Sam Smith v. ABC Trucking
MSJ Response Bundle
Response Due: 1/14/25
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Original MSJ Response
Case Law Review
We read and digested the cases the defense cited to explain what they actually hold versus how they were used in the mot...
CASE REPORT: 24-CV-1029
Plaintiff's Petition Contradicts Deemed Admissions, Precluding Summary Judgment on Liability
Key Findings
Documents We Reviewed
Exhibit_B_1769624756984 • petition_1769624768569 • msj_1769624756984
Why the Court Cannot Grant Summary Judgment
- Whether the 'Release of Lien' signed by Lyle Jackson constitutes a full release of all claims.
- Whether Plaintiff's failure to respond to RFAs 10-14 results in unassailable judicial admissions.
- Whether genuine issues of material fact exist regarding Plaintiff's alleged breach by non-payment.
- Whether Plaintiff's quantum meruit claim is barred by the existence of an express contract.
- Whether Defendant's counterclaims for fraudulent inducement and poor workmanship present triable issues.
The Bottom Line
Summary judgment is improper because significant factual disputes remain regarding the scope and validity of the alleged Release of Lien and the effect of the deemed admissions. Plaintiff's petition directly asserts non-payment and breach, contradicting Defendant's claims of full release and no breach. Furthermore, Defendant's counterclaims for fraudulent inducement and poor workmanship also present contested facts that require resolution at trial.
FILES ALREADY IN YOUR CASE (20)
Defendant_Motion_for_Summary_Judgment_FINAL.pdf
Exhibit_A_Affidavit_of_John_Doe_10-12-25.pdf
Plaintiff_Response_to_Interrogatories_Set_1.pdf
Exhibit_B_Email_Correspondence_Chain_2024-2025.pdf
Defendant_Reply_Brief_in_Support_of_MSJ_Amended.pdf
Exhibit_C_Contract_Agreement_Signed_Copy_Redacted.pdf
Plaintiff_Supplemental_Response_to_Request_for_Admissions.pdf
Exhibit_D_Medical_Records_Dr_Smith_01-15-24_to_06-30-24.pdf
Defendant_Objections_to_Plaintiff_Interrogatories_Set_2.pdf
Exhibit_E_Photographs_Accident_Scene_Property_Damage.pdf
Plaintiff_Motion_to_Compel_Discovery_Responses.pdf
Exhibit_F_Expert_Witness_Report_Dr_Jones_Engineering_Analysis.pdf
Defendant_Response_to_Request_for_Production_Documents_1-50.pdf
Exhibit_G_Deposition_Transcript_John_Doe_Vol_1_Pages_1-200.pdf
Plaintiff_Amended_Complaint_Second_Amended_Verified.pdf
Exhibit_H_Billing_Records_Invoices_Statements_2023-2024.pdf
Defendant_Answer_to_Amended_Complaint_with_Affirmative_Defenses.pdf
Exhibit_I_Surveillance_Video_Footage_Time_Stamped_Redacted.pdf
Plaintiff_Notice_of_Filing_Supplemental_Authority_Case_Law.pdf
Exhibit_J_Insurance_Policy_Documents_Coverage_Declarations_Pages.pdf
Blake Boyd
Senior Case Specialist • DepoGenius
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