Jones et al v. Halliburton Company et al

Filing 119

ANSWER to 116 Amended Answer, Counterclaim by Jamie Leigh Jones, filed.(Vicknair, Heidi)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
JAMIE LEIGH JONES,
Plaintiff,

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v.
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HALLIBURTOIN COMPANY d/b/a KBR
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KELLOGG BROWN & ROOT (KBR);
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KELLOGG BROWN & ROOT, SERVICES,
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INC.; KELLOGG BROWN & ROOT
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INTERNATIONAL, INC.; KELLOGG
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BROWN & ROOT, LLC; KELLOGG BROWN §
& ROOT, INC.; KELLOGG BROWN &
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ROOT, S. de R.L.; KELLOGG BROWN &
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ROOT (KBR), INC.; KBR TECHNICAL
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SERVICES, INC.; OVERSEAS
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ADMINISTRATIVE SERVICES, LTD.; ERIC §
ILER; CHARLES BOARTZ; and SEVERAL
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JOHN DOE RAPISTS
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Defendants.
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CIVIL ACTION NO. 4:07-CV-02719

JURY TRIAL DEMANDED

PLAINTIFF’S ANSWER TO DEFENDANTS’ COUNTER-CLAIM

TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Jamie Leigh Jones, Plaintiff in the above captioned matter, and files this
Answer to Defendants’ Counter-Claim and would respectfully show the Court as follows:
I.
General Denial
1.

Plaintiff denies generally each and every allegation made by Defendant Bortz in his

Counter-Claim and demands strict proof thereof.
II.
2.

No answer is required by Jones to paragraph number 95.

3.

Plaintiff denies the allegations contained in paragraph 96. Jones denies publishing any

false statements, whether in writing or orally, asserting affirmatively that Defendant Bortz and/or
an accomplice drugged her and brutally raped her. Statements Jones has made in this regard are
true.
4.

Plaintiff denies the allegations contained in paragraph 97. Jones denies she has made

statements about Defendant Bortz that are false. Jones denies that she knew statements she made
about Defendant Bortz were false or that she made them with reckless disregard of the truth.
Jones further denies that she made any false statement about Bortz with the intent to cause
substantial injury or harm to Bortz. Jones further denies that Bortz has sustained general or
special damages.
5.

Plaintiff denies the allegations contained in paragraph 98. Jones denies that her written

statements regarding Bortz are libel as defined by the Texas Civil Practice & Remedies Code or
that her statements about Bortz were calculated to injure Bortz’s reputation. Jones further denies
that her statements about Bortz were calculated to impeach Bortz’s honesty, integrity, virtue or
reputation. Rather, Bortz’ character for honesty, integrity, virtue and reputation can be gleaned
from the fact that he raped the unconscious Jones.
6.

Plaintiff denies the allegations contained in paragraph 99.

Jones denies that her

statements about Bortz drugging and raping her are false.
7.

Plaintiff denies the allegations contained in paragraph 100.

Jones denies that her

statements about Bortz drugging and raping her are false.
8.

Plaintiff denies the allegations contained in paragraph 101.

Jones denies that her

statements about Bortz drugging and raping her are false. Jones denies that her communication
to third parties was unjustified.

Plaintiff’s Answer to Defendants’ Counter-Claim

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9.

Plaintiff denies the allegations contained in paragraph 102.

Jones denies that her

statements about Bortz drugging and raping her are false. Jones further denies that Bortz has
sustained damages.
10.

Plaintiff denies the allegations contained in paragraph 103.

Jones denies that her

statements about Bortz drugging and raping her are false. Jones further denies that Bortz has
sustained damages.
11.

Plaintiff denies the allegations contained in paragraph 104.

Jones denies that her

statements about Bortz drugging and raping her are false or that she acted with malice. Jones
further denies that Bortz has sustained damages.
12.

Plaintiff denies the allegations contained in paragraph 105.

Jones denies that her

statements about Bortz drugging and raping her are false or that she acted with malice. Jones
further denies that Bortz has sustained damages or is entitled to any relief.
III.
Affirmative Defenses
13.

Defendant’s counter-claims are barred by the applicable statute of limitations and/or the

doctrine of laches.
IV.
Conclusion & Prayer
14.

For the reasons stated herein and in the interest of justice, Plaintiff respectfully requests

and prays that Defendant take nothing by reason of this counter-claim, and go hence forth
without his fees or costs. Plaintiff further requests and prays for all other relief that she may
show herself entitled to receive.

Plaintiff’s Answer to Defendants’ Counter-Claim

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Respectfully submitted,

/s/ L. Todd Kelly
THE KELLY LAW FIRM, P.C.
L. Todd Kelly
State Bar No. 24035049
Heidi O. Vicknair
Texas Bar No. 24046557
Jeff Musslewhite
State Bar No. 24041555
One Riverway, Suite 1150
Houston, Texas 77056-1920
713- 255-2055 Telephone
713- 523-5939 Facsimile

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument has been served
on all counsel of record listed below, certified mail, return receipt requested, regular mail and/or
facsimile transmission, on this 11th day of October 2010:

Via US Mail and Facsimile 713-226-6241
Daniel K. Hedges
Porter & Hedges, L.L.P.
1000 Main Street, 36th Floor
Houston, Texas 77002

/s/ L. Todd Kelly
L. Todd Kelly

Plaintiff’s Answer to Defendants’ Counter-Claim

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