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FILED
10/28/2021 3:55 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
No. DC-21-12550
JINIMY TL CHO, IN THE DISTRICT COURT
§§§§§§§§§§§§§§
Plainttfl,
V.
101“ JUDICIAL DISTRICT
MATTHEWS RETAIL GROUP, INC.
MATTHEWS REAL ESTATE
d/b/a
INVESTMENT SERVICES, ANDREW
GROSS, AMERICAN ARBITRATION
ASSOCIATION, INC., LEE CORDOVA
AND TEXAS TOZEE, LLC,
Defendants. DALLAS COUNTY, TEXAS
ORIGINAL ANSWER 0F
MATTHEWS RETAIL GROUP, INC. D/B/A MATTHEWS REAL ESTATE
INVESTMENT SERVICES, ANDREW GROSS, AND LEE CORDOVA
Defendants Matthews Retail Group, Inc. d/b/a Matthews Real Estate Investment Services
(“Matthews”), Andrew Gross and Lee Cordova, each individually, (collectively, “Matthews
Defendants”) file their Original Answer to Plaintiff‘s Original Petition, as follows:
GENERAL DENIAL
1. Subject to any stipulations and admissions that may hereafter be made, the Matthews
Defendants assert a general denial as authorized by Rule 92 of the Texas Rules of Civil Procedure,
and respectfully request that Plaintiff be required to prove all of his charges and allegations against
Matthews, Mr. Gross, and Mr. Cordova by meeting the appropriate burden of proof as required by
the Constitution and laws of the State of Texas.
AFFIRMATIVE DEFENSES
Subject to and without waiving the foregoing General Denial, the Matthews Defendants
assert, pursuant to Rule 94 of the Texas Rules of Civil Procedure, the following affirmative defenses
which, singly or in combination, bar Plaintiff s right to recover, in whole or in part, the damages
alleged in Plaintiff’ s Original Petition:
2. Plaintiff’ s claims are barred by the existence of a valid and binding arbitration
agreement that governs the issues at bar.
3. Defendants reserve the right to supplemental these admirative defenses based on
new facts obtained during the discovery process.
PRAYER
WI-IEREFORE, PREMISES CONSIDERED, Defendants Matthews Retail Group, Inc,
Andrew Gross, and Lee Cordova respectfully prays that Plaintiff take nothing by way of this suit;
that Matthews, Mr. Gross, and Mr. Cordova recover all their costs and reasonable attorneys’ fees at
the conclusion of this matter; and that Matthews, Mr. Gross, and Mr. Cordova have all other and
further relief to which they may show themselves to be justly entitled.
Respectfully submitted,
BECK REDDEN LLP
|
By: /s/ Fields Alexander
Fields Alexander
State Bar No. 00783528
falexander@beckredden.com
Cassie Maneen
State Bar No. 24120989
cmaneen@beckredden.com
1221 McKinney Street, Suite 4500
Houston, TX 77010
Telephone: (713) 95 1 -3 700
Facsimile: (713) 95 l -3 720
ATTORNEYS FOR MATTHEWS RETAIL
GROUP, INC. D/B/A MATTHEWS REAL
ESTATE, ANDREW GROSS, AND LEE
CORDOVA
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this documents was served on all counsel of
record Via electronic mail on October 28, 2021.
Williams Chu, Esq.
THE LAW OFFICES 0F WILLIAM CHU
4455 KBJ Freeway, Suite 1008
Dallas, Texas 75244
Dawn Estes
Linda Moore
ESTES THORNE & CARR, PLLC
3811 Turtle Creek Blvd, Suite 2000
Dallas, Texas 75219
/s/ Cassie Maneen
Cassie Maneen
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.
Amanda Wheeler on behalf of Fields Alexander
Bar No. 783528
awheeler@beckredden.com
Envelope ID: 58641096
Status as of 10/29/2021 11:51 AM CST
Associated Case Party: JIMMYTLCHO
Name BarNumber Email TimestampSubmitted Status
william Knisley knisley.wmchulaw@gmail.com 10/28/2021 3:55:35 PM SENT
William Chu wmchulaw@gmail.com 10/28/2021 3:55:35 PM SENT
Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 10/28/2021 3:55:35 PM SENT
Office Efiles wmchulawefile@gmail.com 10/28/2021 3:55:35 PM SENT
William Chu wmchulaw@aol.com 10/28/2021 3:55:35 PM SENT
Associated Case Party: MATTHEWS RETAIL GROUP, INC
Name BarNumber Email TimestampSubmitted Status
Cassie Maneen cmaneen@beckredden.com 10/28/2021 3:55:35 PM SENT
Fileds Alexander falexander@beckredden.com 10/28/2021 3:55:35 PM SENT
Associated Case Party: AMERICAN ARBITRATION ASSOCIATION, INC
Name BarNumber Email TimestampSubmitted Status
Linda G.Moore Imoore@estesthornecarr.com 10/28/2021 3:55:35 PM SENT
Dawn Estes destes@estesthornecarr.com 10/28/2021 3:55:35 PM SENT
Tammy Goodson tgoodson@estesthornecarr.com 10/28/2021 3:55:35 PM SENT
Andrea Howard ahoward@estesthornecarr.com 10/28/2021 3:55:35 PM SENT
Kashonna Ross kross@estesthornecarr.com 10/28/2021 3:55:35 PM SENT
