure, on
November 11, 2021.
Christopher K. Provost
Shelly Greco
Witherite Law Group, PLLC
1004 N. Centrl Expy., Suite 400
Dallas, TX 75231
214-378-6665
214-378-6670 fax
christopherprovost@witheritelaw.com
shellv.greco@witheritelaw.com
CARLOS A. BALIDO
DEFENDANTS’ ORIGINAL ANSWER 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.
Paula Wylie on behalf of Carlos Balido
Bar No. 01631230
paula.wylie@wbclawfirm.com
Envelope ID: 59075587
Status as of 11/11/2021 11:26 AM CST
Associated Case Party: DIWA TINSMAN
Name BarNumber Email TimestampSubmitted Status
Tiffany Florer tiffany.florer@witheritelaw.com 11/11/2021 11:20:58 AM SENT
Christopher Provost Christopher.Provost@witheritelaw.com 1 1/11/2021 11:20:58 AM SENT
Associated Case Party: STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY
Name BarNumber Email TimestampSubmitted Status
Carlos A.Balido BalidoEDocsNotifications@wbclawfirm.com 11/11/2021 11:20:58 AM SENT
Document Filed Date
November 11, 2021
Case Filing Date
October 14, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 11/11/2021 11:20 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY CAUSE NO. DC-21-15195 DIVYA TINSMAN; § 1N THE DISTRICT COURT Plaintiff § § vs. § DALLAS COUNTY, TEXAS § STATE FARM MUTUAL AUTOMOBILE § INSURANCE COMPANY; AND THOMAS § COUCH; § Defendants. § 298TH JUDICIAL DISTRICT DEFENDAN TS’ ORIGINAL ANSWER COME NOW, State Farm Mutual Automobile Insurance Company and Thomas Couch, Defendants in the above styled and numbered cause and file their Original Answer to the Plaintiff‘s Original Petition and in support thereof would respectfully represent and Show unto the Court the following: I. Defendants deny each and every, all and singular, the material allegations contained in Plaintiffs Original Petition and demand strict proof thereof. II. Defendants demand a trial by jury. III. REQUIRED DISCLOSURES Pursuant to Texas Rule of Civil Procedure 194, you are required to disclose, within 30 days of the filing of this answer, the information and material described in Rule 194. WHEREFORE, PREMISES CONSIDERED, Defendants pray that upon final trial and hearing hereof, that no recovery be had from Defendants, but that Defendants go hence without DEFENDANTS’ ORIGINAL ANSWER PAGE 1 day and recover their costs, and for such other and further relief to which Defendants may be justly entitled and will ever pray. Respectfiilly submitted, WALTERS, BALIDO & CRAIN, L.L.P. CARLOS A. BALIDO State Bar No. 01631230 Meadow Park Tower, Suite 1500 10440 North Central Expressway Dallas, TX 75231 Tel: 214-749-4805 Fax: 214-760-1670 balidoedocsnotifications@wbclawfirrncom CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document has been served on all parties of record, in compliance with Rule 21a of the Texas Rules of Civil Procedure, on November 11, 2021. Christopher K. Provost Shelly Greco Witherite Law Group, PLLC 1004 N. Centrl Expy., Suite 400 Dallas, TX 75231 214-378-6665 214-378-6670 fax christopherprovost@witheritelaw.com shellv.greco@witheritelaw.com CARLOS A. BALIDO DEFENDANTS’ ORIGINAL ANSWER 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. Paula Wylie on behalf of Carlos Balido Bar No. 01631230 paula.wylie@wbclawfirm.com Envelope ID: 59075587 Status as of 11/11/2021 11:26 AM CST Associated Case Party: DIWA TINSMAN Name BarNumber Email TimestampSubmitted Status Tiffany Florer tiffany.florer@witheritelaw.com 11/11/2021 11:20:58 AM SENT Christopher Provost Christopher.Provost@witheritelaw.com 1 1/11/2021 11:20:58 AM SENT Associated Case Party: STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status Carlos A.Balido BalidoEDocsNotifications@wbclawfirm.com 11/11/2021 11:20:58 AM SENT