Preview
Electronically Filed
12/29/2021 1:28 PM
Hidalgo County District Clerks
Reviewed By: Keila Hernandez
CAUSE NO.: C-1392-21-B
WALID HAIDAR, INDIVIDUALLY, § IN THE DISTRICT COURT
AND AS REPRESENTATIVE OF 415 §
TRENTON, L.L.C. D/B/A WALK- §
ON'S SPORTS BISTREAUX, §
Plaintiffs / Counter Defendants, §
§
Vs. §
§
G&G CLOSED CIRCUIT EVENTS, §
L.L.C., § 93rd JUDICIAL DISTRICT
Defendant / Counter Plaintiff, §
§
Vs. §
§
MOUSSA HAIDAR, §
INDIVIDUALLY, AND D/BA WALK- §
ON’S SPORTS BISTREAUX & BAR, §
Third-Party Counter Defendants § HIDALGO COUNTY, TEXAS
THIRD PARTY COUNTER DEFENDANT MOUSSA HAIDAR’S FIRST
AMENDED ORIGINAL ANSWER, GENERAL DENIAL, AND AFFIRMATIVE
DEFENSES
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Third Party Counter-Defendant, MOUSSA HAIDAR,
INDIVUDALLY AND AS REPRESENTATIVE OF 415 TRENTON, L.L.C. D/B/A
WALK-ON’S SPORTS BISTREAUX incorrectly named WALK-ON’S SPORTS
BISTREAUX & BAR (hereinafter referred to as “Third-Party Counter-Defendant, and
files this his First Amended Original Answer, General Denial, and Verified Affirmative
Pleas to Defendant G&G Closed Circuit Events, LLC’s Original Counterclaim and Third-
Party Petition and would show the court the following:
First Amended Original Answer, General Denial, and Verified Affirmative Pleas
Page 1
Electronically Filed
12/29/2021 1:28 PM
Hidalgo County District Clerks
Reviewed By: Keila Hernandez
General Denial
Third-Party Counter-Defendant denies each and every, all and singular, of the
allegations contained in Defendant G&G Closed Circuit Events, LLC’s Original
Counterclaim and Third-Party Petition pursuant to Rule 92 of the Texas Rules of Civil
Procedure, and upon trial will demand strict proof thereof by a preponderance of the
evidence.
Verified Affirmative Pleas
Pursuant to Texas Rule of Civil Procedure 93(1) & (2), the counter defendant,
Moussa Haidar, affirmatively plea that they do not have the legal capacity to be sued or be
held liable in this law suit. As per Tex. Bus. Orgs. Code § 101.114, “a member or manager
is not liable for a debt, obligation, or liability of a limited liability company, including a
debt, obligation, or liability under a judgment, decree, or order of a court.” Here, Moussa
Haidar has been named as counter defendants in G&G Closed Circuit Events, LLC’s
Counterclaim and Third-Party Petition. However, the causes of action and statutory
penalties it seeks to enforce can only be enforced as to 415 Trenton, L.L.C. d/b/a Walk-
On’s Sports Bistreaux, if at all. Furthermore, Moussa Haidar neither individually nor
personally acted in such a way to commit any of the alleged violations.
Prayer
WHEREFORE, Third-Party Counter-Defendant prays that after proceeding are
had, judgment is entered that Defendant/ Counter Plaintiff G&G closed Circuit Events,
L.L.C. take nothing, that the Petition be dismissed with prejudice, and for all other relief
to which it may be entitled at law or in equity.
First Amended Original Answer, General Denial, and Verified Affirmative Pleas
Page 2
Electronically Filed
12/29/2021 1:28 PM
Hidalgo County District Clerks
Reviewed By: Keila Hernandez
Respectfully Submitted,
P. GARZA LAW FIRM, P.C.
5429 N. 23rd Street, Suite D
McAllen, Texas 78504
Telephone: (956) 627-2724
Telecopier: (210) 568-6115
Email: eservice@pgarzalaw.com
By: /s/ Pablo Garza III
Pablo Garza III
State Bar No. 24059209
Attorney for Third Party Counter
Defendant - Moussa Haidar
CERTIFICATE OF SERVICE
I, Pablo Garza III, do hereby certify that a true and correct copy of the foregoing
instrument was forwarded to the attorney listed below by the method of service indicated
on December 28, 2021.
Via E-Filing Service
Mr. David M. Diaz
Law Offices of David Diaz, PLLC
825 Watters Creek Blvd, Build. M, Suite 250
Allen, Texas 75013
Email: david@diazlawtx.com
/s/ Pablo Garza III
Pablo Garza III
First Amended Original Answer, General Denial, and Verified Affirmative Pleas
Page 3
Electronically Filed
12/29/2021 1:28 PM
Hidalgo County District Clerks
Reviewed By: Keila Hernandez
VERIFICATIUN
CAUSE NEL: C-1392-21-B
WALLD HMBAR, INDIVIDUALLY, § IN THE DISTRICT COURT
AND AS REPRESENTATIVE OF 415 §
TRENTUN, L.L.C. DIEM. WALKH
ON’S SPflRT'S BISTREAUX,
Pfafnnfi'i,
Vs.
