FILED
DALLAS COUNTY
10/10/2017 11:03 AM
FELICIA PITRE
DISTRICT CLERK

8994
CAUSE NO. DC-17-06313
JESUS GUZMAN,
Plaintiff,
v.
JMA PARTNERS, INC. d/b/a
GUARDIAN PHARMACY SERVICES,
JACK R. MUNN and PROFESSIONAL
COMPOUNDING CENTERS OF
AMERICA, INC.,
Defendants.

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IN THE DISTRICT COURT

95th JUDICIAL DISTRICT

DALLAS COUNTY, TEXAS

DEFENDANT PROFESSIONAL COMPOUNDING CENTERS
OF AMERICA, INC.’S ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, PROFESSIONAL COMPOUNDING CENTERS OF AMERICA,
INC., a Defendant named in the above entitled and numbered cause, and files this its Original
Answer, and for same would respectfully show unto the Court as follows:
I.
GENERAL DENIAL
Defendant denies each and every, all and singular, the material allegations contained
within Plaintiff’s pleadings and demands strict proof thereof.
II.
JURY DEMAND
In accordance with Rule 216 of the Texas Rules of Civil Procedure, Defendant demands
a trial by jury.
WHEREFORE,

PREMISES

CONSIDERED,

Defendant

PROFESSIONAL

COMPOUNDING CENTERS OF AMERICA, INC. prays that the Plaintiff take nothing by
DEFENDANT PROFESSIONAL COMPOUNDING CENTERS
OF AMERICA, INC.’S ORIGINAL ANSWER

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 this suit, that Defendant go hence with its costs without delay, and for such other and further
relief, both general and special, at law and in equity, to which Defendant may show itself justly
entitled.
Respectfully submitted,
FEE, SMITH, SHARP & VITULLO, L.L.P

/S/ THOMAS W. FEE
THOMAS W. FEE
State Bar No. 06873160
CRAIG H. MYERS
State Bar No. 24013222
RANDALL W. MILLER
State Bar No. 24092838
Three Galleria Tower
13155 Noel Road, Suite 1000
Dallas, Texas 75240
972-934-9100
972-934-9200 [Fax]
tfee@feesmith.com
cmyers@feesmith.com
rmiller@feesmith.com
ATTORNEYS FOR DEFENDANT
PROFESSIONAL COMPOUNDING
CENTERS OF AMERICA, INC.

CERTIFICATE OF SERVICE
THIS WILL CERTIFY that a true and correct copy of the foregoing document was
electronically served and that the electronic transmission was reported complete on the 10th day
of October, 2017.

/S/ THOMAS W. FEE
THOMAS W. FEE

DEFENDANT PROFESSIONAL COMPOUNDING CENTERS
OF AMERICA, INC.’S ORIGINAL ANSWER

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