On June 15, 2023 a
Answer
was filed
involving a dispute between
Tca Logistics, Llc,
and
Roadx Express, Ltd.,
for All Other Civil Cases (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
10/16/2023 8:53 AM
Hidalgo County Clerk
Accepted by: Alejandra Lara
CAUSE NO. CL-23-2371-B
TCA LOGISTICS, LLC, § IN THE COUNTY COURT
Plaintiff §
§
vs. § AT LAW NO. 2
§
ROADX EXPRESS, LTD., §
Defendant § HIDALGO COUNTY, TEXAS
DEFENDANT ROADX EXPRESS, LTD.’S ORIGINAL ANSWER TO PLAINTIFF’S
PETITION FOR BILL OF REVIEW
Comes now RoadX Express Ltd., named as Defendant, and files this Original Answer to
Plaintiff’s Petition for Bill of Review, showing the Court the following:
I.
GENERAL DENIAL
Pursuant to the provisions of Rule 92, Texas Rules of Civil Procedure, Defendant
generally denies each and every one, all and singular, of the allegations contained in Plaintiffs’
pleading, asserts that the allegations contained therein are not true, either in whole or in part, and
demands strict proof thereof. Defendant further reserves the right to amend and/or supplement
this Answer at a future date.
II.
AFFIRMATIVE DEFENSE OF LACHES
Defendant pleads that Plaintiff is not entitled to relief by bill of review because it is guilty
of laches; Defendant expressly reserves the right to further plead additional defenses.
III.
PRAYER
WHEREFORE PREMISES CONSIDERED, Defendant prays that upon final hearing
plaintiff’s bill of review be denied and the judgment in Cause # CL-22-0223-B remain in full force
and effect, undisturbed by this bill of review; Defendant further prays that the Court deny any other
relief requested by Plaintiff in its bill of review. Defendant also prays for affirmative relief as
authorized by law and/or equity, including but not limited to a recovery of all of its court costs and
Page 1 of 2
Electronically Submitted
10/16/2023 8:53 AM
Hidalgo County Clerk
Accepted by: Alejandra Lara
attorneys’ fees.
Respectfully submitted,
ADAMS & GRAHAM, L.L.P.
134 E. Van Buren, Suite 301 (78550)
Post Office Drawer 1429
Harlingen, Texas 78551-1429
Phone: (956) 428-7495 - Ext. 145
Facsimile: (956) 428-2954
By:
WILLIAM L. POPE
Texas State Bar No. 16139020
Email: pope@adamsgraham.com
-and-
B. ADAM NEECE
Texas State Bar No. 24108504
Email: aneece@adamsgraham.com
Attorneys for Defendant RoadX Express, Ltd.
CERTIFICATE OF SERVICE
I hereby certify that on the 16th day of October, 2023 a copy of the above and foregoing
Defendant RoadX Express Ltd.’s Original Answer to Plaintiff’s Bill of Review was served upon
to the following counsel of record, via electronic service, to wit:
Lance Kirby Via E-Filing: lakirby@jgkl.com
JONES, GALLIGAN, KEY & LOZANO, LLP.
2300 W. Pike Blvd., Suite 300
Weslaco, Texas 78596
Attorney for Plaintiff
WILLIAM L. POPE
Page 2 of 2
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.
William Pope on behalf of William Pope
Bar No. 16139020
pope@adamsgraham.com
Envelope ID: 80608389
Filing Code Description: Answer/Response
Filing Description: Defendant RoadX Express, Ltd's Original Answer to
Plaintiff's Petition for Bill of Review
Status as of 10/16/2023 10:16 AM CST
Associated Case Party: TCA Logistics, LLC
Name BarNumber Email TimestampSubmitted Status
Lance A.Kirby lakirby@jgkl.com 10/16/2023 8:53:29 AM SENT
Associated Case Party: RoadX Express, Ltd.
