On March 02, 2021 a
Answer
was filed
involving a dispute between
City Of Hitchcock,
College Of The Mainland,
Galveston County,
Hitchcock Independent School District,
and
Freeman, Georgia,
Freeman, Hattie E.,
for Tax Delinquency
in the District Court of Galveston County.
Preview
Filed: 5/6/2021 4:45 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 53202716
By: Monique McNeal
No 21 TX 0129 5/7/2021 9:22 AM
COUNTY of GALVESTON et al § IN THE DISTRICT COURT
v. 212TH JUDICIAL DISTRICT
OF
HATTIE E FREEMAN et al GALVESTON COUNTY TEXAS
ANSWER OF ATTORNEY AD LITEM
NOW COMES, Jeffrey Kilgore, appointed Attorney Ad Litem to represent the interests of HATTIE E.
FREEMAN and GEORGIA FREEMAN if Deceased. The UNKNOWN HEIRS or LEGAL REPRESENTITIVES of
HATTIE F. FREEMAN pursuant to Rule 92 of the Texas Rules of Civil Procedure, makes and files this his Original
Answer to the Original Petition of County of Galveston Texas, and Amended Petitioner in Intervention and would
respectfully show this Court the following:
I.
At this time, Attorney Ad Litem asserts a General Denial and respectfully requests that the Court and Jury require
the Petitioners to prove their claims, charges, and allegations by clear and convincing evidence as required by the
Constitution and Laws of the State of Texas.
II.
Attorney Ad Litem respectfully reserves the right to file an amended Answer in this proceeding in the manner
authorized by the Texas Rules of Civil Procedure.
III.
Attorney ad Litem has been appointed to represent the interest of the defendant, the unknown heirs and or
Representatives of Hattie E. Freeman and Georgia Freeman served by publication and said ad Litem should be paid his
reasonable and necessary attorney fees in connection with protecting and defending the rights of the Defendants.
WHEREFORE, PREMISES CONSIDERED, Jeffrey Kilgore, Attorney Ad Litem, duly appointed by this Court to
represent the interests of the unknown heirs and or Representatives of Hattie E. Freeman, prays that the Plaintiff take
nothing; that costs be adjudged against the Plaintiff the fees of the Attorney ad Litem be paid by the Plaintiff and for such
other and further relief, both general and special, at law and in equity, to which they may show himself justly entitled.
Respectfully submitted
Jeffrey Kilgore
___________________________________
Jeffrey H Kilgore
Attorney Ad Litem
State Bar Number: 11399500
164 Bora Bora Dr.
Galveston, Texas 77554
409-939 6924 fax 866 426 5517
texasmediator97@gmail.com
CERTIFICATE OF SERVICE
I, Jeffrey Kilgore, certify that the foregoing instrument was hand delivered to Petitioners/ forwarded by facsimile/
certified mail RRR or e filed through the District Clerk May 6,2021 to all parties of record.
Jeffrey H Kilgore
Document Filed Date
May 06, 2021
Case Filing Date
March 02, 2021
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Preview
Filed: 5/6/2021 4:45 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 53202716 By: Monique McNeal No 21 TX 0129 5/7/2021 9:22 AM COUNTY of GALVESTON et al § IN THE DISTRICT COURT v. 212TH JUDICIAL DISTRICT OF HATTIE E FREEMAN et al GALVESTON COUNTY TEXAS ANSWER OF ATTORNEY AD LITEM NOW COMES, Jeffrey Kilgore, appointed Attorney Ad Litem to represent the interests of HATTIE E. FREEMAN and GEORGIA FREEMAN if Deceased. The UNKNOWN HEIRS or LEGAL REPRESENTITIVES of HATTIE F. FREEMAN pursuant to Rule 92 of the Texas Rules of Civil Procedure, makes and files this his Original Answer to the Original Petition of County of Galveston Texas, and Amended Petitioner in Intervention and would respectfully show this Court the following: I. At this time, Attorney Ad Litem asserts a General Denial and respectfully requests that the Court and Jury require the Petitioners to prove their claims, charges, and allegations by clear and convincing evidence as required by the Constitution and Laws of the State of Texas. II. Attorney Ad Litem respectfully reserves the right to file an amended Answer in this proceeding in the manner authorized by the Texas Rules of Civil Procedure. III. Attorney ad Litem has been appointed to represent the interest of the defendant, the unknown heirs and or Representatives of Hattie E. Freeman and Georgia Freeman served by publication and said ad Litem should be paid his reasonable and necessary attorney fees in connection with protecting and defending the rights of the Defendants. WHEREFORE, PREMISES CONSIDERED, Jeffrey Kilgore, Attorney Ad Litem, duly appointed by this Court to represent the interests of the unknown heirs and or Representatives of Hattie E. Freeman, prays that the Plaintiff take nothing; that costs be adjudged against the Plaintiff the fees of the Attorney ad Litem be paid by the Plaintiff and for such other and further relief, both general and special, at law and in equity, to which they may show himself justly entitled. Respectfully submitted Jeffrey Kilgore ___________________________________ Jeffrey H Kilgore Attorney Ad Litem State Bar Number: 11399500 164 Bora Bora Dr. Galveston, Texas 77554 409-939 6924 fax 866 426 5517 texasmediator97@gmail.com CERTIFICATE OF SERVICE I, Jeffrey Kilgore, certify that the foregoing instrument was hand delivered to Petitioners/ forwarded by facsimile/ certified mail RRR or e filed through the District Clerk May 6,2021 to all parties of record. Jeffrey H Kilgore