On October 22, 2021 a
Original Counterpetition in Suit Affecting the Parent-Child Relationship - Cross Action/Counterpetition
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.
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NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
NO. 21-10-14737
IN THE INTEREST OF IN THE DISTRICT COURT
GERARDO LONNIE BALTIERRA AND 418TH JUDICIAL DISTRICT
NAYDEAN PEREZ,
CHILDREN MONTGOMERY COUNTY, TEXAS
ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE
PARENT CHILD RELATIONSHIP
Discovery Level
Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas
Rules of Civil Procedure.
2. Objection to Assignment of Case to Associate Judge
Counterpetitioner objects to the assignment of this matter to an associate judge for a trial
on the merits or presiding at a jury trial.
Parties
This suit is brought by GERARDO BALTIERRA, Counterpetitioner. The last three
numbers of GERARDO BALTIERRA's driver's license number are 732. The last three numbers
of GERARDO BALTIERRA's Social Security number are 545.
Counterrespondent is NANCY ANN PEREZ
Counterpetitioner is a father of a childthe subject of this suit.
Counterpetitioner has standing to bring this suit in that he is the presumed father o
GERARDO LONNIE BALTIERRA
ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE
PARENT CHILD RELATIONSHIP
Page 1 of 4
Jurisdiction
No court has continuing jurisdiction of this suit or of the childthe subject of this suit.
Child
The following child the subject of this suit:
Name: GERARDO LONNIE BALTIERRA
ex: Male
Birth date: 03/24/2016
County of Residence: Montgomery
Nonresident Entitled to Citation
GERARDO BALTIERRA, named above, is a nonresident of Texas.
The nonresident person has submitted or will submit to the jurisdiction of Texas by
consent, by entering a general appearance, or by filing a responsive document having the effect
of waiving any contest to personal jurisdiction.
Property
No property of consequence is owned or possessed by the childthe subject of this suit.
Protective Order Statement
No protective order under title 4 of the Texas Family Code, under subchapter A of
chapter 7B of the Texas Code of Criminal Procedure, or order for emergency protection under
Article 17.292 of the Texas Code of Criminal Procedure is in effect in regard to a party to this
suit or a child of a party to this suit, and no application for any such order is pending with regard
to the parties to this suit or the childof the parties to this suit.
Conservatorship
The appointment of the Counterpetitioner and Counterrespondent as joint managing
ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE
PARENT CHILD RELATIONSHIP
Page of
conservators would not be in the best interest of the child. It is in the best interest of the chil
that Counterpetitioner be appointed sole managing conservator of the child.
Counterpetitioner requests the Court to order reasonable periods of electronic
communication
10. Request for Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Counterpetitioner to secure the services of Bryan Fagan, a licensed
attorney, to preserve and protect the ch's rights. Counterrespondent should be ordered to pay
reasonable attorney's fees, expenses, and costs through trial and appeal, and a judgment should
be rendered in favor of this attorney and against Counterrespondent and be ordered paid directly
to Counterpetitioner's attorney, who may enforce the judgment in the attorney's own name.
Counterpetitioner requests postjudgment interest as allowed by law.
Prayer
Counterpetitioner prays that the Court enter its orders in accordance with the allegations
contained in this counterpetition.
Counterpetitioner prays for attorney's fees, expenses, costs, and interest as requested
above.
Counterpetitioner prays for general relief.
Respectfully submitted,
Law Office of Bryan Fagan, PLLC
3707 Cypress Creek Parkway, Suite 400
Houston, Texas 77068
Tel: (281) 817-4370
Fax: (855) 668-0536
Eservice@bryanfagan.com
ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE
PARENT CHILD RELATIONSHIP
Page 3 of 4
By:/s/Teri Estes-Hightower
Teri Estes-Hightower
State Bar No. 24028746
teri@bryanfagan.com
Attorney for Counterpetitioner
Certificate of Service
I certify that a true copy of this Counterpetition in Suit Affecting the Parent Child
Relationship was served in accordance with rule 21a of the Texas Rules of Civil Procedure on
the following on September 6, 2022:
William E. Harrison and T rri Mendez by electronic filing manager.
