Preview
Electronically Filed
10/23/2023 3:22 PM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
CAUSE NO.: C-3112-20-J
C S CONSTRUCTION & DEVELOPMENT § IN THE JUDICIAL
Plaintiff, §
§
VS. § 430TH DISTRICT COURT
§
MANUEL GARCIA AND ANGELICA §
MEDINA §
Defendants. § HIDALGO COUNTY, TEXAS
DEFENDANTS’ ORIGINAL ANSWER AND FIRST AMENDED COUNTERPETITION
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Defendant/Counter-Plaintiff, Manuel Garcia and Angelica Medina
(“COUNTER-PLAINTIFFS”) in the above-entitled and numbered cause, by and through their
attorney of record, Terry Canales, and hereby files this Defendants’ Original Answer and First
Amended Counterpetition, and in support thereof, would respectfully show unto this Court:
I.
GENERAL DENIAL
1.0 Defendant/Counter-Plaintiffs denies each and every allegation in Plaintiff’s
Original Petition and demand strict proof thereof, as required by the Texas Rules of Civil
Procedure.
II.
AFFIRMATIVE DEFENSES
2.0 Defendant/Counter-Plaintiffs asserts the Affirmative Defense of Unclean Hands.
Plaintiff/Counter-Defendant is not entitled to the relief demanded in their Plaintiffs’ Original
Petition, in that the Plaintiffs/Counter-Defendants have come to this Court with unclean hands.
Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 1 of 7
Electronically Filed
10/23/2023 3:22 PM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
Specifically, Plaintiff/Counter-Defendants performed services in an unworkmanlike and negligent
manner. Accordingly, the failure to pay for services rendered, if any, is unwarranted as payment
was not properly earned. As a result, Plaintiffs/Counter-Defendants’ demand for relief should be
barred.
III.
REQUIRED DISCLOSURES
3.0 Pursuant to Rule 194 of the Texas Rules of Civil Procedure, Plaintiff must disclose,
within thirty (30) days of service of this request, the information or material described in 194.2(a)-
(1).
IV.
FACTUAL BACKGROUND
4.0 On July 7, 2019, Counter-Plaintiffs entered into a contract with Counter-Defendant
C&S Construction & Development for a project known as “The Angel Ranch.” After the
commencement of construction, it become readily apparent that the construction was being built
in an unworkmanlike and negligent manner. For example, entry structures of the building were
built incorrectly as they were built without reinforcement or concrete filled cells. This complete
lack of reinforcement is unsafe and a violation of code requirements. Additionally, multiple walls
of the structures were built out of plumb. Multiple windows and entryways were built without steel
plate reinforcement. Additionally, portions of the foundation were improperly laid, causing walls
to come apart at the intersecting corners. The construction work done by Counter-Defendant is
wholly defective and will require demolition and reconstruction.
V.
COUNTERPETITION
Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 2 of 7
Electronically Filed
10/23/2023 3:22 PM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
A. BREACH OF CONTRACT
5.0 All preceding paragraphs above are incorporated herein as if set forth again in full.
5.1 There is a valid, enforceable contract.
5.2 Counter-Plaintiffs are the proper parties to bring suit for breach of contract.
5.3 Counter-Plaintiffs performed, tendered performance of, or was excused from
performing its contractual obligations.
5.4 Counter-Defendants breached the contract.
5.5 Counter-Defendant’s breach has caused Counter-Plaintiffs’ injury.
B. COMMON-LAW FRAUD
6.0 All preceding paragraphs above are incorporated herein as if set forth again in full.
6.1 Counter-Defendant made a representation to Counter-Plaintiffs.
6.2 The representation was material and false.
6.3 When Counter-Defendant made the representation, Counter-Defendant knew the
representation was false, or made the representation reckless, as a positive assertion, and
without knowledge of its truth.
6.4 Counter-Defendant made the representation with the intent that Counter-Plaintiff
act on it.
6.5 Counter-Plaintiff relied on the representation.
6.6 The representation caused Counter-Plaintiff injury.
C. EXPRESS WARRANTY FOR SERVICES
7.0 All preceding paragraphs above are incorporated herein as if set forth again in full.
Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 3 of 7
Electronically Filed
10/23/2023 3:22 PM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
7.1 Counter-Defendant sold services to the Counter-Plaintiffs. Namely, construction
services.
7.2 Counter Defendant made representation(s) to Counter-Plaintiffs about the quality
or characteristics of the services in by affirmation of fact, by promise, or by description.
