Answer: Geico County Mutual Insurance Company vs. Keanna De Keshia Jefferson,Eugene Chance Jefferson

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                                NO. 22-06-08342

 GEICO COUNTY MUTUAL                                  IN THE DISTRICT OF
 INSURANCE COMPANY

 VS.                                                  MONTGOMERY COUNTY, TEXAS

 KEANNA DE KESHIA JEFFERSON
 AND EUGENE CHANCE                                    457TH JUDICIAL DISTRICT
 JEFFERSON

                                FENDANTS’ ORIGINALANSWER

TO THE HONORABLE JUDGE OF SAID COURT:

       COME NOW Eugene Chance Jefferson and Keanna De Keshia Jefferson, Defendants in

the above styled and numbered cause of action, and in response to the complaints filed against

them, would respectfully show unto this Honorable Court and Jury as follows:



       Defendants generally den the material allegations contained in Plaintiff’s pleadings and

demand strict proof thereof.



       Defendants plead Civil Practice and Remedies Code Chapter 33 and its appropriate

subchapters and subparts, Proportionate Responsibility and Contributions, and ask the Court and

Jury to consider the relative damages and conduct of the parties and all tortfeasors, including the

Plaintiff, and accord the Defendants full benefit of Chapter 33 and its subchapters and subparts.

Said Defendants are entitled to a percentage reduction based upon a determination of the relative

responsibility of all persons and party joint tortfeasors or a credit and offset for the amount of

money paid to Plaintiff by any alleged joint tortfeasor who is not a party to the suit at time of trial.
       The incident of which complaint is made was proximately caused by the Plaintiff’s

negligence and carelessness as those terms are understood in common law and the Texas

Transportation Code.

                                                IV.

       Defendants further request the Court to instruct the Jury on the doctrines of sudden

emergency and unavoidable accident as those terms are known in law andapplicable to this case.



       Defendants would show that any injuries, damages or liabilities complained of by Plaintiff

herein are the result in whole or in part of pre existing conditions or subsequent conditions of

Plaintiff and not the result of any act or omission on the part of the Defendants.

                                                VI.

       Defendants invokes self authentication rights pursuant to Tex. R. Civ. P. 193.7, and

specifically that documents/items made available by the opposing party through discovery process

may be used at trial and/or in pre-trial proceedings.



       Defendants hereby serves notice that the only email address valid for service on Defendants

is hcdocket@hope-causey.com

                         DEFENDANTS’ REQUIRED DISCLOSURE

       Under Texas Rules of Civil Procedure 190 and 194, Defendants request that Plaintiff

disclose, within thirty (30) days from the date this request is served, the information or materials

described in Rule 190.2(b)(6) and 194.2.
                      DEFENDANTS’ REQUEST FOR JURY TRIAL

       Defendants formally request a jury trial pursuant to Rule 216 of the Texas Rules of Civil

Procedure and tender payment in the amount of $10.00 as jury fee.

       Defendants also request the official court reporter of the Court to which this case is

assigned to trial to perform all the duties of this office, as set forth in Section 52.046 of the

Government Code.

       WHEREFORE, PREMISES CONSIDERED, Defendants, Eugene Chance Jefferson and

Keanna De Keshia Jefferson, pray that the Plaintiff recover nothing of and from the Defendants

   reason of this suit, that Defendants be discharged without d ay, with costs of court, and for

such other and further relief, both general and special, at law and in equity, to which Defendants

may show themselves justly entitled, and for which Defendants will in duty bound, forever pray.

                                             Respectfully submitted,

                                             HOPE & CAUSEY, P. C.

                                             /s/ John M. Causey

                                             John M. Causey
                                             State Bar No. 04019100
                                             P. O. Box 3188
                                             Conroe, Texas 77305-3188
                                             (936) 441-4673 - Metro
                                             (936) 441-4674 - Facsimile
                                             hcdocket@hope-causey.com

                                             ATTORNEYS FOR DEFENDANTS
CERTIFICATE OF SERVICE

        Pursuant to Rules 21. and 21a. of the Texas Rules of Civil Procedure, I hereby certify that
the original of Defendants’ Original Answer has been filed with the clerk of the court in writing,
and a true and correct copy has been delivered to all interested parties on November 7, 2022
correctly addressed to:

       Jared B. Hall
       Rathbone Group, LLC
       5930 Royal Lane, Ste. E #515
       Dallas, TX 75230-3806                                VIA E-SERVE


                                             /s/ John M. Causey

                                             John M. Causey