Answer: DISCOVER BANK vs. DONALD D RAO

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                FILED
                                                                                                           2/16/2023 11:26 AM
                                                                                                             FELICIA PITRE
                                                                                                           DISTRICT CLERK
                                                                                                        DALLAS CO., TEXAS
                                                                                                      Jeremy Jones DEPUTY


                                   CAUSE NUMBER: DC-23-01312

DISCOVER BANK;                                               §                 IN THE DISTRICT COURT
    PLAINTIFF                                                §
                                                             §
                                                             §
VS.                                                          §               162ND JUDICIAL DISTRICT
                                                             §
DONALD D RAO;                                                §
   DEFENDANT                                                 §                DALLAS COUNTY, TEXAS


                              DEFENDANT’S ORIGINAL ANSWER

  TO THE HONORABLE JUDGE OF SAID COURT:

         COMES NOW

  DONALD D RAO (“Defendant”), Defendant in the above-styled             and numbered cause, and files

  this Original Answer in this action, and would respectfully show the following:

                                                    I.
                                         GENERAL DENIAL
          1.     Defendant generally denies each and every, all and singular, the allegations set forth

  in Plaintiff’s Original Petition, and demands that Plaintiff prove same by a preponderance of the

  credible evidence.

                                                    II.
                                    AF FIRMATIVE DEFENSES
         2.      Defendant pleads the affirmative defense of         LIMITATIONS,        and pleads that

  Plaintiff s alleged damages, if any, are barred by the applicable four (4) year statute of limitations.

                                                    III.
                                                  PRAYER
         3.      WHEREFORE, DEFENDANT               requests judgment   of the Court that Plaintiff take

  nothing by this suit, and that DEFENDANT recover all costs together with such other and further

  relief to which Defendant be justly entitled.

  DEFENDANT’S ORIGINAL ANSWER                                                                  Page   1   of 2
                                                     Respectfully submitted,

                                                     Tom Thomas Legal, P.C.
                                                     4144 N. Central Expy., Ste 870
                                                     Dallas, TX 75204
                                                     214.691.6200
                                                     214.691.6205   —   FAX


                                                     /S/ TOM M. THOMAS II
                                                     Tom M. Thomas II
                                                     SBN: 24030184
                                                     Yvonne Shaw
                                                     SBN: 24070271
                                                     Courts@tomthomaslegal.com
                                                     ATTORNEY FOR DEFENDANT




                                  CERTIFICATE OF SERVICE
       This is to celtify that a true and correct copy of the following instrument was delivered to

all counsel of record pursuant to Rules 21 and 21(a) of the Texas Rules of Civil Procedure, this

the 16th day   of February 2023, via facsimile.




DEFENDANT’S ORIGINAL ANSWER                                                              Page 2 of 2
                         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.

Anastasia Paletykina Cantu on behalf of Tom Max Thomas
Bar No. 24030184
anastasia@tomthomaslegal.com
Envelope ID: 72827325
Status as of 2/16/2023 2:38 PM CST

Associated Case Party: DISCOVER BANK

Name                BarNumber   Email                   TimestampSubmitted       Status
CONSTANCE MUTONG                CMUTONG@ZWICKERPC.COM   2/16/2023 11:26:09 AM    SENT
Zwicker Dallas                  ZATDLit@zwickerpc.com   2/ 16/2023 11:26:09 AM   SENT