Answer: HADNOTT, WILLIAM vs. JACKSON, CONNIE G

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                                CAUSE NO. 2018-47252

                  WILLIAM HADNOT, SARAH J.                            §        IN THE DISTRICT COURT
                  HUMPHREY, JUDY JACKSON and                          §
                  FRANKIE J. LONG

                                            Plaintiffs,
                                                                      §        HARRIS COUNTY, TEXAS
                  vs.

                   CONNIE G. JACKSON AND LOYE                         §
                  J. JACKSON                                          §        129TH JUDICIAL DISTRICT

                                                 DEFENDANTS’ ORIGINAL ANSWER

                  TO THE HONORABLE JUDGE OF SAID COURT

                          NOW     COMES       Connie    G.   Jackson   and   Loye    J. Jackson    (hereinafter,   "Defendant”),

                  Defendant    named    in  the  above   entitled  and  numbered     cause   and  files its Original   Answer     to

                  Plaintiff's Original Petition, and in support thereof would respectfully show unto the Court and

                  jury as follows:

                                                                         I.
                                                             GENERAL DENIAL

                          As  is  authorized   by  Rule   92  of the  Texas   Rules   of  Civil  Procedure,   Defendant     denies

                  each and every, all and singular, the allegations made in Plaintiff’s Original Petition. Defendant

                  says further that,   since Plaintiff has made all these allegations, she should be required to prove

                  each and every one of them by a preponderance of all the credible evidence.

                                                                         II.
                                                           STATEMENT OF CASE

                          Plaintiffs’  have    brought    the  lawsuit   in  bad   faith  and   allegations    are  exaggerated,

                  groundless    and  brought    for the  purpose    of  harassment    and/or   greed.  Plaintiffs  complain    that

                  Defendants has possession of property and they have no benefit of property, such as leasing or
                  selling  of the  property.    This  is a home    left to Plaintiffs  and  Defendants     as a  family  property.

                  Many    for the  Defendant’s    and   Plaintiff’s  family  member     have   resided  at the  property   without

                  paying rent.    In fact, Defendants are the only know family members who have been asked to pay

                  rent  or  to whom     rent has   been  access.    William    Hadnot,    Frankie   Long,   Emily    Hadnot,   Ray

                  Jackson   and   an  entire host  of  Plaintiffs  and  Defendants     relatives  have  resided   at the  property

                  located at 1403 Palmer, Houston, Texas 77003, when they need shelter.                None paid rent and none

                  was asked to pay rent.

                          The home remained empty when no family member was residing there.                    The property has

                  never   been  listed  for rent  through   any   form  of  formal   advertisement.     To   my   knowledge,    the

                  property has    been  leased   once  to a  renter  by William Hadnot.       He   was  the  only beneficiary of

                  monetary benefit of that lease.       Defendants did not benefit financial from that lease.          That is the

                  only time    Defendant    can  recall  the property   being   lease  or occupied    by  someone    other  than   a

                  family member.

                          The plaintiff complains of the property taxes.          The property taxes are divided among the

                  family members, Defendant is included and Defendants pays equal share of the taxes.                   The taxes

                  are not divided up in the percentage as in paragraph 8a in Plaintiff’s original petition.

                          At  the  present  time,  this  home   is the  only   shelter available   to  Defendants.     Defendant

                  Loye J. Jackson is severely affected by cerebral palsy and the property was built to accommodate

                  wheelchairs and wheelchair bound persons.

                          Defendants protest the sale of the property because it is Defendants homestead.
                                                                        III.
                                                                    PRAYER

                  WHEREFORE, PREMISES CONSIDERED, Defendant prays that it have judgment of the Court

                  that Plaintiff take nothing by this suit, that all relief requested by Plaintiff be denied, and all of

                  Plaintiff’s  causes   of   action  be   dismissed    with   prejudice   to  the  refiling  of  same;    and  that

                  Defendants    are  allowed   to  live in  home   until  they  can  afford  a  home   suitable   and  affordable;

                  Defendants    further  prays   for such  other  and   further  relief, both  general  or  special,  at law  or  in

                  equity, to which it may show itself to be justly entitled.



                                                             Respectfully submitted,

                                                             /s/Connie G. Jackson
                                                             Connie G. Jackson, Pro Se
                                                             Loye J. Jackson, Pro Se
                                                             1403 Palmer
                                                             Houston, Texas 77003


                                                     CERTIFICATE OF SERVICE

                          This   is to  certify   that  a  true   and   correct   copy   of the   foregoing    instrument      has

                  been delivered to all parties of record, in compliance with Rule 21a of the Texas Rules of

                  Civil Procedure on this 27th day of August:


                  Sarah J. Humphrey
                  1507 Pennsylvania Ave SE,
                  Washington, DC 20003
                  Humsar40@yahoo.com
                  Attorney for Plaintiffs