On December 15, 2016 a
Answer
was filed
involving a dispute between
Ec Tyler Housing Partners, Ltd.,
and
Graham, Terry,
Graham, Trey,
Terry Graham Interests, Ltd,
Winn, Todd Charles,
for Real Property - Other
in the District Court of Smith County.
Preview
Electronically Filed
2/14/2018 11:25 AM
Lois Rogers, Smith County District Clerk
Reviewed By: Steven Cowan
NO. 16-2512-B
EC TYLER HOUSING PARTNERS, LTD. § IN THE DISTRICT COURT
§
Plaintiff, §
§
V. § 114TH JUDICIAL DISTRICT
§
TERRY GRAHAM, TREY GRAHAM, AND §
TERRY GRAHAM INTERESTS, LTD §
§
Defendant §
§
AND §
§
TERRY GRAHAM INTERESTS, LTD §
Third-Party Plaintiff §
§
V. §
§
TODD WINN, Individually and d/b/a §
TODD WINN CONSTRUCTION §
Third-Party Defendant § SMITH COUNTY, TEXAS
THIRD-PARTY DEFENDANT'S ORIGINAL ANSWER
NOW COMES Todd Winn, Individually and d/b/a Todd Winn Construction, named
Third-Party Defendant in the above-entitled and numbered cause, and files this Original
Answer, and shows the Court:
GENERAL DENIAL
Third-Party Defendant denies each and every allegation of Defendant Terry Graham
Interests, LTD.'s Third-Party Petition, and demands strict proof thereof as required by the
Texas Rules of Civil Procedure.
PRAYER
Third-Party Defendant prays the Court, after notice and hearing or trial, enters
judgment in favor of Third-Party Defendant, awards Third-Party Defendant the costs of
court, attorney's fees, and such other and further relief as Third-Party Defendant may be
entitled to in law or in equity.
Third-Party Defendant's Original Answer
Page 1
Respectfully submitted:
GRIFFITH LAW FIRM, P.C.
404 Titus Street
P.O. Box 864
Gilmer, Texas 75644-0864
Tel: (903) 843-5005
Fax: (903) 843-5392
Email: davidg@griffithlawfirm.com
B y ~
.....avid.Griffith -
State Bar No. 08479300
Attorney for Third-Party Defendant
CERTIFICATE OF SERVICE
I certify that on February 14, 2018, a true and correct copy of the foregoing Third-
Party Defendant's Original Answer has been served on all parties and/or counsel of record,
pursuant to the Texas Rules of Civil Procedure, as follows, to wit:
Attorneys for Defendants/Third-Party Plaintiff
Steven W. Comte
Keith W. Starr
Electronically through the efileTexas.gov
Electronic Filing Manager
Attorneys for Plaintiff
P. William Stark
Amanda R. McKinzie
Jimmy M. Negem
Joe M. Worthington
Electronically through the efileTexas.gov
Electronic Filing Manager
Third-Party Defendant's Original Answer
Page 2
Document Filed Date
February 14, 2018
Case Filing Date
December 15, 2016
Category
Real Property - Other
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Preview
Electronically Filed 2/14/2018 11:25 AM Lois Rogers, Smith County District Clerk Reviewed By: Steven Cowan NO. 16-2512-B EC TYLER HOUSING PARTNERS, LTD. § IN THE DISTRICT COURT § Plaintiff, § § V. § 114TH JUDICIAL DISTRICT § TERRY GRAHAM, TREY GRAHAM, AND § TERRY GRAHAM INTERESTS, LTD § § Defendant § § AND § § TERRY GRAHAM INTERESTS, LTD § Third-Party Plaintiff § § V. § § TODD WINN, Individually and d/b/a § TODD WINN CONSTRUCTION § Third-Party Defendant § SMITH COUNTY, TEXAS THIRD-PARTY DEFENDANT'S ORIGINAL ANSWER NOW COMES Todd Winn, Individually and d/b/a Todd Winn Construction, named Third-Party Defendant in the above-entitled and numbered cause, and files this Original Answer, and shows the Court: GENERAL DENIAL Third-Party Defendant denies each and every allegation of Defendant Terry Graham Interests, LTD.'s Third-Party Petition, and demands strict proof thereof as required by the Texas Rules of Civil Procedure. PRAYER Third-Party Defendant prays the Court, after notice and hearing or trial, enters judgment in favor of Third-Party Defendant, awards Third-Party Defendant the costs of court, attorney's fees, and such other and further relief as Third-Party Defendant may be entitled to in law or in equity. Third-Party Defendant's Original Answer Page 1 Respectfully submitted: GRIFFITH LAW FIRM, P.C. 404 Titus Street P.O. Box 864 Gilmer, Texas 75644-0864 Tel: (903) 843-5005 Fax: (903) 843-5392 Email: davidg@griffithlawfirm.com B y ~ .....avid.Griffith - State Bar No. 08479300 Attorney for Third-Party Defendant CERTIFICATE OF SERVICE I certify that on February 14, 2018, a true and correct copy of the foregoing Third- Party Defendant's Original Answer has been served on all parties and/or counsel of record, pursuant to the Texas Rules of Civil Procedure, as follows, to wit: Attorneys for Defendants/Third-Party Plaintiff Steven W. Comte Keith W. Starr Electronically through the efileTexas.gov Electronic Filing Manager Attorneys for Plaintiff P. William Stark Amanda R. McKinzie Jimmy M. Negem Joe M. Worthington Electronically through the efileTexas.gov Electronic Filing Manager Third-Party Defendant's Original Answer Page 2