On October 22, 2021 a
Answer
was filed
involving a dispute between
Perez, Nancy Ann,
and
Perez, Lesli Nicole,
for Parent Child Relationship - Conservatorship, Access, Support
in the District Court of Montgomery County.
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
Document Filed Date
January 06, 2022
Case Filing Date
October 22, 2021
Category
Parent Child Relationship - Conservatorship, Access, Support
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