On May 08, 2023 a
Answer
was filed
involving a dispute between
Wing, Stephanie Lynn,
and
Wing, Cody Russell,
for Parent Child Relationship - Conservatorship, Access, Support
in the District Court of Montgomery County.
Preview
NO. 23-05--06612
IN THE INTEREST OF § IN THE DISTRICT COURT
ROWAN WING
#3 JUDICIAL DISTRICT
A MINOR CHILD MONTGOMERY COUNTY, TEXAS
RESPONDENT'S ORIGINAL ANSWER CONTINGENT
ON THE MOTION TO DISMISS AND PLEA TO JURISDICTION
COMES NOW CODY RUSSELL WING, Respondent father in this case, and files this
Respondent’s Original Answer Contingent on the Dismiss and Plea to Jurisdiction and in support
thereof would show this Court the following:
1. General Denial
Respondent enters a general denial.
2. Information about Children
Information required by section 154.181(b) of the Texas Family Code will be provided at a
later date.
3. Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Respondent to secure the services of WILLIS EVERETT SMITH, ESQ.,
a licensed attorney, to prepare and prosecute this suit. To effect an equitable a possible resolution of
the case and for services rendered in connection with conservatorship and support of the child
judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against
Petitioner and in favor of Respondent for the use and benefit of Respondent's attorney and be ordered
paid directly to Respondent's attorney, who may enforce the judgment in the attorney's own name.
Respondent requests postjudgment interest as allowed by law.
4. Prayer
Respondent prays that Petitioner take nothing and that Respondent be granted all relief
requested in this Original Answer.
Respondent also prays for attorney's fees, expenses, costs, and interest as requested above.
Respondent prays for general relief.
Respectfully submitted,
WILLIS EVERETT SMITH, ESQ.
ATTORNEY AT LAW
25408 US HWY 59, SUITE#104
PORTER, TEXAS 77365
Tel: (281) 359-6052
Fax: (281) 360-6009
E-Mail: wesmith2@peoplepc.com
Web: www.williseverettsmith.com
By:/S/ Willis Everett Smith, Esq.
WILLIS EVERETT SMITH, ESQ.
State Bar No. 18710500
Attorney for Respondent
CODY RUSSELL WING
Certificate of Service
I certify that a true copy of the above was served on each attorney of record or party in
accordance with the Texas Rules of Civil Procedure via e-service at the email address on the 23 RD
day of May, 2023..
/S/ Willis Everett Smith, Esq.
WILLIS EVERETT SMITH, ESQ.
Attorney for Petitioner CODY RUSSELL WING
2
Document Filed Date
May 23, 2023
Case Filing Date
May 08, 2023
Category
Parent Child Relationship - Conservatorship, Access, Support
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Preview
NO. 23-05--06612 IN THE INTEREST OF § IN THE DISTRICT COURT ROWAN WING #3 JUDICIAL DISTRICT A MINOR CHILD MONTGOMERY COUNTY, TEXAS RESPONDENT'S ORIGINAL ANSWER CONTINGENT ON THE MOTION TO DISMISS AND PLEA TO JURISDICTION COMES NOW CODY RUSSELL WING, Respondent father in this case, and files this Respondent’s Original Answer Contingent on the Dismiss and Plea to Jurisdiction and in support thereof would show this Court the following: 1. General Denial Respondent enters a general denial. 2. Information about Children Information required by section 154.181(b) of the Texas Family Code will be provided at a later date. 3. Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of WILLIS EVERETT SMITH, ESQ., a licensed attorney, to prepare and prosecute this suit. To effect an equitable a possible resolution of the case and for services rendered in connection with conservatorship and support of the child judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Petitioner and in favor of Respondent for the use and benefit of Respondent's attorney and be ordered paid directly to Respondent's attorney, who may enforce the judgment in the attorney's own name. Respondent requests postjudgment interest as allowed by law. 4. Prayer Respondent prays that Petitioner take nothing and that Respondent be granted all relief requested in this Original Answer. Respondent also prays for attorney's fees, expenses, costs, and interest as requested above. Respondent prays for general relief. Respectfully submitted, WILLIS EVERETT SMITH, ESQ. ATTORNEY AT LAW 25408 US HWY 59, SUITE#104 PORTER, TEXAS 77365 Tel: (281) 359-6052 Fax: (281) 360-6009 E-Mail: wesmith2@peoplepc.com Web: www.williseverettsmith.com By:/S/ Willis Everett Smith, Esq. WILLIS EVERETT SMITH, ESQ. State Bar No. 18710500 Attorney for Respondent CODY RUSSELL WING Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure via e-service at the email address on the 23 RD day of May, 2023.. /S/ Willis Everett Smith, Esq. WILLIS EVERETT SMITH, ESQ. Attorney for Petitioner CODY RUSSELL WING 2