On May 16, 2024 a
Answer
was filed
involving a dispute between
Martinez, Alma E.,
and
Crt Logistics Tx, Llc,
Espinosa Reyes, Jonathan I.,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
1/29/2024 8:45 AM
Hidalgo County Clerk
Accepted by: Alejandra Lara
C-2302-24-E
17195
CAUSE NO. CL-23-4789-B
ALMA E. MARTINEZ § IN THE COUNTY COURT
Plaintiff, §
§
v. § ATLAWNO.2
§
JONATHAN I. ESPINOZA REYES, §
AND CTR LOGISTICS TX, LLC §
Defendants. § HIDALGO COUNTY, TEXAS
DEFENDANTS'ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW CTR LOGISTICS TX, LLC and JONATHAN I. ESPINOZA REYES,
Defendants named in the above entitled and numbered cause, and file this their Original Answer,
and for same would respectfully show unto the Court as follows:
I.
GENERAL DENIAL
Defendants deny each and every, all and singular, the material allegations contained within
Plaintiffs pleadings and demands strict proof thereof.
u.
OBJECTION TO RULE 193.7 NOTICE
Defendants object to these attempts to authenticate "all documents produced" by given a
general notice, rather than notice of what particular documents they intend to use, on the grounds
that it is not sufficient actual notice as required by Rule 193.7 of the Texas Rules of Civil
Procedure. Without knowledge of what specific documents these parties intend to use at the trial,
Defendants are handicapped in their defense and their ability to legally object.
DEFENDANTS' ORIGINAL ANSWER Page 1
Electronically Submitted
1/29/2024 8:45 AM
Hidalgo County Clerk
Accepted by: Alejandra Lara
III.
JURY DEMAND
In accordance with Rule 216 of the Texas Rules of Civil Procedure, Defendants demand a
trial by jury. Simultaneously with the filing of this demand, a jury fee is being paid on behalf of
Defendants.
WHEREFORE, PREMISES CONSIDERED, Defendants CTR LOGISTICS TX,
LLC and JONATHAN I. ESPINOZA REYES pray that the Plaintiff takes nothing by this suit,
that Defendants go hence with their costs without delay, and for such other and further relief, both
general and special, at law and in equity, to which Defendants may show himself justly entitled.
Respectfully submitted,
State Bar No.
5301 Southwest Parkway, Suite 460
Austin, Texas 78735
512-4 79-8400
512-479-8402 [Fax]
bsanders@.feesmith.com
ATTORNEY FOR DEFENDANT
CTR LOGISTICS TX, LLC AND
JONATHAN I. ESPINOZA REYES
DEFENDANTS' ORIGINAL ANSWER Page2
Electronically Electronically
Filed Submitted
1/29/2024 8:45 AM
Hidalgo County Clerk
Accepted by: Alejandra Lara
CERTIFICATE OF SERVICE
THIS WILL CERTIFY that a true and correct copy of the foregoing instrument has been served
on all attorneys of record in this cause of action on the 29th day of January 2024.
Via E-File
Manuel Guerra, III
Guerra Law Firm
320 Pecan Blvd
McAllen, Texas 78501
Manuel@guerralwfirm.net
ATTORNEYS FOR PLAINTIFF
DEFENDANTS' ORIGINAL ANSWER Page3
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.
