On April 22, 2021 a
Answer
was filed
involving a dispute between
Williby, Regina,
and
Garcia, Alberto,
Ramirez, Jose Roberto,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
5/28/2021 11:12 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Miranda Lynch DEPUTY
CAUSE NO. DC-2 1-05084
REGINA WILLIBY, IN THE DISTRICT COURT
P1aintiff(s),
vs. 116TH JUDICIAL DISTRICT
JOSE ROBERTO MMIREZ and
ALBERTO GARCLA,
Defendant(s). DALLAS COUNTY, TEXAS
DEFENDANT. ALBERTO GARCIA'S. ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES ALBERTO GARCIA, Defendant in the above-styled and numbered
cause, and files Defendant's Original Answer, and in support hereof would respectfully show
unto the Court the following:
1.
GENERAL DENIAL
Defendant denies each and every, all and singular the material allegations made and
contained in the Original Petition and any petition which Plaintiff(s) may hereinafter file by way
of amendment or supplement, and, in accordance with Texas law, demands that Plaintiff(s) prove
by a preponderance of the credible evidence each and every such allegation made and contained
therein.
2.
AMOUNT OF RECOVERY
In addition to any other limitation under law, recovery of medical or health care expenses
incurred is limited to the amount actually paid or incurred by or on behalf of the claimant.
Williby vs. Ramirez & Garcia PAGE 1
DEFENDANT ALBERTO GARCIA'S ORIGINAL ANSWER
Our File Number: 0544080641 . 1
3.
JURY RE UEST
Defendant respectfully requests a jury trial.
4.
DESIGNATED E-SERVICE EMAIL ADDRESS
The following is the undersigned attorney’s designation of electronic service email
address for all electronically served documents and notices, filed and unfiled, pursuant to
Tex.R.CiV.P. 21(f)(2) & 21(a). (DallasLega1@allstate.com). This is the undersigned’s ONLY
electronic service email address, and service through any other email address will be considered
invalid.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff(s) take
nothing by this suit against Defendant, that Defendant be discharged, and that the Court grant
such other and further relief, both general and special, at law and in equity to which Defendant
may be justly entitled.
Respectfully submitted,
LISA CHASTAIN & ASSOCIATES
m
(AQ-
DIANNE K JONES
TBN: 10010900
1201 Elm Street, Suite 5050
Dallas, TX 75270
E-Service Only: DallasLegal@allstate.com
(214) 659-4366
(877) 678-4763 (fax)
ATTORNEY FOR DEFENDANT(S)
ALBERTO GARCIA
Williby vs. Ramirez & Garcia PAGE 2
DEFENDANT ALBERTO GARCIA'S ORIGINAL ANSWER
Our File Number: 0544080641 . 1
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served in
compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 28th day of May,
202 1 , to:
Mike Freden
FREDEN LAW FIRM
950 E. State Highway 114, Ste. 160
Southlake, Texas 76092
T: (817) 726-1636
F: (817) 231-0033
mike@dfwpersonalinjury.com
ATTORNEY FOR PLAINTIFF
X/s
C/CQ
DIANNE K JONES
Williby vs. Ramirez & Garcia PAGE 3
DEFENDANT ALBERTO GARCIA'S ORIGINAL ANSWER
Our File Number: 0544080641 . 1
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.
ShaJherika Whitfield on behalf of Dianne McVay
Bar No. 10010900
swhj0@allstate.com
Envelope ID: 53917021
Status as of 6/1/2021 8:31 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
MICHAEL CFREDEN mike@dfwpersonalinjury.com 5/28/2021 11:12:27 AM SENT
Document Filed Date
May 28, 2021
Case Filing Date
April 22, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 5/28/2021 11:12 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Miranda Lynch DEPUTY CAUSE NO. DC-2 1-05084 REGINA WILLIBY, IN THE DISTRICT COURT P1aintiff(s), vs. 116TH JUDICIAL DISTRICT JOSE ROBERTO MMIREZ and ALBERTO GARCLA, Defendant(s). DALLAS COUNTY, TEXAS DEFENDANT. ALBERTO GARCIA'S. ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES ALBERTO GARCIA, Defendant in the above-styled and numbered cause, and files Defendant's Original Answer, and in support hereof would respectfully show unto the Court the following: 1. GENERAL DENIAL Defendant denies each and every, all and singular the material allegations made and contained in the Original Petition and any petition which Plaintiff(s) may hereinafter file by way of amendment or supplement, and, in accordance with Texas law, demands that Plaintiff(s) prove by a preponderance of the credible evidence each and every such allegation made and contained therein. 2. AMOUNT OF RECOVERY In addition to any other limitation under law, recovery of medical or health care expenses incurred is limited to the amount actually paid or incurred by or on behalf of the claimant. Williby vs. Ramirez & Garcia PAGE 1 DEFENDANT ALBERTO GARCIA'S ORIGINAL ANSWER Our File Number: 0544080641 . 1 3. JURY RE UEST Defendant respectfully requests a jury trial. 4. DESIGNATED E-SERVICE EMAIL ADDRESS The following is the undersigned attorney’s designation of electronic service email address for all electronically served documents and notices, filed and unfiled, pursuant to Tex.R.CiV.P. 21(f)(2) & 21(a). (DallasLega1@allstate.com). This is the undersigned’s ONLY electronic service email address, and service through any other email address will be considered invalid. WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff(s) take nothing by this suit against Defendant, that Defendant be discharged, and that the Court grant such other and further relief, both general and special, at law and in equity to which Defendant may be justly entitled. Respectfully submitted, LISA CHASTAIN & ASSOCIATES m (AQ- DIANNE K JONES TBN: 10010900 1201 Elm Street, Suite 5050 Dallas, TX 75270 E-Service Only: DallasLegal@allstate.com (214) 659-4366 (877) 678-4763 (fax) ATTORNEY FOR DEFENDANT(S) ALBERTO GARCIA Williby vs. Ramirez & Garcia PAGE 2 DEFENDANT ALBERTO GARCIA'S ORIGINAL ANSWER Our File Number: 0544080641 . 1 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 28th day of May, 202 1 , to: Mike Freden FREDEN LAW FIRM 950 E. State Highway 114, Ste. 160 Southlake, Texas 76092 T: (817) 726-1636 F: (817) 231-0033 mike@dfwpersonalinjury.com ATTORNEY FOR PLAINTIFF X/s C/CQ DIANNE K JONES Williby vs. Ramirez & Garcia PAGE 3 DEFENDANT ALBERTO GARCIA'S ORIGINAL ANSWER Our File Number: 0544080641 . 1 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. ShaJherika Whitfield on behalf of Dianne McVay Bar No. 10010900 swhj0@allstate.com Envelope ID: 53917021 Status as of 6/1/2021 8:31 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status MICHAEL CFREDEN mike@dfwpersonalinjury.com 5/28/2021 11:12:27 AM SENT