On April 19, 2021 a
Answer
was filed
involving a dispute between
Bng Management Group, Llc,
Pk Restaurant Group Inc,
and
Cho, Jimmy,
Giant Blue Inc,
Tozee Construction Inc,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
8/22/2022 5:01 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
CAUSE NO. DC-21-04907
BNG MANAGEMENT GROUP, LLC IN THE DISTRICT COURT OF
§§§§§§§§§§§§
Plaintifif
V. DALLAS COUNTY, TEXAS
TOZEE CONSTRUCTION, IN C.,
GIANT BLUE, INC., AND JIMMY CHO,
INDIVIDUALLY
Defendants. 10 1 st JUDICIAL DISTRICT
PLAINTIFF AND COUNTERDEFENDANT’S ORIGINAL ANSWER
TO DEFENDANTS' ORIGINAL COUNTERPETITION
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Plaintiff PK BNG Management Group, LLC (“BNG” or “Plaintiff ’), and
files this, its Original Answer to Defendants’ Original Counterpetition. In support thereof, Plaintiff
would respectfully show the Court as follows:
I. GENERAL DENIAL
Reserving the right to file other and further pleadings, exceptions, and denials, Plaintiff
BNG generally denies each and every, all and singular, material allegation contained in
Defendant’s Original Counterpetition, and demands strict proof thereof in front of a jury and by a
preponderance of the evidence, in accordance with the laws and rules of civil procedure of the
State of Texas.
II. RESERVATION OF RIGHTS
Plaintiff reserves the right to further amend its Answer as is the right and privilege of Plaintiff
under the Texas Rules of Civil Procedure and the laws of the State of Texas.
PLAINTIFF’S ORIGINAL ANSWER T0 ORIGINAL COUNTERPETITION - Page 1 of 3
III. PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests that
Defendants take nothing by their suit. Plaintiff also asks that the Court grant it such other and
further relief, both at law and in equity, both general and specific, to which it may be justly
entitled, including, but not limited to, costs and attorneys’ fees.
Respectfully submitted,
SONG WHIDDON, PLLC
/s/ Tailim Song
TAILIM SONG
State Bar No. 00792845
tsong@songwhiddon.com
JORDAN WHIDDON
State Bar No. 240104313
jwhiddon@songwhiddon.com
8111 LBJ Freeway, Suite 480
Dallas, Texas 75251
(214) 528-8400 Telephone
(214) 528-8402 Facsimile
ATTORNEYS FOR PLAINTIFF
PLAINTIFF’S ORIGINAL ANSWER T0 ORIGINAL COUNTERPETITION - Page 2 of 3
CERTIFICATE 0F SERVICE
This pleading, PLAINTIFF’S ORIGINAL ANSWER TO DEFENDAN TS’ ORIGINAL
COUNTERPETITION, has been served upon all counsel of record in compliance with Rules 21
and 21a of the Texas Rules of Civil Procedure on August 22, 2022:
William Chu
The Law Offices of William Chu
4455 LBJ Freeway, Suite 1008
Dallas, Texas 75244
wmchulaw@aol.com
T: (972) 392-9888
F: (972) 392-9889
Attorney for Defendants
/s/ Tailz'm Song
Tailim Song
PLAINTIFF’S ORIGINAL ANSWER T0 ORIGINAL COUNTERPETITION - Page 3 of 3
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.
