On January 10, 2005 a
Answer
was filed
involving a dispute between
City Of Houston,
Harris County,
Harris County Education Department,
Harris County Education District,
Harris County Flood Control District,
Harris County Hospital District,
Houston Community College System,
Houston Independent School District,
Port Of Houston Authority Of Harris County,
and
Dehumidification Technologies,
Garcia, Elaine,
Garcia, Genaro C,
Garcia, Genaro Jr,
Greater East End Manag Distby Serving Tax Assessor Collector Paul Bett,
Harvest Bend Section I Association,
Moore, John Knox,
Unknown Heirs Of Genaro C Garcia,
for TAX SUIT
in the District Court of Harris County.
Preview
0
wr
wv
No. 2005-01965 :
HARRIS COUNTY, ET AL § IN THE DISTRICT COURT
§ “
VS. § 151* JUDICIAL istgt
ew
ae
QO.
eo &
GENARO C GARCIA, ET AL HARRIS COUNTY, eh we MBE
Wed on
—_ . 4%
eae
aes 2
DEFENDANT'S ORIGINAL ANSWER oOo s+
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes, Genaro C. Garcia and Unknown Heirs of Genaro c. Garcia who have been
named as Defendants in the above-styled cause, and in answer 'S Original Petition filed
therein would respectfully show the Court and jury the following:
I. GENERAL DENIAL
In answer to Plaintiff's Petition, Defendants exercises their statutory right to require Plaintiff
to prove all material allegations contained in the Plaintiff's Original Petition and for such purpose,
they generally deny them all.
Wherefore, having fully answered, Defendants respectfully pray for judgment of the Court
that the Plaintiff take nothing by his suit, for costs, and for such other and further relief to which
they may be justly entitled, either at law or in equity.
espe! lly submitted,
Hedin Mebane,
Texas Bar No. 12844480
9601 Katy Freeway, Suite 375
Houston, Texas 77024
(713)552-1700 Telephone
(713)552-1761 Facsimile
Attorney Ad Litem
RECORDER'S MEMORANDUM
This instrumentis of poor quality
at the time of imaging
te
CERTIFICATE OF SERVIC
This is to certify that a true and correct copy of the above and foregoing instrument has been
served upon all parties and attorneys of record by facsimile or mail on this 26 day of April, 2006.
Pankaj R. Parmar
Linebarger, Goggan, Blair & Sampson
1301 Travis Street, Suite 300
Houston, Texas 77002
(713) 844-3580 Telephone
(713) 844-3502 Facsimile
Roy D. Hailey
Butler & Hailey
1616 Voss Road Ste 500
Houston Texas 77057
Attorney for Harvest Bend Section I Association
John Knox Moore
906 S Mesquite
Brady, Texas 76825 “dau Makog
Patrick D. Mahoney
Mahoney & Associates
Attorneys at Law
e 9601 Katy Freeway, Suite 375
Houston, Texas 77024-1392
(713)552-1700 & FAX(713)552-1761
‘http Awww anahoney-associates.com
Patrick D. Mahoney* / *Board Certified
Xerxes (Zak) K. Patel Commercial Real Estate Law
Beryl Forrest Mazella** ResidentialReal Estate Law
S. Robert Fling Texas Board of Legal Specialization
**Also Licensed in New York we
& oe,
April 26, 2006 2.
Charles Bacarisse Ee
District Clerk
or
eH, & XA
P.O. Box 4651 Os.
Zt
Houston, TX 77210-4651 ODE
Do SB
Te
RE: Ad Litem Cause No. 2005-01965; Harris County, et al » Genaro CG rarcia,
District Court of Harris County, Texas 151% Judicial District; 6644 Avenue %Hotiston
TX 77011, Lot 47 & 48, Block 205, Central Park.
Dear Mr. Bacarisse:
Enclosed for filing in the above referenced cause, please find the original and one copy of
the following document filed by Defendants:
. Original Answer
Please file the Original Answer in your customary manner and return a file stamped copy to our
office via the self-addressed stamped envelope.
If you have any questions please contact our office.
Sincerely,
Mid) Neth,
Michael Nobles
Law Clerk
Document Filed Date
April 28, 2006
Case Filing Date
January 10, 2005
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0 wr wv No. 2005-01965 : HARRIS COUNTY, ET AL § IN THE DISTRICT COURT § “ VS. § 151* JUDICIAL istgt ew ae QO. eo & GENARO C GARCIA, ET AL HARRIS COUNTY, eh we MBE Wed on —_ . 4% eae aes 2 DEFENDANT'S ORIGINAL ANSWER oOo s+ TO THE HONORABLE JUDGE OF SAID COURT: Now comes, Genaro C. Garcia and Unknown Heirs of Genaro c. Garcia who have been named as Defendants in the above-styled cause, and in answer 'S Original Petition filed therein would respectfully show the Court and jury the following: I. GENERAL DENIAL In answer to Plaintiff's Petition, Defendants exercises their statutory right to require Plaintiff to prove all material allegations contained in the Plaintiff's Original Petition and for such purpose, they generally deny them all. Wherefore, having fully answered, Defendants respectfully pray for judgment of the Court that the Plaintiff take nothing by his suit, for costs, and for such other and further relief to which they may be justly entitled, either at law or in equity. espe! lly submitted, Hedin Mebane, Texas Bar No. 12844480 9601 Katy Freeway, Suite 375 Houston, Texas 77024 (713)552-1700 Telephone (713)552-1761 Facsimile Attorney Ad Litem RECORDER'S MEMORANDUM This instrumentis of poor quality at the time of imaging te CERTIFICATE OF SERVIC This is to certify that a true and correct copy of the above and foregoing instrument has been served upon all parties and attorneys of record by facsimile or mail on this 26 day of April, 2006. Pankaj R. Parmar Linebarger, Goggan, Blair & Sampson 1301 Travis Street, Suite 300 Houston, Texas 77002 (713) 844-3580 Telephone (713) 844-3502 Facsimile Roy D. Hailey Butler & Hailey 1616 Voss Road Ste 500 Houston Texas 77057 Attorney for Harvest Bend Section I Association John Knox Moore 906 S Mesquite Brady, Texas 76825 “dau Makog Patrick D. Mahoney Mahoney & Associates Attorneys at Law e 9601 Katy Freeway, Suite 375 Houston, Texas 77024-1392 (713)552-1700 & FAX(713)552-1761 ‘http Awww anahoney-associates.com Patrick D. Mahoney* / *Board Certified Xerxes (Zak) K. Patel Commercial Real Estate Law Beryl Forrest Mazella** ResidentialReal Estate Law S. Robert Fling Texas Board of Legal Specialization **Also Licensed in New York we & oe, April 26, 2006 2. Charles Bacarisse Ee District Clerk or eH, & XA P.O. Box 4651 Os. Zt Houston, TX 77210-4651 ODE Do SB Te RE: Ad Litem Cause No. 2005-01965; Harris County, et al » Genaro CG rarcia, District Court of Harris County, Texas 151% Judicial District; 6644 Avenue %Hotiston TX 77011, Lot 47 & 48, Block 205, Central Park. Dear Mr. Bacarisse: Enclosed for filing in the above referenced cause, please find the original and one copy of the following document filed by Defendants: . Original Answer Please file the Original Answer in your customary manner and return a file stamped copy to our office via the self-addressed stamped envelope. If you have any questions please contact our office. Sincerely, Mid) Neth, Michael Nobles Law Clerk