On August 24, 2012 a
Answer
was filed
involving a dispute between
Vaughan, Daniel & Karen,
and
Vaughn, Aaron,
Vaughn, Lacy,
for Modify - Custody
in the District Court of Smith County.
Preview
Ma1:.01.2013 04:00 PM Heath & Gotten, PLLC 9032530558 PAGE. 2/
CAUSE NO. 12-2355-D
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IN THE INTEREST OF § IN THE DISTRTCWOUJRJ‘ ,. 5
TRISTAN VAUGHAN, § 5;.-
'I‘ANNER VAUGHAN, § 32 1 S'I'
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'I‘ARYAN VAUGHAN, AND §
TRINITY VAUGHAN, §
§
CHILDREN. § SMITH COUNTY, TEXAS
RESPONDENT’S ORIGINAL AN SWER
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Lacy Vaughan, Respondent, files her Original Answer, and respectfully
shows the Court as follows:
|.. Respondent obj cots to the assignment of this matter to an associate judge for a trial on. the
merits or presiding at a jury trial.
2. ReSpondent enters a general denial, as provided by Rules 85 and 92 of the Texas Rules of
Civil Procedure.
3. ln accordance with Rule 2 16 of the Texas Rules of Civil Procedure, Respondent hereby
demands a jury trial,as provided by Section 105.002 of the Texas Family Code.
4. Respondent requests that the Court award her Attorney Ad Litem reasonable fees and
expenses for legal services, in accordance with the provisions of Section 107.015 of the Texas
Family Code.
Prayer
WHEREFORB, PREMISES CONSIDERED, Lacy Vaughan, Respondent, prays that the
Court enter itsorders in accordance with the allegations contained in this Respondent’s Original
Answer; that trial be determined by jury; that her Attorney Ad Litcm. be allowed reasonable fees
and expenses as requested above; and for general relief.
7 m i v 7 I
RESIMNDENT’SORINALASWER PAGE”
Mar.01.2013 04:00 PM Heath & Cotten, PLLC 9032530558 PAGE. 3/
Respectfully submitted,
HEATH & COHEN, P.L.L.C.
100 Independence Place, Suite 207
Tyler, Texas 75703-1 327
Tel. 903.224.5554
Fax. 903.253.0558
By:
Jarrod Heath
Texas Bar No. 24078647
Jmod.I-IClaw@gmail.com
ANORNEY AD LITEM FDR
RESPONDENT LACY VAUGHAN
CERTIFICATE 0F SERVICE
I hereby certify that a true and correct copy of Respondent’s
this Original Answer has
been sewed on all attorneys of record or parties, in accordance with Rule 21a ot‘thc Texas Rules
of Civil Procedure.
Jarrod Heath
Rmomms ORIGINAL ANSWER 7 n fl V
PAGE 2
Document Filed Date
March 04, 2013
Case Filing Date
August 24, 2012
Category
Modify - Custody
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Preview
Ma1:.01.2013 04:00 PM Heath & Gotten, PLLC 9032530558 PAGE. 2/ CAUSE NO. 12-2355-D 7;?!) {flq .L:_.;I_‘, P IN THE INTEREST OF § IN THE DISTRTCWOUJRJ‘ ,. 5 TRISTAN VAUGHAN, § 5;.- 'I‘ANNER VAUGHAN, § 32 1 S'I' J 'I‘ARYAN VAUGHAN, AND § TRINITY VAUGHAN, § § CHILDREN. § SMITH COUNTY, TEXAS RESPONDENT’S ORIGINAL AN SWER TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES Lacy Vaughan, Respondent, files her Original Answer, and respectfully shows the Court as follows: |.. Respondent obj cots to the assignment of this matter to an associate judge for a trial on. the merits or presiding at a jury trial. 2. ReSpondent enters a general denial, as provided by Rules 85 and 92 of the Texas Rules of Civil Procedure. 3. ln accordance with Rule 2 16 of the Texas Rules of Civil Procedure, Respondent hereby demands a jury trial,as provided by Section 105.002 of the Texas Family Code. 4. Respondent requests that the Court award her Attorney Ad Litem reasonable fees and expenses for legal services, in accordance with the provisions of Section 107.015 of the Texas Family Code. Prayer WHEREFORB, PREMISES CONSIDERED, Lacy Vaughan, Respondent, prays that the Court enter itsorders in accordance with the allegations contained in this Respondent’s Original Answer; that trial be determined by jury; that her Attorney Ad Litcm. be allowed reasonable fees and expenses as requested above; and for general relief. 7 m i v 7 I RESIMNDENT’SORINALASWER PAGE” Mar.01.2013 04:00 PM Heath & Cotten, PLLC 9032530558 PAGE. 3/ Respectfully submitted, HEATH & COHEN, P.L.L.C. 100 Independence Place, Suite 207 Tyler, Texas 75703-1 327 Tel. 903.224.5554 Fax. 903.253.0558 By: Jarrod Heath Texas Bar No. 24078647 Jmod.I-IClaw@gmail.com ANORNEY AD LITEM FDR RESPONDENT LACY VAUGHAN CERTIFICATE 0F SERVICE I hereby certify that a true and correct copy of Respondent’s this Original Answer has been sewed on all attorneys of record or parties, in accordance with Rule 21a ot‘thc Texas Rules of Civil Procedure. Jarrod Heath Rmomms ORIGINAL ANSWER 7 n fl V PAGE 2