DOCUMENT 8

ELECTRONICALLY FILED
7/29/2015 4:28 PM
38-DV-2015-900413.00
CIRCUIT COURT OF
HOUSTON COUNTY, ALABAMA
CARLA H. WOODALL, CLERK

IN THE DISTRICT COURT OF HOUSTON COUNTY, ALABAMA

ALLSTATE INDEMNITY COMPANY, )
ET AL
)
)
Plaintiff,
)
)
v.
)
)
GILBERT CONSTRUCTION, INC.,
)
C/O CHRIS GILBERT
)
)
Defendant.
)

Case No. DV- 2015-900413

ANSWER
Comes now the Defendant, Gilbert Construction, Inc., c/o Chris Gilbert
(collectively, Gilbert), and answers the Complaint as follows:
1.

Defendant Gilbert is without sufficient information to admit or deny the

allegations of paragraph 1 of Plaintiffs Complaint, therefore, Defendant denies same

and demands strict proof thereof.
2.

Defendant Gilbert is without sufficient information to admit or deny the

allegations of paragraph 2 of Plaintiffs Complaint, therefore, Defendant denies same

and demands strict proof thereof.
3.

Defendant Gilbert admits the allegations contained in paragraph 3 of

Plaintiffs Complaint.
4.

Defendant Gilbert denies the allegations contained in paragraph 4 of

Plaintiffs Complaint and demands strict proof thereof.

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5.

Defendant Gilbert denies the material allegations of paragraph 5 of

Plaintiffs Complaint and demands strict proof thereof.

6.

Defendant Gilbert is without sufficient information to admit or deny the

allegations of paragraph 6 of Plaintiffs Complaint, therefore, Defendant denies same

and demands strict proof thereof.
7.

Defendant Gilbert is without sufficient information to admit or deny the

allegations contained in paragraph 7 of Plaintiffs Complaint, therefore, Defendant

denies same and demands strict proof thereof.
8.

Defendant Gilbert is without sufficient information to admit or deny the

allegations contained in paragraph 8 of Plaintiffs Complaint, therefore, Defendant

denies same and demands strict proof thereof.
9.

Defendant Gilbert denies the allegations contained in paragraph 9 of

Plaintiffs Complaint, therefore, Defendant denies same and demands strict proof
thereof.
10.

Defendant Gilbert denies the allegations contained in paragraph 10 of

Plaintiffs Complaint and demands strict proof thereof.

11.

Defendant Gilbert is without sufficient information to admit or deny the

allegations contained in paragraph 11 of Plaintiffs Complaint, therefore, Defendant

denies same and demands strict proof thereof.
12.

Defendant Gilbert is without sufficient information to admit or deny the

allegations contained in paragraph 12 of Plaintiffs Complaint, therefore, Defendant

denies same and demands strict proof thereof.
2

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13.

The last paragraph is unnumbered and is Plaintiffs prayer for relief, As

such, it requires no answer, but insofar as an answer may be deemed necessary,

Defendant denies the allegations and demands strict proof thereof.

Respectfully submitted this 29th day of July, 2015.

/s/ Ashton H. Ott

Ashton H. Ott (HOL080)
Attorney for Defendant
OF COUNSEL:
Farmer, Price, Hornsby & Weatherford, LLP
P.O. Drawer 2228
Dothan, AL 36302
(334) 793-2424
(334) 793-6624-Fax
aott@fphw-law.com
CERTIFICATE OF SERVICE
I hereby certify that the above and foregoing was served with the Clerk of the
Court using the AlaFile system, which will perfect service on AlaFile participants
electronically, and a copy has been mailed by the United States Postal Service to any
non-participants of AlaFile, properly addressed and postage prepaid, this 29th day of
July, 2015, upon the following:
Samuel James Weisgarber, Esq.
VARNER & ASSOCIATES
2600 Corporate Drive, Ste. 200
2600 Meadow Brook South
Birmingham, AL 35242
/s/Ashton H. Ott
Of Counsel