/s/Teri Estes-Hightower
Teri Estes-Hightower
Attorney for GERARDO BALTIERRA
ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE
PARENT CHILD RELATIONSHIP
Page 4 of 4
Document Filed Date
September 06, 2022
Case Filing Date
October 22, 2021
Category
Parent Child Relationship - Conservatorship, Access, Support
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NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NO. 21-10-14737 IN THE INTEREST OF IN THE DISTRICT COURT GERARDO LONNIE BALTIERRA AND 418TH JUDICIAL DISTRICT NAYDEAN PEREZ, CHILDREN MONTGOMERY COUNTY, TEXAS ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE PARENT CHILD RELATIONSHIP Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2. Objection to Assignment of Case to Associate Judge Counterpetitioner objects to the assignment of this matter to an associate judge for a trial on the merits or presiding at a jury trial. Parties This suit is brought by GERARDO BALTIERRA, Counterpetitioner. The last three numbers of GERARDO BALTIERRA's driver's license number are 732. The last three numbers of GERARDO BALTIERRA's Social Security number are 545. Counterrespondent is NANCY ANN PEREZ Counterpetitioner is a father of a childthe subject of this suit. Counterpetitioner has standing to bring this suit in that he is the presumed father o GERARDO LONNIE BALTIERRA ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE PARENT CHILD RELATIONSHIP Page 1 of 4 Jurisdiction No court has continuing jurisdiction of this suit or of the childthe subject of this suit. Child The following child the subject of this suit: Name: GERARDO LONNIE BALTIERRA ex: Male Birth date: 03/24/2016 County of Residence: Montgomery Nonresident Entitled to Citation GERARDO BALTIERRA, named above, is a nonresident of Texas. The nonresident person has submitted or will submit to the jurisdiction of Texas by consent, by entering a general appearance, or by filing a responsive document having the effect of waiving any contest to personal jurisdiction. Property No property of consequence is owned or possessed by the childthe subject of this suit. Protective Order Statement No protective order under title 4 of the Texas Family Code, under subchapter A of chapter 7B of the Texas Code of Criminal Procedure, or order for emergency protection under Article 17.292 of the Texas Code of Criminal Procedure is in effect in regard to a party to this suit or a child of a party to this suit, and no application for any such order is pending with regard to the parties to this suit or the childof the parties to this suit. Conservatorship The appointment of the Counterpetitioner and Counterrespondent as joint managing ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE PARENT CHILD RELATIONSHIP Page of conservators would not be in the best interest of the child. It is in the best interest of the chil that Counterpetitioner be appointed sole managing conservator of the child. Counterpetitioner requests the Court to order reasonable periods of electronic communication 10. Request for Attorney's Fees, Expenses, Costs, and Interest It was necessary for Counterpetitioner to secure the services of Bryan Fagan, a licensed attorney, to preserve and protect the ch's rights. Counterrespondent should be ordered to pay reasonable attorney's fees, expenses, and costs through trial and appeal, and a judgment should be rendered in favor of this attorney and against Counterrespondent and be ordered paid directly to Counterpetitioner's attorney, who may enforce the judgment in the attorney's own name. Counterpetitioner requests postjudgment interest as allowed by law. Prayer Counterpetitioner prays that the Court enter its orders in accordance with the allegations contained in this counterpetition. Counterpetitioner prays for attorney's fees, expenses, costs, and interest as requested above. Counterpetitioner prays for general relief. Respectfully submitted, Law Office of Bryan Fagan, PLLC 3707 Cypress Creek Parkway, Suite 400 Houston, Texas 77068 Tel: (281) 817-4370 Fax: (855) 668-0536 Eservice@bryanfagan.com ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE PARENT CHILD RELATIONSHIP Page 3 of 4 By:/s/Teri Estes-Hightower Teri Estes-Hightower State Bar No. 24028746 teri@bryanfagan.com Attorney for Counterpetitioner Certificate of Service I certify that a true copy of this Counterpetition in Suit Affecting the Parent Child Relationship was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on September 6, 2022: William E. Harrison and T rri Mendez by electronic filing manager. /s/Teri Estes-Hightower Teri Estes-Hightower Attorney for GERARDO BALTIERRA ORIGINAL COUNTERPETITION IN SUIT AFFECTING THE PARENT CHILD RELATIONSHIP Page 4 of 4