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    DC 17 03444

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    Braendon
    VRH Sales, LLC d/b/a Verified Response Security & Investigations filed an original answer to a third-party petition filed against it by WRH Sage Pointe, LLP and WRH Realty Services, Inc. in a lawsuit regarding an incident involving an unidentified gunman. The answer generally denies the allegations against it, asserts that the incident was caused by others over whom it had no control, and demands a jury trial. It requests that the third-party plaintiffs take nothing and that VRH Sales be awarded costs.

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    © All Rights Reserved
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    DC 17 03444

    Uploaded by

    Braendon
    140 views3 pages
    VRH Sales, LLC d/b/a Verified Response Security & Investigations filed an original answer to a third-party petition filed against it by WRH Sage Pointe, LLP and WRH Realty Services, Inc. in a lawsuit regarding an incident involving an unidentified gunman. The answer generally denies the allegations against it, asserts that the incident was caused by others over whom it had no control, and demands a jury trial. It requests that the third-party plaintiffs take nothing and that VRH Sales be awarded costs.

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    DC-17-03444

    Original Title

    DC-17-03444

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    VRH Sales, LLC d/b/a Verified Response Security & Investigations filed an original answer to a third-party petition filed against it by WRH Sage Pointe, LLP and WRH Realty Services, Inc. in a lawsuit regarding an incident involving an unidentified gunman. The answer generally denies the allegations against it, asserts that the incident was caused by others over whom it had no control, and demands a jury trial. It requests that the third-party plaintiffs take nothing and that VRH Sales be awarded costs.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    140 views3 pages

    DC 17 03444

    Uploaded by

    Braendon
    VRH Sales, LLC d/b/a Verified Response Security & Investigations filed an original answer to a third-party petition filed against it by WRH Sage Pointe, LLP and WRH Realty Services, Inc. in a lawsuit regarding an incident involving an unidentified gunman. The answer generally denies the allegations against it, asserts that the incident was caused by others over whom it had no control, and demands a jury trial. It requests that the third-party plaintiffs take nothing and that VRH Sales be awarded costs.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    of 3

    FILED

    DALLAS COUNTY
    1/8/2018 3:40 PM
    FELICIA PITRE
    DISTRICT CLERK

    PIC.23862

    CAUSE NO. DC-17-03444

    ANTONIO SEGURA, § IN THE DISTRICT COURT


    Plaintiff, §
    §
    V. §
    §
    WRH SAGE POINTE, LLP and WRH §
    REALTY SERVICES, INC., §
    Defendants, § DALLAS COUNTY, TEXAS
    §
    V. §
    §
    VRH SALES, LLC, d/b/a VERIFIED §
    RESPONSE SECURITY & §
    INVESTIGATIONS, §
    Third-Party Defendant. § 95th JUDICIAL DISTRICT

    THIRD-PARTY DEFENDANT’S ORIGINAL ANSWER


    TO THIRD-PARTY PLAINTIFFS’ ORIGINAL PETITION

    TO THE HONORABLE JUDGE OF SAID COURT:

    Third-Party Defendant, VRH SALES, LLC D/B/A VERIFIED RESPONSE

    SECURITY & INVESTIGATIONS, now comes and files its Original Answer to Third-Party

    Plaintiffs WRH SAGE POINTE, LLP and WRH REALTY SERVICES, INC.’s Original

    Petition. In support of same, Third-Party Defendant would respectfully show unto the Court as

    follows:

    I.
    GENERAL DENIAL

    Third-Party Defendant denies each and every, all and singular, the material allegations

    contained in Third-Party Plaintiffs’ Original Petition and demands strict proof thereof.

    II.

    Third-Party Defendant would further show that the occurrence which forms the basis of

    Plaintiff’s lawsuit was caused by persons or entities other than Third-Party Defendant and was

    THIRD-PARTY DEFENDANT’S ORIGINAL ANSWER PAGE 1 OF 3


    TO THIRD-PARTY PLAINTIFFS’ ORIGINAL PETITION
    caused by other persons or entities over whom Third-Party Defendant had no control, or for

    whose actions Third-Party Defendant is not responsible. Specifically, Third-Party Defendant

    contends that the incident made the basis of this lawsuit was caused by the unlawful acts of John

    Doe, the unidentified gunman.

    III.
    JURY DEMAND

    In accordance with Rule 216 of the TEXAS RULES OF CIVIL PROCEDURE, Third-Party

    Defendant hereby demands a trial by jury. A jury fee has been paid.

    WHEREFORE, PREMISES CONSIDERED, Third-Party Defendant VRH Sales, LLC

    d/b/a Verified Response Security & Investigations prays that Third-Party Plaintiff take nothing

    by this suit, that Third-Party Defendant be awarded its costs, and for such other and further

    relief, both general and special, at law or in equity, to which Third-Party Defendant may show

    itself to be justly entitled.

    Respectfully submitted,

    FLETCHER, FARLEY
    SHIPMAN & SALINAS, LLP

    /s/ Fernando P. Arias


    FERNANDO P. ARIAS
    State Bar No. 24025946
    C. RYAN CURRY
    State Bar No. 24050145
    9201 N. Central Expressway, 6th Floor
    Dallas, Texas 75231
    214-987-9600
    214-987-9866 fax
    [email protected]
    [email protected]

    ATTORNEYS FOR THIRD-PARTY


    DEFENDANT VRH SALES, LLC D/B/A
    VERIFIED RESPONSE SECURITY &
    INVESTIGATIONS

    THIRD-PARTY DEFENDANT’S ORIGINAL ANSWER PAGE 2 OF 3


    TO THIRD-PARTY PLAINTIFFS’ ORIGINAL PETITION
    CERTIFICATE OF SERVICE

    THIS WILL CERTIFY that a true and correct copy of the foregoing instrument has been
    mailed, telecopied, hand delivered, or electronically transmitted to all attorneys of record in this
    cause of action, in compliance with Rule 21a. of the TEXAS RULES OF CIVIL PROCEDURE, on the
    8th day of January, 2018.
    /s/ Fernando P. Arias
    FERNANDO P. ARIAS

    THIRD-PARTY DEFENDANT’S ORIGINAL ANSWER PAGE 3 OF 3


    TO THIRD-PARTY PLAINTIFFS’ ORIGINAL PETITION

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