Exhibit A-Counter-Defendant First Bank's Original Answer

• 
• 
• 
• 
• 
• 

                        

						    Preview
                        
                        
                          EXHIBIT ANo. 2016-86829

FIRST BANK § IN THE DISTRICT COURT
§
§

vs. § HARRIS COUNTY, TEXAS
§

KOPPER FUNDING CORPORATION and §

NICOLAS M. BAZAN, P.C. § 165th JUDICIAL DISTRICT

COUNTER-DEFENDANT FIRST BANK’S ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF THIS COURT:

COMES NOW, Counter-Defendant FIRST BANK (“First Bank”), and would show the Court
the following:

1. General Denial. First Bank enters a general denial of the charges and allegations
contained in the ORIGINAL COUNTERCLAIM OF KOPPER FUNDING CORPORATION, and
any amendment or supplement thereto, and accordingly, requests that the Court require KOPPER
FUNDING CORPORATION, NICOLAS M. BAZAN, P.C. (“Corporate Guarantor”), and NICOLAS
M. BAZAN (“Individual Guarantor”) (collectively called herein, “Defendants”) to prove those
charges and allegations by a preponderance of the evidence, as required by the Constitution and laws
of the State of Texas.

2. Specific Denials. Without waiving the foregoing, First Bank specifically:

a. Denies…