CAUSE NO. 29996 H. WALKER ROYALL, Plaintiff, vs. WRIGHT W. GORE, JR., DENNIS HENDERSON, WRIGHT W. GORE, III, and WESTERN SEAFOOD COMPANY Defendants. § § § § § § § § § IN THE DISTRICT COURT OF BRAZORIA COUNTY, TEXAS 239TH JUDICIAL DISTRICT § SECOND AMENDED ANSWER OF WRIGHT W. GORE, III DEFENDANT, WRIGHT W. GORE, III files his Second Amended Answer to Plaintiff’s Second Amended Original Petition, as follows: 1. Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Defendant hereby generally deny each and every material allegation in Plaintiff’s Second Amended Original Petition and demand strict proof thereof. AFFIRMATIVE DEFENSES 2. Answering further, if same be necessary, Defendant alleges that Plaintiff’s injuries and/or damages, if any, were caused in whole or in part by the negligent acts or omissions of third parties for whom this Defendant exercised no actual or apparent control. 3. Plaintiff’s causes of action are barred in whole or in part by the statute applicable of limitations. 4. Defendant further asserts that the alleged statements were true. Second Amended Answer to Plaintiff’s 2nd Amended Petition................................................PAGE 1 5. Pleading further, Defendant asserts Plaintiff consented to the allege publication. 6. Defendant further asserts that the alleged statements are protected by common law qualified privilege. 7. Defendant further answers that the occurrence in question and the alleged damages were the result of a new, independent, and intervening cause. 8. Answering further, Defendant asserts the alleged statements are protected by the First Amendment. WHEREFORE, Wright W. Gore, III prays for judgment of the Court that Plaintiff take nothing by this suit, for their costs, and for such other and further relief to which they may be justly entitled. Respectfully submitted, COKINOS, BOSIEN & YOUNG By: __________________________________ Marc A. Young State Bar No. 22201500 TRACY B. GLENN State Bar No. 24000063 1500 Woodson Tower 2919 Allen Parkway Houston, Texas 77019 Telephone: (713) 535-5500 Telecopier: (713) 535-5533 ATTORNEYS FOR WRIGHT W. GORE, III Second Amended Answer to Plaintiff’s 2nd Amended Petition................................................PAGE 2 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document has been served upon all counsel of record, by certified mail, return receipt requested, facsimile on this 5th day of April, 2006. Bruce Gaible Hays, McConn, Rice & Pickering 400 Two Allen Center 1200 Smith Street Houston, Texas 77002 Patrick Zummo Zummo & Mitchell, LLP Three Allen Center 333 Clay Street, Suite 4500 Houston, Texas 77002 Dennis Henderson, Pro Se P. O. Box 2490 Fort Myers, Florida 33932 _________________________________________ TRACY B. GLENN _ /opt/scribd/conversion/tmp/scratch9/24858963.doc
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2nd Amended Answer to 2nd Amended Petition

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CAUSE NO. 29996 H. WALKER ROYALL, Plaintiff, vs. WRIGHT W. GORE, JR., DENNIS HENDERSON, WRIGHT W. GORE, III, and WESTERN SEAFOOD COMPANY Defendants. § § § § § § § § § IN THE DISTRICT COURT OF BRAZORIA COUNTY, TEXAS 239TH JUDICIAL DISTRICT § SECOND AMENDED ANSWER OF WRIGHT W. GORE, III DEFENDANT, WRIGHT W. GORE, III files his Second Amended Answer to Plaintiff’s Second Amended Original Petition, as follows: 1. Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Defendant hereby generally deny each and every material allegation in Plaintiff’s Second Amended Original Petition and demand strict proof thereof. AFFIRMATIVE DEFENSES 2. Answering further, if same be necessary, Defendant alleges that Plaintiff’s injuries and/or damages, if any, were caused in whole or in part by the negligent acts or omissions of third parties for whom this Defendant exercised no actual or apparent control. 3. Plaintiff’s causes of action are barred in whole or in part by the statute applicable of limitations. 4. Defendant further asserts that the alleged statements were true. Second Amended Answer to Plaintiff’s 2nd Amended Petition................................................PAGE 1 5. Pleading further, Defendant asserts Plaintiff consented to the allege publication. 6. Defendant further asserts that the alleged statements are protected by common law qualified privilege. 7. Defendant further answers that the occurrence in question and the alleged damages were the result of a new, independent, and intervening cause. 8. Answering further, Defendant asserts the alleged statements are protected by the First Amendment. WHEREFORE, Wright W. Gore, III prays for judgment of the Court that Plaintiff take nothing by this suit, for their costs, and for such other and further relief to which they may be justly entitled. Respectfully submitted, COKINOS, BOSIEN & YOUNG By: __________________________________ Marc A. Young State Bar No. 22201500 TRACY B. GLENN State Bar No. 24000063 1500 Woodson Tower 2919 Allen Parkway Houston, Texas 77019 Telephone: (713) 535-5500 Telecopier: (713) 535-5533 ATTORNEYS FOR WRIGHT W. GORE, III Second Amended Answer to Plaintiff’s 2nd Amended Petition................................................PAGE 2 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document has been served upon all counsel of record, by certified mail, return receipt requested, facsimile on this 5th day of April, 2006. Bruce Gaible Hays, McConn, Rice & Pickering 400 Two Allen Center 1200 Smith Street Houston, Texas 77002 Patrick Zummo Zummo & Mitchell, LLP Three Allen Center 333 Clay Street, Suite 4500 Houston, Texas 77002 Dennis Henderson, Pro Se P. O. Box 2490 Fort Myers, Florida 33932 _________________________________________ TRACY B. GLENN _ /opt/scribd/conversion/tmp/scratch9/24858963.doc
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