On March 29, 2023 a
Answer
was filed
involving a dispute between
Tovar, Laura M,
and
Dbdp Lp,
Meldi Restaurant Management Inc.,
Patel, Davin,
Rahman, Rahib,
Steve'S Landing And Marina Inc.,
Steve'S Landing Restaurant, Ltd.,
for Personal Injury
in the District Court of Galveston County.
Preview
Filed: 6/6/2023 5:11 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 76353241
By: Shailja Dixit
6/7/2023 8:07 AM
CAUSE NO. 23-CV-0506
LAURA M TOVAR, § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
v. §
§ GALVESTON COUNTY, TEXAS
STEVE’S LANDING RESTAURANT, LTD., §
STEVE’S LANDING AND MARINA INC., DBDP §
LP., MELDI RESTAURANT MANAGEMENT INC., §
DAVIN PATEL AND RAHIB RAHMAN, §
§
Defendants. § 212th JUDICIAL DISTRICT
DEFENDANT DAVIN PATEL’S ORIGINAL ANSWER
Defendant, Davin Patel (“Patel” or “Defendant”), hereby submits his Original Answer to
Plaintiff’s Original Petition and respectfully shows the Court the following.
I. GENERAL DENIAL
1. Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Patel generally denies
each and every allegation contained in Plaintiff’s Original Petition and demands strict proof
thereof. Patel reserves the right to amend his pleadings as permitted by the Rules.
II. AFFIRMATIVE DEFENSES
2. Pursuant to Rule 94 and without waiving the foregoing general denial, Patel
asserts the following affirmative defenses to Plaintiff’s Original Petition:
3. Failure to State a Claim. Patel is not liable in whole or in part because of Plaintiff’s
failure to state a claim.
4. Contributory Negligence. Patel is not liable in whole or in part because Plaintiff’s
injuries were caused in whole or in part by her own negligence.
5. Reservation of Rights. Patel reserves his right to amend this answer to the Petition
after he has had an opportunity to more closely investigate these claims as is his right and privilege
under the Rules and the laws of the State of Texas.
6. Additional Defenses/Affirmative Defenses. Patel reserves and preserves all
defenses and affirmative defenses that are available under the laws of the State of Texas, including
those defenses available under Rule 94, and asserts each affirmative defense as may be appropriate
and necessary.
7. Each of the above defenses and affirmative defenses is asserted in the alternative
and none of the asserted defenses is an admission by Patel. Each of the foregoing defenses is
simply a pleading of possible legal defenses to the allegations made by Plaintiff.
8. By pleading these defenses, Patel does not assume the burden of proof on any
defenses for which it would not otherwise have the burden of proof under Texas law.
PRAYER FOR RELIEF
Defendant Patel respectfully requests that Plaintiff take nothing against Patel, that the
claims against Patel be dismissed with prejudice, that Patel recover any costs, including reasonable
attorneys’ fees, and for any other relief to which Patel may be justly entitled under law or equity.
Dated: June 6, 2023
Respectfully Submitted,
By: ________________________
Davin Patel
Pro Se
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served upon
all counsel of record via e-service at the time of filing, in accordance with the Texas Rules of
Civil Procedure, on this 6th day of June, 2023.
________________________
Davin Patel
Pro Se
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.
Envelope ID: 76353241
Filing Code Description: Original Answer
Filing Description: Defendant Davin Patel's Original Answer
Status as of 6/7/2023 8:08 AM CST
Associated Case Party: LAURAMTOVAR
Name BarNumber Email TimestampSubmitted Status
Fabiana Baum fbaum@pulf.com 6/6/2023 5:11:59 PM SENT
Deborah Aguirre daguirre@pulf.com 6/6/2023 5:11:59 PM SENT
Associated Case Party: STEVE'S LANDING RESTAURANT, LTD.
Name BarNumber Email TimestampSubmitted Status
Linda Haynes lh@brandimartelaw.com 6/6/2023 5:11:59 PM SENT
Nathan Brandimarte nmb@brandimartelaw.com 6/6/2023 5:11:59 PM SENT
Associated Case Party: MELDI RESTAURANT MANAGEMENT INC.
