Preview
Filed
9/14/2023 1:21 PM
Anne Lorentzen
2023-71844 / Court: 234 District Clerk
Nueces County, Texas
Cause No. 2023CCV-60891-1
SUNOCO, LLC IN THE COUNTY COURT
Plaintiffs,
Vv. AT LAW, NUMBER 1 (ONE)
ASMITA REAL PROPERTY, INC.
SEHAM C-STORE LLC and
RIYAZALI R. MOMIN, Individually
Defendant. NUECES COUNTY, TEXAS
DEFENDANTS, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC.,
AND RIYAZALI R. MOMIN’S ORIGINAL ANSWER SUBJECT TO THEIR MOTION
TO TRANSFER VENUE AND PLEA TO THE JURISDICTION
TO THE HONORABLE COURT:
COMES NOW, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC and
RIYAZALI R. MOMIN, Defendants in the above-styled and numbered cause, and file this their
Original Answer, Subject to their Motion to Transfer Venue and Plea to the Jurisdiction and in
support thereof, would respectfully show the Court the following:
I
GENERAL DENIAL
Pursuant to Texas Rule of Civil Procedure 92, Defendants, ASMITA REAL PROPERTY,
INC., SEHAM C-STORE, LLC and RIYAZALI R. MOMIN, hereby enter a General Denial of all
matters pled by Plaintiff, and request that the Court require Plaintiffs to prove their charges and
allegations by a preponderance of the evidence under the Constitution and the Laws of the State of
Texas.
Defendants, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC and RIYAZALI
R. MOMIN, reserve the right to amend this answer and assert any and all available affirmative
1
defenses which may be available to them.
I.
CONCLUSION AND PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendants, ASMITA REAL PROPERTY,
INC., SEHAM C-STORE, LLC and RIYAZALIR. MOMIN, pray that upon a trial of this cause that
they have judgment and that Plaintiff takes nothing by its case and that Defendants are awarded their
costs and expenses in the matter and for such other and further relief, at law and in equity, to which
Defendants are entitled.
Respectfully submitted,
DABNEY PAPPAS
By: /s/ Gus E. Pappas
Gus E. Pappas
State Bar No. 15454850
gus@dabneypappas.com
1776 Yorktown, Suite 425
Houston, Texas 77056
(713) 621-2678 Telephone
(713) 621-0074 Facsimile
ATTORNEY FOR DEFENDANTS
ASMITA REAL PROPERTY,
SEHAM C-STORE, LLC AND
RIYAZALI R. MOMIN
CERTIFICATE OF SERVICE
In accordance with TEX. R. CIV. P. 21A, L, Gus E. Pappas, do hereby certify that a true and
correct copy of the above and foregoing Defendants, ASMITA REAL PROPERTY, INC., SEHAM
C-STORE, LLC and RIY AZALI R. MOMIN’s Original Answer, Subject to their Motion to Transfer
Venue and Plea to the Jurisdiction was forwarded to the following counsel of record, by electronic
service, on this the 14" day of September, 2023.
C.M. Henkel, IIT
State Bar ID No. 0946300
800 N. Shoreline Blvd., Suite 2000 S
Corpus Christi, Texas 78401
(361) 884-5400 Telephone
(361) 884-5401 Facismile
shenkel@coplawfirm.com
/s/ Gus E. Pappas
Gus E, Pappas
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.