7.3 The representation(s) became part of the basis of the bargain.
7.4 Counter-Defendants breached the warranty.
7.5 If required by the parties’ agreement, Counter-Plaintiffs notified Counter-
Defendant of the breach.
7.6 Counter-Plaintiffs suffered injury.
D. NEGLIGENCE
8.0 All preceding paragraphs above are incorporated herein as if set forth again in full.
8.1 Counter-Defendant owed a legal/contractual duty to Counter-Plaintiffs. Namely, to
perform construction services free from material structural defects.
8.2 Counter-Defendant breached said duty.
8.3 Counter-Defendant’s breach has proximately caused Counter-Plaintiffs’ injuries.
E. NEGLIGENT MISREPRESENTATION
9.0 All preceding paragraphs above are incorporated herein as if set forth again in full.
9.1 Counter-Defendant made representation(s) to Counter-Plaintiffs in the course of the
Counter-Defendant’s business or in a transaction in which the Counter-Defendant had a
pecuniary interest.
9.2 Counter-Defendant supplied false information for the guidance of others.
Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 4 of 7
Electronically Filed
10/23/2023 3:22 PM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
9.3 Counter-Defendant did not use reasonable care in obtaining or communicating the
information.
9.4 Counter-Plaintiffs justifiably relied on the representation(s).
9.5 Counter-Defendant’s negligent misrepresentation proximately caused the Counter-
Plaintiffs’ injury.
F. FRAUDULENT LIEN/CLAIM UNDER SECTION 12.002 CIVIL PRACTICE AND
REMEDIES CODE
10.0 All preceding paragraphs above are incorporated herein as if set forth again in full.
10.1 Counter-Defendant has made, presented, or used a document or other record with:
(1) knowledge that the document or other record is a fraudulent court record or a fraudulent
lien or claim against real or personal property or an interest in real or personal property;
(2) intent that the document or other record be given the same legal effect as a court record
or document of a court created by or established under the constitution or laws of this state
or the United States or another entity listed in Section 37.01, Penal Code, evidencing a
valid lien or claim against real or personal property or an interest in real or personal
property; and (3) intent to cause another person to suffer: (A) physical injury; (B)
financial injury; or (C) mental anguish or emotional distress.
G. ATTORNEY’S FEES
11.0 It was necessary for Counter-Plaintiffs to secure the services of Terry Canales
Attorney at Law, a licensed attorney, to prepare and prosecute this suit. Judgment for attorney's
fees, expenses, and costs through trial and appeal should be granted against Counter-Defendants
and in favor of Counter-Plaintiffs for the use and benefit of Counter-Plaintiffs’ attorney and be
Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 5 of 7
Electronically Filed
10/23/2023 3:22 PM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
ordered paid directly to Counter-Plaintiffs’ attorney, who may enforce the judgment in the
attorney's own name. Counter-Plaintiffs requests post-judgment interest as allowed by law.
VI.
DAMAGES
12.0 All preceding paragraphs above are incorporated herein as if set forth again in full.
12.1 For the preceding causes of actions, Counter-Plaintiffs can recover actual damages,
economic damages, loss of sale damages, loss of business damages, exemplary damages, attorneys,
fees, and other equitable remedies.
12.2 In the instant action, Counter-Plaintiffs are entitled to damages in excess of
$1,000,000.00 (one-million US dollars and no cents).
VII.
JURY TRIAL
13.0 Counter-Plaintiffs hereby request a trial by jury.
VIII.
PRAYER
WHEREFORE PREMISES CONSIDERED, Defendant/Counter-Plaintiffs herein,
respectfully prays that the Court, upon final hearing of these matters, grant judgment in favor of
Counter-Plaintiffs and against Counter-Defendant. Defendant/Counter-Plaintiffs further requests
and pleads for all other relief they are justly entitled to at law or equity.
Respectfully submitted,
Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 6 of 7
Electronically Filed
10/23/2023 3:22 PM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
/s/ Terry Canales
Terry Canales
TERRY CANALES
ATTORNEY AT LAW, P.L.L.C.
310 S. Closner Blvd.
Edinburg, TX 78539
Phone: (956) 316-2223
Facsimile: (956) 316-2229
Email: bjchapa@rgvattorney.com
Attorney for Defendants
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing was this 23rd day of October,
2023, forwarded to all counsel of record via Texas eFile.
/s/ Terry Canales
TERRY CANALES
Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 7 of 7
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.
