On May 06, 2005 a
Answer
was filed
involving a dispute between
Martin, Frederick,
Martin, Melayne,
and
Bohls, Aaron,
Whanger, Jeffrey,
for DAMAGES (OTH)
in the District Court of Harris County.
Preview
te
~ ~ PL
¥
CAUSE NO. 2005-31134 ao
<
FREDRICK MARTIN, ET AL. IN THE DISTRICT COURT of 22
5z
vs. HARRIS COUNTY, T
Ss
JEFFERY WHANGER AND =
x ae
AARON BOHLS 189 JUDICIAL DISTRECT
DEFENDANT'S FIRST AMENDED ANSWER : 10406
TO THE HONORABLE JUDGE OF THIS COURT:
AARON odes, Defendant, files this First Amended Answer,
and would show the following:
I.
Defendant, denies each and every allegation in Plaintiff's
Original Petition and demands strict proof by a preponderance of
the evidence.
Il.
Defendant further affirmatively alleges that the
Plaintiffs’ causes of action, if any, are barred by Texas Civil
Practice and Remedies Code §16.003(a), establishing a two-year
limitation period. The cause of action is one for personal
injury. The limitation period commenced running on May 8, 2003.
Plaintiffs’ petition was not filed until after May 8, 2005.
Plaintiffs did not exercise due diligence in suing and serving
Defendant.
WHEREFORE, Defendant requests judgment of the Court that
Plaintiff take nothing by this suit, and that defendant recover
RECORDER'S MEMORANDUM
is Poor quality
atthe time of imaging
—
~ “n
”
w rn
all costs together with such other and further relief to which
defendant may be justly entitled.
Respectfully submitt a,
IVIER & DY, L .P
if (
LAA
eo
D. Craig ivi
st te Bar No. 8300
Jaha O Saling
St te Bar No. } 68600
14144 West Clay
Hou ton, Texas 77019
7134751-1818
713-751-1817 fax
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the
above and foregoing instrument has been forwarded to
opposing counsel by U.S. Mail, Certified, Return Receipt
.
Req Maat Hand-Delivery and/or transpittal, on this
the day of February, 2096
A
Jan oO. Sa
Document Filed Date
February 23, 2006
Case Filing Date
May 06, 2005
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te ~ ~ PL ¥ CAUSE NO. 2005-31134 ao < FREDRICK MARTIN, ET AL. IN THE DISTRICT COURT of 22 5z vs. HARRIS COUNTY, T Ss JEFFERY WHANGER AND = x ae AARON BOHLS 189 JUDICIAL DISTRECT DEFENDANT'S FIRST AMENDED ANSWER : 10406 TO THE HONORABLE JUDGE OF THIS COURT: AARON odes, Defendant, files this First Amended Answer, and would show the following: I. Defendant, denies each and every allegation in Plaintiff's Original Petition and demands strict proof by a preponderance of the evidence. Il. Defendant further affirmatively alleges that the Plaintiffs’ causes of action, if any, are barred by Texas Civil Practice and Remedies Code §16.003(a), establishing a two-year limitation period. The cause of action is one for personal injury. The limitation period commenced running on May 8, 2003. Plaintiffs’ petition was not filed until after May 8, 2005. Plaintiffs did not exercise due diligence in suing and serving Defendant. WHEREFORE, Defendant requests judgment of the Court that Plaintiff take nothing by this suit, and that defendant recover RECORDER'S MEMORANDUM is Poor quality atthe time of imaging — ~ “n ” w rn all costs together with such other and further relief to which defendant may be justly entitled. Respectfully submitt a, IVIER & DY, L .P if ( LAA eo D. Craig ivi st te Bar No. 8300 Jaha O Saling St te Bar No. } 68600 14144 West Clay Hou ton, Texas 77019 7134751-1818 713-751-1817 fax CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument has been forwarded to opposing counsel by U.S. Mail, Certified, Return Receipt . Req Maat Hand-Delivery and/or transpittal, on this the day of February, 2096 A Jan oO. Sa