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`CAUSE No. 10-CV-3828
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`IN THE DISTRICTJCQIIRT Oé
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`§
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`RICHARD CHENEY & BERNICE
`CHENEY
`
`Plaintiffs,
`
`vs.
`
`TEXAS WINDSTORM INSURANCE
`
`ASSOCIATION
`
`Defendant.
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`~
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`“
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`GALVESTON COUNTY, TEXAS
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`10"‘ JUDICIAL DISTRICT
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`DEFENDANT TEXAS WINDSTORM INSURANCE ASSOCIATION’S
`ORIGINAL ANSWER AND GENERAL DENIAL
`
`TO THE HONORABLE JUDGE OF SAID COURT:
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`COMES NOW Texas Windstorm Insurance Association, Defendant in the above-styled and
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`numbered cause, and in answer to the allegations contained in Plaintiffs’ Original Petition, alleges
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`and at the trial hereof will Show as follows:
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`I.
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`General Denial
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`Defendant exercises its right pursuant to Rule 92, Texas Rules of Civil Procedure, to deny
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`all and singular, each and every material allegation contained in Plaintiffs’ Original Petition and any
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`amendments and/or supplements thereto and demands strict proof of the same.
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`WHEREFORE, PREMISES CONSIDERED, Defendant Texas Windstorm Insurance
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`Association prays that Plaintiffs take nothing by their suit and that Defendant Texas Windstorm
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`Insurance Association have judgment for costs, and such further relief to which it is justly entitled.
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`G:\USERS\COLLINS\30l 3-5900 - 5999\30l3—5904\P1ds\Def TWIA's O
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`r Answer and General Denial.wpd
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`Respectfully submitted,
`
` D
`
`. Wright
`tate Bar No. 2
`00
`
`J. Matt Breeland
`
`State Bar No. 24057771
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`DAVIS & WILKERSON, P.C.
`P.O. Box 2283
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`Austin, Texas 78768-2283
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`(512) 482-0614 telephone
`(512) 482-0342 facsimile
`ATTORNEYS FOR DEFENDANT TEXAS
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`WINDSTORM INSURANCE ASSOCIATION
`
`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy ofthe foregoing has been forwarded to all counsel
`of record listed below via certified mail, return receipt requested, on this the 27th day of December,
`2010.
`
`Riley L. Burnett, Jr.
`Caryn M. Papantonakis
`Clark, Burnett, Love & Lee, G.P.
`
`440 Louisiana, Suite 1600
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`Houston, Texas 77002
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`G:\USERS\COLLINS\3013-5900 - 5999\3013-5904\P1ds\DefTWIA's Original Answer and General DeniaI.wpd
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`Page 2
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`
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`Street A<l<l.'es\.-
`1801S.MoF’aL‘
`Swle 300
`AHs’.H>_ Texas 78746
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`ix/lwlflg Am'lr(:s.<:
`PO. Box 2283
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`l»_?><ris 787682283
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`1.512.482.0614
`F 512.482.0342
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`DAVIS &WlLKERSON, P.C.
`
`December 27, 2010
`
`Via Certified Mail/RRR
`Latonia D. Wilson
`
`Galveston County District Clerk
`600 59"‘ Street, Suite 4001
`Galveston, TX 77551
`
`Re:
`
`Cause No. 10-CV-3 828; Richard Cheney and Bernice Cheney v. Texas Windstorm
`Insurance Association; in the 10”‘ Judicial District, Galveston County, Texas
`
`Dear Ms. Wilson:
`
`Enclosed for filing in the above-referenced cause is an original and one (1) copy of Defendant
`Texas Windstorm Insurance Association ’s Original Answer and General Denial. Please file-
`stamp our copy and return it to me in the enclosed self-addressed stamped envelope.
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`By copy of this letter, we are sending true and correct copies of said Answer to all counsel of
`record.
`
`If you have any questions regarding this filing, please feel free to call me at 512/482-0614.
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`Sincerely,
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` G:\USERS\COLLINS\3013-5900 — 5999\30l3-5904\Corr\Clerk Filing Ltr re Answenwpd
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`Enclosures: as stated
`
`Matt Brceland < 111l’V1‘CL‘l.'lU(l"<I(lwlI|W,C0m
`
`RETURNED COPY
`
`DEC 30 2010
`T
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