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
fred.arias@fletcherfarley.com
ryan.curry@fletcherfarley.com

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