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.
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10:56 FR FIRST AMERICAN TITLE13 661 8212 TO 7137555754 P. 03
MAY 29 2007
~ i
ASSESSE;
CAUSE NO. 2007-13921
ENTERED
VERIFIED
G %\é
2
HARRIS COUNTY, ET AL IN THE D)
SS
40;
i og ,
VS 1® JUDICIAL COURT OBE
“SAS
LE @ th
RALPH DOMINO, ET. AL HARRIS COUNTY, TEXAS CPSs Se,oS
LOS,
%
@
DEFENDANT’S ORIGINAL ANSWER
In accordance with Texas Rules of Civil Procedure Defendant, MICHAEL ANTHONY
ROCHON (In Rem Only) denies each and every, alland 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 Plaintiff's 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 attorney’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 equity, to which he may
show himself entitled.
_.
MAY 29 2007 10:56 FR FIRST AMERICAN TITLEI3 661 8212 TO 7137555754 P. 04
~
(Shh
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ay Mh
YY,
Res
Za Le
W#TSON
YY 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, Idelivered a copy of the above DEFENDANT’S
ORIGINAL ANSWER to ANGELICA M. ANDEZ, OF, INEBARGER GOGGAN
BLAIR & SAMPSON, LLP, Attorney or Sih tifE A SH (713)844-3502.
a £4) t2
CA ro WAT: tox
** TOTAL PAGE. 04 *#
Document Filed Date
May 29, 2007
Case Filing Date
March 09, 2007
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10:56 FR FIRST AMERICAN TITLE13 661 8212 TO 7137555754 P. 03 MAY 29 2007 ~ i ASSESSE; CAUSE NO. 2007-13921 ENTERED VERIFIED G %\é 2 HARRIS COUNTY, ET AL IN THE D) SS 40; i og , VS 1® JUDICIAL COURT OBE “SAS LE @ th RALPH DOMINO, ET. AL HARRIS COUNTY, TEXAS CPSs Se,oS LOS, % @ DEFENDANT’S ORIGINAL ANSWER In accordance with Texas Rules of Civil Procedure Defendant, MICHAEL ANTHONY ROCHON (In Rem Only) denies each and every, alland 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 Plaintiff's 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 attorney’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 equity, to which he may show himself entitled. _. MAY 29 2007 10:56 FR FIRST AMERICAN TITLEI3 661 8212 TO 7137555754 P. 04 ~ (Shh YL] ay Mh YY, Res Za Le W#TSON YY 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, Idelivered a copy of the above DEFENDANT’S ORIGINAL ANSWER to ANGELICA M. ANDEZ, OF, INEBARGER GOGGAN BLAIR & SAMPSON, LLP, Attorney or Sih tifE A SH (713)844-3502. a £4) t2 CA ro WAT: tox ** TOTAL PAGE. 04 *#