On March 09, 2007 a
Answer
was filed
involving a dispute between
City Of Houston,
City Of Houston Liens,
Harris County,
Harris County Department Of Education District,
Harris County Flood Control District,
Harris County Hospital District,
Houston Community College System,
Houston Independent School District,
Port Of Houston Authority,
and
Domino, Ralph,
Domino, Shirley,
Rochon, Michael Anthony,
State Of Texas Child Support Division,
for TAX SUIT
in the District Court of Harris County.
Preview
me,
CAUSE NO. 2007-13921
HARRIS COUNTY, ET AL IN THE DISTRICT COURT
VS 11" JUDICIAL COURT
RALPH DOMINO, ET. AL HARRIS COUNTY, TEXAS
DEFENDANT’S ORIGINAL ANSWER
In accordance with Texas Rules of Civil Procedure Defendant, MICHAEL ANTHONY
ROCHON (In Rem Only) denies each and every, all and singular, the material allegations in
PLAINTIFF’S ORIGINAL PETITION, and demands that Plaintiff prove all charges and
allegations against MICHAEL ANTHONY ROCHON (In Rem Only), by a preponderance
of the evidence as required by the Constitution and laws of the State of Texas.
Defendant, MICHAEL ANTHONY ROCHON (In Rem Only), denies each and every item
in Plaintiffs Original Petition, which is the basis of Plaintiff's action, and demand strict
proof thereof.
AMENDMENT
Defendant reserves the right to amend this answer in accordance with the Texas Rules of
Civil Procedure.
ATTORNEY’S FEES AND EXPENSES
It was necessary for Petitioner to secure the services of CAROL L. WATSON, a licensed
attorney, to prepare and prosecute this suit. Defendant requests that reasonable attomey’s fees and
expenses be taxed as costs and be ordered paid directly to Defendant’s attomey, who may enforce
the order for fees in the attorney’s own name.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendant MICHAEL ANTHONY
ROCHON (In Rem Only), having Answered, prays that the Court enter judgment that Plaintiff take
nothing by this suit, and that Defendant go hence with out delay, with his costs, attorney’s fees and
with such other and further relief, both general and special, at law and in eqilty,LorIb Bi LER,
Dsttict
show himself entitled.
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? 'Y FOR DEFENDANT
+ 20934600
2656 SOUTH LOOP WEST, SUITE 140
HOUSTON, TEXAS 77054
Tele: 713-661-3231
Fax: 713-661-8212
CERTIFICATE OF SERVICE
On the 29th day of May, 2007, I delivered a copy of the above DEFENDANT’S
ORIGINAL ANSWER to ANGELICA M RNANDEZ, OF, hINEBARGER GOGGAN
BLAIR & SAMPSON, LLP, Attorney op bai Simp (713)844-3502.
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WAT: ion
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2656 South Loop West, #140
Houston, Texas 77054 fa N a WNos =n 7 eye) me
Tele: (713) 661-3231 PAs
Cl Coe a ela
Fax (713) 661-8212
Fax
Tor \ rom Carol Watson
Fax: 115) B44 -3S G2 Pages:
Phone: Date: S- 24-07
Re ZOO? 1SQ2| ce:
O urgent O ForReview (0 Please Comment O Please Reply CO Please Recycle
® Comments:
________ Original: Anower
The information contained in this facsimile message is legally privileged and confidential
information intended only for the use of the individual or entity named below. If the reader of
this message is not the intended recipient, you are hereby notified that any dissemination,
distribution, or copy of this telecopy is strictly prohibited. if you have received this telecopy in
error, please immediately notify us at (713) 661-3231 and return the original message to us at