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FILED 10/28/2021 3:55 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY No. DC-21-12550 JINIMY TL CHO, IN THE DISTRICT COURT §§§§§§§§§§§§§§ Plainttfl, V. 101“ JUDICIAL DISTRICT MATTHEWS RETAIL GROUP, INC. MATTHEWS REAL ESTATE d/b/a INVESTMENT SERVICES, ANDREW GROSS, AMERICAN ARBITRATION ASSOCIATION, INC., LEE CORDOVA AND TEXAS TOZEE, LLC, Defendants. DALLAS COUNTY, TEXAS ORIGINAL ANSWER 0F MATTHEWS RETAIL GROUP, INC. D/B/A MATTHEWS REAL ESTATE INVESTMENT SERVICES, ANDREW GROSS, AND LEE CORDOVA Defendants Matthews Retail Group, Inc. d/b/a Matthews Real Estate Investment Services (“Matthews”), Andrew Gross and Lee Cordova, each individually, (collectively, “Matthews Defendants”) file their Original Answer to Plaintiff‘s Original Petition, as follows: GENERAL DENIAL 1. Subject to any stipulations and admissions that may hereafter be made, the Matthews Defendants assert a general denial as authorized by Rule 92 of the Texas Rules of Civil Procedure, and respectfully request that Plaintiff be required to prove all of his charges and allegations against Matthews, Mr. Gross, and Mr. Cordova by meeting the appropriate burden of proof as required by the Constitution and laws of the State of Texas. AFFIRMATIVE DEFENSES Subject to and without waiving the foregoing General Denial, the Matthews Defendants assert, pursuant to Rule 94 of the Texas Rules of Civil Procedure, the following affirmative defenses which, singly or in combination, bar Plaintiff s right to recover, in whole or in part, the damages alleged in Plaintiff’ s Original Petition: 2. Plaintiff’ s claims are barred by the existence of a valid and binding arbitration agreement that governs the issues at bar. 3. Defendants reserve the right to supplemental these admirative defenses based on new facts obtained during the discovery process. PRAYER WI-IEREFORE, PREMISES CONSIDERED, Defendants Matthews Retail Group, Inc, Andrew Gross, and Lee Cordova respectfully prays that Plaintiff take nothing by way of this suit; that Matthews, Mr. Gross, and Mr. Cordova recover all their costs and reasonable attorneys’ fees at the conclusion of this matter; and that Matthews, Mr. Gross, and Mr. Cordova have all other and further relief to which they may show themselves to be justly entitled. Respectfully submitted, BECK REDDEN LLP | By: /s/ Fields Alexander Fields Alexander State Bar No. 00783528 falexander@beckredden.com Cassie Maneen State Bar No. 24120989 cmaneen@beckredden.com 1221 McKinney Street, Suite 4500 Houston, TX 77010 Telephone: (713) 95 1 -3 700 Facsimile: (713) 95 l -3 720 ATTORNEYS FOR MATTHEWS RETAIL GROUP, INC. D/B/A MATTHEWS REAL ESTATE, ANDREW GROSS, AND LEE CORDOVA CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this documents was served on all counsel of record Via electronic mail on October 28, 2021. Williams Chu, Esq. THE LAW OFFICES 0F WILLIAM CHU 4455 KBJ Freeway, Suite 1008 Dallas, Texas 75244 Dawn Estes Linda Moore ESTES THORNE & CARR, PLLC 3811 Turtle Creek Blvd, Suite 2000 Dallas, Texas 75219 /s/ Cassie Maneen Cassie Maneen 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. Amanda Wheeler on behalf of Fields Alexander Bar No. 783528 awheeler@beckredden.com Envelope ID: 58641096 Status as of 10/29/2021 11:51 AM CST Associated Case Party: JIMMYTLCHO Name BarNumber Email TimestampSubmitted Status william Knisley knisley.wmchulaw@gmail.com 10/28/2021 3:55:35 PM SENT William Chu wmchulaw@gmail.com 10/28/2021 3:55:35 PM SENT Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 10/28/2021 3:55:35 PM SENT Office Efiles wmchulawefile@gmail.com 10/28/2021 3:55:35 PM SENT William Chu wmchulaw@aol.com 10/28/2021 3:55:35 PM SENT Associated Case Party: MATTHEWS RETAIL GROUP, INC Name BarNumber Email TimestampSubmitted Status Cassie Maneen cmaneen@beckredden.com 10/28/2021 3:55:35 PM SENT Fileds Alexander falexander@beckredden.com 10/28/2021 3:55:35 PM SENT Associated Case Party: AMERICAN ARBITRATION ASSOCIATION, INC Name BarNumber Email TimestampSubmitted Status Linda G.Moore Imoore@estesthornecarr.com 10/28/2021 3:55:35 PM SENT Dawn Estes destes@estesthornecarr.com 10/28/2021 3:55:35 PM SENT Tammy Goodson tgoodson@estesthornecarr.com 10/28/2021 3:55:35 PM SENT Andrea Howard ahoward@estesthornecarr.com 10/28/2021 3:55:35 PM SENT Kashonna Ross kross@estesthornecarr.com 10/28/2021 3:55:35 PM SENT