Plaintiff's Reply to Defendant's Response Regarding Their Traditional Motion for Summary Judgment - Answer/Contest/Response/Waiver Index # 30 - Martin Gomez V. Mellon Real Estate, Inc.

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On February 23, 2022 a case was filed by Gomez, Martin, represented by Joshua A. Estes, against Mellon Real Estate Inc, represented by H Scott Alexander, in the jurisdiction of Fort Bend County. Judge Surendran K. Pattel presiding.

                        
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CAUSENO. 22-DCV-291322

  MARTIN GOMEZ                                                    IN THE DISTRICT COURT OF
  PLAINTIFF,


                                                                  FORT BEND COUNTY, TEXAS


   MELLON        REAL ESTATE, INC.                                     TH JUDICIAL DISTRICT
  DEFENDANT(S)

                        REPLY TO DEFENDANT S RESPONSE REGARDING THEIR
                    TRADITIONAL MOTION FOR SUMMARY JUDGMENT



TO THE HONORABLE                JUDGE PATTEL:

         COMES NOW, Plaintiff, Martin Gomez and files this reply and would respectfully show

the court as follows:

                                                   Summary

         Defendant owned the property for over 30 years, knew there was no lights
         illuminating the streets, knew of the ordinances (he was on the committee regarding
         the changes) and failed to have lighted streets at night as required.
         Because he violated the ordinances, he breached …