On February 27, 2019 a
Answer
was filed
involving a dispute between
Cisneros, Roberto,
and
Navarro, Andres Matthew,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
8/21/2019 10:07 AM
Hidalgo County Clerk
Accepted by: Oscar Gonzalez
CAUSE NO. CL-19-1213-A
ROBERT CISNEROS, IN THE COUNTY COURT
Plaintiff(s),
vs. COUNTY COURT AT LAW NO. 1
ANDRES MATTHEW NAVARRO,
Defendant(s). HIDALGO COUNTY, TEXAS
DEFENDANT ANDRES MATTHEW NAVARROJS FIRST AMENDED ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES ANDRES MATTHEW NAVARRO, hereinafter referred t0 as Defendant,
and files this First Amended Answer, respectfully showing the Court the following:
1.
GENERAL DENIAL
Defendant denies each and every, all and singular, the allegations made and contained in
the Original Petition filed by the Plaintiff(s), and any petition which Plaintiff(s) may hereinafter
file by way of amendment or supplement, for the purpose 0f requiring the Plaintiff(s) t0 prove
said allegations by a preponderance of the evidence t0 a fair and impartial jury in accordance
with the laws of this State.
2.
AMOUNT OF RECOVERY
In addition t0 any other limitation under law, recovery of medical 0r health care expenses
incurred is limited t0 the amount actually paid 0r incurred by 0r 0n behalf of the claimant.
Cisneros vs. Navarro PAGE 1
DEFENDANT ANDRES MATTHEW NAVARRO,'S FIRST AMENDED ANSWER
Our File Number: 04549978581
Electronically Submitted
8/21/2019 10:07 AM
Hidalgo County Clerk
Accepted by: Oscar Gonzalez
3.
JURY DEMAND
In accordance With Rule 216 of the Texas Rules of Civil Procedure, Defendant demands
a trial by jury. A jury fee has already been paid.
4.
DESIGNATED E-SERVICE EMAIL ADDRESS
The following is the undersigned attorney’s designation 0f electronic service email
address for all electronically served documents and notices, filed and unfiled, pursuant to
TeX.R.CiV.P. 21(f)(2) & 21(a). (McAllenLegal@allstate.com). This is the undersigned’s ONLY
electronic service email address, and service through any other email address will be considered
invalid.
5.
AFFIRAMTIVE DEFENSES
Defendant would show that this accident was the result of a sudden emergency/unavoidable
accident.
Defendant would show that Plaintiff’s injuries and damages as alleged in Plaintiff’s
Petition, although such injuries and damages are not so acknowledged, were caused in whole or
part, 0r contributed t0 by the Plaintiff’s failure t0 mitigate his damages.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff takes nothing
by Plaintiffs suit against Defendant, that Defendant be discharged, and that the Court grant such
other and further relief, both general and special, at law and in equity to which Defendant may be
justly entitled.
Cisneros vs. Navarro PAGE 2
DEFENDANT ANDRES MATTHEW NAVARRO,'S FIRST AMENDED ANSWER
Our File Number: 04549978581
Electronically Submitted
8/21/2019 10:07 AM
Hidalgo County Clerk
Accepted by: Oscar Gonzalez
Respectfully submitted,
SUSAN L. FLORENCE & ASSOCIATES
Wm
MICHAEL A. GUERRA
TBN: 24032375
200 S. 10th Street, Suite 1402
McAllen, TX 78501
McAllenLegal@allstate.com
(956) 630-9203
(877) 697-1295 (fax)
ATTORNEY FOR DEFENDANT(S)
ANDRES MATTHEW NAVARRO,
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy 0f the foregoing has been served in
compliance With Rules 21 and 21a 0f the Texas Rules 0f Civil Procedure 0n the 218T day 0f
August, 2019, to:
Attorney for Plaintiff Cisneros
Graciela Orellana, Esquire
Law Offices of Ezequiel Reyna, Jr., P.C.
