On October 11, 2021 a
Defendant's Original Answer - Answer/Contest/Response/Waiver Index # 6
was filed
involving a dispute between
Discover Bank,
and
Chacko, Tomichan I,
for Contract - Consumer/Commercial/Debt
in the District Court of Fort Bend County.
Preview
Cause No. DCV
DISCOVER BANK, IN THE DISTRICT COURT
Plaintiff
JUDICIAL DISTRICT
TOMICHAN I. CHACKO
Defendant FORT BEND COUNTY, TEXAS
DEFENDANT’ ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES TOMICHAN I. CHACKO, Defendant in this cause, and files this Original
Answer, and in support thereof would respectfully show the Court the following:
GENERAL DENIAL
Defendant den each and every, all and singular, the allegations of the Petition, and
demand strict proof thereof, in accordance with Rule 92 of the Texas Rules of Civil Procedure.
II. PRAYER
WHEREFORE, premises considered, Defendant respectfully request that upon final
hearing in this matter (1) Plaintiff takes nothing by its Petition; (2) the Court enter a Judgment
declaring the rights of the parties, as set forth above; and ( ) the Court grant Defendant such other
and further relief to which may show himself to be entitled.
Respectfully submitted,
ULPEPPER , P.C.
Paul Culpepper
SBN: 24032105
P.O. Box 1413
ugar Lan Texas 774
Tel: (281) 494
Fax: (281) 494
mail: paul@culpepper law.com
ATTORNEY FOR DEFENDANT
CERTIFICATE OF SERVICE
I certify that on January 20, 2022, a copy of Defendant’s Original Answer was served by the
method indicated upon the following:
Via Facsimilie (281) 494-0213 and/or E-mail Transmission
Chidi A. Oha
Zwicker & Associates, P.C.
14090 Southwest Frwy., Suite 408
Sugar Land, TX 77478
E-mail: zate_litigation@zwickerpc.com
Attorney for Plaintiff
Paul Culpepper
Document Filed Date
January 20, 2022
Case Filing Date
October 11, 2021
Category
Contract - Consumer/Commercial/Debt
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Cause No. DCV DISCOVER BANK, IN THE DISTRICT COURT Plaintiff JUDICIAL DISTRICT TOMICHAN I. CHACKO Defendant FORT BEND COUNTY, TEXAS DEFENDANT’ ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES TOMICHAN I. CHACKO, Defendant in this cause, and files this Original Answer, and in support thereof would respectfully show the Court the following: GENERAL DENIAL Defendant den each and every, all and singular, the allegations of the Petition, and demand strict proof thereof, in accordance with Rule 92 of the Texas Rules of Civil Procedure. II. PRAYER WHEREFORE, premises considered, Defendant respectfully request that upon final hearing in this matter (1) Plaintiff takes nothing by its Petition; (2) the Court enter a Judgment declaring the rights of the parties, as set forth above; and ( ) the Court grant Defendant such other and further relief to which may show himself to be entitled. Respectfully submitted, ULPEPPER , P.C. Paul Culpepper SBN: 24032105 P.O. Box 1413 ugar Lan Texas 774 Tel: (281) 494 Fax: (281) 494 mail: paul@culpepper law.com ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE I certify that on January 20, 2022, a copy of Defendant’s Original Answer was served by the method indicated upon the following: Via Facsimilie (281) 494-0213 and/or E-mail Transmission Chidi A. Oha Zwicker & Associates, P.C. 14090 Southwest Frwy., Suite 408 Sugar Land, TX 77478 E-mail: zate_litigation@zwickerpc.com Attorney for Plaintiff Paul Culpepper