On October 15, 2018 a
Answer
was filed
involving a dispute between
Great Oaks South Homeowners Association Inc,
and
Carter, Tracy,
Fletcher, Charles, Jr,
for Other Civil
in the District Court of Fort Bend County.
Preview
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No, 18-DCV-256011
GREAT OAKS SOUTH HOMEOWNERS § Fort Bend County — 240" Judicial District Court
ASSOCIATION, INC. § INTHE JUDICIAL DISTRICT COURT
vs. ; OF FORT BEND COUNTY, TEXAS
§
TRACY CARTER AND §
CHARLES FLETCHER JR. §
ANSWER
Tracy Carter and Charles Fletcher, Pro Se, hereby submits this Answer to the Petition on file
herein, and alleges as follows:
1, Answering paragraph/allegations 1, 2, 3, and 4 of Plaintiff's Petition, Defendants ADMITS
each allegation contained therein,
2. Answering paragraph/allegations 5, 6, 7, 8, 9, 10 and | lof Plaintiff’s Petition, Defendants.
states that Defendants does not have sufficient knowledge or information to form a belief as to
the truth of these Allegations, Therefore, Defendants DENIES each allegation contained therein.
AFFIRMATIVE DEFENSES
1, Defendants hereby incorporates by reference those affirmative defenses
enumerated in TRCP 8 as though fully set forth herein, as applicable upon discovery. In the
event further investigation or discovery reveals the applicability of any such defenses,
Defendants reserves the right to seek leave of court to amend this Answer to more
specifically assert any such defense. Such defenses are herein incorporated by reference for the
specific purposes of not waiving any such defenses.
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7
Incorrect accounting.
Unreasonable charges (interest, late fees, management fees, and attorneys’ fees).
WHEREFORE, these Answering Defendants prays that this Honorable Court will:
Dismiss the Petition with prejudice or grant Plaintiff a reduced amount based upon
the admissions, denials and affirmative defenses, if any, as alleged above herein;
Award Defendants further relief as the court deems just and equitable.
Datedthis ff dayor_Novewel, 20 63
Defendants Pro Se
Name: Tracy Carter and Charles Fletcher Jr.
Mailing Address: 7243 Chickory Woods Lane
City, State, Zip: Houston, Texas 77083
Telephone: 281-277-2436
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 14" day of November, 2018, I placed a true and correct copy
of the foregoing ANSWER in the United States Mail in Houston, Texas, with first-class postage
prepaid, addressed to the following:
J.C. Jamison,
9821 Katy Freeway, Ste. 350
Houston, Texas 77024
713 - 510-1000 <3
Email:jjamison@holtyoung.com g Fe
1e
ie
ul
Sr a
BY
x
i.
Document Filed Date
November 14, 2018
Case Filing Date
October 15, 2018
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USAO_Fax 11/14/2018 10:54:06 AM PAGE 2/003 Fax Server . ” No, 18-DCV-256011 GREAT OAKS SOUTH HOMEOWNERS § Fort Bend County — 240" Judicial District Court ASSOCIATION, INC. § INTHE JUDICIAL DISTRICT COURT vs. ; OF FORT BEND COUNTY, TEXAS § TRACY CARTER AND § CHARLES FLETCHER JR. § ANSWER Tracy Carter and Charles Fletcher, Pro Se, hereby submits this Answer to the Petition on file herein, and alleges as follows: 1, Answering paragraph/allegations 1, 2, 3, and 4 of Plaintiff's Petition, Defendants ADMITS each allegation contained therein, 2. Answering paragraph/allegations 5, 6, 7, 8, 9, 10 and | lof Plaintiff’s Petition, Defendants. states that Defendants does not have sufficient knowledge or information to form a belief as to the truth of these Allegations, Therefore, Defendants DENIES each allegation contained therein. AFFIRMATIVE DEFENSES 1, Defendants hereby incorporates by reference those affirmative defenses enumerated in TRCP 8 as though fully set forth herein, as applicable upon discovery. In the event further investigation or discovery reveals the applicability of any such defenses, Defendants reserves the right to seek leave of court to amend this Answer to more specifically assert any such defense. Such defenses are herein incorporated by reference for the specific purposes of not waiving any such defenses. USAO_Fax 11/14/2018 10:54:06 AM PAGE 3/003 Fax Server 7 Incorrect accounting. Unreasonable charges (interest, late fees, management fees, and attorneys’ fees). WHEREFORE, these Answering Defendants prays that this Honorable Court will: Dismiss the Petition with prejudice or grant Plaintiff a reduced amount based upon the admissions, denials and affirmative defenses, if any, as alleged above herein; Award Defendants further relief as the court deems just and equitable. Datedthis ff dayor_Novewel, 20 63 Defendants Pro Se Name: Tracy Carter and Charles Fletcher Jr. Mailing Address: 7243 Chickory Woods Lane City, State, Zip: Houston, Texas 77083 Telephone: 281-277-2436 CERTIFICATE OF MAILING I HEREBY CERTIFY that on the 14" day of November, 2018, I placed a true and correct copy of the foregoing ANSWER in the United States Mail in Houston, Texas, with first-class postage prepaid, addressed to the following: J.C. Jamison, 9821 Katy Freeway, Ste. 350 Houston, Texas 77024 713 - 510-1000 <3 Email:jjamison@holtyoung.com g Fe 1e ie ul Sr a BY x i.