On January 27, 2010 a
Defendant's Original Answer - FILED BY KIM HOA THI LUONG - rec. via cert. mail
was filed
involving a dispute between
Lone Star National Bank,
and
Luong, Kim Hoa Thi,
for Contract - Consumer/Commercial/Debt
in the District Court of Hidalgo County.
Preview
ML m
'
AT
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O'CL
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M
MAR 30 2023
ARTURO W00 M., COWTY GEM
W __0FHDALGOW.
" "a u"
CAUSE N0. CL-10-0231-A u
U fl
LONE STAR NATIONAL BANK, § IN THE COUNTY
COURT
Plaintiff, §
§
v. § AT LAW NUMBER
ONE
§
KIM HOA Tm LUONG, §
Defendant. § . 0F HIDALGO COUNTY,
TEXAS
DEFENDANT’S ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
I, KIM HOA THI LUONG, named the Defendant in the above-entitled and
numbered cause, and in response to Plaintiff‘s Application for Writ of Scire Facias to Revive
Dormant Judgment, am filing my Original Answer and in support thereof respectfully show l
unto the Court the follow:
I. GENERAL DENIAL
deny each and every,
l all and singular, allegations set forth in Plaintiff‘s
Application, and without waiving my and further pleadings, motions and
right to file other
discovery. demands that Plaintiff be held to the most
requirements of proof, that Plaintiff
strict
be required to prove the charges and allegation made against me. ln addition. invokes my due l
process protection guaranteed under the United States and Texas Constitutions; each of which
provide procedural and substantive protection from deprivation 0f property without due process
of law. pray for such other and further relief, both general and special,
l at law and in equity, to
which may be justly entitled to whether specially prayed for or not.
l
WHEREFORE. PREMISES CONSIDERED l pray that the Court enter judgment in
my favor and against Plaintiff whereby Plaintiff takes nothing, that costs be assessed against
Plaintiff and l recover my cost incurred by reason 0f this suit, and that the Court award me all
other and further relief, both general and special, at law and in equity, to which I may be justly
entitled whether specially prayed for or not. l hereby state that I will be in coun the day of the
hearing and am respectfully requesting an option to pay the Judgment.
M
l
Respectfully submitted,
flu) V?
KIM H0 LU6NG
l l9l8 Auburn Brook
San Antonio, Texas 78253
Telephone No. (832) 298-2149
Email: kimhoaluong@gmail.com
CERTIFICATE OF SERVICE
l certify that on March Z 1', 2023 a true and correct copy of my Answer was served
by U.S. Mail as indicated below.
LSML
Weldon Beau Nixon
WALSH, MCGURK, CORDOVA, NIXON, PLLC
1506 South Lone Star Way. Suite 10
'
Edinburg, Texas 78539
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Document Filed Date
March 30, 2023
Case Filing Date
January 27, 2010
Category
Contract - Consumer/Commercial/Debt
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ML m ' AT ' O'CL ' M MAR 30 2023 ARTURO W00 M., COWTY GEM W __0FHDALGOW. " "a u" CAUSE N0. CL-10-0231-A u U fl LONE STAR NATIONAL BANK, § IN THE COUNTY COURT Plaintiff, § § v. § AT LAW NUMBER ONE § KIM HOA Tm LUONG, § Defendant. § . 0F HIDALGO COUNTY, TEXAS DEFENDANT’S ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: I, KIM HOA THI LUONG, named the Defendant in the above-entitled and numbered cause, and in response to Plaintiff‘s Application for Writ of Scire Facias to Revive Dormant Judgment, am filing my Original Answer and in support thereof respectfully show l unto the Court the follow: I. GENERAL DENIAL deny each and every, l all and singular, allegations set forth in Plaintiff‘s Application, and without waiving my and further pleadings, motions and right to file other discovery. demands that Plaintiff be held to the most requirements of proof, that Plaintiff strict be required to prove the charges and allegation made against me. ln addition. invokes my due l process protection guaranteed under the United States and Texas Constitutions; each of which provide procedural and substantive protection from deprivation 0f property without due process of law. pray for such other and further relief, both general and special, l at law and in equity, to which may be justly entitled to whether specially prayed for or not. l WHEREFORE. PREMISES CONSIDERED l pray that the Court enter judgment in my favor and against Plaintiff whereby Plaintiff takes nothing, that costs be assessed against Plaintiff and l recover my cost incurred by reason 0f this suit, and that the Court award me all other and further relief, both general and special, at law and in equity, to which I may be justly entitled whether specially prayed for or not. l hereby state that I will be in coun the day of the hearing and am respectfully requesting an option to pay the Judgment. M l Respectfully submitted, flu) V? KIM H0 LU6NG l l9l8 Auburn Brook San Antonio, Texas 78253 Telephone No. (832) 298-2149 Email: kimhoaluong@gmail.com CERTIFICATE OF SERVICE l certify that on March Z 1', 2023 a true and correct copy of my Answer was served by U.S. Mail as indicated below. LSML Weldon Beau Nixon WALSH, MCGURK, CORDOVA, NIXON, PLLC 1506 South Lone Star Way. Suite 10 ' Edinburg, Texas 78539 F'zuw : KJM Hon “Fm LuéNcr Haw: Augmaw anzooK $4.75! Srfirw MHm o 7x 7&2 55 :mumwwmn m US POSTAGE FRST-cuss ousmsssso 7:251 «moms «mosxmo Kwnoo 06:2q u ?DEE 3330 DUEL 317H ”3‘12 Emma , £202 G Z W'N aaAIaoaa P4). 80% 95 gDwaA/cr W 7K§4b nnmdnl" [3 nm/b/ 785Q0~ 005358 ulolhnn,"Ilniu“‘1’1M2,1pm};Ihhu' \