BLAIR KEITH PESHAK
SMALL CLAIMS COURT
V
PRECINCT 3
DON HUGHES AND NATIONWIDE
WILLIAMSON COUNTY, TEXAS
INSURANCE COMPANY
DEFENDANT'S ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, DON HUGHES and NATIONWIDE MUTUAL INSURANCE
COMPANY, Defendants in the above-entitled and numbered cause, and for answer
to the Plaintiff's pleading on file herein, would respectfully show unto
the Court as follows:
I.
Subject to such stipulations and admissions as may
hereafter be made, these Defendants assert a General Denial as is authorized
by Rule 92 of the Texas Rules of Civil Procedure, and Defendants respectfully
request that the Plaintiff be required to prove the charges and allegations
against these Defendants by a preponderance of the evidence as is required
by the Constitution and laws of the State of Texas.
II.
Pursuant to Rule 216 of the Texas Rules of Civil
Procedure, Defendants hereby make demand and application for jury trial.
WHEREFORE, PREMISES CONSIDERED, Defendants, DON
HUGHES and NATIONWIDE MUTUAL INSURANCE COMPANY, pray that upon final hearing
hereof, they have judgment and that Plaintiff take nothing against them
by way of this cause of action, and that THEY GO
HENCE WITHOUT DAY FOR COSTS, AND FOR SUCH OTHER AND FURTHER RELIEF, BOTH
GENERAL AND SPECIAL, AT LAW AND IN EQUITY, TO WHICH DEFENDANTS MAY SHOW
THEMSELVES JUSTLY ENTITLED.
Respectfully Submitted,
(signature)
________________________________________
ANDREA SARGENT-FAMBLES
ATTORNEY FOR DEFENDANTS
Bar Number 06800240
8415 DATAPOINT DRIVE, SUITE 110
SAN ANTONIO TX 78229
(210) 949-6130
(210) 949-6392 Fax
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 13th day of February, 2001.
(signature)
________________________________________
ANDREA SARGENT-FAMBLES