Answer: Joseph D Abell vs. Kroger Texas L.P. D/B/A Kroger Store No. K034 East/Houston

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                                NOW, Defendant, KROGER TEXAS                        D/BA/ KROGER           STORE NO. K034

                                               referred     to   as   “Kroger”)     in the    above styled   and




        Subject to such stipulations and admissions as may hereafter be made, this

a general denial as is authorized by Rule 92 of the Texas Rules of Civil Procedure, and Defendant

respectfully request   that Plaintiff be required to prove the char               and allegations against this

Defendant by a preponderance of the evidence a            is required by the constitution and laws of the




        That Defendant respectfully reserve        the right at this time to amend this original answer to

the Plaintiff   allegations after said Defendant          had the opportunity to more closely inv

these claims, as is the right and privilege of said Defendant under the Rules of Civil Procedure and




        WHEREFORE,        PREMISES     CONSIDERED,           Defendant       KROGER      TEXAS

KROGER STORE NO. K034 EAST/HOUSTON                               that Plaintiff      nothing by reason of this
THE AKERS FIRM, PLLC




                                                   Brock C. Akers
                                                   State Bar No. 00953250
                                                   3401 Allen Parkway, Suite 101
                                                   Houston, Texas 77019

                                                              8662 (Fax)
                                                         bca@akersfirm.com
                                                   ATTORNEYS FOR DEFENDANT




        I hereby certify that a true copy of the foregoing Defendant  Original Answer has been
served in compliance with R_ es 21 and 21a ofthe Texas Rules of Civil Procedure on this