FILED

DALLAS COUNTY
11/14/2016 11:40:57 AM
FELICIA PITRE
DISTRICT CLERK

CAUSE NO. DC-16-13549

SECOND CITY LEASING, LLC IN THE DISTRICT COURT

Plaintiff

v. DALLAS COUNTY, TEXAS

GREGORY HARDY
Defendant. 298" JUDICIAL DISTRICT

DEFENDANT GREGORY HARDY'S ORIGINAL ANSWER

AND REQUEST FOR DISCLOSURE

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW Gregory Hardy, Defendant in the above-styled and numbered cause, and

makes and files this his Original Answer and Request for Disclosure to Plaintiffs Original

Petition on file herein, and for such answer would respectfully show unto the Court the

following:

1.

General Denial

Defendant denies each and every allegation contained in Plaintiffs original pleading and

amendments or supplements thereto, and demands strict proof thereof by a preponderance of

evidence pursuant to Rule 92 of the Texas Rules of Civil Procedure.

2.

Request for Disclosure under T.R.C.P. 194

Under the authority of Texas Rule of Civil Procedure 194.2, Defendant requests that

Plaintiff disclose, within 30 days of the service of this request, the information or material

described in Rule 194.2(a) through (1). A response to a request under Rule 194.2(f) is due

according to Rule 195.2 of the Texas Rules of Civil Procedure.

DEFE. `S ORIGINAL ANSVcER AND

PAGE 1 OF 3
REQUEST FOR DNOLO
 Prayer

WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiffs cause be in

all things denied and that Plaintiff go without costs. Defendant prays for general relief, recovery

of costs and for such other and further relief to which Defendant may show himself justly

entitled, at law or in equity.

Respectfully submitted,

THE COLANERI FIRM, P.C.

744( 7471
Marcus C. Marsden,
State Bar No. 13014200
Email: marcus@colanerifirm.com
1161 West Corporate Drive, Suite 101
Arlington, Texas 76006
Tel: (817) 640-1588
Fax: (817) 640-1680
Attorney for Defendant

CERTIFICATE OF SERVICE

The undersigned does hereby certify that on the 1411 day of November, 2016, the
foregoing document was sent, via electronic service, to the following counsel of record:

Matthew D. Giadrosich
Padfield & Stout, LLP
421 W. Third Street, Suite 910
Fort Worth, Texas 76102
Email: mdg@livepad.com

744 e
Marcus C. Marsden, J

DEFENDANT GREGORY HARDY'S ORIGINAL ANSWER AND

PAGE 2 OF 3
REQUEST FOR DISCLOSURE