Your law firm was hired by the insurance company for Doug Cagely. They have asked you to prepare an Original Answer to the Texas District Court Petition filed on behalf of Julia Wedgewood in Chapter 5. Your assignment is to Prepare an Original Answer to this lawsuit. Remember, Texas only requires a General Denial to answer a lawsuit, unlike Federal District Court. You may assert a Counter Claim or any affirmative defenses you deem applicable based upon the facts of the case. Again, this is not a Federal Court case so do not use federal forms. You may use my Instructor Forms or ProDoc or any other form file so long as your form complies with the Texas Rules of Civil Procedure. You may create addresses for purposes of jurisdiction and service. You may allege any damages which are reasonably related to the facts provided.

Fact Pattern for Chapter 6 Assignment:

Julia Wedgewood was driving her BMW westerly on Main street as she approached the intersection of Main and Post Streets.The intersection is controlled by four-way stop signs. There were no vehicles in front of Julia as she approached her stop sign.She began slowing for the stop and came to a near stop then proceeded into the intersection. Approaching from her right on Poststreet was Doug Cagely. He reached this same intersection at nearly the same time as Julia. Believing Julia was going to make acomplete stop he also proceeded into the intersection of Main and Post. The vehicles impacted in the middle of the intersection.

After impact both drivers exited their respective vehicles and each accused the other of being at fault. Julia sustained severe injuries to both her back and neck. She was taken by ambulance to the local hospital where she was treated for her injuries. Doug received injuries to his neck and received facial lacerations from impact with the steering wheel. Doug Cagely's insurance company has hired your law firm to represent Doug Cagely and file an Original Answer.

Please make your submission as early as possible in the week so that I may review what you have submitted, and provide comment and make suggestions to correct your submission. You may then re-submit your corrected assignment for additional credit. All re-submissions must be filed timely (before 6pm on the date of class). You may e mail me so that I will know when you have made your submission or re-submission.)

It is never recommended that you wait until the day of class to start preparing your submission. First, you may encounter computer issues or internet issues which will prevent you from timely submitting your work. Late work cannot be accepted. Second, if you wait until the day of class I may not have time to grade your submission and for you to have time to make corrections identified in a timely manner.

Use the same fact pattern from Chapters 5 and 6. Your law office represents the Plaintiff in a state district court personal injury case. On January 15, 2020, you served your discovery upon Defendant in the form of The First Set of Interrogatories. More than 30 days have elapsed and you have yet to receive answers to your interrogatories. Your attorney has sent correspondence to opposing counsel inquiring as to when you might be receiving this discovery and again you have received no response. Your assignment is to prepare aMotion to Compel Answers to Interrogatoriesusing the above facts. Request all applicable relief. Prepare aNotice of Oral Hearingand anOrderto accompany the Motion.