On April 26, 2023 a
Answer
was filed
involving a dispute between
Red Target Llc Dba Scj Commercial Financial Services,
and
Lobos Rm Trucking Llc,
Rendon, Manuel,
Rendon, Maria,
Rendon, Rocio,
for Contract - Other Contract (OCA)
in the District Court of Hidalgo County.
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Electronically Submitted
5/22/2023 12:00 AM
Hidalgo County Clerk
Accepted by: Sarah Reyes
Cause No. CL-23-1729-I
RED TARGET LLC DBA SCJ COMMERCIAL
FINANCIAL SERVICES § In the Hidalgo County Civil
Court
§
Plaintiff
Vs. § County Court at Law #9
Rocio Rendon, Manuel Rendon, Lobos RM Trucking, § 100 N. Closner Blvd.
Maria Rendon Edinburg, TX 78539
§
Defendant(s)
DEFENDANT’S ORIGINAL ANSWER AND DISCLOSURE REQUEST
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Rocio Rendon, Manuel Rendon, Lobos RM Trucking, Maria Rendon (“Defendants”) and
files the Defendant’s Original Answer, Affirmative Defenses and Disclosure Request in Response to Plaintiff’s
Original Petition.
I. GENERAL DENIAL
1. Subject to and without waiving any of the foregoing Motions or defenses and as authorized by Rule 92 of the
Texas Rules of Civil Procedure and the Texas Civil Practice and Remedies Code, and subject to such matters
as may be stipulated on the trial hereof, Defendant generally denies the allegations of Plaintiff’s Original
Petition and demands strict proof thereof.
II. DEFENSES
2. Defendant denies each and every, all and singular, the allegations and causes of action contained in the
Plaintiff’s Original Petition, and demands strict proof thereof, and thereafter files the following specific
verified denials in support. Specifically, the Defendant asserts that the Plaintiff lacks the requisite legal
capacity and authority to bring its’ claims in this lawsuit based upon insufficient assignment and standing to
asserts its justiciable rights in the account at issue.
3. All the Plaintiff’s Causes of Action may be barred by offset amounts already paid. Defendant may conduct
discovery to determine whether the facts in this case support the defense.
4. All the Plaintiff’s Causes of Action may lack consideration. Defendant may conduct discovery to determine
whether the facts in this case support the defense.
5. All the Plaintiff’s Causes of Action may be barred by the Statute of Limitations. Defendant may conduct
discovery to determine whether the facts in this case support the defense.
6. Defendant reserves the right to amend this Answer to assert other and further defenses.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that the Court deny any and all relief sought
by the Plaintiff and enter a take-nothing judgement against Plaintiff. Defendant prays for general relief.
III. DEFENDANT'S REQUEST FOR DISCLOSURE
7. Disclosure Request. Pursuant to Rule 194 of the Texas Rules of Civil Procedure you are requested to
disclose, within (30) days of this request, the information or material described in Rule 194.2, including all
documents, electronic information, and tangible items that the Plaintiff has in its possession, custody, or
control and may use to support its claims
Electronically Submitted
5/22/2023 12:00 AM
Hidalgo County Clerk
Accepted by: Sarah Reyes
IV. CONCLUSION AND PRAYER
For These Reasons, Defendant prays that Plaintiff take nothing by its suit, and that Defendant be granted
all relief, both at law and in equity, to which he may be justly entitled to receive.
Respectfully Submitted,
Signature of Attorney
Signature
Printed Name: Hooman Khoshnood
Hooman Khoshnood Law, PC
Address: 8701 TX-71, State Hwy 71.
Suite 201Q, Austin TX 78735
Telephone: (512) 866-9811
Fax: 1-512-727-9241
Email: hooman@hklawpc.com
State Bar No.: 24119401
CERTIFICATE OF SERVICE
I, Hooman Khoshnood, certify that a true and correct copy of the Defendant’s Original Answer and Requests
for Disclosure has been sent to the Plaintiff’s counsel of record BARNETT & GARCIA with the mailing
address of 3821 Juniper Trace, Suite 108 Austin, Texas 78738 on this the May 20, 2023 via efile.
/s/ Hooman Khoshnood
Hooman Khoshnood
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.