E-file Terry Canales, Attorney at Law PLLC on behalf of Terry Canales
Bar No. 24052947
efile.tclaw@gmail.com
Envelope ID: 80875082
Filing Code Description: Answer
Filing Description: DEFENDANTS ORIGINAL ANSWER AND FIRST
AMENDED COUNTERPETITION
Status as of 10/24/2023 9:38 AM CST
Associated Case Party: CS Construction & Development
Name BarNumber Email TimestampSubmitted Status
DAVID FLORES dflores@rgvfirm.com 10/23/2023 3:22:00 PM SENT
JOY BARBOZA jb@rgvfirm.com 10/23/2023 3:22:00 PM SENT
Victoria Olivarez vo@rgvfirm.com 10/23/2023 3:22:00 PM SENT
David L.Flores davidf@floresandtorresllp.com 10/23/2023 3:22:00 PM ERROR
Associated Case Party: Manuel Garcia
Name BarNumber Email TimestampSubmitted Status
Karalynn Cromeens Karalynn@TheCromeensLawFirm.com 10/23/2023 3:22:00 PM SENT
Jonelle Oldacre joldacre@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT
Meghan Billeaud paralegal@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT
Natalie Smith NSmith@TheCromeensLawFirm.com 10/23/2023 3:22:00 PM SENT
Liliana lopez LLopez@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT
Terry Canales tclawoffice@rgvattorney.com 10/23/2023 3:22:00 PM SENT
Terry Canales tcanales@rgvattorney.com 10/23/2023 3:22:00 PM SENT
Billy J.Chapa bjchapa@rgvattorney.com 10/23/2023 3:22:00 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Manuel Garcia manuelg956@yahoo.com 10/23/2023 3:22:00 PM SENT
DAVID LFLORES MARYQ@FLORESANDTORRESLLP.COM 10/23/2023 3:22:00 PM ERROR
JOHN GRIFFITH JRG@RGVFIRM.COM 10/23/2023 3:22:00 PM SENT
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.
E-file Terry Canales, Attorney at Law PLLC on behalf of Terry Canales
Bar No. 24052947
efile.tclaw@gmail.com
Envelope ID: 80875082
Filing Code Description: Answer
Filing Description: DEFENDANTS ORIGINAL ANSWER AND FIRST
AMENDED COUNTERPETITION
Status as of 10/24/2023 9:38 AM CST
Case Contacts
MAYRA MALDONADO mmaldonado@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT
Preview
Electronically Filed 10/23/2023 3:22 PM Hidalgo County District Clerks Reviewed By: Adrienne Rocha CAUSE NO.: C-3112-20-J C S CONSTRUCTION & DEVELOPMENT § IN THE JUDICIAL Plaintiff, § § VS. § 430TH DISTRICT COURT § MANUEL GARCIA AND ANGELICA § MEDINA § Defendants. § HIDALGO COUNTY, TEXAS DEFENDANTS’ ORIGINAL ANSWER AND FIRST AMENDED COUNTERPETITION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Defendant/Counter-Plaintiff, Manuel Garcia and Angelica Medina (“COUNTER-PLAINTIFFS”) in the above-entitled and numbered cause, by and through their attorney of record, Terry Canales, and hereby files this Defendants’ Original Answer and First Amended Counterpetition, and in support thereof, would respectfully show unto this Court: I. GENERAL DENIAL 1.0 Defendant/Counter-Plaintiffs denies each and every allegation in Plaintiff’s Original Petition and demand strict proof thereof, as required by the Texas Rules of Civil Procedure. II. AFFIRMATIVE DEFENSES 2.0 Defendant/Counter-Plaintiffs asserts the Affirmative Defense of Unclean Hands. Plaintiff/Counter-Defendant is not entitled to the relief demanded in their Plaintiffs’ Original Petition, in that the Plaintiffs/Counter-Defendants have come to this Court with unclean hands. Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 1 of 7 Electronically Filed 10/23/2023 3:22 PM Hidalgo County District Clerks Reviewed By: Adrienne Rocha Specifically, Plaintiff/Counter-Defendants performed services in an unworkmanlike and negligent manner. Accordingly, the failure to pay for services rendered, if any, is unwarranted as payment was not properly earned. As a result, Plaintiffs/Counter-Defendants’ demand for relief should be barred. III. REQUIRED DISCLOSURES 3.0 Pursuant to Rule 194 of the Texas Rules of Civil Procedure, Plaintiff must disclose, within thirty (30) days of service of this request, the information or material described in 194.2(a)- (1). IV. FACTUAL BACKGROUND 4.0 On July 7, 2019, Counter-Plaintiffs entered into a contract with Counter-Defendant C&S Construction & Development for a project known as “The Angel Ranch.” After the commencement of construction, it become readily apparent that the construction was being built in an unworkmanlike and negligent manner. For example, entry structures of the building were built incorrectly as they were built without reinforcement or concrete filled cells. This complete lack of reinforcement is unsafe and a violation of code