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Cause No. 2017-41522
VANDAVEN JOHNSON IN THE DISTRICT COURT OF
Vv. HARRIS COUNTY, TEXAS
BATTLEGROUND OIL SPECIALTY
TERMINAL COMPANY, LLC,
KINDER MORGAN BATTLEGROUND
OIL, LLC, KINDER MORGAN, INC.,
BOONE TOWING, INC. AND
ATLANTIC RICHFIELD COMPANY
DADO OY UD LD) CO UH UD
295" JUDICIAL DISTRICT
DEFENDANT ARTCO’S ORIGINAL ANSWER
COMES NOW, AMERICAN RIVER TRANSPORTATION CO., LLC (“ARTCO’),
Defendant in the above-entitled and numbered cause, and files this it's Original Answer,
and would show unto this Honorable Court as follows:
I
General Denial
Pursuant to the provisions of Rule 92 of the Texas Rules of Civil Procedure,
Defendant, ARTCO, denies each and every, all and singular, the allegations contained in
Plaintiff's First Amended Petition, and demands strict proof thereof.
I.
Pursuant to Scindia Steam Navigation Co. Lid. v. De Los Santos, 541 U.S, 156
(1981), ARTCO had no duty to supervise Plaintiff, VANDAVEN JOHNSON (‘JOHNSON’).
I,
Pursuant to Scindia, ARTCO had no duty to tra…