Name BarNumber Email TimestampSubmitted Status
William L.Pope pope@adamsgraham.com 10/16/2023 8:53:29 AM SENT
Benjamin AdamNeece aneece@adamsgraham.com 10/16/2023 8:53:29 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
IRODRIGUEZ @JGKL.COM IRODRIGUEZ@JGKL.COM 10/16/2023 8:53:29 AM ERROR
Document Filed Date
October 16, 2023
Case Filing Date
June 15, 2023
Category
All Other Civil Cases (OCA)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically Submitted 10/16/2023 8:53 AM Hidalgo County Clerk Accepted by: Alejandra Lara CAUSE NO. CL-23-2371-B TCA LOGISTICS, LLC, § IN THE COUNTY COURT Plaintiff § § vs. § AT LAW NO. 2 § ROADX EXPRESS, LTD., § Defendant § HIDALGO COUNTY, TEXAS DEFENDANT ROADX EXPRESS, LTD.’S ORIGINAL ANSWER TO PLAINTIFF’S PETITION FOR BILL OF REVIEW Comes now RoadX Express Ltd., named as Defendant, and files this Original Answer to Plaintiff’s Petition for Bill of Review, showing the Court the following: I. GENERAL DENIAL Pursuant to the provisions of Rule 92, Texas Rules of Civil Procedure, Defendant generally denies each and every one, all and singular, of the allegations contained in Plaintiffs’ pleading, asserts that the allegations contained therein are not true, either in whole or in part, and demands strict proof thereof. Defendant further reserves the right to amend and/or supplement this Answer at a future date. II. AFFIRMATIVE DEFENSE OF LACHES Defendant pleads that Plaintiff is not entitled to relief by bill of review because it is guilty of laches; Defendant expressly reserves the right to further plead additional defenses. III. PRAYER WHEREFORE PREMISES CONSIDERED, Defendant prays that upon final hearing plaintiff’s bill of review be denied and the judgment in Cause # CL-22-0223-B remain in full force and effect, undisturbed by this bill of review; Defendant further prays that the Court deny any other relief requested by Plaintiff in its bill of review. Defendant also prays for affirmative relief as authorized by law and/or equity, including but not limited to a recovery of all of its court costs and Page 1 of 2 Electronically Submitted 10/16/2023 8:53 AM Hidalgo County Clerk Accepted by: Alejandra Lara attorneys’ fees. Respectfully submitted, ADAMS & GRAHAM, L.L.P. 134 E. Van Buren, Suite 301 (78550) Post Office Drawer 1429 Harlingen, Texas 78551-1429 Phone: (956) 428-7495 - Ext. 145 Facsimile: (956) 428-2954 By: WILLIAM L. POPE Texas State Bar No. 16139020 Email: pope@adamsgraham.com -and- B. ADAM NEECE Texas State Bar No. 24108504 Email: aneece@adamsgraham.com Attorneys for Defendant RoadX Express, Ltd. CERTIFICATE OF SERVICE I hereby certify that on the 16th day of October, 2023 a copy of the above and foregoing Defendant RoadX Express Ltd.’s Original Answer to Plaintiff’s Bill of Review was served upon to the following counsel of record, via electronic service, to wit: Lance Kirby Via E-Filing: lakirby@jgkl.com JONES, GALLIGAN, KEY & LOZANO, LLP. 2300 W. Pike Blvd., Suite 300 Weslaco, Texas 78596 Attorney for Plaintiff WILLIAM L. POPE Page 2 of 2 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. William Pope on behalf of William Pope Bar No. 16139020 pope@adamsgraham.com Envelope ID: 80608389 Filing Code Description: Answer/Response Filing Description: Defendant RoadX Express, Ltd's Original Answer to Plaintiff's Petition for Bill of Review Status as of 10/16/2023 10:16 AM CST Associated Case Party: TCA Logistics, LLC Name BarNumber Email TimestampSubmitted Status Lance A.Kirby lakirby@jgkl.com 10/16/2023 8:53:29 AM SENT Associated Case Party: RoadX Express, Ltd. Name BarNumber Email TimestampSubmitted Status William L.Pope pope@adamsgraham.com 10/16/2023 8:53:29 AM SENT Benjamin AdamNeece aneece@adamsgraham.com 10/16/2023 8:53:29 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status IRODRIGUEZ @JGKL.COM IRODRIGUEZ@JGKL.COM 10/16/2023 8:53:29 AM ERROR