Answer: ARMANDA LITTLE vs. KENNETH MARK HAAS

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                                FILED
                                                                                                         DALLAS COUNTY
                                                                                                        12/10/2018 9:48 AM
                                                                                                            FELICIA PITRE
                                                                                                         DISTRICT CLERK

                                                                                                  Martin Reyes
                                     CAUSE NO. DC-18-16938

  ARMANDA LITTLE,                                       IN THE DISTRICT COURT

        Plaintiff(s),

  vs.                                                   192ND JUDICIAL DISTRICT

  KENNETH MARK HAAS,

        Defendant(s).                                   DALLAS COUNTY, TEXAS

                DEFENDANT, KENNETH MARK HAAS', ORIGINAL ANSWER

TO THE HONORABLE JUDGE OF SAID COURT:

          NOW COMES KENNETH MARK HAAS, Defendant in the above-styled and numbered

cause, and files Defendant's Original Answer, and in support hereof would respectfully show

unto the Court the following:

                                                  1.

                                       GENERAL DENIAL

          Defendant denies each and every, all and singular the material allegations made and

contained in the Original Petition and any petition which Plaintiff(s) may hereinafter file by way

of amendment or supplement, and, in accordance with Texas law, demands that Plaintiff(s) prove

by a preponderance of the credible evidence each and every such allegation made and contained

therein.

                                                  2.

                                    AMOUNT OF RECOVERY

          In addition to any other limitation under law, recovery of medical or health care expenses

incurred is limited to the amount actually paid or incurred by or on behalf of the claimant.




Little vs. Haas                                                                                PAGE 1
DEFENDANT KENNETH MARK HAAS'S ORIGINAL ANSWER
Our File Number: 0453665507.1
                                                3.

                                       JURY REQUEST

       Defendant respectfully requests a jury trial.

                                                4.

                          DESIGNATED E-SERVICE EMAIL ADDRESS

       The following is the undersigned attorney’s designation of 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). (DallasLegal@allstate.com). This is the undersigned’s ONLY

electronic service email address, and service through any other email address will be considered

invalid.

       WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff(s) take

nothing by this 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.

                                                       Respectfully submitted,

                                                       SUSAN L. FLORENCE & ASSOCIATES




                                                                                  for
                                                       DIANNE JONES MCVAY
                                                       TBN: 10010900

                                                       1201 Elm St., Suite 5050
                                                       Dallas, TX 75270-2104
                                                       DallasLegal@allstate.com
                                                       (214) 659-4366
                                                       (877) 678-4763 (fax)

                                                       ATTORNEY FOR DEFENDANT(S)
                                                       KENNETH MARK HAAS
Little vs. Haas                                                                           PAGE 2
DEFENDANT KENNETH MARK HAAS'S ORIGINAL ANSWER
Our File Number: 0453665507.1
                               CERTIFICATE OF SERVICE

       I hereby certify that a true and correct copy of the foregoing has been served in

compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 10th day of

December 2018, to:

Attorney for Plaintiff Little
John C. Wren, Esquire
Loncar Associates
424 S Cesar Chavez
Dallas TX 75201
VIA FACSIMILE: (214) 382-5838




                                                                            for
                                                DIANNE JONES MCVAY




Little vs. Haas                                                                    PAGE 3
DEFENDANT KENNETH MARK HAAS'S ORIGINAL ANSWER
Our File Number: 0453665507.1