Answer: In the Matter of the Marriage of Monica Marie De La Haya and John David Moffitt and in the Interest of Minor Child(ren)

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                                Filed
                                                                                                             7/31/2023 4:27 PM
                                                                                                      Beverley McGrew Walker
                                                                                                                   District Clerk
                                                                                                       Fort Bend County, Texas
                                                                                                         Brette Sansom

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA.

                                      CAUSE NO. 23-DCV-305867

IN THE MATTER          OF THE                        §   IN THE DISTRICT COURT
MARRIAGE OF

MONICA MARIE DE LA HAYA
AND                                                      328th JUDICIAL DISTRICT
JOHN DAVID MOFFITT, JR.

AND IN THE INTEREST OF
                                AND
               CHILDREN                                  FORT BEND COUNTY, TEXAS


                               RESPONDENT’S ORIGINAL ANSWER

          In response to MONICA       MARIE DE LA HAYA’s Original Petition for Divorce filed on

July 11, 2023, JOHN DAVID MOFFITT, JR. files this Original Answer.

Parties

          I. JOHN    DAVID     MOFFITT,      JR.     is the   Respondent   in this action.   The   last three

numbers of JOHN DAVID MOFFITT, JR.'s Texas driver’s license number are [J The last
three numbers of JOHN DAVID MOFFITT, JR.'s Social Security number are fl

General Denial

          2. Pursuant to Rule 92 of the Texas Rules of Civil Procedure, JOHN DAVID MOFFITT,

JR. enters a general denial.

Protective Order

          3. No Protective Order.     A protective order under Title 4 of the Texas Family Code is not

in effect between the parties in this suit, and no application is pending before the Court.

Statement on Health Insurance




                                                   Page I Of 2
4. The information required under Section 154.181(b) and Section 154.1815 of the Texas

Family Code will be filed with this Court before any hearing on Temporary Orders or a Final

Order.

                                              Prayer

         JOHN DAVID MOFFITT, JR. requests that this Court grant the relief requested in his

Original Answer and for general relief.




                                              Respectfully submitted,

                                              The Tholstrup Law Firm, L.P.
                                              440 Louisiana Street, Suite 200
                                              Houston, TX 77002
                                              Phone: (713) 225-1280
                                              Fax: (713) 583-4844



                                              /s/ Richard J. Tholstrup
                                              Richard J. Tholstrup
                                              Attorney for JOHN DAVID MOFFITT, JR.
                                              State Bar No. 00793079
                                              Email: richard@tholstruplaw.com


                                      Certificate of Service

         1 certify that a true copy of this document was served in accordance with Rule 21a of the

Texas Rules of Civil Procedure on the following on July 31, 2023.

         Kourtney Parker by electronic filing manager at service@huntlawtexas.com.


                                              /s/ Richard J. Tholstrup
                                              Richard J. Tholstrup
                                              Attorney for JOHN DAVID MOFFITT, JR.




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Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Richard Tholstrup on behalf of Richard Tholstrup
Bar No. 793079
richard@tholstruplaw.com
Envelope ID: 78056094
Filing Code Description: Answer/Contest/Response/Waiver
Filing Description: Respondent's Original Answer
Status as of 8/1/2023 9:14 AM CST

Associated Case Party: MonicaMarieDe La Haya

Name                      BarNumber | Email                       TimestampSubmitted | Status

Kourtney Malone-Parker | 24104590     service@huntlawtexas.com | 7/31/2023 4:27:00 PM    | SENT


Case Contacts

Name                      BarNumber | Email                      TimestampSubmitted | Status

Richard JosephTholstrup                richard@tholstruplaw.com | 7/31/2023 4:27:00 PM   | SENT
John DavidMoffitt                      jdmtx100@gmail.com         7/31/2023 4:27:00 PM   | SENT