Answer to Complaint

1. 1
DEFENDANTS’ ORIGINAL ANSWER
1662805V.1
CAUSE NO. DC-20-13604
JACQUELYN MEDINA,
Plaintiff,
v.
HYATT CORPORATION, a Delaware
Corporation dba HYATT REGENCY DFW,
AB/FH DFW PROPERTY, LLC, a Delaware
Limited Liability Company, and THE
SERVICES COMPANIES, a Florida
Corporation,
Defendants.
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IN THE DISTRICT COURT OF
DALLAS COUNTY, TEXAS
116th
JUDICIAL DISTRICT
DEFENDANTS HYATT CORPORATION dba HYATT REGENCY DFW, AB/FH DFW
PROPERTY, LLC, AND THE SERVICES COMPANIES’ ORIGINAL ANSWER
COME NOW, Hyatt Corporation, d/b/a, Hyatt Regency DFW, AB/FH DFW Property,
LLC, and The Services Companies (hereinafter “Defendants”) in the above-entitled cause, and file
their Original Answer and would respectfully show as follows:
I.
GENERAL DENIAL
Defendants generally deny each and every, all and singular, the claims and allegations
contained in Plaintiff’s Petition and all supplements, modifications and amendments thereto, and
demand strict proof thereof by a preponderance of the credible evidence pursuant to TEX. R. CIV.
P. 92.
FILED
10/23/2020 4:06 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez DEPUTY

2. 2
DEFENDANTS’ ORIGINAL ANSWER
1662805V.1
II.
DEFENSES
1. Sole Proximate Cause. Defendants assert that, with respect to the occurrence in
question, the negligence, fault, acts and/or omissions of persons not a party to the suit were the
sole proximate cause of Plaintiff’s injuries and/or damages, if any, and without which, Plaintiff’s
injuries and/or damages would not have occurred, or in the alternative, said negligence, fault, acts
and/or omissions were a contributing proximate cause of this occurrence and Plaintiff’s injuries
and/or damages, if any.
2. No act or omission attributable to Defendants constitutes a proximate cause of any
injury and/or damage to Plaintiff. Defendants further assert the injuries and/or damages
complained of were not foreseeable, nor was any act or omission, allegedly attributable to
Defendants, a cause-in-fact of any injuries or damages to Plaintiff.
3. Plaintiff’s Fault. Defendants further aver Plaintiff’s injuries and/or damages, if any,
were proximately caused, in whole or in part, by Plaintiff’s own acts and omissions, each and all
of which were a proximate, producing, or new and independent cause of the alleged damages.
4. Contributory Negligence. Defendants allege that Plaintiff was contributorily
negligent and/or intentionally, willfully and wantonly negligent on the day in question. Defendants
further alleges that Plaintiff’s negligence was the proximate cause, or alternatively, the producing
cause of all injuries and/or damages allegedly suffered by Plaintiff. Defendants allege that the
conduct of Plaintiff in failing to use ordinary care for her safety and welfare was fifty-one (51%)
percent or more of the cause of the alleged injuries and/or damages, if any.
5. Failure to Mitigate Damages. Defendants further allege that Plaintiff has failed to
mitigate her damages as required by law.

3. 3
DEFENDANTS’ ORIGINAL ANSWER
1662805V.1
6. Third parties. Defendants further allege that Plaintiff’s alleged injuries and/or
damages, if any, were proximately caused in whole or in part by the acts and omissions of third
parties over whom Defendants had no control or right to control.
7. New and Independent Cause. Defendants further allege that Plaintiff’s injuries
and/or damages, if any, were not the cause of any act or omission on the part of Defendant, but
rather were the result of acts or omissions of a separate and independent agency, not reasonably
foreseeable to Defendants which altered the natural sequence of events and over which Defendants
had no control.
8. Paid or Incurred Medical Expenses. Defendants invoke the limitation on liability
for medical or health care expenses as provided by section 41.0105 of the TEXAS CIVIL PRACTICE
& REMEDIES CODE. Specifically, Plaintiff is limited to recovery of medical or health care expenses
actually paid or incurred by or on behalf of Plaintiff.
9. Pre-judgment Interest Limitations. Defendants hereby invoke its entitlement to all
definitions, instructions, defenses and limitations provided by Chapter 41 of the TEXAS CIVIL
PRACTICE AND REMEDIES CODE, including but not limited to, sections 41.008, and 41.0105.
10. Reasonable and Necessary Medical Expenses. Defendants would further show that
the medical treatment claimed by Plaintiff was excessive and unnecessary and that the medical
expenses claimed were unreasonable and unnecessary and were not proximately caused by the
accident made basis of this lawsuit.
11. Rights. Defendants invoke all rights, remedies and elections afforded them pursuant
to Chapters 32 and 33 of the TEXAS CIVIL PRACTICE & REMEDIES CODE regarding contribution,
indemnity, comparative and/or proportionate responsibility to the extent the same are or may be
applicable.

