On March 01, 2023 a
Answer
was filed
involving a dispute between
Inbox Moving Service, Llc,
and
Barnes, Maryann,
for BILL OF REVIEW (CIVIL)
in the District Court of Dallas County.
Preview
FILED
4/17/2023 8:52 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Steve Brashear DEPUTY
CAUSE NO. DC-23—02888
INBOX MOVING SERVICE, LLC, § IN THE DISTRICT COURT
Plaintiff §
§
§
§
V §
§ 298th JUDICIAL DISTRICT
§
g
MARYANN BARNES, §
Defendant. § DALLAS COUNTY, TEXAS
DEFENDANT’S ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, MARYANN BARNES, Defendant, and files this Original Answer, and
in support of same would respectfully show the Court as follows:
I.
GENERAL DENIAL
1. Defendant MARYANN BARNES asserts a general denial as authorized by Rule 92 of the
TEXAS RULES 0F CIVIL PROCEDURE and respectfully requests that the Plaintiff be required
to prove the charges and allegations against Defendant MARYANN BARNES by a
preponderance of the evidence as is required by the Constitution and the Laws of the State
of Texas.
II.
PRAYER
WHEREFORE, premises considered, upon notice and hearing as required by law,
Defendant MARYANN BARNES requests that the Court enter an order that Plaintiff INBOX
MOVING SERVICE, LLC take nothing by this suit and for such other and further relief, at law
or in equity to which Defendant may show herself to be justly entitled.
DEFENDANT’S ORIGINAL ANSWER PAGE |
1
Respectfully submitted,
COOK KEITH & DAVIS
A PROFESSIONAL CORPORATION
/s/ Stephen W. Davis
STEPHEN W. DAVIS
State Bar N0. 24066792
stephen@cookkeithdavis.com
REGINALD A. JALA
State Bar No. 24132126
reggie@cookkeithdavis.com
6688 North Central Expressway, Suite 1000
Dallas, TX 75206
(214) 368-4686
(214) 593-5713 Telecopy
ATTORNEYS FOR DEFENDANT
CERTIFICATE OF SERVICE
I hereby certify that on the 17th day of April 2023, a true and correct copy of the above
and foregoing was served upon all parties herein in accordance with the TEXAS RULES 0F CIVIL
PROCEDURE.
JASON FELTOON
FELTOON LAW, PLLC
jason@feltoon.1aw
5141 Cromwell Dr., Suite 104
Kyle, Texas 78640
/s/Re,qinald A. J ala
REGINALD A. JALA
DEFENDANT’s 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.
Darrell Cook on behalf of Stephen Davis
Bar No. 24066792
all@cookkeithdavis.com
Envelope ID: 74692690
Filing Code Description: Original Answer - General Denial
Filing Description:
Status as of 4/17/2023 8:58 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Liz Cole liz@feltoon.law 4/17/2023 8:52:36 AM SENT
JASON FELTOON jason@feltoon.law 4/ 17/2023 8:52:36 AM SENT
Document Filed Date
April 17, 2023
Case Filing Date
March 01, 2023
Category
BILL OF REVIEW (CIVIL)
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FILED 4/17/2023 8:52 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Steve Brashear DEPUTY CAUSE NO. DC-23—02888 INBOX MOVING SERVICE, LLC, § IN THE DISTRICT COURT Plaintiff § § § § V § § 298th JUDICIAL DISTRICT § g MARYANN BARNES, § Defendant. § DALLAS COUNTY, TEXAS DEFENDANT’S ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, MARYANN BARNES, Defendant, and files this Original Answer, and in support of same would respectfully show the Court as follows: I. GENERAL DENIAL 1. Defendant MARYANN BARNES asserts a general denial as authorized by Rule 92 of the TEXAS RULES 0F CIVIL PROCEDURE and respectfully requests that the Plaintiff be required to prove the charges and allegations against Defendant MARYANN BARNES by a preponderance of the evidence as is required by the Constitution and the Laws of the State of Texas. II. PRAYER WHEREFORE, premises considered, upon notice and hearing as required by law, Defendant MARYANN BARNES requests that the Court enter an order that Plaintiff INBOX MOVING SERVICE, LLC take nothing by this suit and for such other and further relief, at law or in equity to which Defendant may show herself to be justly entitled. DEFENDANT’S ORIGINAL ANSWER PAGE | 1 Respectfully submitted, COOK KEITH & DAVIS A PROFESSIONAL CORPORATION /s/ Stephen W. Davis STEPHEN W. DAVIS State Bar N0. 24066792 stephen@cookkeithdavis.com REGINALD A. JALA State Bar No. 24132126 reggie@cookkeithdavis.com 6688 North Central Expressway, Suite 1000 Dallas, TX 75206 (214) 368-4686 (214) 593-5713 Telecopy ATTORNEYS FOR DEFENDANT CERTIFICATE OF SERVICE I hereby certify that on the 17th day of April 2023, a true and correct copy of the above and foregoing was served upon all parties herein in accordance with the TEXAS RULES 0F CIVIL PROCEDURE. JASON FELTOON FELTOON LAW, PLLC jason@feltoon.1aw 5141 Cromwell Dr., Suite 104 Kyle, Texas 78640 /s/Re,qinald A. J ala REGINALD A. JALA DEFENDANT’s 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. Darrell Cook on behalf of Stephen Davis Bar No. 24066792 all@cookkeithdavis.com Envelope ID: 74692690 Filing Code Description: Original Answer - General Denial Filing Description: Status as of 4/17/2023 8:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Liz Cole liz@feltoon.law 4/17/2023 8:52:36 AM SENT JASON FELTOON jason@feltoon.law 4/ 17/2023 8:52:36 AM SENT