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FILED
3/3/2023 9:26 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kellie Juricek DEPUTY
CAUSE NO. DC-23-00125
CENTRE DEVELOPMENT CO., INC., § IN THE DISTRICT COURT
§
Plaintiff, §
§
V. § OF DALLAS COUNTY, TEXAS
§
RENAISSANCE PRECAST, INC. d/b/a §
RENAISSANCE CAST STONE, 1NC., §
RUSSELL J. RIEMAN, and MELISSA P. §
RIEMAN, §
§
Defendants. § 68TH JUDICML DISTRICT
DEFENDANTS RENAISSANCE PRECAST, INC.
AND MELISSA P. REIMAN’S ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Defendants Renaissance Precast, Inc.1 and Melissa P. Rieman (hereinafter
“Defendants”), and would respectfully show the following:
I. GENERAL DENIAL
Pursuant to TEX. R. CIV. P. 92, Defendants deny each and every allegation asserted in
Plaintiff s Original Petition (the “Petition”) and demand that Plaintiff be required to present strict
proof of all of its claims and allegations in the Petition and to establish its claims by a
preponderance of the evidence or by clear and convincing evidence submitted to the Court as the
law requires.
1
Plaintiff sued Defendant Renaissance Precast, Inc. as “d/b/a Renaissance Cast Stone, Inc.” Defendant Renaissance
Precast, Inc. formerly did business as “Renaissance Cast Stone, Inc.” but changed its name officially to Defendant
Renaissance Precast, Inc.. As such, although correctly identified, Defendant Renaissance Precast, Inc. denies such a
d/b/a under Tex. R. Civ. P. 92 and 93 as necessary.
DEFENDANTS RENAISSANCE PRECAST, INC.
AND MELISSA P. REIMAN’S ORIGINAL ANSWER PAGE 1
II. VERIFIED DENIAL
Pursuant to TEX. R. CIV. P. 93, Plaintiff sued Defendant Renaissance Precast, Inc. as “d/b/a
Renaissance Cast Stone, Inc.” Defendant Renaissance Precast, Inc. formerly did business as
“Renaissance Cast Stone, Inc.” but changed its name officially to Defendant Renaissance Precast,
Inc. As such, although correctly identified, Defendant Renaissance Precast, Inc. denies such a
d/b/a as necessary.
III. AFFIRMATIVE DEFENSES
Pursuant to TEX. R. CIV. P. 94, as affirmative defenses to Plaintiff’s claims, Defendants
assert the following affirmative defenses:
l. Failure to mitigate.
2. Wear and tear and/or ordinary wear and tear.
Payment.
Accord and satisfaction and/or novation.
Waiver.
Acceptance of consideration.
III. PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendants respectfully pray that Plaintiff
take nothing by reason of its claims in this lawsuit, that the claims asserted against Defendants be
dismissed with prejudice, and that Defendants be awarded costs of court, and such other and fiIrther
relief to which they may be justly entitled.
DEFENDANTS RENAISSANCE PRECAST, INC.
AND MELISSA P. REIMAN’S ORIGINAL ANSWER PAGE 2
Respectfully Submitted,
AYRES LAW OFFICE, P.C.
By: /s/ Christopher S. Avres
CHRISTOPHER S. AYRES
State Bar No. 24036167
csayres@ayreslawoffice.com
R. JACK AYRES, JR.
State Bar No. 01473000
1jayres@ayreslawoffice.com
One Glen Lakes Tower
8140 Walnut Hill Lane, Suite 830
Dallas, Texas 75231
972-991-2222
972-386-0091 (Fax)
ATTORNEYS FOR DEFENDANTS
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing pleading was
forwarded to all registered counsel Via the Court’s electronic filing system on the date and time of its
submission.
/s/ Christopher S. Ayres
CHRISTOPHER S. AYRES
DEFENDANTS RENAISSANCE PRECAST, INC.
AND MELISSA P. REIMAN’S ORIGINAL ANSWER PAGE 3
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.
Debbie Whatley on behalf of Christopher Ayres
Bar No. 24036167
dwhatley@ayreslawoffice.com
Envelope ID: 73307627
Status as of 3/3/2023 9:30 AM CST
Associated Case Party: CENTRE DEVELOPMENT CO., INC.
Name BarNumber Email TimestampSubmitted Status
Kevin Moran kevin@theholmesfirm.com 3/3/2023 9:26:56 AM SENT
JD Reed jd@theholmesfirm.com 3/3/2023 9:26:56 AM SENT
Grace Burris grace@theholmesfirm.com 3/3/2023 9:26:56 AM SENT
Sean Scribner sean@theholmesfirm.com 3/3/2023 9:26:56 AM SENT
Taylor Bell taylor@theholmesfirm.com 3/3/2023 9:26:56 AM SENT
Associated Case Party: RENAISSANCE PRECAST, INC.