4. 4
DEFENDANTS’ ORIGINAL ANSWER
1662805V.1
12. Settlement, Credit, Reduction. If any defendant or third-party settles, or has settled,
or is otherwise dismissed prior to judgment, Defendants reserve the right to pursue a credit,
percentage reduction, or any of the relief to which he may be entitled with respect to any such
settlement or any other settlement between Plaintiff and any other person or entity who has paid
or promised to pay money or anything of monetary value to Plaintiff at any time in consideration
for limiting or eliminating any potential liability arising out of or relating to the events from which
this suit arises. Further, Defendants assert their right to a credit and to make an election of credit
for purposes of any settlement entered into with any other defendant, tortfeasor, or other party,
pursuant to §33.014 of the TEXAS CIVIL PRACTICE & REMEDIES CODE.
13. Reservation. Defendants reserve the right to amend, supplement and add
affirmative defenses and/or assert any counter-claims, cross-claims or third-party claims that
discovery may reveal.
III.
JURY DEMAND
Defendants join in Plaintiff’s request for a jury in this case.
IV.
REQUEST FOR DISCLOSURE
Pursuant to Texas Rule of Civil Procedure 194, Plaintiff is requested to disclose, within
thirty (30) days of service of this request, the information or material described in Texas Rule of
Civil Procedure 194.2(a) – (l).
V.
SELF AUTHENTICATION NOTICE
Defendants hereby give notice in accordance with Rule 193.7 of the Texas Rules of Civil
Procedure that any and all documents produced during discovery may be used against the

5. 5
DEFENDANTS’ ORIGINAL ANSWER
1662805V.1
producing parties at any pre-trial proceeding and/or trial of this matter without the necessity of
authenticating the document.
VI.
PRAYER
Defendants respectfully pray Plaintiff takes nothing by reason of his suit here in, and that
Defendants recover their costs.
Respectfully submitted,
/s/ Brittany Davis
CHRISTINE BURKHART
Bar No. 24102731
Christine.Burkhart@wilsonelser.com
BRITTANY DAVIS
Bar No. 24093404
Brittany.Davis@wilsonelser.com
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER, L.L.P.
Bank of America Plaza
901 Main Street, Suite 4800
Dallas, Texas 75202
Telephone: (214) 698-8000
Facsimile: (214) 698-1101
ATTORNEYS FOR DEFENDANTS

6. 6
DEFENDANTS’ ORIGINAL ANSWER
1662805V.1
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing document was served on all parties
and/or their counsel of record in accordance with Texas Rules of Civil Procedure 21 and 21a on
the 23rd
day of October 2020.
Ramona Ladwig e-served: ramona@kazlg.com
Mohammad Kazerouni e-served: mike@kazlg.com
KAZEROUNI LAW GROUP, APC
1910 Pacific Avenue, Suite 14155
Dallas, TX 75201
800-400-6808
800-520-5523 (fax)
Attorneys for Plaintiff
/s/ Brittany Davis
Attorney

7. Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Pam Lamper on behalf of Brittany Davis
Bar No. 24093404
pamela.lamper@wilsonelser.com
Envelope ID: 47487648
Status as of 10/26/2020 2:47 PM CST
Case Contacts
Name
RAMONA LADWIG
Christine Burkhart
Brittany Davis
Efile Las Vegas
Pam Lamper
BarNumber Email
ramona@kazlg.com
christine.burkhart@wilsonelser.com
brittany.davis@wilsonelser.colm
EfileLasVegas.@wilsonelser.com
pamela.lamper@wilslonelser.com
TimestampSubmitted
10/23/2020 4:06:04 PM
10/23/2020 4:06:04 PM
10/23/2020 4:06:04 PM
10/23/2020 4:06:04 PM
10/23/2020 4:06:04 PM
Status
SENT
SENT
ERROR
ERROR
ERROR