On June 23, 2020 a
Answer
was filed
involving a dispute between
Credit Corp Solutions Inc.,
and
Rios-Garcia, Tranquilino,
for Contract - Consumer/Commercial/Debt (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
10/17/2023 5:25 PM
Hidalgo County Clerk
Accepted by: Valeria Garcia
CAUSE NO. CL-20-2576-H
CREDIT CORP SOLUTIONS INC. § IN THE COUNTY COURT
§
vs. § AT LAW NO. 8
§
TRANQUILINO RIOS-GARCIA § HIDALGO COUNTY, TEXAS
DEFENDANT TRANQUILINO RIOS-GARCIA’S
ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
Tranquilino Rios-Garcia (“Defendant”), Defendant in the above-styled and numbered
cause, and files this Original Answer to Plaintiff Credit Corp Solutions Inc.’s (“Plaintiff”) Original
Petition. In support of same, Defendant would respectfully show unto this Honorable Court the
following:
I.
GENERAL DENIAL
1. Pursuant to Tex. R. Civ. P. 92, Defendant enters a general denial of the matters pled
by Plaintiff and demands strict proof thereof that this claim be denied and dismissed in its entirety.
II.
RIGHT TO AMEND
2. Pleading additionally and/or in the alternative, Defendant reserves the right to
amend its answer following further discovery in this cause and as allowed by Texas law.
III.
JURY DEMAND
3. Pursuant to Tex. R. Civ. P. 216, Defendant requests a trial by jury.
Electronically Submitted
10/17/2023 5:25 PM
Hidalgo County Clerk
Accepted by: Valeria Garcia
Respectfully submitted,
THE FUENTES FIRM, P.C.
/s/ Kimberly Rankin
Kimberly R. Rankin
State Bar No. 24051230
5507 Louetta Road, Suite A
Spring, Texas 77379
Telephone: (281) 378-7640
kim@fuentesfirm.com
ATTORNEY FOR DEFENDANT
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing has been served in accordance with
the Texas Rules of Civil Procedure on October 17, 2023.
/s/ Kimberly Rankin
Kimberly R. Rankin
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.
Ashley Runcie on behalf of Kimberly Rankin
Bar No. 24051230
ashley@fuentesfirm.com
Envelope ID: 80695166
Filing Code Description: Answer
Filing Description: Defendant Tranquilino Rios-Garcia's Original Answer
Status as of 10/18/2023 8:08 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
ABC LEGAL ABC LEGAL mjscourts@abclegal.com 10/17/2023 5:25:27 PM SENT
Associated Case Party: Tranquilino Rios-garcia
Name BarNumber Email TimestampSubmitted Status
Sophia Casso sophia@fuentesfirm.com 10/17/2023 5:25:27 PM SENT
Ashley Runcie ashley@fuentesfirm.com 10/17/2023 5:25:27 PM SENT
Kim Rankin kim@fuentesfirm.com 10/17/2023 5:25:27 PM SENT
Document Filed Date
October 17, 2023
Case Filing Date
June 23, 2020
Category
Contract - Consumer/Commercial/Debt (OCA)
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Electronically Submitted 10/17/2023 5:25 PM Hidalgo County Clerk Accepted by: Valeria Garcia CAUSE NO. CL-20-2576-H CREDIT CORP SOLUTIONS INC. § IN THE COUNTY COURT § vs. § AT LAW NO. 8 § TRANQUILINO RIOS-GARCIA § HIDALGO COUNTY, TEXAS DEFENDANT TRANQUILINO RIOS-GARCIA’S ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: Tranquilino Rios-Garcia (“Defendant”), Defendant in the above-styled and numbered cause, and files this Original Answer to Plaintiff Credit Corp Solutions Inc.’s (“Plaintiff”) Original Petition. In support of same, Defendant would respectfully show unto this Honorable Court the following: I. GENERAL DENIAL 1. Pursuant to Tex. R. Civ. P. 92, Defendant enters a general denial of the matters pled by Plaintiff and demands strict proof thereof that this claim be denied and dismissed in its entirety. II. RIGHT TO AMEND 2. Pleading additionally and/or in the alternative, Defendant reserves the right to amend its answer following further discovery in this cause and as allowed by Texas law. III. JURY DEMAND 3. Pursuant to Tex. R. Civ. P. 216, Defendant requests a trial by jury. Electronically Submitted 10/17/2023 5:25 PM Hidalgo County Clerk Accepted by: Valeria Garcia Respectfully submitted, THE FUENTES FIRM, P.C. /s/ Kimberly Rankin Kimberly R. Rankin State Bar No. 24051230 5507 Louetta Road, Suite A Spring, Texas 77379 Telephone: (281) 378-7640 kim@fuentesfirm.com ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing has been served in accordance with the Texas Rules of Civil Procedure on October 17, 2023. /s/ Kimberly Rankin Kimberly R. Rankin 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. Ashley Runcie on behalf of Kimberly Rankin Bar No. 24051230 ashley@fuentesfirm.com Envelope ID: 80695166 Filing Code Description: Answer Filing Description: Defendant Tranquilino Rios-Garcia's Original Answer Status as of 10/18/2023 8:08 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status ABC LEGAL ABC LEGAL mjscourts@abclegal.com 10/17/2023 5:25:27 PM SENT Associated Case Party: Tranquilino Rios-garcia Name BarNumber Email TimestampSubmitted Status Sophia Casso sophia@fuentesfirm.com 10/17/2023 5:25:27 PM SENT Ashley Runcie ashley@fuentesfirm.com 10/17/2023 5:25:27 PM SENT Kim Rankin kim@fuentesfirm.com 10/17/2023 5:25:27 PM SENT