On April 08, 2020 a
Jury Demand
was filed
involving a dispute between
and
for INJURY OR DAMAGE, INVOLVING MOTOR VEHICLE
in the District Court of Tarrant County.
Preview
FILED
352-316364-20 TARRANT COUNTY
5/18/2020 2:21 PM
THOMAS A. WILDER
NO. 352-316364-20 DISTRICT CLERK
DAVID PADILLA § IN THE DISTRICT COURT
PLAINTIFF, §
§
§
VS. § TARRANT COUNTY, TEXAS
§
RALPH ZIMMERMAN, AUDRA ZIMMERMAN, §
PERSONAL REPRESENTATIVE OF THE ESTATE §
OF AND HEIR OF RALPH ZIMMERMAN §
DEFENDANTS. § 352ND JUDICIAL DISTRICT
DEFENDANTS’ ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Ralph Zimmerman, Audra Zimmerman, Personal Representative of the
Estate of and Heir of Ralph Zimmerman, Defendants in the above-styled and -numbered cause,
and in answer to Plaintiff’s Original Petition filed against them by David Padilla, files this
Original Answer for which they say:
I.
Defendants generally deny each and every, all and singular, the allegations contained in
Plaintiff’s Original Petition and, in accordance with the law, demands that Plaintiff prove by a
preponderance of the credible evidence all allegations contained therein.
II.
Answering further and without waiving any of the foregoing matters, Defendants would
show that Plaintiff’s recovery of medical or healthcare expenses incurred is limited to the amount
actually paid or incurred by or on behalf of Plaintiff, pursuant to Texas Civil Practice & Remedies
Code § 41.0105.
DEFENDANTS’ ORIGINAL ANSWER -1-
WHEREFORE, PREMISES CONSIDERED, Defendants pray that Plaintiff take nothing by reason
of this suit, for costs of suit, and for such other and further relief, both at law or in equity, to which
they may be justly entitled.
Respectfully submitted,
____________________________________
Chad Kimble, State Bar 24007483
Kyle Smith, State Bar 24102512
D. Brent Beasley, State Bar 24082669
LAW OFFICE OF CHAD KIMBLE, P.C.
1204 S. White Chapel Blvd.
Southlake, Texas 76092
eservice@chadkimblelaw.com
817.766.7488
817.423.7492 fax
ATTORNEY FOR DEFENDANTS
CERTIFICATE OF SERVICE
The undersigned certifies that on the 18th day of May, 2020, a true copy of the foregoing
has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure.
____________________________________
Kyle L. Smith
DEFENDANTS’ ORIGINAL ANSWER -2-
Document Filed Date
May 18, 2020
Case Filing Date
April 08, 2020
Category
INJURY OR DAMAGE, INVOLVING MOTOR VEHICLE
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 352-316364-20 TARRANT COUNTY 5/18/2020 2:21 PM THOMAS A. WILDER NO. 352-316364-20 DISTRICT CLERK DAVID PADILLA § IN THE DISTRICT COURT PLAINTIFF, § § § VS. § TARRANT COUNTY, TEXAS § RALPH ZIMMERMAN, AUDRA ZIMMERMAN, § PERSONAL REPRESENTATIVE OF THE ESTATE § OF AND HEIR OF RALPH ZIMMERMAN § DEFENDANTS. § 352ND JUDICIAL DISTRICT DEFENDANTS’ ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Ralph Zimmerman, Audra Zimmerman, Personal Representative of the Estate of and Heir of Ralph Zimmerman, Defendants in the above-styled and -numbered cause, and in answer to Plaintiff’s Original Petition filed against them by David Padilla, files this Original Answer for which they say: I. Defendants generally deny each and every, all and singular, the allegations contained in Plaintiff’s Original Petition and, in accordance with the law, demands that Plaintiff prove by a preponderance of the credible evidence all allegations contained therein. II. Answering further and without waiving any of the foregoing matters, Defendants would show that Plaintiff’s recovery of medical or healthcare expenses incurred is limited to the amount actually paid or incurred by or on behalf of Plaintiff, pursuant to Texas Civil Practice & Remedies Code § 41.0105. DEFENDANTS’ ORIGINAL ANSWER -1- WHEREFORE, PREMISES CONSIDERED, Defendants pray that Plaintiff take nothing by reason of this suit, for costs of suit, and for such other and further relief, both at law or in equity, to which they may be justly entitled. Respectfully submitted, ____________________________________ Chad Kimble, State Bar 24007483 Kyle Smith, State Bar 24102512 D. Brent Beasley, State Bar 24082669 LAW OFFICE OF CHAD KIMBLE, P.C. 1204 S. White Chapel Blvd. Southlake, Texas 76092 eservice@chadkimblelaw.com 817.766.7488 817.423.7492 fax ATTORNEY FOR DEFENDANTS CERTIFICATE OF SERVICE The undersigned certifies that on the 18th day of May, 2020, a true copy of the foregoing has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure. ____________________________________ Kyle L. Smith DEFENDANTS’ ORIGINAL ANSWER -2-