G&G CLUSED CIRCUIT EVENTS,
L.L.C.,
Defendam.
m nmmmL
{Nflmwmmmmfimlflwfimwmmm
DISTRICT
Vs.
M01} SSA MAR,
INDIVIDUALLY, AND IHBA WALK-
DN’S SPHRTS EISTREAUX & BAR,
T&Erd—Pm Counter flefifldam‘ HmAIflfl COUNTY, TEXAS
STATE 0F TEXAS
WW5”
C0 UNTY flF HJBALGfl
VERIFICATION 0F MflUSSA HAIDAR
BEFORE ME, the undersigned authority, on thifi day pmonally appeared Mnussa
Haidar known m Inc to be the parsnn “hose name is subscribed to the fnregoh-jg
imtmment
and acknowledgeri to that she executed the same for the pmposcs and
considmmion therein
expressed.
“My name is Melissa Haidar; I am the Plaintiff in the abave—refereflced matter, I
am over the age of eightma-n (13) years. I am compfitcni and authorizad to testify 10 the
facts set forth herein. I have read the foregoing Firs! Amended
Original Answer, General
Denial, andAfimative Defamer; therein are true and correct.”
I
Maussa Haidar, individually, and on behaif
fif415 Trenton, L.L.C. dfbr’a Walkufln’s
Sports Bisteaux
First Amendeé Original Answer, General Dania], and Verified Affirmative
Pleas
Page 4
Electronically Filed
12/29/2021 1:28 PM
Hidalgo County District Clerks
Reviewed By: Keila Hernandez
SWORN
-
aa
1:0 and subscribed before me by the said person cm this
December, 2H2], to emit}; which “fitness my hand and seal Gf offing.
$332333”
My Cummhsinn
m 15. 1m
Expires
NOT; ARYPUELIC
Commissinn cxpimfi:
w 23‘“
2
day 0f
5
Fin! Amended Original Answer, General Denial, and Verified Affirmative Pleas
Page 5
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Pablo Garza
Bar No. 24059209
pablo@pgarzalaw.com
Envelope ID: 60370216
Status as of 12/29/2021 2:25 PM CST
Associated Case Party: Walid Haidar
Name BarNumber Email TimestampSubmitted Status
Lit Docket lit-docket@moore-firm.com 12/29/2021 1:28:26 PM SENT
Kimberly Garcia kimberly@pgarzalaw.com 12/29/2021 1:28:26 PM SENT
E Service eservice@pgarzalaw.com 12/29/2021 1:28:26 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
david diaz david@diazlawtx.com 12/29/2021 1:28:26 PM SENT
Preview
Electronically Filed 12/29/2021 1:28 PM Hidalgo County District Clerks Reviewed By: Keila Hernandez CAUSE NO.: C-1392-21-B WALID HAIDAR, INDIVIDUALLY, § IN THE DISTRICT COURT AND AS REPRESENTATIVE OF 415 § TRENTON, L.L.C. D/B/A WALK- § ON'S SPORTS BISTREAUX, § Plaintiffs / Counter Defendants, § § Vs. § § G&G CLOSED CIRCUIT EVENTS, § L.L.C., § 93rd JUDICIAL DISTRICT Defendant / Counter Plaintiff, § § Vs. § § MOUSSA HAIDAR, § INDIVIDUALLY, AND D/BA WALK- § ON’S SPORTS BISTREAUX & BAR, § Third-Party Counter Defendants § HIDALGO COUNTY, TEXAS THIRD PARTY COUNTER DEFENDANT MOUSSA HAIDAR’S FIRST AMENDED ORIGINAL ANSWER, GENERAL DENIAL, AND AFFIRMATIVE DEFENSES TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Third Party Counter-Defendant, MOUSSA HAIDAR, INDIVUDALLY AND AS REPRESENTATIVE OF 415 TRENTON, L.L.C. D/B/A WALK-ON’S SPORTS BISTREAUX incorrectly named WALK-ON’S SPORTS BISTREAUX & BAR (hereinafter referred to as “Third-Party Counter-Defendant, and files this his First Amended Original Answer, General Denial, and Verified Affirmative Pleas to Defendant G&G Closed Circuit Events, LLC’s Original Counterclaim and Third- Party Petition and would show the court the following: First Amended Original Answer, General Denial, and Verified Affirmative Pleas Page 1 Electronically Filed 12/29/2021 1:28 PM Hidalgo County District Clerks Reviewed By: Keila Hernandez General Denial Third-Party Counter-Defendant denies each and every, all and singular, of the allegations contained in Defendant G&G Closed Circuit Events, LLC’s Original Counterclaim and Third-Party Petition pursuant to Rule 92 of the Texas Rules of Civil Procedure, and upon trial will demand strict proof thereof by a preponderance of the evidence. Verified Affirmative Pleas Pursuant to Texas Rule of Civil Procedure 93(1) & (2), the counter defendant, Moussa Haidar, affirmatively plea that they do not have the legal capacity to be sued or be held liable in this law suit. As per Tex. Bus. Orgs. Code § 101.114, “a member or manager is not liable for a debt, obligation, or liability of a limited liability