Name BarNumber Email TimestampSubmitted Status
Michael S.Wright Michael@wright-lawfirm.com 6/6/2023 5:11:59 PM SENT
Jan Walker Jan@wright-lawfirm.com 6/6/2023 5:11:59 PM SENT
Document Filed Date
June 06, 2023
Case Filing Date
March 29, 2023
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Filed: 6/6/2023 5:11 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 76353241 By: Shailja Dixit 6/7/2023 8:07 AM CAUSE NO. 23-CV-0506 LAURA M TOVAR, § IN THE DISTRICT COURT OF § Plaintiff, § § v. § § GALVESTON COUNTY, TEXAS STEVE’S LANDING RESTAURANT, LTD., § STEVE’S LANDING AND MARINA INC., DBDP § LP., MELDI RESTAURANT MANAGEMENT INC., § DAVIN PATEL AND RAHIB RAHMAN, § § Defendants. § 212th JUDICIAL DISTRICT DEFENDANT DAVIN PATEL’S ORIGINAL ANSWER Defendant, Davin Patel (“Patel” or “Defendant”), hereby submits his Original Answer to Plaintiff’s Original Petition and respectfully shows the Court the following. I. GENERAL DENIAL 1. Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Patel generally denies each and every allegation contained in Plaintiff’s Original Petition and demands strict proof thereof. Patel reserves the right to amend his pleadings as permitted by the Rules. II. AFFIRMATIVE DEFENSES 2. Pursuant to Rule 94 and without waiving the foregoing general denial, Patel asserts the following affirmative defenses to Plaintiff’s Original Petition: 3. Failure to State a Claim. Patel is not liable in whole or in part because of Plaintiff’s failure to state a claim. 4. Contributory Negligence. Patel is not liable in whole or in part because Plaintiff’s injuries were caused in whole or in part by her own negligence. 5. Reservation of Rights. Patel reserves his right to amend this answer to the Petition after he has had an opportunity to more closely investigate these claims as is his right and privilege under the Rules and the laws of the State of Texas. 6. Additional Defenses/Affirmative Defenses. Patel reserves and preserves all defenses and affirmative defenses that are available under the laws of the State of Texas, including those defenses available under Rule 94, and asserts each affirmative defense as may be appropriate and necessary. 7. Each of the above defenses and affirmative defenses is asserted in the alternative and none of the asserted defenses is an admission by Patel. Each of the foregoing defenses is simply a pleading of possible legal defenses to the allegations made by Plaintiff. 8. By pleading these defenses, Patel does not assume the burden of proof on any defenses for which it would not otherwise have the burden of proof under Texas law. PRAYER FOR RELIEF Defendant Patel respectfully requests that Plaintiff take nothing against Patel, that the claims against Patel be dismissed with prejudice, that Patel recover any costs, including reasonable attorneys’ fees, and for any other relief to which Patel may be justly entitled under law or equity. Dated: June 6, 2023 Respectfully Submitted, By: ________________________ Davin Patel Pro Se CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served upon all counsel of record via e-service at the time of filing, in accordance with the Texas Rules of Civil Procedure, on this 6th day of June, 2023. ________________________ Davin Patel Pro Se 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. Envelope ID: 76353241 Filing Code Description: Original Answer Filing Description: Defendant Davin Patel's Original Answer Status as of 6/7/2023 8:08 AM CST Associated Case Party: LAURAMTOVAR Name BarNumber Email TimestampSubmitted Status Fabiana Baum fbaum@pulf.com 6/6/2023 5:11:59 PM SENT Deborah Aguirre daguirre@pulf.com 6/6/2023 5:11:59 PM SENT Associated Case Party: STEVE'S LANDING RESTAURANT, LTD. Name BarNumber Email TimestampSubmitted Status Linda Haynes lh@brandimartelaw.com 6/6/2023 5:11:59 PM SENT Nathan Brandimarte nmb@brandimartelaw.com 6/6/2023 5:11:59 PM SENT Associated Case Party: MELDI RESTAURANT MANAGEMENT INC. Name BarNumber Email TimestampSubmitted Status Michael S.Wright Michael@wright-lawfirm.com 6/6/2023 5:11:59 PM SENT Jan Walker Jan@wright-lawfirm.com 6/6/2023 5:11:59 PM SENT