On October 18, 2023 a
Answer
was filed
involving a dispute between
Lou, Alexander E.,
and
Lou, Ria,
for Divorce - With Children
in the District Court of Fort Bend County.
Preview
Filed
10/19/2023 11:31 AM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Gloria Fuentes
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
NO. 23-DCV-309747
IN THE MATTER OF IN THE DISTRICT COURT
THE MARRIAGE OF
ALEXANDER E. LOU 505
AND ‘7H JUDICIAL DISTRICT
RIA LOU
AND IN THE INTEREST OF
FORT BEND COUNTY, TEXAS
CHILDREN
RESPONDENT'S ORIGINAL ANSWER
RIA LOU, Respondent, files this Original Answer to Original Petition for Divorce. The
last three numbers of RIA LOU's driver's license number are The last three numbers of RIA
LOU's Social Security number al
1 General Denial
Respondent enters a general denial.
a Objection to Assignment of Case to Associate Judge
Respondent objects to the assignment of this matter to an associate judge for a trial on the
merits or presiding at a jury trial.
5, Information about Children
Information required by section 154.18I(b) and section 154.1815 of the Texas Family
Code is Cigna Health is the children’s medical insurance provider. The policy identification
number is P= Petitioner is responsible for paying the insurance premium coverage.
Monthly premium coverage is unknown at this time.
RESPONDENT'S ORIGINAL ANSWER
Page 1 of 3
4 Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Respondent to secure the services of Daniel Ogbeide, a licensed
attorney, to prepare and prosecute this suit. To effect an equitable division of the estate of the
parties and as a part of the division, and for services rendered in connection with conservatorship
and support of the children, judgment for attorney's fees, expenses, and costs through trial and
appeal should be granted against Petitioner and in favor of Respondent for the use and benefit of
Respondent's attorney and be ordered paid directly to Respondent's attorney, who may enforce
the judgment in the attorney's own name. Respondent requests postjudgment interest as allowed
by law.
Prayer
Respondent prays that Petitioner takes nothing, and that Respondent be granted all relief
requested in this Original Answer.
Respondent also prays for attorney's fees, expenses, costs, and interest as requested
above.
Respondent prays for general relief.
Respectfully submitted,
DANIEL OGBEIDE LAW, PLLC
7324 Southwest Freeway
Suite 570
Houston, TX 77074
Tel: (713) 435-9202
oy. Dot paie
Daniel Ogbeide
State Bar No. 24085508
Nkeiruka Grace Smith
State Bar No. 24131670
daniel@danielolaw.com
Attorney for Respondent
RESPONDENT'S ORIGINAL ANSWER
Page 2 of 3
Certificate of Service
I certify that a true copy of this Respondent's Original Answer was served in accordance
with rule 21a of the Texas Rules of Civil Procedure on the following on October 19, 2023:
Carolyn Robertson by electronic filing manager.
(Deactpeye
Daniel Ogbeide
Attorney for Respondent
RESPONDENT'S ORIGINAL ANSWER
Page 3 of 3
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.
Daniel Ogbeide on behalf of Daniel Ogbeide
Bar No. 24085508
daniel@danielolaw.com
Envelope ID: 80761382
Filing Code Description: Counter Claim/Cross
Action/Interpleader/Intervention/Third Party
Filing Description: Original Counterpetition for Divorce
Status as of 10/19/2023 1:25 PM CST
Associated Case Party: Ria Lou
Name BarNumber | Email TimestampSubmitted Status
Daniel Ogbeide daniel@danielolaw.com | 10/19/2023 11:31:21 AM | SENT
Associated Case Party: AlexanderE.Lou
Name BarNumber | Email TimestampSubmitted Status
Carolyn Robertson CRobertsonAttorney@gmail.com | 10/19/2023 11:31:21 AM | SENT
Document Filed Date
October 19, 2023
Case Filing Date
October 18, 2023
Category
Divorce - With Children
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Filed 10/19/2023 11:31 AM Beverley McGrew Walker District Clerk Fort Bend County, Texas Gloria Fuentes NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NO. 23-DCV-309747 IN THE MATTER OF IN THE DISTRICT COURT THE MARRIAGE OF ALEXANDER E. LOU 505 AND ‘7H JUDICIAL DISTRICT RIA LOU AND IN THE INTEREST OF FORT BEND COUNTY, TEXAS CHILDREN RESPONDENT'S ORIGINAL ANSWER RIA LOU, Respondent, files this Original Answer to Original Petition for Divorce. The last three numbers of RIA LOU's driver's license number are The last three numbers of RIA LOU's Social Security number al 1 General Denial Respondent enters a general denial. a Objection to Assignment of Case to Associate Judge Respondent objects to the assignment of this matter to an associate judge for a trial on the merits or presiding at a jury trial. 5, Information about Children Information required by section 154.18I(b) and section 154.1815 of the Texas Family Code is Cigna Health is the children’s medical insurance provider. The policy identification number is P= Petitioner is responsible for paying the insurance premium coverage. Monthly premium coverage is unknown at this time. RESPONDENT'S ORIGINAL ANSWER Page 1 of 3 4 Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of Daniel Ogbeide, a licensed attorney, to prepare and prosecute this suit. To effect an equitable division of the estate of the parties and as a part of the division, and for services rendered in connection with conservatorship and support of the children, judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Petitioner and in favor of Respondent for the use and benefit of Respondent's attorney and be ordered paid directly to Respondent's attorney, who may enforce the judgment in the attorney's own name. Respondent requests postjudgment interest as allowed by law. Prayer Respondent prays that Petitioner takes nothing, and that Respondent be granted all relief requested in this Original Answer. Respondent also prays for attorney's fees, expenses, costs, and interest as requested above. Respondent prays for general relief. Respectfully submitted, DANIEL OGBEIDE LAW, PLLC 7324 Southwest Freeway Suite 570 Houston, TX 77074 Tel: (713) 435-9202 oy. Dot paie Daniel Ogbeide State Bar No. 24085508 Nkeiruka Grace Smith State Bar No. 24131670 daniel@danielolaw.com Attorney for Respondent RESPONDENT'S ORIGINAL ANSWER Page 2 of 3 Certificate of Service I certify that a true copy of this Respondent's Original Answer was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on October 19, 2023: Carolyn Robertson by electronic filing manager. (Deactpeye Daniel Ogbeide Attorney for Respondent RESPONDENT'S ORIGINAL ANSWER Page 3 of 3 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. Daniel Ogbeide on behalf of Daniel Ogbeide Bar No. 24085508 daniel@danielolaw.com Envelope ID: 80761382 Filing Code Description: Counter Claim/Cross Action/Interpleader/Intervention/Third Party Filing Description: Original Counterpetition for Divorce Status as of 10/19/2023 1:25 PM CST Associated Case Party: Ria Lou Name BarNumber | Email TimestampSubmitted Status Daniel Ogbeide daniel@danielolaw.com | 10/19/2023 11:31:21 AM | SENT Associated Case Party: AlexanderE.Lou Name BarNumber | Email TimestampSubmitted Status Carolyn Robertson CRobertsonAttorney@gmail.com | 10/19/2023 11:31:21 AM | SENT