Answer: Marshall Smith vs. Dynamic Engine Solutions, LLC d/b/a Precision ATV

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                                CAUSE NO. 23-05-07559

 MARSHALL SMITH                                                    IN THE DISTRICT COURT OF

 Plaintiff     ,

                                                                             JUDICIAL DISTRICT

 DYNAMIC ENGINE SOLUTIONS,
 LLC d/b/a PRECISION A
 Defendant                                                    MONTGOMERYCOUNTY, TEXAS

   DEFENDANTDYNAMIC ENGINE SOLUTIONS LLC D/B/A PRECISION A                                      ’S
                      ORIGINAL ANSWER

       Defendant Dynamic Engine Solutions, LLC d/b/a Precision A                         (“Defendant”/

 Precision”) file this Original Answer and respectfully show the Court as follows:

                                            GENERAL DENIAL

               Precision generally denies the allegations in Plaintiff’s Original Petition as is

authorized by the Texas Rules of Civil Procedure and respectfully request that Plaintiff be required

to prove his charges and allegations against them by a preponderance of the evidence as required

by the Constitution and the laws of the State of Texas.



                                         AFFIRMATIVE DEFENSES

               Plaintiff’s claims fail in whole or in part due to Plaintiff’s consent.

               Plaintiff’s claims fail in whole or in part due to waiver on the part of Plaintiff.

               Plaintiff’s claims fail in whole or in part due to Plaintiff’s own acts or omissions.

                   aintiff’s claims fail in whole or in part due to the doctrine of estoppel.




DEFENDANT’S ORIGINAL ANSWER
               Plaintiff’s claims fail in whole or in part due to Defendant’s reliance on the

representations of Plaintiff.

               Plaintiff’s claims fail in whole or in part due Plaintiff’s failure to state a claim upon

which relief can be granted.

                                         URY REQUEST

       Precision asserts their right to a trial by jury and tender the required fee in accordance with

the Local Rules and Rules of Civil Procedure.



                                             PRAYER

       WHEREFORE, premises considered, Defendant Precision prays that Plaintiff take nothing

by this lawsuit, that Plaintiff’s claims be dismissed with prejudice, and that Defendants be awarded

their reasonable attorneys’ fees costs of court, and all other relief to which it may be entitled under

CPRC 37.009, or as otherwise allowed by law.

Dated: June 28, 2023

                                                       Respectfully submitted,

                                                       QUADROS, MIGL & CROSBY, PLLC

                                                       By: /s/ Shannon A.S. Quadros
                                                       Shannon A.S. Quadros
                                                       Texas Bar No.: 24072766
                                                       Email: squadros@qmclaw.com
                                                       Boyd S. Hoekel
                                                       Texas Bar No.: 24002298
                                                       Email: bhoekel@qmclaw.com
                                                       712 Main Street, Ste. 1100
                                                       Houston, Texas 77002
                                                       Telephone: 713-300-9662
                                                       Fax: 214-731-3117
                                                       COUNSEL           FOR      DEFENDANT
                                                       PRECISION ATV




DEFENDANT’S ORIGINAL ANSWER
                             CERTIFICATE OF SERVICE

      I hereby certify that a true and correct copy of the foregone pleading has been served on
May 26, 2023, to the parties listed below as follows:


Travis Owens
Conner Tichota
Owens Law Group, PLLC
P.O. Box 8605
The Woodlands, TX 77387
Via the Court’s Efiling System


                                                           Shannon A.S. Quadros
                                                           Shannon A.S. Quadros




DEFENDANT’S ORIGINAL ANSWER