On August 02, 2019 a
Answer
was filed
involving a dispute between
Rhodes, Vashone,
and
Exclusive Nationwide Delivery, Inc,
Gomez, James,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
6/10/2020 1:21 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
Cause N0. DC-19-10926
Vashone Rhodes § In the District Court of
Plaintiff § Dallas County, Texas
vs. 160th District Court
§
James Gomez §
To the Honorable Judge of Said Court-
Comes now Exclusive Nationwide Delivery, Inc, Defendant and files this Original Answer to Plaintiffs
Amended Petition and would show as follows:
First
1. Defendant specifically denies and invokes TEX. CIV. Prac & REM Code § 41 .005 Which
provides the recovery 0f medical 0r health care expenses incurred are limited to the amount
actually paid or incurred by or on behalf 0f the Plaintiff.
2. Defendant further alleges that Plaintiff s claims for pre—judgment and post-judgment interest are
limited by dates and amounts set forth in TEX. FIN. Code § 304.
3. Defendant denies that it has committed any acts 0r omissions Which would justify Plaintiff’ s
claims for gross negligence 0r exemplary or punitive damages. Defendant alleges that if
exemplary damages are awarded that it is by TEX. CIV. Prac & REM Code § 41.007.
limited
Wherefore premises considered Defendant prays upon trial hereof, Plaintiff take nothing,
that
Defendant recover its costs, and such other and further relief Which Defendant may be entitled in
law 0r equity.
4. Defendant generally denies all causes of action and demands strict proof thereon by a
preponderance 0f the evidence as set forth in TEX. Rule of Civil Procedure 92.
Respectfully submitted,
/s/ Craig Laird
By: Craig Laird
SBN: 11795420
800 W. Airport Freeway
Suite 800, L.B. 6015
Irving, TX 75062
(972) 554-0929
(214) 260—4935 Fax
PCL@LAIRD.LAWYER
Attorney for Defendant
Exclusive Nationwide Delivery, Inc
Certificate of Service
9th
This is to certify that on the day 0f June, 2020 the foregoing Original Answer was served 0n
all counsel 0f record through the e-file system.
/s/ Crai Laird
By: Craig Laird
Document Filed Date
June 10, 2020
Case Filing Date
August 02, 2019
Category
MOTOR VEHICLE ACCIDENT
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FILED 6/10/2020 1:21 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY Cause N0. DC-19-10926 Vashone Rhodes § In the District Court of Plaintiff § Dallas County, Texas vs. 160th District Court § James Gomez § To the Honorable Judge of Said Court- Comes now Exclusive Nationwide Delivery, Inc, Defendant and files this Original Answer to Plaintiffs Amended Petition and would show as follows: First 1. Defendant specifically denies and invokes TEX. CIV. Prac & REM Code § 41 .005 Which provides the recovery 0f medical 0r health care expenses incurred are limited to the amount actually paid or incurred by or on behalf 0f the Plaintiff. 2. Defendant further alleges that Plaintiff s claims for pre—judgment and post-judgment interest are limited by dates and amounts set forth in TEX. FIN. Code § 304. 3. Defendant denies that it has committed any acts 0r omissions Which would justify Plaintiff’ s claims for gross negligence 0r exemplary or punitive damages. Defendant alleges that if exemplary damages are awarded that it is by TEX. CIV. Prac & REM Code § 41.007. limited Wherefore premises considered Defendant prays upon trial hereof, Plaintiff take nothing, that Defendant recover its costs, and such other and further relief Which Defendant may be entitled in law 0r equity. 4. Defendant generally denies all causes of action and demands strict proof thereon by a preponderance 0f the evidence as set forth in TEX. Rule of Civil Procedure 92. Respectfully submitted, /s/ Craig Laird By: Craig Laird SBN: 11795420 800 W. Airport Freeway Suite 800, L.B. 6015 Irving, TX 75062 (972) 554-0929 (214) 260—4935 Fax PCL@LAIRD.LAWYER Attorney for Defendant Exclusive Nationwide Delivery, Inc Certificate of Service 9th This is to certify that on the day 0f June, 2020 the foregoing Original Answer was served 0n all counsel 0f record through the e-file system. /s/ Crai Laird By: Craig Laird