On September 02, 2016 a
Jeff R Answer - ORIGINAL ANSWER - GENERAL DENIAL
was filed
involving a dispute between
Strom Aviation, Inc.,
and
Aviation Consulting Experts Inc,
J&J Robinson Ventures, L.L.C.,
Robinson Aircraft Interiors, Inc.,
Robinson, Jeffrey Wayne,
Robinson, Joe Wayne,
Wrolson, Daniel G,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
CAUSE NO. DC-16-11118
STROM AVIATION, INC. IN THE DISTRICT COURT OF
Plaintiff
JEFFREY WAYNE ROBINSON,
JOE WAYNE ROBINSON, HARBOR
AMERICA, INC. AND AVIATION
CONSULTING EXPERTS, INC.
DALLAS COUNTY, TEXAS
Defendants
OBINSON AIRCRAFT INTERIORS,
INC.,
Defendantand Third Party Plaintiff
IEL G. WROLSON
Third Party Defendant 95th JUDICIAL DISTRICT
DEFENDANT EFFREY WAYNE ROBINSON'S ANSWERTO
PLAINTIFF’S FIRST AMENDED ORIGINAL PETITION
TO THE HONORABLE COURT:
Defendant effrey Wayne Robinson files his Answer to Plaintiff’s First Amended
OriginalPetition (the “Petition”) and states as follows:
I. GENERAL DENIAL
As authorized by Rule 92 of the Texas Rules of Civil Procedure, Defendant
denies each and every, all and singular, the material allegations contained in the Petition or any
amended or supplemental petitions, and demands strict proof at the time of trial in accordance
with the Texas Rules of Civil Procedure.
EFFREY WAYNE ROBINSON'S ANSWER TO
PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE 1
II. AFFIRMATIVEDEFENSES
Without conceding that the following are in fact affirmative defenses or that Defendant
the burden of proof on the following, Defendant plead more specifically as follows:
Plaintiff’s claims are barred in whole or in part by the doctrines of waiver,
estoppel, and/or ratification.
Plaintiff’s claims are barred in whole or in part by the doctrine of unclean hands.
Plaintiff’s claims are barred in whole or in part because Plaintiff failed to mitigate
any damages it allegedly has incurred.
Plaintiff’s claims are barred, in whole or part, by set off.
Plaintiff’s claims are barred in whole or in part by the doctrine of laches.
Plaintiff’s claims are barred, in whole or in part, because Plaintiff’s damages, if
any, were caused, in whole or in part, by the acts or omissions of others, for whom Defendant
not responsible.
Plaintiff’s claims are barred, in whole or in part, because the actions or omissions
of persons, other than Defendant w intervening or supervening causes of Plaintiff’s damages, if
any.
Plaintiff’s claims are barred, in whole or in part, because other parties or unnamed
third parties are the sole proximate cause of Plaintiff’s damages, if any.
Plaintiff’s claims are barred, in whole or in part, because Plaintiff's own acts or
omissions caused or contributed to Plaintiff’sdamages , if any
Plaintiff’s claims are barred, in whole or in part, by the doctrines of legal
justification and/or privilege.
Jury Demand
Defendant hereby request that this case be tried before a jury.
EFFREY WAYNE ROBINSON'S ANSWER TO
PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE
Prayer for Relief
WHEREFORE, PREMISES CONSIDERED, Defendant respectfully request
That Strom take nothing by its Petition;
That Defendant recover reasonable and necessary attorneys’ fees incurred
in connection with this matter, and
Such other and further relief in law and in equity which the court may
deem appropriate.
Respectfully submitted,
GODWIN BOWMAN MARTINEZ
By: /s/ Carolyn R. Raines
Carolyn Raines
State Bar No. 00787852
Carolyn.Raines@GodwinLaw.com
Jenny L. Martinez
State Bar No. 24013109
Jenny.Martinez@GodwinLaw.com
Renaissance Tower
1201 Elm, Suite 1700
Dallas, Texas 75270 2084
(214) 939 Telephone
(214) 760 Facsimile
ATTORNEYS FOR DEFENDANT
EFFREY WAYNE ROBINSON
EFFREY WAYNE ROBINSON'S ANSWER TO
PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above and foregoing
document was served as indicated below upon the following counsel of record on November 7
2016, as follows:
VIA ELECTRONIC SERVICE:
Thomas E. Kurth
Debra McComas
Haynes & Boone, L.L.P.