Rocio Lozano on behalf of Bret Sanders
Bar No. 24033152
rlozano@feesmith.com
Envelope ID: 83875219
Filing Code Description: Answer/Response
Filing Description: 2024-01-29 Defendants' Original Answer
Status as of 1/29/2024 9:35 AM CST
Associated Case Party: ALMAE.MARTINEZ
Name BarNumber Email TimestampSubmitted Status
MANUEL GUERRA III manuel@guerralawfirm.net 1/29/2024 8:45:37 AM SENT
Andrew Coward andrew@guerralawfirm.net 1/29/2024 8:45:37 AM SENT
Cindy Leal cindy@glf-pc.com 1/29/2024 8:45:37 AM SENT
Associated Case Party: CRT LOGISTICS TX, LLC
Name BarNumber Email TimestampSubmitted Status
Bret A.Sanders bsanders@feesmith.com 1/29/2024 8:45:37 AM SENT
Rocio Lozano rlozano@feesmith.com 1/29/2024 8:45:37 AM SENT
Eva Castaneda ecastaneda@feesmith.com 1/29/2024 8:45:37 AM SENT
John Plumlee jplumlee@feesmith.com 1/29/2024 8:45:37 AM SENT
Diana Price dprice@feesmith.com 1/29/2024 8:45:37 AM SENT
Document Filed Date
May 16, 2024
Case Filing Date
May 16, 2024
Category
Injury or Damage - Motor Vehicle (OCA)
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Electronically Submitted 1/29/2024 8:45 AM Hidalgo County Clerk Accepted by: Alejandra Lara C-2302-24-E 17195 CAUSE NO. CL-23-4789-B ALMA E. MARTINEZ § IN THE COUNTY COURT Plaintiff, § § v. § ATLAWNO.2 § JONATHAN I. ESPINOZA REYES, § AND CTR LOGISTICS TX, LLC § Defendants. § HIDALGO COUNTY, TEXAS DEFENDANTS'ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COME NOW CTR LOGISTICS TX, LLC and JONATHAN I. ESPINOZA REYES, Defendants named in the above entitled and numbered cause, and file this their Original Answer, and for same would respectfully show unto the Court as follows: I. GENERAL DENIAL Defendants deny each and every, all and singular, the material allegations contained within Plaintiffs pleadings and demands strict proof thereof. u. OBJECTION TO RULE 193.7 NOTICE Defendants object to these attempts to authenticate "all documents produced" by given a general notice, rather than notice of what particular documents they intend to use, on the grounds that it is not sufficient actual notice as required by Rule 193.7 of the Texas Rules of Civil Procedure. Without knowledge of what specific documents these parties intend to use at the trial, Defendants are handicapped in their defense and their ability to legally object. DEFENDANTS' ORIGINAL ANSWER Page 1 Electronically Submitted 1/29/2024 8:45 AM Hidalgo County Clerk Accepted by: Alejandra Lara III. JURY DEMAND In accordance with Rule 216 of the Texas Rules of Civil Procedure, Defendants demand a trial by jury. Simultaneously with the filing of this demand, a jury fee is being paid on behalf of Defendants. WHEREFORE, PREMISES CONSIDERED, Defendants CTR LOGISTICS TX, LLC and JONATHAN I. ESPINOZA REYES pray that the Plaintiff takes nothing by this suit, that Defendants go hence with their costs without delay, and for such other and further relief, both general and special, at law and in equity, to which Defendants may show himself justly entitled. Respectfully submitted, State Bar No. 5301 Southwest Parkway, Suite 460 Austin, Texas 78735 512-4 79-8400 512-479-8402 [Fax] bsanders@.feesmith.com ATTORNEY FOR DEFENDANT CTR LOGISTICS TX, LLC AND JONATHAN I. ESPINOZA REYES DEFENDANTS' ORIGINAL ANSWER Page2 Electronically Electronically Filed Submitted 1/29/2024 8:45 AM Hidalgo County Clerk Accepted by: Alejandra Lara CERTIFICATE OF SERVICE THIS WILL CERTIFY that a true and correct copy of the foregoing instrument has been served on all attorneys of record in this cause of action on the 29th day of January 2024. Via E-File Manuel Guerra, III Guerra Law Firm 320 Pecan Blvd McAllen, Texas 78501 Manuel@guerralwfirm.net ATTORNEYS FOR PLAINTIFF DEFENDANTS' ORIGINAL ANSWER Page3 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. Rocio Lozano on behalf of Bret Sanders Bar No. 24033152 rlozano@feesmith.com Envelope ID: 83875219 Filing Code Description: Answer/Response Filing Description: 2024-01-29 Defendants' Original Answer Status as of 1/29/2024 9:35 AM CST Associated Case Party: ALMAE.MARTINEZ Name BarNumber Email TimestampSubmitted Status MANUEL GUERRA III manuel@guerralawfirm.net 1/29/2024 8:45:37 AM SENT Andrew Coward andrew@guerralawfirm.net 1/29/2024 8:45:37 AM SENT Cindy Leal cindy@glf-pc.com 1/29/2024 8:45:37 AM SENT Associated Case Party: CRT LOGISTICS TX, LLC Name BarNumber Email TimestampSubmitted Status Bret A.Sanders bsanders@feesmith.com 1/29/2024 8:45:37 AM SENT Rocio Lozano rlozano@feesmith.com 1/29/2024 8:45:37 AM SENT Eva Castaneda ecastaneda@feesmith.com 1/29/2024 8:45:37 AM SENT John Plumlee jplumlee@feesmith.com 1/29/2024 8:45:37 AM SENT Diana Price dprice@feesmith.com 1/29/2024 8:45:37 AM SENT