Monica Maldonado on behalf of Gus Pappas
Bar No. 15454850
monica@dabneypappas.com
Envelope ID: 79556612
Filing Code Description: Original Answer
Filing Description: Defendants, Asmita Real Property, Inc., Seham
C-Store, LLC and Riyazali R. Momin's Original Answer Subject to Their
Motion to Transfer Venue and Plea
Status as of 9/14/2023 1:29 PM CST
Case Contacts
Name BarNumber | Email TimestampSubmitted Status
Lauren Perez Iperez@coplawfirm.com 9/14/2023 1:21:43 PM SENT
Sophia Pulido spulido@coplawfirm.com 9/14/2023 1:21:43 PM SENT
C MHenkel III shenkel@coplawfirm.com 9/14/2023 1:21:43 PM SENT
Gus EPappas gus@dabneypappas.com 9/14/2023 1:21:43 PM SENT
Preview
Filed 9/14/2023 1:21 PM Anne Lorentzen 2023-71844 / Court: 234 District Clerk Nueces County, Texas Cause No. 2023CCV-60891-1 SUNOCO, LLC IN THE COUNTY COURT Plaintiffs, Vv. AT LAW, NUMBER 1 (ONE) ASMITA REAL PROPERTY, INC. SEHAM C-STORE LLC and RIYAZALI R. MOMIN, Individually Defendant. NUECES COUNTY, TEXAS DEFENDANTS, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC., AND RIYAZALI R. MOMIN’S ORIGINAL ANSWER SUBJECT TO THEIR MOTION TO TRANSFER VENUE AND PLEA TO THE JURISDICTION TO THE HONORABLE COURT: COMES NOW, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC and RIYAZALI R. MOMIN, Defendants in the above-styled and numbered cause, and file this their Original Answer, Subject to their Motion to Transfer Venue and Plea to the Jurisdiction and in support thereof, would respectfully show the Court the following: I GENERAL DENIAL Pursuant to Texas Rule of Civil Procedure 92, Defendants, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC and RIYAZALI R. MOMIN, hereby enter a General Denial of all matters pled by Plaintiff, and request that the Court require Plaintiffs to prove their charges and allegations by a preponderance of the evidence under the Constitution and the Laws of the State of Texas. Defendants, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC and RIYAZALI R. MOMIN, reserve the right to amend this answer and assert any and all available affirmative 1 defenses which may be available to them. I. CONCLUSION AND PRAYER WHEREFORE, PREMISES CONSIDERED, Defendants, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC and RIYAZALIR. MOMIN, pray that upon a trial of this cause that they have judgment and that Plaintiff takes nothing by its case and that Defendants are awarded their costs and expenses in the matter and for such other and further relief, at law and in equity, to which Defendants are entitled. Respectfully submitted, DABNEY PAPPAS By: /s/ Gus E. Pappas Gus E. Pappas State Bar No. 15454850 gus@dabneypappas.com 1776 Yorktown, Suite 425 Houston, Texas 77056 (713) 621-2678 Telephone (713) 621-0074 Facsimile ATTORNEY FOR DEFENDANTS ASMITA REAL PROPERTY, SEHAM C-STORE, LLC AND RIYAZALI R. MOMIN CERTIFICATE OF SERVICE In accordance with TEX. R. CIV. P. 21A, L, Gus E. Pappas, do hereby certify that a true and correct copy of the above and foregoing Defendants, ASMITA REAL PROPERTY, INC., SEHAM C-STORE, LLC and RIY AZALI R. MOMIN’s Original Answer, Subject to their Motion to Transfer Venue and Plea to the Jurisdiction was forwarded to the following counsel of record, by electronic service, on this the 14" day of September, 2023. C.M. Henkel, IIT State Bar ID No. 0946300 800 N. Shoreline Blvd., Suite 2000 S Corpus Christi, Texas 78401 (361) 884-5400 Telephone (361) 884-5401 Facismile shenkel@coplawfirm.com /s/ Gus E. Pappas Gus E, Pappas 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. Monica Maldonado on behalf of Gus Pappas Bar No. 15454850 monica@dabneypappas.com Envelope ID: 79556612 Filing Code Description: Original Answer Filing Description: Defendants, Asmita Real Property, Inc., Seham C-Store, LLC and Riyazali R. Momin's Original Answer Subject to Their Motion to Transfer Venue and Plea Status as of 9/14/2023 1:29 PM CST Case Contacts Name BarNumber | Email TimestampSubmitted Status Lauren Perez Iperez@coplawfirm.com 9/14/2023 1:21:43 PM SENT Sophia Pulido spulido@coplawfirm.com 9/14/2023 1:21:43 PM SENT C MHenkel III shenkel@coplawfirm.com 9/14/2023 1:21:43 PM SENT Gus EPappas gus@dabneypappas.com 9/14/2023 1:21:43 PM SENT