On May 27, 2016 a
Answer
was filed
involving a dispute between
Attorney General Of Texas,
Gupta, Atul Kumar,
Jain, Vibha,
and
Gupta, Atul Kumar,
Jain, Vibha,
for Divorce - With Children
in the District Court of Fort Bend County.
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Filed
5/9/2019 4:13 PM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Megan Munoz
NO. 16-DCV-232757
IN THE INTEREST OF IN THE DISTRICT COURT
a 32874 JUDICIAL DISTRICT
A CHILD FORT BEND COUNTY, TEXAS
RESPONDENT'S ORIGINAL ANSWER
VIBHA JAIN, Respondent, files this Original Answer to Petition to Modify Parent-Child
Relationship. The last three numbers of VIBHA JAIN's driver's license number are The
last three numbers of VIBHA JAIN's Social Security number arc ll
1 General Denial
Respondent enters a general denial.
2 Objection to Assignment of Case to Associate Judge
Respondent objects to the assignment of this matter to an associate judge for a trial on the
merits or presiding at a jury trial.
3. Information about Children
Information required by section 154.181(b) of the Texas Family Code may be
supplemented.
4 Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Respondent to secure the services of Christine R. Thrash, a licensed
attorney, to prepare and prosecute this suit. To effect an equitable division of the estate of the
parties and as a part of the division, and for services rendered in connection with conservatorship
and support of the children, 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.
5. 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,
Law Office of Christine R. Thrash, PLLC
440 Louisiana Street, Suite 900
Houston, Texas 77002
Tel: (713) 224-7777
Fax: (877) 308-6443
Email: christine@thrashlawtexas.com
By:/e/ Christine R. Thnach
Christine R. Thrash
State Bar No. 24033271
Attorney for Respondent
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 on May 9, 2019.
Law Office of Leena Bhasin
State Bar No. 24029155
P.O. Box 841183
Pearland, Texas 77584
Tel: 832-860-5074
Fax: 281-489-5015
Email: leenabhasinlawoffice.com
VIA ELECTRONIC SERVICE
Attorney for Petitioner
lel ChristineR. Thrash
Christine R. Thrash
Attorney for Respondent
Document Filed Date
May 09, 2019
Case Filing Date
May 27, 2016
Category
Divorce - With Children
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Filed 5/9/2019 4:13 PM Beverley McGrew Walker District Clerk Fort Bend County, Texas Megan Munoz NO. 16-DCV-232757 IN THE INTEREST OF IN THE DISTRICT COURT a 32874 JUDICIAL DISTRICT A CHILD FORT BEND COUNTY, TEXAS RESPONDENT'S ORIGINAL ANSWER VIBHA JAIN, Respondent, files this Original Answer to Petition to Modify Parent-Child Relationship. The last three numbers of VIBHA JAIN's driver's license number are The last three numbers of VIBHA JAIN's Social Security number arc ll 1 General Denial Respondent enters a general denial. 2 Objection to Assignment of Case to Associate Judge Respondent objects to the assignment of this matter to an associate judge for a trial on the merits or presiding at a jury trial. 3. Information about Children Information required by section 154.181(b) of the Texas Family Code may be supplemented. 4 Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of Christine R. Thrash, a licensed attorney, to prepare and prosecute this suit. To effect an equitable division of the estate of the parties and as a part of the division, and for services rendered in connection with conservatorship and support of the children, 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. 5. 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, Law Office of Christine R. Thrash, PLLC 440 Louisiana Street, Suite 900 Houston, Texas 77002 Tel: (713) 224-7777 Fax: (877) 308-6443 Email: christine@thrashlawtexas.com By:/e/ Christine R. Thnach Christine R. Thrash State Bar No. 24033271 Attorney for Respondent 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 on May 9, 2019. Law Office of Leena Bhasin State Bar No. 24029155 P.O. Box 841183 Pearland, Texas 77584 Tel: 832-860-5074 Fax: 281-489-5015 Email: leenabhasinlawoffice.com VIA ELECTRONIC SERVICE Attorney for Petitioner lel ChristineR. Thrash Christine R. Thrash Attorney for Respondent