On February 17, 2022 a
Answer
was filed
involving a dispute between
Turcios, Cleofes Jose,
and
Trinh, Tony,
Trinh, Trinh,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
4/8/2022 3:04 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jeremy Jones DEPUTY
CAUSE NO. DC-22-01952
CLEOFES JOSE TURCIOS, IN THE DISTRICT COURT
Plaintiff,
VS. 192ND JUDICIAL DISTRICT
TONY TRINH AND TRINH TRINH,
Defendants. DALLAS COUNTY, TEXAS
DEFENDANT. TONY TRINH'S. ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES TONY TRINH, 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.
Turcios vs. Trinh, et a1. PAGE 1
DEFENDANT TONY TRINH'S ORIGINAL ANSWER
Our File Number: 0580492874.1
3.
JURY RE UEST
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). (DallasLega1@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.
Respectfiilly submitted,
LISA CHASTAIN & ASSOCIATES
71251th
TESCH E. USSERY
TBN: 24115886
P.O. Box 655441
Dallas, TX 75265
E-Service Only: DallasLegal@allstate.com
(817) 247-8009
(877) 678-4763 (fax)
ATTORNEY FOR DEFENDANT(S)
TONY TRINH
Turcios vs. Trinh, et a1. PAGE 2
DEFENDANT TONY TRINH'S ORIGINAL ANSWER
Our File Number: 0580492874.1
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 8th day of April, 2022, to:
David S. Kohm
David S. Kohm & Associates
1414 W. Randol Mill Rd., Ste. 118
Arlington, Texas 76012
lit-efile@attorneykohm.com
Attorney for Plaintiff
#UMJm/lkwwb/
TESCH E. USSERY
Turcios vs. Trinh, et a1. PAGE 3
DEFENDANT TONY TRINH'S ORIGINAL ANSWER
Our File Number: 05804928741
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.
Lilibeth Jaramillo on behalf of Tesch Ussery
Bar No. 24115886
ljara@allstate.com
Envelope ID: 63413010
Status as of 4/1 1/2022 11:19 AM CST
Associated Case Party: CLEOFESJOSETURCIOS
Name BarNumber Email TimestampSubmitted Status
David Kohm 1 1658563 lit-efile@attorneykohm.com 4/8/2022 3:04:38 PM SENT
Document Filed Date
April 08, 2022
Case Filing Date
February 17, 2022
Category
MOTOR VEHICLE ACCIDENT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 4/8/2022 3:04 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jeremy Jones DEPUTY CAUSE NO. DC-22-01952 CLEOFES JOSE TURCIOS, IN THE DISTRICT COURT Plaintiff, VS. 192ND JUDICIAL DISTRICT TONY TRINH AND TRINH TRINH, Defendants. DALLAS COUNTY, TEXAS DEFENDANT. TONY TRINH'S. ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES TONY TRINH, 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. Turcios vs. Trinh, et a1. PAGE 1 DEFENDANT TONY TRINH'S ORIGINAL ANSWER Our File Number: 0580492874.1 3. JURY RE UEST 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). (DallasLega1@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. Respectfiilly submitted, LISA CHASTAIN & ASSOCIATES 71251th TESCH E. USSERY TBN: 24115886 P.O. Box 655441 Dallas, TX 75265 E-Service Only: DallasLegal@allstate.com (817) 247-8009 (877) 678-4763 (fax) ATTORNEY FOR DEFENDANT(S) TONY TRINH Turcios vs. Trinh, et a1. PAGE 2 DEFENDANT TONY TRINH'S ORIGINAL ANSWER Our File Number: 0580492874.1 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 8th day of April, 2022, to: David S. Kohm David S. Kohm & Associates 1414 W. Randol Mill Rd., Ste. 118 Arlington, Texas 76012 lit-efile@attorneykohm.com Attorney for Plaintiff #UMJm/lkwwb/ TESCH E. USSERY Turcios vs. Trinh, et a1. PAGE 3 DEFENDANT TONY TRINH'S ORIGINAL ANSWER Our File Number: 05804928741 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. Lilibeth Jaramillo on behalf of Tesch Ussery Bar No. 24115886 ljara@allstate.com Envelope ID: 63413010 Status as of 4/1 1/2022 11:19 AM CST Associated Case Party: CLEOFESJOSETURCIOS Name BarNumber Email TimestampSubmitted Status David Kohm 1 1658563 lit-efile@attorneykohm.com 4/8/2022 3:04:38 PM SENT