On June 24, 2015 a
Answer
was filed
involving a dispute between
Doe I, John,
and
Anderson, Alexander A.,
Anderson, Levonna C.,
Anderson, William C.,
The Anderson Private School,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
JURY DEMAND 7/13/2015 3:05:22 PM
FELICIA PITRE
DISTRICT CLERK
Christi Underwood
CAUSE NO DC-15-07174
JOHN DOE I, INDIVIDUALLY AND AS NEXT ' IN THE DISTRICT COURT
FRIEND OF JOHN DOE II, A MINOR '
'
Plaintiffs, '
'
VS. ' DALLAS COUNTY, TEXAS
'
THE ANDERSON PRIVATE SCHOOL, WILLIAM
C. ANDERSON, INDIVIDUALLY, LEVONNA C.'
ANDERSON, INDIVIDUALLY, ALEXANDER A '
ANDERSON, INDIVIDUALLY, RIPLEY '
ENTERTAINMENT, INC. AND JIM PATTISON '
U.S.A., INC. '
'
Defendants. ' 44TH JUDICIAL DISTRICT
DEFENDANTS ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Ripley Entertainment, Inc., Defendant in the above styled and numbered
cause and files this its Original Answer to the Plaintiffs’ Original Petition and in support thereof
would respectfully represent and show unto the Court the following:
I. GENERAL DENIAL
1. Defendant denies each and every, all and singular, the material allegations contained in
Plaintiffs’ Original Petition and demands strict proof thereof.
II. NOTICE OF INTENT
Defendant hereby gives
notice of intent to utilize items produced in discovery in the trial of this matter and the authenticity
of such items is self-proven per the Texas Rules of Civil Procedure, 193.7.
III. JURY DEMAND
2. Defendant demands a trial by jury.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that upon final trial and
hearing hereof, that no recovery be had from Defendant and Defendant go hence without day and
recover their costs, and for such other and further relief to which Defendants may be justly
entitled and will ever pray.
Respectfully submitted,
WALTERS, BALIDO & CRAIN, L.L.P.
/s/: S. Todd Parks
BY: ___________________________________
S. TODD PARKS - 15526520
todd.parks@wbclawfirm.com
Service of Documents:
ParksEDocsNotifications@wbclawfirm.com
Meadow Park Tower, Suite 1500
10440 North Central Expressway
Dallas, Texas 75231
Phone No. 214/749-4805
Fax No. 214/760-1670
ATTORNEY FOR DEFENDANT RIPLEY
ENTERTAINMENT, INC.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served upon
all parties of record as follows on this the 13th day of July, 2015:
John Sloan Via Email: jsloan@sloanmatney.com
SLOAN MATNEY, LLP Via Fax: 214.237.5474
3838 Oak Lawn Ave., Suite 1200
Dallas, TX 75219
/s/: S. Todd Parks
___________________________________
S. TODD PARKS
DEFENDANT’S ORIGINAL ANSWER PAGE 2
Document Filed Date
July 13, 2015
Case Filing Date
June 24, 2015
Category
OTHER PERSONAL INJURY
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FILED DALLAS COUNTY JURY DEMAND 7/13/2015 3:05:22 PM FELICIA PITRE DISTRICT CLERK Christi Underwood CAUSE NO DC-15-07174 JOHN DOE I, INDIVIDUALLY AND AS NEXT ' IN THE DISTRICT COURT FRIEND OF JOHN DOE II, A MINOR ' ' Plaintiffs, ' ' VS. ' DALLAS COUNTY, TEXAS ' THE ANDERSON PRIVATE SCHOOL, WILLIAM C. ANDERSON, INDIVIDUALLY, LEVONNA C.' ANDERSON, INDIVIDUALLY, ALEXANDER A ' ANDERSON, INDIVIDUALLY, RIPLEY ' ENTERTAINMENT, INC. AND JIM PATTISON ' U.S.A., INC. ' ' Defendants. ' 44TH JUDICIAL DISTRICT DEFENDANTS ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Ripley Entertainment, Inc., Defendant in the above styled and numbered cause and files this its Original Answer to the Plaintiffs’ Original Petition and in support thereof would respectfully represent and show unto the Court the following: I. GENERAL DENIAL 1. Defendant denies each and every, all and singular, the material allegations contained in Plaintiffs’ Original Petition and demands strict proof thereof. II. NOTICE OF INTENT Defendant hereby gives notice of intent to utilize items produced in discovery in the trial of this matter and the authenticity of such items is self-proven per the Texas Rules of Civil Procedure, 193.7. III. JURY DEMAND 2. Defendant demands a trial by jury. WHEREFORE, PREMISES CONSIDERED, Defendant prays that upon final trial and hearing hereof, that no recovery be had from Defendant and Defendant go hence without day and recover their costs, and for such other and further relief to which Defendants may be justly entitled and will ever pray. Respectfully submitted, WALTERS, BALIDO & CRAIN, L.L.P. /s/: S. Todd Parks BY: ___________________________________ S. TODD PARKS - 15526520 todd.parks@wbclawfirm.com Service of Documents: ParksEDocsNotifications@wbclawfirm.com Meadow Park Tower, Suite 1500 10440 North Central Expressway Dallas, Texas 75231 Phone No. 214/749-4805 Fax No. 214/760-1670 ATTORNEY FOR DEFENDANT RIPLEY ENTERTAINMENT, INC. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served upon all parties of record as follows on this the 13th day of July, 2015: John Sloan Via Email: jsloan@sloanmatney.com SLOAN MATNEY, LLP Via Fax: 214.237.5474 3838 Oak Lawn Ave., Suite 1200 Dallas, TX 75219 /s/: S. Todd Parks ___________________________________ S. TODD PARKS DEFENDANT’S ORIGINAL ANSWER PAGE 2