Name BarNumber Email TimestampSubmitted Status
Debbie Whatley fiIings@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT
Christopher Ayres csayres@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT
Associated Case Party: RUSSELL RIEMAN
Name BarNumber Email TimestampSubmitted Status
Debbie Whatley fiIings@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT
Christopher Ayres csayres@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT
Associated Case Party: MELISSA RIEMAN
Name BarNumber Email TimestampSubmitted Status
Debbie Whatley fiIings@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT
Christopher Ayres csayres@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT
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FILED 3/3/2023 9:26 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kellie Juricek DEPUTY CAUSE NO. DC-23-00125 CENTRE DEVELOPMENT CO., INC., § IN THE DISTRICT COURT § Plaintiff, § § V. § OF DALLAS COUNTY, TEXAS § RENAISSANCE PRECAST, INC. d/b/a § RENAISSANCE CAST STONE, 1NC., § RUSSELL J. RIEMAN, and MELISSA P. § RIEMAN, § § Defendants. § 68TH JUDICML DISTRICT DEFENDANTS RENAISSANCE PRECAST, INC. AND MELISSA P. REIMAN’S ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Defendants Renaissance Precast, Inc.1 and Melissa P. Rieman (hereinafter “Defendants”), and would respectfully show the following: I. GENERAL DENIAL Pursuant to TEX. R. CIV. P. 92, Defendants deny each and every allegation asserted in Plaintiff s Original Petition (the “Petition”) and demand that Plaintiff be required to present strict proof of all of its claims and allegations in the Petition and to establish its claims by a preponderance of the evidence or by clear and convincing evidence submitted to the Court as the law requires. 1 Plaintiff sued Defendant Renaissance Precast, Inc. as “d/b/a Renaissance Cast Stone, Inc.” Defendant Renaissance Precast, Inc. formerly did business as “Renaissance Cast Stone, Inc.” but changed its name officially to Defendant Renaissance Precast, Inc.. As such, although correctly identified, Defendant Renaissance Precast, Inc. denies such a d/b/a under Tex. R. Civ. P. 92 and 93 as necessary. DEFENDANTS RENAISSANCE PRECAST, INC. AND MELISSA P. REIMAN’S ORIGINAL ANSWER PAGE 1 II. VERIFIED DENIAL Pursuant to TEX. R. CIV. P. 93, Plaintiff sued Defendant Renaissance Precast, Inc. as “d/b/a Renaissance Cast Stone, Inc.” Defendant Renaissance Precast, Inc. formerly did business as “Renaissance Cast Stone, Inc.” but changed its name officially to Defendant Renaissance Precast, Inc. As such, although correctly identified, Defendant Renaissance Precast, Inc. denies such a d/b/a as necessary. III. AFFIRMATIVE DEFENSES Pursuant to TEX. R. CIV. P. 94, as affirmative defenses to Plaintiff’s claims, Defendants assert the following affirmative defenses: l. Failure to mitigate. 2. Wear and tear and/or ordinary wear and tear. Payment. Accord and satisfaction and/or novation. Waiver. Acceptance of consideration. III. PRAYER WHEREFORE, PREMISES CONSIDERED, Defendants respectfully pray that Plaintiff take nothing by reason of its claims in this lawsuit, that the claims asserted against Defendants be dismissed with prejudice, and that Defendants be awarded costs of court, and such other and fiIrther relief to which they may be justly entitled. DEFENDANTS RENAISSANCE PRECAST, INC. AND MELISSA P. REIMAN’S ORIGINAL ANSWER PAGE 2 Respectfully Submitted, AYRES LAW OFFICE, P.C. By: /s/ Christopher S. Avres CHRISTOPHER S. AYRES State Bar No. 24036167 csayres@ayreslawoffice.com R. JACK AYRES, JR. State Bar No. 01473000 1jayres@ayreslawoffice.com One Glen Lakes Tower 8140 Walnut Hill Lane, Suite 830 Dallas, Texas 75231 972-991-2222 972-386-0091 (Fax) ATTORNEYS FOR DEFENDANTS CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing pleading was forwarded to all registered counsel Via the Court’s electronic filing system on the date and time of its submission. /s/ Christopher S. Ayres CHRISTOPHER S. AYRES DEFENDANTS RENAISSANCE PRECAST, INC. AND MELISSA P. REIMAN’S ORIGINAL ANSWER PAGE 3 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. Debbie Whatley on behalf of Christopher Ayres Bar No. 24036167 dwhatley@ayreslawoffice.com Envelope ID: 73307627 Status as of 3/3/2023 9:30 AM CST Associated Case Party: CENTRE DEVELOPMENT CO., INC. Name BarNumber Email TimestampSubmitted Status Kevin Moran kevin@theholmesfirm.com 3/3/2023 9:26:56 AM SENT JD Reed jd@theholmesfirm.com 3/3/2023 9:26:56 AM SENT Grace Burris grace@theholmesfirm.com 3/3/2023 9:26:56 AM SENT Sean Scribner sean@theholmesfirm.com 3/3/2023 9:26:56 AM SENT Taylor Bell taylor@theholmesfirm.com 3/3/2023 9:26:56 AM SENT Associated Case Party: RENAISSANCE PRECAST, INC. Name BarNumber Email TimestampSubmitted Status Debbie Whatley fiIings@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT Christopher Ayres csayres@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT Associated Case Party: RUSSELL RIEMAN Name BarNumber Email TimestampSubmitted Status Debbie Whatley fiIings@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT Christopher Ayres csayres@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT Associated Case Party: MELISSA RIEMAN Name BarNumber Email TimestampSubmitted Status Debbie Whatley fiIings@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT Christopher Ayres csayres@ayreslawoffice.com 3/3/2023 9:26:56 AM SENT