On July 27, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Oputa, Odili U.,
and
Bay Matrix, Llc,
for Other Civil
in the District Court of Fort Bend County.
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CAUSE NO. -306522
ODILI U. OPUTA IN THE DISTRICT COURT
Plaintiff,
FORT BENDCOUNTY, TEXAS
BAY MATRIX, LLC
Defendant.
JUDICIAL DISTRICT
DEFENDANT, BAY MATRIX, LLC’S ORIGINAL ANSWER
SUBJECT TO MOTION TO STAY
Defendant Bay Matrix, LLC (“Defendant” or “Bay Matrix ) files this Original Answer
Subject to Motion to Stay, and respectfully shows as follows:
GENERAL DENIAL
Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Defendant generally denies all
the allegations contained in Plaintiffs Original Petition (“Petition”) and demands strict proof
thereof. Defendant further reserves any and all rights held under the Texas Rules of Civil
Procedure for subsequent amendment of this pleading.
RAYER
WHEREFORE, PREMISES CONSIDERED, Defendant Bay Matrix, LLC respectfully
requests that Plaintiff take nothing by way of his claims and that Defendant have such other and
further reliefto which may justly be entitled or that the Court deems proper.
Respectfully submitted,
OHREER AW IRM PLLC
E. Michelle Bohreer
State Bar No. 06717100
Pritesh Soni
State Bar No.
777 Post Oak Blvd., Suite 950
Houston, Texas 770
Telephone: 3006
Facsimile:
michelle@bohreerlaw.com
pritesh@bohreerlaw.com
ATTORNEY FOR DEFENDANT
BAY MATRIX, LLC
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing document has been delivered
or forwarded to all counsel and unrepresented persons as listed below, ] by personal delivery
or receipted delivery service, or [ ] by certified or registered mail, return receipt requested, by
depositing the same, postpaid, in an official deposit under the care and custody of the United States
Postal Service, or [ | by facsimile to the recipient's facsimile number identified below, or [ X ] by
service to the recipient’s email address identified below and the electronic transmission was
reported as complete, on this the day of September , in accordance with the Rule 21a
of the Texas Rules of Civil Procedure:
George H. Rau III
Henneman Rau Kirklin & Smith LLP
815 Walker Street, Suite 1440
Houston, TX
Email: grau@hrkslaw.com
Telephone: 6030
Facsimile: 6141
ATTORNEY FOR PLAINTIFF
smb 40
E. Michelle Bohreer
Document Filed Date
September 11, 2023
Case Filing Date
July 27, 2023
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CAUSE NO. -306522 ODILI U. OPUTA IN THE DISTRICT COURT Plaintiff, FORT BENDCOUNTY, TEXAS BAY MATRIX, LLC Defendant. JUDICIAL DISTRICT DEFENDANT, BAY MATRIX, LLC’S ORIGINAL ANSWER SUBJECT TO MOTION TO STAY Defendant Bay Matrix, LLC (“Defendant” or “Bay Matrix ) files this Original Answer Subject to Motion to Stay, and respectfully shows as follows: GENERAL DENIAL Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Defendant generally denies all the allegations contained in Plaintiffs Original Petition (“Petition”) and demands strict proof thereof. Defendant further reserves any and all rights held under the Texas Rules of Civil Procedure for subsequent amendment of this pleading. RAYER WHEREFORE, PREMISES CONSIDERED, Defendant Bay Matrix, LLC respectfully requests that Plaintiff take nothing by way of his claims and that Defendant have such other and further reliefto which may justly be entitled or that the Court deems proper. Respectfully submitted, OHREER AW IRM PLLC E. Michelle Bohreer State Bar No. 06717100 Pritesh Soni State Bar No. 777 Post Oak Blvd., Suite 950 Houston, Texas 770 Telephone: 3006 Facsimile: michelle@bohreerlaw.com pritesh@bohreerlaw.com ATTORNEY FOR DEFENDANT BAY MATRIX, LLC CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document has been delivered or forwarded to all counsel and unrepresented persons as listed below, ] by personal delivery or receipted delivery service, or [ ] by certified or registered mail, return receipt requested, by depositing the same, postpaid, in an official deposit under the care and custody of the United States Postal Service, or [ | by facsimile to the recipient's facsimile number identified below, or [ X ] by service to the recipient’s email address identified below and the electronic transmission was reported as complete, on this the day of September , in accordance with the Rule 21a of the Texas Rules of Civil Procedure: George H. Rau III Henneman Rau Kirklin & Smith LLP 815 Walker Street, Suite 1440 Houston, TX Email: grau@hrkslaw.com Telephone: 6030 Facsimile: 6141 ATTORNEY FOR PLAINTIFF smb 40 E. Michelle Bohreer