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5/31/2018 9:44 AM

Chris Daniel - District Clerk Harris County


Envelope No. 24956840
By: Chandra Lawson
Filed: 5/31/2018 9:44 AM

NO. 2018-30042

CITY OF BAYTOWN, § IN THE DISTRICT COURT


Plaintiff, §
§
v. § OF HARRIS COUNTY, TEXAS
§
PATRICK MAHONEY, §
Defendant. § 295TH JUDICIAL DISTRICT

DEFENDANT’S ORIGINAL ANSWER AND JURY DEMAND

TO THE HONORABLE JUDGE OF THE COURT:

Defendant Patrick Mahoney files this original answer to Plaintiff’s Original Petition. In

support, Defendant would show the Court as follows.

I. GENERAL DENIAL

1. Defendant generally denies the allegations in Plaintiff’s Original Petition and

demands strict proof of the allegations.

II. JURY DEMAND

2. Defendant demands a trial by jury. The jury fee is being tendered with this filing.

III. PRAYER FOR RELIEF

Defendant prays that the decision of the Texas Department of Insurance Division of

Workers’ Compensation Appeals Panel be upheld in its entirety, that Plaintiff be ordered to pay

Defendant’s attorney fees and costs under TEX. LABOR CODE § 408.221(c), and that the Court

award Plaintiff all other relief that this Court may deem proper.

1
Respectfully submitted,

DEATS, DURST & OWEN, P.L.L.C.


707 W. 34th Street
Austin, Texas 78705
(512) 474-6200
(512) 474-7896 (Fax)

/s/ Matt Bachop


Matt Bachop
State Bar No. 24055127
mbachop@ddollaw.com

ATTORNEY FOR DEFENDANT

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document has been
forwarded via electronic service, on this the 31st day of May, 2018, to:

Brandi Prejean
bprejean@thorntonfirm.com
THORNTON, BIECHLIN, REYNOLDS & GUERRA, L.C.
912 S. Capital of Texas Hwy., Suite 300
Austin, TX 78746

/s/ Matt Bachop


Matt Bachop