IN THE COUNTY COURT AT LAW NUMBER TWO

EL PASO COUNTY, TEXAS

DONALD L. THOMPSON
Plaintiff, Pro-Se

      vs.                                                                                       Cause No. 94-12,817

ALLSTATE INSURANCE COMPANY
and ROBERT WILSON
Defendants

SPECIAL EXCEPTION AND ORIGINAL ANSWER

 

TO THE HONORABLE JUDGE OF SAID COURT:

     Comes now ALLSTATE INSURANCE COMPANY, Defendant in the above-captioned matter, and files this its Special Exception and Original Answer to Plaintiff's Original Petition and would show the court as follows:

I. SPECIAL EXCEPTION

     Defendant would specially except to Paragraphs XI and X of Plaintiff's Petition because the allegations contained in such paragraphs fail to specify the exact damages allegedly sustained by Plaintiff or the amount of damages claimed by Plaintiff as required by Rule 47(c) of the Texas Rules of Civil Procedure. In accordance with this Special Exception, Defendant requests that Plaintiff be ordered to replead these allegations in conformity with the law and absent same, that said paragraphs be dismissed.

II. ANSWER

     Subject to the above and foregoing and pursuant to Rule 92 of the Texas Rules of Civil Procedure, Defendant denies generally, each and every, all and singular, the allegations contained in Plaintiff's Original Petition and demands strict proof thereof by a preponderance of the credible evidence.

     WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff take nothing by virtue of his suit, that Defendant recover its costs, and for such other and further relief to which Defendant may be justly entitled.

Respectfully submitted,

MAYFIELD & PERRENOT, P.C.                                                                               Attorneys for Defendant

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was mailed, certified mail, return receipt requested to Mr. Donald L. Thompson, Pro-Se, 5101 Azalea, Amarillo, Texas 79110 on the ______ day of August, 1995.

File No. 1134-987

 

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