Preview
Electronically Filed
6/21/2024 2:30 PM
Hidalgo County District Clerks
Reviewed By: Clarissa Alvarez
CAUSE NO. C-2370-24-H
ELIAZAR FLORES, INDIVIDUALLY AND § IN THE DISTRICT COURT
KARLA ARELLANO, INDIVIDUALLY AND §
A/N/F OF RUBY ARELLANO, A MINOR §
§
v. § 389TH JUDICIAL DISTRICT
§
ELMER ALEXANDER ALVAREZ §
HERNANDEZ AND VILMA SANCHEZ § HIDALGO COUNTY, TEXAS
DEFENDANTS’ ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, defendants, Elmer Alexander Alvarez Hernandez and Vilma Sanchez,
herein, and reserving their right t0 file other and further notices, pleadings, exceptions, denials,
defenses, amendments, and cross—actions and/or counterclaims, file this their Original Answer to
Plaintiffs’ First Original Petition, in the above-styled and numbered cause, and would respectfully
show unto this Honorable Court as follows:
I.
GENERAL DENIAL
Defendants, Elmer Alexander Alvarez Hernandez and Vilma Sanchez, deny each and every,
all and singular, the allegations in Plaintiffs’ First Original Petition, and demand strict proof by a
preponderance of the good and credible evidence.
II.
AFFIRMATIVE DEFENSE
The amounts charged for the medical services claimed by Plaintiffs were in excess of the
usual and customary charges for those services at the time and place that the services were provided.
WHEREFORE, PREMISES CONSIDERED, defendants, Elmer Alexander Alvarez
Hernandez and Vilma Sanchez, request judgment of the Court that plaintiffs, Eliazar Flores,
F: \2024 \253 \PIeadings\Defendams Original Answer. wpd
’
Electronically Filed
6/21/2024 2:30 PM
Hidalgo County District Clerks
Reviewed By: Clarissa Alvarez
Individually and Karla Arellano, Individually and A/N/F of Ruby Arellano, a minor, recover naught
by their suit, and that defendants, Elmer Alexander Alvarez Hernandez and Vilma Sanchez, recover
their costs and be granted such other relief, general and specific, legal and equitable, t0 which they
may show themselves justly entitled to receive.
Respectfully submitted,
GUERRA & SABO, PLLC
10213 N. 10‘“ Street
McAllen, Texas 78504
Telephone: (956) 383-4300
Facsimile: (956) 383-4304
Frank Sabo, Jf.
State Bar No. 17500300
fsabo uerrasabo.com
ATTORNEY FOR DEFENDANTS
CERTIFICATE OF SERVICE
This is to certify that on the 21st day of June, 2024, the above and foregoing has been
served on the following counsel of record in accordance with the Texas Rules of Civil Procedure:
Via E—Fz'le
Herbert A. Janzen
Law Offices of Herbert A. Janzen
903 Welch Street
Houston, Texas 77006
Frank Sabo, Jr.
F: \2024\253 \Pleadings\Defendants’ Original Anmrer. wpd 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.
Cindy Trevino on behalf of Frank Sabo, Jr.
Bar No. 17500300
ctrevino@guerrasabo.com
Envelope ID: 89066955
Filing Code Description: Answer
Filing Description: Defendants' Original Answer
Status as of 6/21/2024 4:24 PM CST
Associated Case Party: Ruby Arellano
Name BarNumber Email TimestampSubmitted Status
Herbert A.Janzen herbjanzen.office@yahoo.com 6/21/2024 2:30:06 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
HERBERT AJANZEN HERBJANZEN.OFFICE@YAHOO.COM 6/21/2024 2:30:06 PM SENT
Associated Case Party: Elmer Hernandez
Name BarNumber Email TimestampSubmitted Status
Frank Sabo, Jr. fsabo@guerrasabo.com 6/21/2024 2:30:06 PM SENT
Preview
Electronically Filed 6/21/2024 2:30 PM Hidalgo County District Clerks Reviewed By: Clarissa Alvarez CAUSE NO. C-2370-24-H ELIAZAR FLORES, INDIVIDUALLY AND § IN THE DISTRICT COURT KARLA ARELLANO, INDIVIDUALLY AND § A/N/F OF RUBY ARELLANO, A MINOR § § v. § 389TH JUDICIAL DISTRICT § ELMER ALEXANDER ALVAREZ § HERNANDEZ AND VILMA SANCHEZ § HIDALGO COUNTY, TEXAS DEFENDANTS’ ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, defendants, Elmer Alexander Alvarez Hernandez and Vilma Sanchez, herein, and reserving their right t0 file other and further notices, pleadings, exceptions, denials, defenses, amendments, and cross—actions and/or counterclaims, file this their Original Answer to Plaintiffs’ First Original Petition, in the above-styled and numbered cause, and would respectfully show unto this Honorable Court as follows: I. GENERAL DENIAL Defendants, Elmer Alexander Alvarez Hernandez and Vilma Sanchez, deny each and every, all and singular, the allegations in Plaintiffs’ First Original Petition, and demand strict proof by a preponderance of the good and credible evidence. II. AFFIRMATIVE DEFENSE The amounts charged for the medical services claimed by Plaintiffs were in excess of the usual and customary charges for those services at the time and place that the services were provided. WHEREFORE, PREMISES CONSIDERED, defendants, Elmer Alexander Alvarez Hernandez and Vilma Sanchez, request judgment of the Court that plaintiffs, Eliazar Flores, F: \2024 \253 \PIeadings\Defendams Original Answer. wpd ’ Electronically Filed 6/21/2024 2:30 PM Hidalgo County District Clerks Reviewed By: Clarissa Alvarez Individually and Karla Arellano, Individually and A/N/F of Ruby Arellano, a minor, recover naught by their suit, and that defendants, Elmer Alexander Alvarez Hernandez and Vilma Sanchez, recover their costs and be granted such other relief, general and specific, legal and equitable, t0 which they may show themselves justly entitled to receive. Respectfully submitted, GUERRA & SABO, PLLC 10213 N. 10‘“ Street McAllen, Texas 78504 Telephone: (956) 383-4300 Facsimile: (956) 383-4304 Frank Sabo, Jf. State Bar No. 17500300 fsabo uerrasabo.com ATTORNEY FOR DEFENDANTS CERTIFICATE OF SERVICE This is to certify that on the 21st day of June, 2024, the above and foregoing has been served on the following counsel of record in accordance with the Texas Rules of Civil Procedure: Via E—Fz'le Herbert A. Janzen Law Offices of Herbert A. Janzen 903 Welch Street Houston, Texas 77006 Frank Sabo, Jr. F: \2024\253 \Pleadings\Defendants’ Original Anmrer. wpd 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. Cindy Trevino on behalf of Frank Sabo, Jr. Bar No. 17500300 ctrevino@guerrasabo.com Envelope ID: 89066955 Filing Code Description: Answer Filing Description: Defendants' Original Answer Status as of 6/21/2024 4:24 PM CST Associated Case Party: Ruby Arellano Name BarNumber Email TimestampSubmitted Status Herbert A.Janzen herbjanzen.office@yahoo.com 6/21/2024 2:30:06 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status HERBERT AJANZEN HERBJANZEN.OFFICE@YAHOO.COM 6/21/2024 2:30:06 PM SENT Associated Case Party: Elmer Hernandez Name BarNumber Email TimestampSubmitted Status Frank Sabo, Jr. fsabo@guerrasabo.com 6/21/2024 2:30:06 PM SENT