Answer to 1 Complaint with Jury Demand by Valeria M. Contreras, M.D., Filed. (Goodman, Colin)
1Defendant denies that Plaintiff has any civil rights causes of action against her. Defendant lacks knowledge or information sufficient to form a belief about the truth of the remaining allegations in Paragraph 1.
2Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 2.
3Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 3.
4Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 4.
5Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 5.
6Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 6.
7Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 7.
8Defendant avers that Paragraph 8 contains legal contentions which do not require responsive pleadings. To the extent that Paragraph 8 contains allegations, Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations.
9Defendant denies that she violated any of Plaintiff’s constitutional rights or that she violated the Americans with Disabilities Act.
10Defendant denies Plaintiff has federal claims that may be asserted against them but admit that this Court has jurisdiction over federal claims through 28 U.S.C. §1331.
11Defendant admits that venue is proper in this Court but denies that she is liable to Plaintiff under any of Plaintiff’s causes of action.
12Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 12.
13Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 13.
14Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 14.
15Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 15.
16Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 16.
17Defendant denies that she is an employee of Harris Health and denies that she is a proper party to this lawsuit. Defendant lacks knowledge or information sufficient to form a belief about the truth of the remaining allegations in Paragraph 17.
18Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 18.
19Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 19.
20Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 20.
21Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 21.
22Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 22.
23Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 23.
24Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 24.
25Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 25.
26Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 26.
27Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 27.
28Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 28.
29Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 29.
30Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 30.
31Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 31.
32Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 32.
33Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 33.
34Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 34.
35Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 35.
36Defendant asserts that Plaintiff inadequately describes the actions of a qualified health professional when evaluating patients. Defendant lacks knowledge or information sufficient to form a belief about the truth of the remaining allegations in Paragraph 36.
37Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 37.
38Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 38.
39Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 39.
40Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 40.
41Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 41.
42Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 42.
43Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 43.
44Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 44.
45Defendant denies the allegations contained in Paragraph 45.
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Public U.S. federal court record (district court docket 73112445, document 19). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.