On October 06, 2021 a
Answer
was filed
involving a dispute between
Herring, Cliann,
and
Morrison, Steven,
for Other Civil - Under $250,000
in the District Court of Montgomery County.
Preview
CAUSE NO. 21-10-13873
CLAINN HERRING, Plaintiff IN THE COUNTY COURT
STEVE MORRISON, Defendant JUDICIAL DISTRICT COURT
REYNIEL FUNDORA, Third Party Defendant
MONTGOMERY COUNTY, TEXAS
THIRD-PARTY DEFENDANT’S ORIGINAL ANSWER TO DEFENDANT
STEVE MORRISON FIRST AMENDED ANSWER AND ORIGINAL
PETITION AGAINST THIRDPARTY DEFENDANT
REYNIEL FUNDORA Third Party Defendant, files this Original Answer to Defendant,
STEVE MORRISON, First Amended Answer, and Original Petition Against Third Party
Defendant.
Party Identification
The Third Party Defendant’s name is REYNIEL FUNDORA. The last three numbers
of REYNIEL FUNDORA’s Texas Driver’s License are . The last three numbers of
REYNIEL FUNFODORA’ssocial security number are 7762.
General Denial
Defendant denies each and every allegation of Plaintiff’s and Defendant’s Original
Petition, and any amendments or supplements thereto, and demands strict proof thereof
as required by the Texas Rules of Civil Procedure.
Affirmative Defenses
By way of affirmative defense, Third-Party Defendant pleads the following:
The terms of the alleged contract are indefinite, rendering the contract
unenforceable.
Third-Party Defendant denies that all conditions precedent has occurred.
Third Party Defendant denies that Plaintiff and Defendant failed to make demand
as alleged.
Plaintiff’s claims for exemplary, punitive, or other damages are barred, limited,
restricted, or governed by the provisions of Chapter 41 of the Texas Civil Practice
and Remedies Code, and any other applicable constitution, Statute, or law
concerning the recovery of such damages.
Prayer
WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff and
Defendant take nothing herein, that Third Party Defendant is awarded the relief prayed for
hereinabove, and for such other and further relief, special or general, legal or equitable, as
may be shown that Third-Party Defendant is justly entitled to receive.
Respectfully Submitted,
/s/Mario arela
Mario Varela
TBN: 24 085682
THE LAW OFFICE OF MARIO VARELA, PLLC
8554 Katy Freeway Ste. 340
Houston, Texas 77024
P: (713) 684-3550
E: mvarela@varela.law
Attorney for Reyniel Fundora
ERTIFICATE OF SERVICE
Page of
Montgomery, County Cause NO. 21- 13873
I certify that true and correct copy of the foregoing Third Party Defendant’s Original
Answer to was served with rule 21a of the Texas Rules of Civil Procedure on the following
November 21, 2022via electronic filing mana ger to: houstonservice@koonsfuller.com and
paul@bailifflawfirm.com
/s/Mario arela
Mario Varela
TBN: 24 085682
THE LAW OFFICE OF MARIO VARELA, PLLC
8554 Katy Freeway Ste. 340
Houston, Texas 77024
P: (713) 684-3550
E: mvarela@varela.law
Attorney for Reyniel Fundora
Page of
Montgomery, County Cause NO. 21- 13873
Document Filed Date
November 21, 2022
Case Filing Date
October 06, 2021
Category
Other Civil - Under $250,000
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
CAUSE NO. 21-10-13873 CLAINN HERRING, Plaintiff IN THE COUNTY COURT STEVE MORRISON, Defendant JUDICIAL DISTRICT COURT REYNIEL FUNDORA, Third Party Defendant MONTGOMERY COUNTY, TEXAS THIRD-PARTY DEFENDANT’S ORIGINAL ANSWER TO DEFENDANT STEVE MORRISON FIRST AMENDED ANSWER AND ORIGINAL PETITION AGAINST THIRDPARTY DEFENDANT REYNIEL FUNDORA Third Party Defendant, files this Original Answer to Defendant, STEVE MORRISON, First Amended Answer, and Original Petition Against Third Party Defendant. Party Identification The Third Party Defendant’s name is REYNIEL FUNDORA. The last three numbers of REYNIEL FUNDORA’s Texas Driver’s License are . The last three numbers of REYNIEL FUNFODORA’ssocial security number are 7762. General Denial Defendant denies each and every allegation of Plaintiff’s and Defendant’s Original Petition, and any amendments or supplements thereto, and demands strict proof thereof as required by the Texas Rules of Civil Procedure. Affirmative Defenses By way of affirmative defense, Third-Party Defendant pleads the following: The terms of the alleged contract are indefinite, rendering the contract unenforceable. Third-Party Defendant denies that all conditions precedent has occurred. Third Party Defendant denies that Plaintiff and Defendant failed to make demand as alleged. Plaintiff’s claims for exemplary, punitive, or other damages are barred, limited, restricted, or governed by the provisions of Chapter 41 of the Texas Civil Practice and Remedies Code, and any other applicable constitution, Statute, or law concerning the recovery of such damages. Prayer WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff and Defendant take nothing herein, that Third Party Defendant is awarded the relief prayed for hereinabove, and for such other and further relief, special or general, legal or equitable, as may be shown that Third-Party Defendant is justly entitled to receive. Respectfully Submitted, /s/Mario arela Mario Varela TBN: 24 085682 THE LAW OFFICE OF MARIO VARELA, PLLC 8554 Katy Freeway Ste. 340 Houston, Texas 77024 P: (713) 684-3550 E: mvarela@varela.law Attorney for Reyniel Fundora ERTIFICATE OF SERVICE Page of Montgomery, County Cause NO. 21- 13873 I certify that true and correct copy of the foregoing Third Party Defendant’s Original Answer to was served with rule 21a of the Texas Rules of Civil Procedure on the following November 21, 2022via electronic filing mana ger to: houstonservice@koonsfuller.com and paul@bailifflawfirm.com /s/Mario arela Mario Varela TBN: 24 085682 THE LAW OFFICE OF MARIO VARELA, PLLC 8554 Katy Freeway Ste. 340 Houston, Texas 77024 P: (713) 684-3550 E: mvarela@varela.law Attorney for Reyniel Fundora Page of Montgomery, County Cause NO. 21- 13873