On March 13, 2014 a
ORIG ANSWER/SPECIAL APPEARANCE
was filed
involving a dispute between
A I Divestitures Inc,
and
Richard Hyde Executive Director Of The Tceq,
Texas Commission On Environmental Quality,
for ADMINISTRATIVE APPEAL (GEN LIT )
in the District Court of Travis County.
Preview
4/4/2014 12:15:57 PM
Amalia Rodriguez-Mendoza
District Clerk
Travis County
Cause No. D-1-GN-14-000770 D-1-GN-14-000770
A. I. DIVESTITURES, INC., IN THE DISTRICT COURT
Plaintiff,
ve
TEXAS COMMISSION ON TRAVIS COUNTY, TEXAS
ENVIRONMENTAL QUALITY and
RICHARD HYDE, in his official
capacity as executive director of the
Texas Commission on Environmental
Quality
MONON MMMMMM
250TH JUDICIAL DISTRICT
Defendants.
ORIGINAL ANSWER OF DEFENDANTS
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY AND RICHARD HYDE,
IN HIS OFFICIAL CAPACITY AS EXECUTIVE DIRECTOR OF THE
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Defendants, Texas Commission on Environmental Quality and Richard Hyde, in his
official capacity as Executive Director of the Texas Commission on Environmental Quality,
through the Office of the Attorney General of Texas, submit this answer to Plaintiffs
Original Petition.
Defendants deny each and every allegation in Plaintiff's Original Petition and
demand strict proof thereof. Defendants reserve the right to amend this answer as
permitted under the Texas Rules of Civil Procedure.
WHEREFORE, having fully answered, Defendants pray that Plaintiff take nothing
by this suit, and that Defendants recover their costs. Defendants further pray for such
other relief to which they may be entitled.Respectfully submitted,
GREG ABBOTT
Attorney General of Texas
DANIEL T. HODGE
First Assistant Attorney General
JOHN B. SCOTT
Deputy Attorney General for Civil Litigation
JON NIERMANN
Chief, Environmental Protection Division
/s/ Kellie E. Billings-Ray
KELLIE E. BILLINGS-RAY
Assistant Attorney General
State Bar No. 24042447
LINDA B. SECORD
Assistant Attorney General
State Bar No. 17973400
Environmental Protection Division
P. O. Box 12548, MC-066
Austin, Texas 78711-2548
Tel: (512) 463-2012
Fax: (512) 457-4638
ATTORNEYS FOR DEFENDANTS
Original Answer of Defendant
D-1-GN-14-000770 Page 2 of 3CERTIFICATE OF SERVICE
I hereby certify that on April 4, 2014, a true and correct copy of the foregoing
Original Answer of Defendants Texas Commission on Environmental Quality and Richard Hyde
in his Official Capacity as Executive Director of the Texas Commission on Environmental Quality
was served on the following counsel electronically through an electronic filing manager or
by email:
Janessa C. Glenn
MOLTZ MorTON & GLENN, LLP
Travis Oaks Building
5113 Southwest Parkway, Suite 120
Austin, Texas 78735
Tel: (512) 439-2174
Fax: (512) 439-2165
jglenn@mmandg.com
Attorney for Plaintiff,
AL. Divestitures, Inc.
/s/ Kellie E. Billings-Ray
KELLIE E. BILLINGS-RAY
Original Answer of Defendant
D-1-GN-14-000770 Page 3 of 3
Document Filed Date
April 04, 2014
Case Filing Date
March 13, 2014
Category
ADMINISTRATIVE APPEAL (GEN LIT )
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4/4/2014 12:15:57 PM Amalia Rodriguez-Mendoza District Clerk Travis County Cause No. D-1-GN-14-000770 D-1-GN-14-000770 A. I. DIVESTITURES, INC., IN THE DISTRICT COURT Plaintiff, ve TEXAS COMMISSION ON TRAVIS COUNTY, TEXAS ENVIRONMENTAL QUALITY and RICHARD HYDE, in his official capacity as executive director of the Texas Commission on Environmental Quality MONON MMMMMM 250TH JUDICIAL DISTRICT Defendants. ORIGINAL ANSWER OF DEFENDANTS TEXAS COMMISSION ON ENVIRONMENTAL QUALITY AND RICHARD HYDE, IN HIS OFFICIAL CAPACITY AS EXECUTIVE DIRECTOR OF THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Defendants, Texas Commission on Environmental Quality and Richard Hyde, in his official capacity as Executive Director of the Texas Commission on Environmental Quality, through the Office of the Attorney General of Texas, submit this answer to Plaintiffs Original Petition. Defendants deny each and every allegation in Plaintiff's Original Petition and demand strict proof thereof. Defendants reserve the right to amend this answer as permitted under the Texas Rules of Civil Procedure. WHEREFORE, having fully answered, Defendants pray that Plaintiff take nothing by this suit, and that Defendants recover their costs. Defendants further pray for such other relief to which they may be entitled.Respectfully submitted, GREG ABBOTT Attorney General of Texas DANIEL T. HODGE First Assistant Attorney General JOHN B. SCOTT Deputy Attorney General for Civil Litigation JON NIERMANN Chief, Environmental Protection Division /s/ Kellie E. Billings-Ray KELLIE E. BILLINGS-RAY Assistant Attorney General State Bar No. 24042447 LINDA B. SECORD Assistant Attorney General State Bar No. 17973400 Environmental Protection Division P. O. Box 12548, MC-066 Austin, Texas 78711-2548 Tel: (512) 463-2012 Fax: (512) 457-4638 ATTORNEYS FOR DEFENDANTS Original Answer of Defendant D-1-GN-14-000770 Page 2 of 3CERTIFICATE OF SERVICE I hereby certify that on April 4, 2014, a true and correct copy of the foregoing Original Answer of Defendants Texas Commission on Environmental Quality and Richard Hyde in his Official Capacity as Executive Director of the Texas Commission on Environmental Quality was served on the following counsel electronically through an electronic filing manager or by email: Janessa C. Glenn MOLTZ MorTON & GLENN, LLP Travis Oaks Building 5113 Southwest Parkway, Suite 120 Austin, Texas 78735 Tel: (512) 439-2174 Fax: (512) 439-2165 jglenn@mmandg.com Attorney for Plaintiff, AL. Divestitures, Inc. /s/ Kellie E. Billings-Ray KELLIE E. BILLINGS-RAY Original Answer of Defendant D-1-GN-14-000770 Page 3 of 3