requirements. Additionally, multiple walls of the structures were built out of plumb. Multiple windows and entryways were built without steel plate reinforcement. Additionally, portions of the foundation were improperly laid, causing walls to come apart at the intersecting corners. The construction work done by Counter-Defendant is wholly defective and will require demolition and reconstruction. V. COUNTERPETITION Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 2 of 7 Electronically Filed 10/23/2023 3:22 PM Hidalgo County District Clerks Reviewed By: Adrienne Rocha A. BREACH OF CONTRACT 5.0 All preceding paragraphs above are incorporated herein as if set forth again in full. 5.1 There is a valid, enforceable contract. 5.2 Counter-Plaintiffs are the proper parties to bring suit for breach of contract. 5.3 Counter-Plaintiffs performed, tendered performance of, or was excused from performing its contractual obligations. 5.4 Counter-Defendants breached the contract. 5.5 Counter-Defendant’s breach has caused Counter-Plaintiffs’ injury. B. COMMON-LAW FRAUD 6.0 All preceding paragraphs above are incorporated herein as if set forth again in full. 6.1 Counter-Defendant made a representation to Counter-Plaintiffs. 6.2 The representation was material and false. 6.3 When Counter-Defendant made the representation, Counter-Defendant knew the representation was false, or made the representation reckless, as a positive assertion, and without knowledge of its truth. 6.4 Counter-Defendant made the representation with the intent that Counter-Plaintiff act on it. 6.5 Counter-Plaintiff relied on the representation. 6.6 The representation caused Counter-Plaintiff injury. C. EXPRESS WARRANTY FOR SERVICES 7.0 All preceding paragraphs above are incorporated herein as if set forth again in full. Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 3 of 7 Electronically Filed 10/23/2023 3:22 PM Hidalgo County District Clerks Reviewed By: Adrienne Rocha 7.1 Counter-Defendant sold services to the Counter-Plaintiffs. Namely, construction services. 7.2 Counter Defendant made representation(s) to Counter-Plaintiffs about the quality or characteristics of the services in by affirmation of fact, by promise, or by description. 7.3 The representation(s) became part of the basis of the bargain. 7.4 Counter-Defendants breached the warranty. 7.5 If required by the parties’ agreement, Counter-Plaintiffs notified Counter- Defendant of the breach. 7.6 Counter-Plaintiffs suffered injury. D. NEGLIGENCE 8.0 All preceding paragraphs above are incorporated herein as if set forth again in full. 8.1 Counter-Defendant owed a legal/contractual duty to Counter-Plaintiffs. Namely, to perform construction services free from material structural defects. 8.2 Counter-Defendant breached said duty. 8.3 Counter-Defendant’s breach has proximately caused Counter-Plaintiffs’ injuries. E. NEGLIGENT MISREPRESENTATION 9.0 All preceding paragraphs above are incorporated herein as if set forth again in full. 9.1 Counter-Defendant made representation(s) to Counter-Plaintiffs in the course of the Counter-Defendant’s business or in a transaction in which the Counter-Defendant had a pecuniary interest. 9.2 Counter-Defendant supplied false information for the guidance of others. Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 4 of 7 Electronically Filed 10/23/2023 3:22 PM Hidalgo County District Clerks Reviewed By: Adrienne Rocha 9.3 Counter-Defendant did not use reasonable care in obtaining or communicating the information. 9.4 Counter-Plaintiffs justifiably relied on the representation(s). 9.5 Counter-Defendant’s negligent misrepresentation proximately caused the Counter- Plaintiffs’ injury. F. FRAUDULENT LIEN/CLAIM UNDER SECTION 12.002 CIVIL PRACTICE AND REMEDIES CODE 10.0 All preceding paragraphs above are incorporated herein as if set forth again in full. 10.1 Counter-Defendant has made, presented, or used a document or other record with: (1) knowledge that the document or other record is a fraudulent court record or a fraudulent lien or claim against real or personal property or an interest in real or personal property; (2) intent that the document or other record be given the same legal effect as a court record or document of a court created by or established under the constitution or laws of this state or the United States or another entity listed in Section 37.01, Penal Code, evidencing a valid lien or claim against real or personal