Hooman Khoshnood on behalf of Hooman Khoshnood
Bar No. 24122796
hooman@hklawpc.com
Envelope ID: 75841279
Filing Code Description: Answer/Response
Filing Description: Defendant's Answer
Status as of 5/22/2023 7:58 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
assuredcivilprocessagency @yahoo.com assuredcivilprocessagency@yahoo.com 5/20/2023 9:11:44 PM SENT
Document Filed Date
May 22, 2023
Case Filing Date
April 26, 2023
Category
Contract - Other Contract (OCA)
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Electronically Submitted 5/22/2023 12:00 AM Hidalgo County Clerk Accepted by: Sarah Reyes Cause No. CL-23-1729-I RED TARGET LLC DBA SCJ COMMERCIAL FINANCIAL SERVICES § In the Hidalgo County Civil Court § Plaintiff Vs. § County Court at Law #9 Rocio Rendon, Manuel Rendon, Lobos RM Trucking, § 100 N. Closner Blvd. Maria Rendon Edinburg, TX 78539 § Defendant(s) DEFENDANT’S ORIGINAL ANSWER AND DISCLOSURE REQUEST TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Rocio Rendon, Manuel Rendon, Lobos RM Trucking, Maria Rendon (“Defendants”) and files the Defendant’s Original Answer, Affirmative Defenses and Disclosure Request in Response to Plaintiff’s Original Petition. I. GENERAL DENIAL 1. Subject to and without waiving any of the foregoing Motions or defenses and as authorized by Rule 92 of the Texas Rules of Civil Procedure and the Texas Civil Practice and Remedies Code, and subject to such matters as may be stipulated on the trial hereof, Defendant generally denies the allegations of Plaintiff’s Original Petition and demands strict proof thereof. II. DEFENSES 2. Defendant denies each and every, all and singular, the allegations and causes of action contained in the Plaintiff’s Original Petition, and demands strict proof thereof, and thereafter files the following specific verified denials in support. Specifically, the Defendant asserts that the Plaintiff lacks the requisite legal capacity and authority to bring its’ claims in this lawsuit based upon insufficient assignment and standing to asserts its justiciable rights in the account at issue. 3. All the Plaintiff’s Causes of Action may be barred by offset amounts already paid. Defendant may conduct discovery to determine whether the facts in this case support the defense. 4. All the Plaintiff’s Causes of Action may lack consideration. Defendant may conduct discovery to determine whether the facts in this case support the defense. 5. All the Plaintiff’s Causes of Action may be barred by the Statute of Limitations. Defendant may conduct discovery to determine whether the facts in this case support the defense. 6. Defendant reserves the right to amend this Answer to assert other and further defenses. WHEREFORE, PREMISES CONSIDERED, Defendant prays that the Court deny any and all relief sought by the Plaintiff and enter a take-nothing judgement against Plaintiff. Defendant prays for general relief. III. DEFENDANT'S REQUEST FOR DISCLOSURE 7. Disclosure Request. Pursuant to Rule 194 of the Texas Rules of Civil Procedure you are requested to disclose, within (30) days of this request, the information or material described in Rule 194.2, including all documents, electronic information, and tangible items that the Plaintiff has in its possession, custody, or control and may use to support its claims Electronically Submitted 5/22/2023 12:00 AM Hidalgo County Clerk Accepted by: Sarah Reyes IV. CONCLUSION AND PRAYER For These Reasons, Defendant prays that Plaintiff take nothing by its suit, and that Defendant be granted all relief, both at law and in equity, to which he may be justly entitled to receive. Respectfully Submitted, Signature of Attorney Signature Printed Name: Hooman Khoshnood Hooman Khoshnood Law, PC Address: 8701 TX-71, State Hwy 71. Suite 201Q, Austin TX 78735 Telephone: (512) 866-9811 Fax: 1-512-727-9241 Email: hooman@hklawpc.com State Bar No.: 24119401 CERTIFICATE OF SERVICE I, Hooman Khoshnood, certify that a true and correct copy of the Defendant’s Original Answer and Requests for Disclosure has been sent to the Plaintiff’s counsel of record BARNETT & GARCIA with the mailing address of 3821 Juniper Trace, Suite 108 Austin, Texas 78738 on this the May 20, 2023 via efile. /s/ Hooman Khoshnood Hooman Khoshnood 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. Hooman Khoshnood on behalf of Hooman Khoshnood Bar No. 24122796 hooman@hklawpc.com Envelope ID: 75841279 Filing Code Description: Answer/Response Filing Description: Defendant's Answer Status as of 5/22/2023 7:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status assuredcivilprocessagency @yahoo.com assuredcivilprocessagency@yahoo.com 5/20/2023 9:11:44 PM SENT