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  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
  • In the Interest of 
Gerardo Lonnie BaltierraParent Child Relationship - Conservatorship, Access, Support document preview
						
                                

Preview

NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NO. IN THE INTEREST OF IN THE DISTRICT COURT GERARDO LONNIE BALTIERRA AND JUDICIAL DISTRICT NAYDEAN PEREZ CHILDREN MONTGOMERY COUNTY, TEXAS RESPONDENT S ORIGINAL ANSWER GERARDO BALTIERRA, Respondent, files this original answer. The last three numbers of Respondent s driver s license number are 732. The last three numbers of the Respondent's Social Security number are 545. 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. 2. Information about Children Information required by section 154.181(b) and section 154.1815 of the Texas Family Code will be supplemented. Denial of Allegations Respondent enters a general denial. Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of Sandra P. Fuentez, a licensed attorney, to prepare and defend this suit. If the parties are unable to reach an agreement on all issues, Petitioner, NANCY ANN PEREZ, should be ordered to pay reasonable attorney s fees, expenses, and costs through trial Respondent’s Original Answer-Baltierra Page 1 of 3 and appeal, and a judgment should be rendered in favor of this attorney and against Petitioner 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. Praye Respondent prays that all relief prayed for by Petitioner be denied and that Respondent be granted all relief requested in this answer. Respondent prays for attorney s fees, expenses, and costs as requested above. Respondent prays for general relief. uentez Law, P.L.L.C. 33018 Tamina Rd. gnolia, TX 77354 Tel: 713 Fax: 713 /s/ Sandra P. Fuentez Sandra P. Fuentez State Bar No. 24045294 fuentezlaw@gmail.com Attorney for Respondent Respondent’s Original Answe Baltierra Page of Certificate of Service I certify that a true copy of this Respondent's Original Answer was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on January William E. Harrisonby electronic filing manager. Terri C Mendez by electronic filing manager. /s/ Sandra P. Fuentez Sandra P. Fuentez Attorney for Respondent Respondent’s Original Answe Baltierra Page of