On February 10, 2022 a
Answer
was filed
involving a dispute between
Cobb, Ronda,
and
Cesar Chavez Foundation,
Riverside Ccf Cb Partners, L.P.,
Rodriguez, Reynaldo,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
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FILED
4/11/2022 11:00 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
PIC.26467
CAUSE NO. DC-22-01700
RONDA COBB, § IN THE DISTRICT COURT
Plaintiff, §
§
VS. §
§
RIVERSIDE CCF/CB PARTNERS, L.P. § DALLAS COUNTY, TEXAS
D/B/A THE PARK AT CLIFF CREEK §
APARTMENTS; CESAR CHAVEZ §
FOUNDATION; REYNALDO §
RODRIGUEZ D/B/A RODRIGUEZ §
PAINTING, §
Defendants. § 298m JUDICIAL DISTRICT
DEFENDANTS’ ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT
CLIFF CREEK APARTMENTS and CESAR CHAVEZ FOUNDATION, Defendants in the
above entitled and numbered cause, and file this their Original Answer and for same would
respectfully show unto the Court as follows:
I.
General Denial
Defendants deny each and every, all and singular, the material allegations contained
within Plaintiff’ s pleadings and demand strict proof thereof.
II.
JIHZ D61113116
Defendants hereby, in accordance with Rule 216 of the Texas Rules of Civil Procedure,
demand a trial by jury.
WHEREFORE, PREMISES CONSIDERED, Defendants pray that the Plaintiff take
nothing by this suit, that Defendants be awarded their costs, and for such other and further relief,
DEFENDAN TS’ ORIGINAL ANSWER - Page 1
both general and special, at law and in equity, to which Defendants may show themselves justly
entitled.
Respectfully submitted,
FLETCHER, FARLEY, SHIPMAN
& SALINAS, L.L.P.
BY: /s/D0uglas D. Fletcher
DOUGLAS D. FLETCHER
State Bar No. 07139500
Email: doug.fletcher@fletcherfarlev.com
JULIA L. SINOR
State Bar No. 24032540
Email: iulia.sinor@fletcherfarley.com
9201 N. Central Expressway, Suite 600
Dallas, Texas 75231
(214) 987-9600 (office)
(214) 987-9866 (telecopier)
ATTORNEYS FOR DEF ENDANTS
RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A
THE PARK AT CLIFF CREEK
APARTMENTS AND CESAR CHAVEZ
FOUNDATION
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing instrument has been
electronically served, mailed, telecopied or hand delivered to all attorneys of record, in
compliance with Rule 21a. of the Texas Rules of Civil Procedure, on this the 11th day of April,
2022.
/s/D0uglas D. Fletcher
DOUGLAS D. FLETCHER
DEFENDAN TS’ ORIGINAL ANSWER - Pa2e 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.
Douglas Fletcher on behalf of Douglas Fletcher
Bar No. 07139500
sheila.landua@fletcherfarley.com
Envelope ID: 63441682
Status as of 4/1 1/2022 1:36 PM CST
Associated Case Party: RONDA COBB
Name BarNumber Email TimestampSubmitted Status
GAGANDEEP KSETH gkseth@dukeseth.com 4/11/2022 11:00:51 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Douglas DFletcher sheila.landua@fletcherfarley.com 4/11/2022 11:00:51 AM SENT
Document Filed Date
April 11, 2022
Case Filing Date
February 10, 2022
Category
OTHER PERSONAL INJURY
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FILED 4/11/2022 11:00 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY PIC.26467 CAUSE NO. DC-22-01700 RONDA COBB, § IN THE DISTRICT COURT Plaintiff, § § VS. § § RIVERSIDE CCF/CB PARTNERS, L.P. § DALLAS COUNTY, TEXAS D/B/A THE PARK AT CLIFF CREEK § APARTMENTS; CESAR CHAVEZ § FOUNDATION; REYNALDO § RODRIGUEZ D/B/A RODRIGUEZ § PAINTING, § Defendants. § 298m JUDICIAL DISTRICT DEFENDANTS’ ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS and CESAR CHAVEZ FOUNDATION, Defendants in the above entitled and numbered cause, and file this their Original Answer and for same would respectfully show unto the Court as follows: I. General Denial Defendants deny each and every, all and singular, the material allegations contained within Plaintiff’ s pleadings and demand strict proof thereof. II. JIHZ D61113116 Defendants hereby, in accordance with Rule 216 of the Texas Rules of Civil Procedure, demand a trial by jury. WHEREFORE, PREMISES CONSIDERED, Defendants pray that the Plaintiff take nothing by this suit, that Defendants be awarded their costs, and for such other and further relief, DEFENDAN TS’ ORIGINAL ANSWER - Page 1 both general and special, at law and in equity, to which Defendants may show themselves justly entitled. Respectfully submitted, FLETCHER, FARLEY, SHIPMAN & SALINAS, L.L.P. BY: /s/D0uglas D. Fletcher DOUGLAS D. FLETCHER State Bar No. 07139500 Email: doug.fletcher@fletcherfarlev.com JULIA L. SINOR State Bar No. 24032540 Email: iulia.sinor@fletcherfarley.com 9201 N. Central Expressway, Suite 600 Dallas, Texas 75231 (214) 987-9600 (office) (214) 987-9866 (telecopier) ATTORNEYS FOR DEF ENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing instrument has been electronically served, mailed, telecopied or hand delivered to all attorneys of record, in compliance with Rule 21a. of the Texas Rules of Civil Procedure, on this the 11th day of April, 2022. /s/D0uglas D. Fletcher DOUGLAS D. FLETCHER DEFENDAN TS’ ORIGINAL ANSWER - Pa2e 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. Douglas Fletcher on behalf of Douglas Fletcher Bar No. 07139500 sheila.landua@fletcherfarley.com Envelope ID: 63441682 Status as of 4/1 1/2022 1:36 PM CST Associated Case Party: RONDA COBB Name BarNumber Email TimestampSubmitted Status GAGANDEEP KSETH gkseth@dukeseth.com 4/11/2022 11:00:51 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Douglas DFletcher sheila.landua@fletcherfarley.com 4/11/2022 11:00:51 AM SENT