Tailim Song on behalf of Tailim Song
Bar No. 00792845
tsong@tailimsong.com
Envelope ID: 67528465
Status as of 8/23/2022 8:33 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
William Chu wmchulaw@aol.com 8/22/2022 5:01 :00 PM SENT
Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 8/22/2022 5:01:00 PM SENT
Yuliana Ramirez yuliana@tailimsong.com 8/22/2022 5:01:00 PM SENT
william Knisley knisley.wmchulaw@gmail.com 8/22/2022 5:01:00 PM SENT
Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 8/22/2022 5:01:00 PM SENT
Tailim Song tsong@tailimsong.com 8/22/2022 5:01:00 PM SENT
Office Efiles wmchulawefile@gmail.com 8/22/2022 5:01:00 PM SENT
Abigael Campbell acampbell@tailimsong.com 8/22/2022 5:01:00 PM SENT
Document Filed Date
August 22, 2022
Case Filing Date
April 19, 2021
Category
CNTR CNSMR COM DEBT
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FILED 8/22/2022 5:01 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY CAUSE NO. DC-21-04907 BNG MANAGEMENT GROUP, LLC IN THE DISTRICT COURT OF §§§§§§§§§§§§ Plaintifif V. DALLAS COUNTY, TEXAS TOZEE CONSTRUCTION, IN C., GIANT BLUE, INC., AND JIMMY CHO, INDIVIDUALLY Defendants. 10 1 st JUDICIAL DISTRICT PLAINTIFF AND COUNTERDEFENDANT’S ORIGINAL ANSWER TO DEFENDANTS' ORIGINAL COUNTERPETITION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Plaintiff PK BNG Management Group, LLC (“BNG” or “Plaintiff ’), and files this, its Original Answer to Defendants’ Original Counterpetition. In support thereof, Plaintiff would respectfully show the Court as follows: I. GENERAL DENIAL Reserving the right to file other and further pleadings, exceptions, and denials, Plaintiff BNG generally denies each and every, all and singular, material allegation contained in Defendant’s Original Counterpetition, and demands strict proof thereof in front of a jury and by a preponderance of the evidence, in accordance with the laws and rules of civil procedure of the State of Texas. II. RESERVATION OF RIGHTS Plaintiff reserves the right to further amend its Answer as is the right and privilege of Plaintiff under the Texas Rules of Civil Procedure and the laws of the State of Texas. PLAINTIFF’S ORIGINAL ANSWER T0 ORIGINAL COUNTERPETITION - Page 1 of 3 III. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests that Defendants take nothing by their suit. Plaintiff also asks that the Court grant it such other and further relief, both at law and in equity, both general and specific, to which it may be justly entitled, including, but not limited to, costs and attorneys’ fees. Respectfully submitted, SONG WHIDDON, PLLC /s/ Tailim Song TAILIM SONG State Bar No. 00792845 tsong@songwhiddon.com JORDAN WHIDDON State Bar No. 240104313 jwhiddon@songwhiddon.com 8111 LBJ Freeway, Suite 480 Dallas, Texas 75251 (214) 528-8400 Telephone (214) 528-8402 Facsimile ATTORNEYS FOR PLAINTIFF PLAINTIFF’S ORIGINAL ANSWER T0 ORIGINAL COUNTERPETITION - Page 2 of 3 CERTIFICATE 0F SERVICE This pleading, PLAINTIFF’S ORIGINAL ANSWER TO DEFENDAN TS’ ORIGINAL COUNTERPETITION, has been served upon all counsel of record in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on August 22, 2022: William Chu The Law Offices of William Chu 4455 LBJ Freeway, Suite 1008 Dallas, Texas 75244 wmchulaw@aol.com T: (972) 392-9888 F: (972) 392-9889 Attorney for Defendants /s/ Tailz'm Song Tailim Song PLAINTIFF’S ORIGINAL ANSWER T0 ORIGINAL COUNTERPETITION - Page 3 of 3 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. Tailim Song on behalf of Tailim Song Bar No. 00792845 tsong@tailimsong.com Envelope ID: 67528465 Status as of 8/23/2022 8:33 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status William Chu wmchulaw@aol.com 8/22/2022 5:01 :00 PM SENT Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 8/22/2022 5:01:00 PM SENT Yuliana Ramirez yuliana@tailimsong.com 8/22/2022 5:01:00 PM SENT william Knisley knisley.wmchulaw@gmail.com 8/22/2022 5:01:00 PM SENT Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 8/22/2022 5:01:00 PM SENT Tailim Song tsong@tailimsong.com 8/22/2022 5:01:00 PM SENT Office Efiles wmchulawefile@gmail.com 8/22/2022 5:01:00 PM SENT Abigael Campbell acampbell@tailimsong.com 8/22/2022 5:01:00 PM SENT