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  • Discover Bank v. Yuriko PunzalContract - Consumer/Commercial/Debt document preview
  • Discover Bank v. Yuriko PunzalContract - Consumer/Commercial/Debt document preview
  • Discover Bank v. Yuriko PunzalContract - Consumer/Commercial/Debt document preview
  • Discover Bank v. Yuriko PunzalContract - Consumer/Commercial/Debt document preview
						
                                

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CAUSE NUMBER 21-DCV-283881 DISCOVER BANK § IN THE 458TH DISTRICT COURT PLAINTIFF § vs. § § YURIKO PUNZAL § DEFENDANT § FORT BEND COUNTY, TX DEFENDANT’S ORIGINAL ANSWER COMES NOW YURIKO PUNZAL (“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. AFFIRMATIVE 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 recovers all costs together with such other and further relief to which Defendant be justly entitled. Page of RESPECTFULLY SUBMITTED, LAW OFFICE OF MICHAEL R. CASTRO, PLLC 445 E FM 1382 SUITE 3676 CEDAR HILL, TX 75104 Phone 214.236.0998 Fax 214.723.5922 mcastro@mylitigationdefense.com /S/ MICHAEL CASTRO MICHAEL CASTRO ATTORNEY FOR DEFENDANT TEXAS SBN 24065025 mcastro@mylitigationdefense.com CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the following instrument was delivered to the counsel of record, pursuant to Rules 21 and 21(a) of the Texas Rules of Civil Procedure, this the 5 TH day of August 2021, via ELECTRONIC FILE AND SERVE. /S/ MICHAEL CASTRO MICHAEL CASTRO ATTORNEY FOR DEFENDANT TEXAS SBN 24065025 mcastro@mylitigationdefense.com Page 2 of 2