Answer: NICOLE E. DOWNIE-FRASER vs. VALERIA SAINZ

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                                FILED
                                                                                                        DALLAS COUNTY
                                                                                                        9/14/2017 7:48 AM
                                                                                                           FELICIA PITRE
                                                                                                        DISTRICT CLERK



                                     CAUSE NO. DC-17-10220

  NICOLE E. DOWNIE-FRASER,                              IN THE DISTRICT COURT

        Plaintiff(s),

  vs.                                                   95TH JUDICIAL DISTRICT

  VALERIA SAINZ,

        Defendant(s).                                   DALLAS COUNTY, TEXAS

                        DEFENDANT VALERIA SAINZ'S ORIGINAL ANSWER

TO THE HONORABLE JUDGE OF SAID COURT:

          NOW COMES VALERIA SAINZ, 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.




Downie-Fraser vs. Sainz                                                                        PAGE 1
DEFENDANT VALERIA SAINZ'S ORIGINAL ANSWER
                                                 3.

                                        JURY REQUEST

       Defendant respectfully requests a jury trial.

       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




                                                       KAVITA BHALLA
                                                       TBN: 24080789

                                                       1201 Elm St., Suite 5050
                                                       Dallas, TX 75270-2104
                                                       DallasLegal@allstate.com
                                                       (214) 659-4352
                                                       (877) 678-4763 (fax)

                                                       ATTORNEY FOR DEFENDANT(S)
                                                       VALERIA SAINZ




Downie-Fraser vs. Sainz                                                                   PAGE 2
DEFENDANT VALERIA SAINZ'S ORIGINAL ANSWER
                                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 14th day of

September, 2017 to:

Attorney for Plaintiff Downie-Fraser
Cameron Dean, Esquire
Ben Abbott & Associates, PLLC
1934 Pendleton Dr
Garland TX 75041




                                               KAVITA BHALLA




Downie-Fraser vs. Sainz                                                            PAGE 3
DEFENDANT VALERIA SAINZ'S ORIGINAL ANSWER