company, including a debt, obligation, or liability under a judgment, decree, or order of a court.” Here, Moussa Haidar has been named as counter defendants in G&G Closed Circuit Events, LLC’s Counterclaim and Third-Party Petition. However, the causes of action and statutory penalties it seeks to enforce can only be enforced as to 415 Trenton, L.L.C. d/b/a Walk- On’s Sports Bistreaux, if at all. Furthermore, Moussa Haidar neither individually nor personally acted in such a way to commit any of the alleged violations. Prayer WHEREFORE, Third-Party Counter-Defendant prays that after proceeding are had, judgment is entered that Defendant/ Counter Plaintiff G&G closed Circuit Events, L.L.C. take nothing, that the Petition be dismissed with prejudice, and for all other relief to which it may be entitled at law or in equity. First Amended Original Answer, General Denial, and Verified Affirmative Pleas Page 2 Electronically Filed 12/29/2021 1:28 PM Hidalgo County District Clerks Reviewed By: Keila Hernandez Respectfully Submitted, P. GARZA LAW FIRM, P.C. 5429 N. 23rd Street, Suite D McAllen, Texas 78504 Telephone: (956) 627-2724 Telecopier: (210) 568-6115 Email: eservice@pgarzalaw.com By: /s/ Pablo Garza III Pablo Garza III State Bar No. 24059209 Attorney for Third Party Counter Defendant - Moussa Haidar CERTIFICATE OF SERVICE I, Pablo Garza III, do hereby certify that a true and correct copy of the foregoing instrument was forwarded to the attorney listed below by the method of service indicated on December 28, 2021. Via E-Filing Service Mr. David M. Diaz Law Offices of David Diaz, PLLC 825 Watters Creek Blvd, Build. M, Suite 250 Allen, Texas 75013 Email: david@diazlawtx.com /s/ Pablo Garza III Pablo Garza III First Amended Original Answer, General Denial, and Verified Affirmative Pleas Page 3 Electronically Filed 12/29/2021 1:28 PM Hidalgo County District Clerks Reviewed By: Keila Hernandez VERIFICATIUN CAUSE NEL: C-1392-21-B WALLD HMBAR, INDIVIDUALLY, § IN THE DISTRICT COURT AND AS REPRESENTATIVE OF 415 § TRENTUN, L.L.C. DIEM. WALKH ON’S SPflRT'S BISTREAUX, Pfafnnfi'i, Vs. G&G CLUSED CIRCUIT EVENTS, L.L.C., Defendam. m nmmmL {Nflmwmmmmfimlflwfimwmmm DISTRICT Vs. M01} SSA MAR, INDIVIDUALLY, AND IHBA WALK- DN’S SPHRTS EISTREAUX & BAR, T&Erd—Pm Counter flefifldam‘ HmAIflfl COUNTY, TEXAS STATE 0F TEXAS WW5” C0 UNTY flF HJBALGfl VERIFICATION 0F MflUSSA HAIDAR BEFORE ME, the undersigned authority, on thifi day pmonally appeared Mnussa Haidar known m Inc to be the parsnn “hose name is subscribed to the fnregoh-jg imtmment and acknowledgeri to that she executed the same for the pmposcs and considmmion therein expressed. “My name is Melissa Haidar; I am the Plaintiff in the abave—refereflced matter, I am over the age of eightma-n (13) years. I am compfitcni and authorizad to testify 10 the facts set forth herein. I have read the foregoing Firs! Amended Original Answer, General Denial, andAfimative Defamer; therein are true and correct.” I Maussa Haidar, individually, and on behaif fif415 Trenton, L.L.C. dfbr’a Walkufln’s Sports Bisteaux First Amendeé Original Answer, General Dania], and Verified Affirmative Pleas Page 4 Electronically Filed 12/29/2021 1:28 PM Hidalgo County District Clerks Reviewed By: Keila Hernandez SWORN - aa 1:0 and subscribed before me by the said person cm this December, 2H2], to emit}; which “fitness my hand and seal Gf offing. $332333” My Cummhsinn m 15. 1m Expires NOT; ARYPUELIC Commissinn cxpimfi: w 23‘“ 2 day 0f 5 Fin! Amended Original Answer, General Denial, and Verified Affirmative Pleas Page 5 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Pablo Garza Bar No. 24059209 pablo@pgarzalaw.com Envelope ID: 60370216 Status as of 12/29/2021 2:25 PM CST Associated Case Party: Walid Haidar Name BarNumber Email TimestampSubmitted Status Lit Docket lit-docket@moore-firm.com 12/29/2021 1:28:26 PM SENT Kimberly Garcia kimberly@pgarzalaw.com 12/29/2021 1:28:26 PM SENT E Service eservice@pgarzalaw.com 12/29/2021 1:28:26 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status david diaz david@diazlawtx.com 12/29/2021 1:28:26 PM SENT