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DSC COMMUNICATIONS CORPORATION, Plaintiff, v. EVAN BROWN, Defendant. |
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IN THE DISTRICT COURT OF COLLIN COUNTY, TEXAS 199 JUDICIAL DISTRICT |
TO THE HONORABLE JUDGE OF THE COURT:
Now comes Evan Brown, an individual, and in answer to Plaintiff s Original Petition and Application for Injunctive Relief, and any subsequent amendments thereto, files the following answer pursuant to the Texas Rules of Civil Procedure:
As allowed by Rule 92 of the Texas Rules of Civil Procedure, the Defendant hereby enters a general denial of matters pleaded by the Plaintiff.
Pursuant to Rule 93 of the Texas Rules of Civil Procedure, the Defendant specifically pleads that the "Employment, Copyright and Proprietary Information Agreement" ("Employment Agreement") referred to in Plaintiffs pleadings is without consideration; alternatively, that the consideration for the Employment Agreement has failed in whole or in part.
Pleading affirmatively, the Defendant alleges the affirmative defense of ambiguity to the Employment Agreement. The Employment Agreement is so ambiguous as to be unenforceable, in whole or in part.
Pursuant to Rule 54 of the Texas Rules of Civil Procedure, the Defendant specifically denies that conditions precedent to recovery have been performed or have occurred.
Pleading affirmatively, the Defendant alleges that the Plaintiff is not entitled to an injunction, and requests that the injunction against him be dissolved.
Defendant demands trial by jury.
WHEREFORE, PREMISES CONSIDERED, Defendant Evan Brown prays that upon trial hereof Plaintiff take nothing, that Defendant recover his costs, and for such other and further relief to which Defendant may be justly entitled, either in law or equity.
__________________________
RICHARD A. SAYLES
State Bar No. 17697500
STEVEN E. ALDOUS
State Bar No. 00982100
ERIC D. PEARSON
State Bar No. 15690472
SAYLES & LIDJI
A Professional Corporation
4400 Renaissance Tower
1201 Elm Street
Dallas, TX 75270
(214) 939-8700
FAX (214) 939-8787
The undersigned certifies that a copy of the foregoing instrument was served upon the attorneys of record of all parties to the above cause in accordance with Rule 21a, Texas Rules of Civil Procedure, on this 23rd day of May, 1997.
John Stooksberry, Esq.
Boyd Veigel
P.O. Box 1179
McKinney, TX 75070
STATE OF TEXAS |
COUNTY OF DALLAS |
BEFORE ME, the undersigned authority, on this day personally appeared Evan Brown, who being duly sworn by me, upon his oath stated that the information contained in paragraph II of Defendant's Original Answer is true and correct.
SUBSCRIBED AND SWORN TO BEFORE ME on this the 23rd day of May, 1997, to certify which witness my hand and official seal of office.
My Commission Expires:
1/13/99
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