On August 20, 2021 a
Answer
was filed
involving a dispute between
Mccormack, John N.,
and
Industrial Labs Llc,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
FILED
9/23/2021 2:35 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Terri Kilgore DEPUTY
CAUSE NO. DC-21-11306
§ IN THE DISTRICT COURT
IN RE: JOHN N. MCCORMACK g 68TH JUDICIAL DISTRICT
g DALLAS COUNTY, TEXAS
DEFENDANT'S ORIGINAL ANSWER TO PETITION TO OBTAIN
DEPOSITION 0F CORPORATE REPRESENTATIVE
NOW COMES Defendant, Industrial Labs LLC, named Defendant in the above-entitled
and numbered cause, and files this Original Answer to Petition to Obtain Deposition of
Corporate Representative, and shows the Court:
Party Identification Information
Industrial Labs LLC is a Texas Corporation whose principal place of business is 1400
Sherman Street, Suite 116, Richardson, Texas 75081.
General Denial
Defendant denies each and every allegation of Plaintiff‘s Original Petition, and demands
strict proof thereof as required by the Texas Rules of Civil Procedure.
Prayer
Defendant prays the Court, after notice and hearing or trial, enters judgment in favor of
Defendant, awards Defendant the costs of court, attorney's fees, and such other and further relief
as Defendant may be entitled to in law or in equity.
Defendant’s General Denial — Industrial Labs LLC — Page 1
Respectfully submitted,
Law Offices of Paul G. Dell, PC
By:
‘2
Paul G. Dell
Texas Bar No. 24063097
Email: paul@dell-legal.com
15110 Dallas Parkway, Suite 310
Dallas, Texas 75248
Tel. (972) 325.4444
Fax. (972) 692.7525
Attorney for Defendant
Industrial Labs LLC
Defendant’s General Denial — Industrial Labs LLC — Page 2
CERTIFICATE OF SERVICE
I certify that a true copy of this Defendant’s Original Answer to Petition to Obtain
Deposition of Corporate Representative was served in accordance with rule 21a of the
Texas Rules of Civil Procedure on the following on this 23rd day of September 2021.
‘2
Paul G. Dell
Defendant’s General Denial — Industrial Labs LLC — Page 3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Ruth Kim on behalf of Paul Dell
Bar No. 24063097
ruth@dell-legal.com
Envelope ID: 57546739
Status as of 9/24/2021 12:52 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
SCO'I'I' RSEIFERT sseifert@spencerfane.com 9/23/2021 2:35:18 PM SENT
Document Filed Date
September 23, 2021
Case Filing Date
August 20, 2021
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FILED 9/23/2021 2:35 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Terri Kilgore DEPUTY CAUSE NO. DC-21-11306 § IN THE DISTRICT COURT IN RE: JOHN N. MCCORMACK g 68TH JUDICIAL DISTRICT g DALLAS COUNTY, TEXAS DEFENDANT'S ORIGINAL ANSWER TO PETITION TO OBTAIN DEPOSITION 0F CORPORATE REPRESENTATIVE NOW COMES Defendant, Industrial Labs LLC, named Defendant in the above-entitled and numbered cause, and files this Original Answer to Petition to Obtain Deposition of Corporate Representative, and shows the Court: Party Identification Information Industrial Labs LLC is a Texas Corporation whose principal place of business is 1400 Sherman Street, Suite 116, Richardson, Texas 75081. General Denial Defendant denies each and every allegation of Plaintiff‘s Original Petition, and demands strict proof thereof as required by the Texas Rules of Civil Procedure. Prayer Defendant prays the Court, after notice and hearing or trial, enters judgment in favor of Defendant, awards Defendant the costs of court, attorney's fees, and such other and further relief as Defendant may be entitled to in law or in equity. Defendant’s General Denial — Industrial Labs LLC — Page 1 Respectfully submitted, Law Offices of Paul G. Dell, PC By: ‘2 Paul G. Dell Texas Bar No. 24063097 Email: paul@dell-legal.com 15110 Dallas Parkway, Suite 310 Dallas, Texas 75248 Tel. (972) 325.4444 Fax. (972) 692.7525 Attorney for Defendant Industrial Labs LLC Defendant’s General Denial — Industrial Labs LLC — Page 2 CERTIFICATE OF SERVICE I certify that a true copy of this Defendant’s Original Answer to Petition to Obtain Deposition of Corporate Representative was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on this 23rd day of September 2021. ‘2 Paul G. Dell Defendant’s General Denial — Industrial Labs LLC — Page 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ruth Kim on behalf of Paul Dell Bar No. 24063097 ruth@dell-legal.com Envelope ID: 57546739 Status as of 9/24/2021 12:52 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status SCO'I'I' RSEIFERT sseifert@spencerfane.com 9/23/2021 2:35:18 PM SENT