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DynCorps' Answer to Original Complaint

DynCorps' Answer to Original Complaint

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Published by DallasObserver

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Published by: DallasObserver on Jun 01, 2010
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06/25/2010

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Defendants' Original Answer to Plaintiff's Original Complaint - Page 1 of 12DALLAS\414945.2
IN THE UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF TEXASDALLAS DIVISIONMICHAEL RIDDLE §§Plaintiff, §§v. § CIVIL ACTION NO. 3:10-cv-00546-L§DYNCORP INTERNATIONAL INC., §MARK RAY, AIMAN K. ZUREIKAT §AND RICHARD C. CASHON §§Defendants. §DEFENDANTS' ORIGINAL ANSWER TO PLAINTIFF'S ORIGINAL COMPLAINT
TO THE HONORABLE UNITED STATES DISTRICT COURTDefendants DynCorp International Inc. ("DynCorp"), Aiman K. Zureikat ("Zureikat")and Richard C. Cashon ("Cashon") (collectively, "Defendants"), through their counsel, Robert E.Sheeder, Bracewell & Giuliani LLP, 1445 Ross Avenue, Suite 3800, Dallas, Texas 75202,answer Plaintiff's Original Complaint ("Complaint") as follows:
FIRST DEFENSE
The Complaint fails, in whole or in part, to state a claim upon which relief can begranted.
SECOND DEFENSE
In response to each of the allegations contained in Plaintiff's Complaint, Defendantsmake the following responses in correspondingly numbered paragraphs:
I. NATURE OF LAWSUIT
1.
 
Defendants are without sufficient knowledge or information to form abelief as to the truthfulness of the allegations in Paragraph 1 of the Complaint, and,accordingly, they are denied.
Case 3:10-cv-00546-L Document 8 Filed 05/27/10 Page 1 of 12 PageID 38
 
Defendants' Original Answer to Plaintiff's Original Complaint - Page 2 of 12DALLAS\414945.2
2.
 
Defendants are without sufficient knowledge or information to form abelief as to the truthfulness of the allegations in Paragraph 2 of the Complaint, and,accordingly, they are denied.3.
 
Defendants deny each and every allegation in Paragraph 3 of theComplaint.
II. JURISDICTION
4.
 
Defendants admit only that this Court has jurisdiction over this matter, butdeny that there is any legal or factual basis to Plaintiff's claims or that Plaintiff is entitledto the relief sought. Venue is inappropriate in the Dallas Division of the NorthernDistrict of Texas. Alternatively, the Fort Worth Division is the more appropriate forum.Defendants deny each and every other allegation contained in Paragraph 4 of theComplaint.
III. PARTIES
5.
 
Defendants admit, based on personnel records, that Plaintiff is anindividual residing in the Northern District of Texas.6.
 
Defendants admit only that DynCorp International Inc. is a Delawarecorporation and CT Corporation System is its designated agent for service of process inthe State of Texas. Defendants deny each and every other allegation contained inParagraph 6 of the Complaint.
Case 3:10-cv-00546-L Document 8 Filed 05/27/10 Page 2 of 12 PageID 39
 
Defendants' Original Answer to Plaintiff's Original Complaint - Page 3 of 12DALLAS\414945.2
7.
 
Defendants admit only that Ray resides in the Northern District of Texas.
 
Defendants deny each and every other allegation contained in Paragraph 7 of theComplaint.8.
 
Defendants deny each and every allegation contained in Paragraph 8 of theComplaint.9.
 
Defendants admit the allegations in Paragraph 9 of the Complaint.10.
 
Defendants admit the allegations in Paragraph 10 of the Complaint.11.
 
Defendants deny each and every allegation contained in Paragraph 11 of the Complaint.
IV. FACTUAL BACKGROUND
12.
 
Defendants deny the allegation in Paragraph 12 of the Complaint thatDynCorp International Inc. hired or employed Plaintiff, but admit the remainingallegations in Paragraph 12 of the Complaint.13.
 
Defendants admit only that a contract between the State Department andDynCorp International LLC included language referencing a database that was referred toas CADRE. Defendants deny each and every other allegation in Paragraph 13 of theComplaint.14.
 
Defendants are without sufficient knowledge or information to form abelief as to the truthfulness of the allegations in Paragraph 14 of the Complaint, and,accordingly, they are denied.15.
 
Defendants deny each and every allegation contained in Paragraph 15 of the Complaint.16.
 
Defendants deny each and every allegation contained in Paragraph 16 of the Complaint.
Case 3:10-cv-00546-L Document 8 Filed 05/27/10 Page 3 of 12 PageID 40

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