2323 Victory Avenue, Suite 700
Dallas, Texas 75219
John R. Gavin
Lewis & Backhaus, P.C.
5501 LBJ Freeway, Suite 800
Dallas, Texas 75240
/s/ Carolyn R. Raines
Carolyn R. Raines
EFFREY WAYNE ROBINSON'S ANSWER TO
PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE
Preview
CAUSE NO. DC-16-11118 STROM AVIATION, INC. IN THE DISTRICT COURT OF Plaintiff JEFFREY WAYNE ROBINSON, JOE WAYNE ROBINSON, HARBOR AMERICA, INC. AND AVIATION CONSULTING EXPERTS, INC. DALLAS COUNTY, TEXAS Defendants OBINSON AIRCRAFT INTERIORS, INC., Defendantand Third Party Plaintiff IEL G. WROLSON Third Party Defendant 95th JUDICIAL DISTRICT DEFENDANT EFFREY WAYNE ROBINSON'S ANSWERTO PLAINTIFF’S FIRST AMENDED ORIGINAL PETITION TO THE HONORABLE COURT: Defendant effrey Wayne Robinson files his Answer to Plaintiff’s First Amended OriginalPetition (the “Petition”) and states as follows: I. GENERAL DENIAL As authorized by Rule 92 of the Texas Rules of Civil Procedure, Defendant denies each and every, all and singular, the material allegations contained in the Petition or any amended or supplemental petitions, and demands strict proof at the time of trial in accordance with the Texas Rules of Civil Procedure. EFFREY WAYNE ROBINSON'S ANSWER TO PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE 1 II. AFFIRMATIVEDEFENSES Without conceding that the following are in fact affirmative defenses or that Defendant the burden of proof on the following, Defendant plead more specifically as follows: Plaintiff’s claims are barred in whole or in part by the doctrines of waiver, estoppel, and/or ratification. Plaintiff’s claims are barred in whole or in part by the doctrine of unclean hands. Plaintiff’s claims are barred in whole or in part because Plaintiff failed to mitigate any damages it allegedly has incurred. Plaintiff’s claims are barred, in whole or part, by set off. Plaintiff’s claims are barred in whole or in part by the doctrine of laches. Plaintiff’s claims are barred, in whole or in part, because Plaintiff’s damages, if any, were caused, in whole or in part, by the acts or omissions of others, for whom Defendant not responsible. Plaintiff’s claims are barred, in whole or in part, because the actions or omissions of persons, other than Defendant w intervening or supervening causes of Plaintiff’s damages, if any. Plaintiff’s claims are barred, in whole or in part, because other parties or unnamed third parties are the sole proximate cause of Plaintiff’s damages, if any. Plaintiff’s claims are barred, in whole or in part, because Plaintiff's own acts or omissions caused or contributed to Plaintiff’sdamages , if any Plaintiff’s claims are barred, in whole or in part, by the doctrines of legal justification and/or privilege. Jury Demand Defendant hereby request that this case be tried before a jury. EFFREY WAYNE ROBINSON'S ANSWER TO PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE Prayer for Relief WHEREFORE, PREMISES CONSIDERED, Defendant respectfully request That Strom take nothing by its Petition; That Defendant recover reasonable and necessary attorneys’ fees incurred in connection with this matter, and Such other and further relief in law and in equity which the court may deem appropriate. Respectfully submitted, GODWIN BOWMAN MARTINEZ By: /s/ Carolyn R. Raines Carolyn Raines State Bar No. 00787852 Carolyn.Raines@GodwinLaw.com Jenny L. Martinez State Bar No. 24013109 Jenny.Martinez@GodwinLaw.com Renaissance Tower 1201 Elm, Suite 1700 Dallas, Texas 75270 2084 (214) 939 Telephone (214) 760 Facsimile ATTORNEYS FOR DEFENDANT EFFREY WAYNE ROBINSON EFFREY WAYNE ROBINSON'S ANSWER TO PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above and foregoing document was served as indicated below upon the following counsel of record on November 7 2016, as follows: VIA ELECTRONIC SERVICE: Thomas E. Kurth Debra McComas Haynes & Boone, L.L.P. 2323 Victory Avenue, Suite 700 Dallas, Texas 75219 John R. Gavin Lewis & Backhaus, P.C. 5501 LBJ Freeway, Suite 800 Dallas, Texas 75240 /s/ Carolyn R. Raines Carolyn R. Raines EFFREY WAYNE ROBINSON'S ANSWER TO PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION PAGE