702 W
EXpy 83 Ste 100
Weslaco TX 78596
Wm
MICHAEL A. GUERRA
Cisneros vs. Navarro PAGE 3
DEFENDANT ANDRES MATTHEW NAVARRO,'S FIRST AMENDED ANSWER
Our File Number: 04549978581
Document Filed Date
August 21, 2019
Case Filing Date
February 27, 2019
Category
Injury or Damage - Motor Vehicle (OCA)
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Electronically Submitted 8/21/2019 10:07 AM Hidalgo County Clerk Accepted by: Oscar Gonzalez CAUSE NO. CL-19-1213-A ROBERT CISNEROS, IN THE COUNTY COURT Plaintiff(s), vs. COUNTY COURT AT LAW NO. 1 ANDRES MATTHEW NAVARRO, Defendant(s). HIDALGO COUNTY, TEXAS DEFENDANT ANDRES MATTHEW NAVARROJS FIRST AMENDED ANSWER TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES ANDRES MATTHEW NAVARRO, hereinafter referred t0 as Defendant, and files this First Amended Answer, respectfully showing the Court the following: 1. GENERAL DENIAL Defendant denies each and every, all and singular, the allegations made and contained in the Original Petition filed by the Plaintiff(s), and any petition which Plaintiff(s) may hereinafter file by way of amendment or supplement, for the purpose 0f requiring the Plaintiff(s) t0 prove said allegations by a preponderance of the evidence t0 a fair and impartial jury in accordance with the laws of this State. 2. AMOUNT OF RECOVERY In addition t0 any other limitation under law, recovery of medical 0r health care expenses incurred is limited t0 the amount actually paid 0r incurred by 0r 0n behalf of the claimant. Cisneros vs. Navarro PAGE 1 DEFENDANT ANDRES MATTHEW NAVARRO,'S FIRST AMENDED ANSWER Our File Number: 04549978581 Electronically Submitted 8/21/2019 10:07 AM Hidalgo County Clerk Accepted by: Oscar Gonzalez 3. JURY DEMAND In accordance With Rule 216 of the Texas Rules of Civil Procedure, Defendant demands a trial by jury. A jury fee has already been paid. 4. DESIGNATED E-SERVICE EMAIL ADDRESS The following is the undersigned attorney’s designation 0f electronic service email address for all electronically served documents and notices, filed and unfiled, pursuant to TeX.R.CiV.P. 21(f)(2) & 21(a). (McAllenLegal@allstate.com). This is the undersigned’s ONLY electronic service email address, and service through any other email address will be considered invalid. 5. AFFIRAMTIVE DEFENSES Defendant would show that this accident was the result of a sudden emergency/unavoidable accident. Defendant would show that Plaintiff’s injuries and damages as alleged in Plaintiff’s Petition, although such injuries and damages are not so acknowledged, were caused in whole or part, 0r contributed t0 by the Plaintiff’s failure t0 mitigate his damages. WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff takes nothing by Plaintiffs suit against Defendant, that Defendant be discharged, and that the Court grant such other and further relief, both general and special, at law and in equity to which Defendant may be justly entitled. Cisneros vs. Navarro PAGE 2 DEFENDANT ANDRES MATTHEW NAVARRO,'S FIRST AMENDED ANSWER Our File Number: 04549978581 Electronically Submitted 8/21/2019 10:07 AM Hidalgo County Clerk Accepted by: Oscar Gonzalez Respectfully submitted, SUSAN L. FLORENCE & ASSOCIATES Wm MICHAEL A. GUERRA TBN: 24032375 200 S. 10th Street, Suite 1402 McAllen, TX 78501 McAllenLegal@allstate.com (956) 630-9203 (877) 697-1295 (fax) ATTORNEY FOR DEFENDANT(S) ANDRES MATTHEW NAVARRO, CERTIFICATE OF SERVICE I hereby certify that a true and correct copy 0f the foregoing has been served in compliance With Rules 21 and 21a 0f the Texas Rules 0f Civil Procedure 0n the 218T day 0f August, 2019, to: Attorney for Plaintiff Cisneros Graciela Orellana, Esquire Law Offices of Ezequiel Reyna, Jr., P.C. 702 W EXpy 83 Ste 100 Weslaco TX 78596 Wm MICHAEL A. GUERRA Cisneros vs. Navarro PAGE 3 DEFENDANT ANDRES MATTHEW NAVARRO,'S FIRST AMENDED ANSWER Our File Number: 04549978581