property or an interest in real or personal property; and (3) intent to cause another person to suffer: (A) physical injury; (B) financial injury; or (C) mental anguish or emotional distress. G. ATTORNEY’S FEES 11.0 It was necessary for Counter-Plaintiffs to secure the services of Terry Canales Attorney at Law, a licensed attorney, to prepare and prosecute this suit. Judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Counter-Defendants and in favor of Counter-Plaintiffs for the use and benefit of Counter-Plaintiffs’ attorney and be Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 5 of 7 Electronically Filed 10/23/2023 3:22 PM Hidalgo County District Clerks Reviewed By: Adrienne Rocha ordered paid directly to Counter-Plaintiffs’ attorney, who may enforce the judgment in the attorney's own name. Counter-Plaintiffs requests post-judgment interest as allowed by law. VI. DAMAGES 12.0 All preceding paragraphs above are incorporated herein as if set forth again in full. 12.1 For the preceding causes of actions, Counter-Plaintiffs can recover actual damages, economic damages, loss of sale damages, loss of business damages, exemplary damages, attorneys, fees, and other equitable remedies. 12.2 In the instant action, Counter-Plaintiffs are entitled to damages in excess of $1,000,000.00 (one-million US dollars and no cents). VII. JURY TRIAL 13.0 Counter-Plaintiffs hereby request a trial by jury. VIII. PRAYER WHEREFORE PREMISES CONSIDERED, Defendant/Counter-Plaintiffs herein, respectfully prays that the Court, upon final hearing of these matters, grant judgment in favor of Counter-Plaintiffs and against Counter-Defendant. Defendant/Counter-Plaintiffs further requests and pleads for all other relief they are justly entitled to at law or equity. Respectfully submitted, Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 6 of 7 Electronically Filed 10/23/2023 3:22 PM Hidalgo County District Clerks Reviewed By: Adrienne Rocha /s/ Terry Canales Terry Canales TERRY CANALES ATTORNEY AT LAW, P.L.L.C. 310 S. Closner Blvd. Edinburg, TX 78539 Phone: (956) 316-2223 Facsimile: (956) 316-2229 Email: bjchapa@rgvattorney.com Attorney for Defendants CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing was this 23rd day of October, 2023, forwarded to all counsel of record via Texas eFile. /s/ Terry Canales TERRY CANALES Counter-Defendants’ Original Answer and First Amended Counterpetition | Page 7 of 7 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. E-file Terry Canales, Attorney at Law PLLC on behalf of Terry Canales Bar No. 24052947 efile.tclaw@gmail.com Envelope ID: 80875082 Filing Code Description: Answer Filing Description: DEFENDANTS ORIGINAL ANSWER AND FIRST AMENDED COUNTERPETITION Status as of 10/24/2023 9:38 AM CST Associated Case Party: CS Construction & Development Name BarNumber Email TimestampSubmitted Status DAVID FLORES dflores@rgvfirm.com 10/23/2023 3:22:00 PM SENT JOY BARBOZA jb@rgvfirm.com 10/23/2023 3:22:00 PM SENT Victoria Olivarez vo@rgvfirm.com 10/23/2023 3:22:00 PM SENT David L.Flores davidf@floresandtorresllp.com 10/23/2023 3:22:00 PM ERROR Associated Case Party: Manuel Garcia Name BarNumber Email TimestampSubmitted Status Karalynn Cromeens Karalynn@TheCromeensLawFirm.com 10/23/2023 3:22:00 PM SENT Jonelle Oldacre joldacre@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT Meghan Billeaud paralegal@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT Natalie Smith NSmith@TheCromeensLawFirm.com 10/23/2023 3:22:00 PM SENT Liliana lopez LLopez@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT Terry Canales tclawoffice@rgvattorney.com 10/23/2023 3:22:00 PM SENT Terry Canales tcanales@rgvattorney.com 10/23/2023 3:22:00 PM SENT Billy J.Chapa bjchapa@rgvattorney.com 10/23/2023 3:22:00 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Manuel Garcia manuelg956@yahoo.com 10/23/2023 3:22:00 PM SENT DAVID LFLORES MARYQ@FLORESANDTORRESLLP.COM 10/23/2023 3:22:00 PM ERROR JOHN GRIFFITH JRG@RGVFIRM.COM 10/23/2023 3:22:00 PM SENT 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. E-file Terry Canales, Attorney at Law PLLC on behalf of Terry Canales Bar No. 24052947 efile.tclaw@gmail.com Envelope ID: 80875082 Filing Code Description: Answer Filing Description: DEFENDANTS ORIGINAL ANSWER AND FIRST AMENDED COUNTERPETITION Status as of 10/24/2023 9:38 AM CST Case Contacts MAYRA MALDONADO mmaldonado@thecromeenslawfirm.com 10/23/2023 3:22:00 PM SENT