Defendants Kopper Funding Corporation, Nicolas M. Bazan, P.C. and Nicolas M. Bazan's Response to Plaintiff's First Bank's Amended Motion for Summary Judgment

On December 19, 2016 a debt/contract - debt/contract case was filed by First Bank, represented by Hart, Vickilyn Wilkinson, against Bazan, Brenda W (As Heir Representative Administrator Or, Bazan, Nicolas M, Kopper Funding Corporation, and Nicolas M Bazan P C, represented by Bazan, Nicolas M., in the jurisdiction of Harris County. Judge URSULA A. HALL presiding.

                        
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CAUSE NO. 2016-86829 FIRST BANK, IN THE DISTRICT COURT OF Plaintiff, VS. HARRIS COUNTY, TEXAS KOPPER FUNDING CORPORATION and NICOLAS M. BAZAN, P.C., Defendants. On On Or Ur on On Lor LOD 165™ JUDICIAL DISTRICT DEFENDANTS KOPPER FUNDING CORPORATION, NICOLAS M. BAZAN, P.C. AND NICOLAS M. BAZAN’S RESPONSE TO PLAINTIFF FIRST BANK’S AMENDED MOTION FOR SUMMARY JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: Comes now Defendants, Kopper Funding Corporation, Nicolas M. Bazan, P.C and Nicolas M. , Bazan, Individually, (hereinafter Defendants and/or Defendants/CounterPlaintiffs) and brings this their Response to the Plaintiff First Banks’, (hereinafter Plaintiff and or Plaintiff/CounterDefendant) Amended Motion for Summary Judgment and would show the Court as follows. IL. THE FACTS OF THIS CASE 1. For the purpose of brevity, the Defendants refer the Court to the facts of the case as already outlined in the Defendants’ Fourth Amended Motion for Continuance filed on or about September 20, 2…

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