On December 16, 2004 a
Answer
was filed
involving a dispute between
Gutierrez, Frank (Ind And As Representative Of The Estate Of Theresa,
Gutierrez, Michelle,
Gutirrez, Amanda,
Gutirrez, Frank Jr,
Gutirrez, Michelle,
Ramirez, Patricia,
and
Demain,
Doe, John,
Duremdes, Fulgencio P,
Memorial Hermann Hospital System,
Moore, Frederick,
University Of Texas Health Science Center At Houston,
Vogt, Christine,
for MALPRACTICE (MEDICAL)
in the District Court of Harris County.
Preview
%
NO. 2005-73415
FRANK GUTIERREZ, INDIVIDUALLY § “IN THE DISTRICT COURT o8 >
and AS REPRESENTATIVE OF THE
q yoy
ae
ESTATE OF THERESA GUTIERREZ > BAD
a
and AS NEXT FRIEND OF MICHELLE i _ ORM
nu
GUTIERREZ, A MINOR, AMANDA al Oo
oot
20
| =
eR
(0.00
vs. wo
MEMORIAL HERMANN HOSPITAL
SYSTEM, FREDERICK MOORE, M.D.,
CHRISTINE VOGT, M.D.,
FULGENCIO P. DUREMDES, M.D.,
DEMAIN, M.D., and JOHN DOE, M.D.
(Unknown Shock Trauma Intensive Care
Resident) 11™ JUDICIAL DISTRICT
DEFENDANT, CHRISTIANE VOGT-HARENKAMP, M.D.’S
ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, CHRISTIANE VOGT-HARENKAWP, M.D. (incorrectly referred to in
Plaintiffs’ Original Petition as “Christine Vogt, M.D.), one of the Defendants in the above-
entitled and numbered cause, and in answer to Plaintiffs’ Original Petition respectfully
shows the Court as follows:
As authorized by Rule 92 of the Texas Rules of Civil Procedure, Defendant enters
a general denial of matters pled by the Plaintiffs and requests that the Court require the
Plaintiffs to prove their charges and allegations by a preponderance of the evidence as
required by the Constitution and laws of the State of Texas.
RECORDER'S MEMORANOUM
This instrument is of poor «tality
at the time of imaging
I.
Defendant asserts that she is not a proper party to this lawsuit pursuant to Section
101.106 of the Texas Civil Practice & Remedies Code.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that upon final hearing
judgment be entered that Plaintiffs take nothing by reason of this suit and that Defendant
be discharged with her costs.
Respectfully submitted,
HOLM, B E & McCAB!
By:
hr B-Holm
TBA No. 09900300
Lisa M. Woods
TBA No. 24037738
1010 Lamar, Suite 1100
Houston, Texas 77002
(713) 652-9700 — Telephone
(713) 652-9702 — Facsimile
ATTORNEYS FOR DEFENDANT,
CHRISTIANE VOGT-HARENKANP, M.D.
JURY DEMAND
Defendant hereby demands a jury trial in t ‘apove se.
~~
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the above and foregoing Defendant's
Original Answer and Jury Demand has been forwarded to all counsel of record by regular
mail, or certified mail, return receipt requested, or by Facsimile, or by hand-delivepy this the
day of January, 2006.
7O
lolm
Document Filed Date
January 10, 2006
Case Filing Date
December 16, 2004
Category
MALPRACTICE (MEDICAL)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
% NO. 2005-73415 FRANK GUTIERREZ, INDIVIDUALLY § “IN THE DISTRICT COURT o8 > and AS REPRESENTATIVE OF THE q yoy ae ESTATE OF THERESA GUTIERREZ > BAD a and AS NEXT FRIEND OF MICHELLE i _ ORM nu GUTIERREZ, A MINOR, AMANDA al Oo oot 20 | = eR (0.00 vs. wo MEMORIAL HERMANN HOSPITAL SYSTEM, FREDERICK MOORE, M.D., CHRISTINE VOGT, M.D., FULGENCIO P. DUREMDES, M.D., DEMAIN, M.D., and JOHN DOE, M.D. (Unknown Shock Trauma Intensive Care Resident) 11™ JUDICIAL DISTRICT DEFENDANT, CHRISTIANE VOGT-HARENKAMP, M.D.’S ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, CHRISTIANE VOGT-HARENKAWP, M.D. (incorrectly referred to in Plaintiffs’ Original Petition as “Christine Vogt, M.D.), one of the Defendants in the above- entitled and numbered cause, and in answer to Plaintiffs’ Original Petition respectfully shows the Court as follows: As authorized by Rule 92 of the Texas Rules of Civil Procedure, Defendant enters a general denial of matters pled by the Plaintiffs and requests that the Court require the Plaintiffs to prove their charges and allegations by a preponderance of the evidence as required by the Constitution and laws of the State of Texas. RECORDER'S MEMORANOUM This instrument is of poor «tality at the time of imaging I. Defendant asserts that she is not a proper party to this lawsuit pursuant to Section 101.106 of the Texas Civil Practice & Remedies Code. WHEREFORE, PREMISES CONSIDERED, Defendant prays that upon final hearing judgment be entered that Plaintiffs take nothing by reason of this suit and that Defendant be discharged with her costs. Respectfully submitted, HOLM, B E & McCAB! By: hr B-Holm TBA No. 09900300 Lisa M. Woods TBA No. 24037738 1010 Lamar, Suite 1100 Houston, Texas 77002 (713) 652-9700 — Telephone (713) 652-9702 — Facsimile ATTORNEYS FOR DEFENDANT, CHRISTIANE VOGT-HARENKANP, M.D. JURY DEMAND Defendant hereby demands a jury trial in t ‘apove se. ~~ CERTIFICATE OF SERVICE This will certify that a true and correct copy of the above and foregoing Defendant's Original Answer and Jury Demand has been forwarded to all counsel of record by regular mail, or certified mail, return receipt requested, or by Facsimile, or by hand-delivepy this the day of January, 2006. 7O lolm