2656 S. Loop W., Suite 140, Houston, Texas 77054 via the United States Postal Service.
If there is a problem with this transmission, please call sender at (713) 661-3231
ZOGEPPSELL OL ZIZB 199 ELAWIL NVOIUSNV LSUIA Yd 8V:0T LO0Z 62 AVW
TO ‘d
Preview
me, CAUSE NO. 2007-13921 HARRIS COUNTY, ET AL IN THE DISTRICT COURT VS 11" JUDICIAL COURT RALPH DOMINO, ET. AL HARRIS COUNTY, TEXAS DEFENDANT’S ORIGINAL ANSWER In accordance with Texas Rules of Civil Procedure Defendant, MICHAEL ANTHONY ROCHON (In Rem Only) denies each and every, all and singular, the material allegations in PLAINTIFF’S ORIGINAL PETITION, and demands that Plaintiff prove all charges and allegations against MICHAEL ANTHONY ROCHON (In Rem Only), by a preponderance of the evidence as required by the Constitution and laws of the State of Texas. Defendant, MICHAEL ANTHONY ROCHON (In Rem Only), denies each and every item in Plaintiffs Original Petition, which is the basis of Plaintiff's action, and demand strict proof thereof. AMENDMENT Defendant reserves the right to amend this answer in accordance with the Texas Rules of Civil Procedure. ATTORNEY’S FEES AND EXPENSES It was necessary for Petitioner to secure the services of CAROL L. WATSON, a licensed attorney, to prepare and prosecute this suit. Defendant requests that reasonable attomey’s fees and expenses be taxed as costs and be ordered paid directly to Defendant’s attomey, who may enforce the order for fees in the attorney’s own name. PRAYER WHEREFORE, PREMISES CONSIDERED, Defendant MICHAEL ANTHONY ROCHON (In Rem Only), having Answered, prays that the Court enter judgment that Plaintiff take nothing by this suit, and that Defendant go hence with out delay, with his costs, attorney’s fees and with such other and further relief, both general and special, at law and in eqilty,LorIb Bi LER, Dsttict show himself entitled. aze gcd 4- (4, 04 __ i igns county *¥: Time: et By. Depaty 20 ‘d ZOSEPVSETL OL ZIZB 199 erathit NVOIYSNV LSHId Yd 8vV:0T L00% 62 AVN oe Respegy IL ug ted 2 7], — S$ SO) ? 'Y FOR DEFENDANT + 20934600 2656 SOUTH LOOP WEST, SUITE 140 HOUSTON, TEXAS 77054 Tele: 713-661-3231 Fax: 713-661-8212 CERTIFICATE OF SERVICE On the 29th day of May, 2007, I delivered a copy of the above DEFENDANT’S ORIGINAL ANSWER to ANGELICA M RNANDEZ, OF, hINEBARGER GOGGAN BLAIR & SAMPSON, LLP, Attorney op bai Simp (713)844-3502. (Ww 22 SU, LA 2 WAT: ion €0 “d TOSEVVSETL OL cree 199 ElAILIL NVOIMANV LSHIA YA 8V:OT 400% 6% AVN _ ~ 2656 South Loop West, #140 Houston, Texas 77054 fa N a WNos =n 7 eye) me Tele: (713) 661-3231 PAs Cl Coe a ela Fax (713) 661-8212 Fax Tor \ rom Carol Watson Fax: 115) B44 -3S G2 Pages: Phone: Date: S- 24-07 Re ZOO? 1SQ2| ce: O urgent O ForReview (0 Please Comment O Please Reply CO Please Recycle ® Comments: ________ Original: Anower The information contained in this facsimile message is legally privileged and confidential information intended only for the use of the individual or entity named below. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this telecopy is strictly prohibited. if you have received this telecopy in error, please immediately notify us at (713) 661-3231 and return the original message to us at 2656 S. Loop W., Suite 140, Houston, Texas 77054 via the United States Postal Service. If there is a problem with this transmission, please call sender at (713) 661-3231 ZOGEPPSELL OL ZIZB 199 ELAWIL NVOIUSNV LSUIA Yd 8V:0T LO0Z 62 AVW TO ‘d