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.
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NX Cause No. 2005-01965
HARRIS COUNTY IN THE DISTRICT COURT
ETAL,
Plaintiffs,
VS. OF HARRIS COUNTY, TEXAS
+ se
GENARO C. GARCIA,
E
ETAL.
Defendants. 151* JUDICIAL DISTRICT= =
« >
yeu = a
|
ORIGINAL ANSWER OF DEFENDANT HARVEST BEND, SECTION Lgssoctr
S55 oO
TO THE HONORABLE JUDGE OF SAID COURT. OTe
Theo
Eee
COMES NOW, Harvest Bend, Section I Association (Association), one ofthe etary
Sal
above entitled and numbered cause, and files this its Original Answer to Plaintiff's tigiit
Petition.
General Denial
The Association denies each and every allegation set forth in Plaintiff's Original Petition.
Prayer
For these reasons, the Association asks the court to render a take-nothing judgment against
plaintiffs, assess costs against plaintiffs, and award the Association all other relief to which it is
entitled,
Respectfully submitted,
BUTLER& Y, P.C,
avis
TBN: 00792447
Roy D. Hailey
TBN: 08706400
1616 South Voss, Suite 500
Houston, Texas 77057-2631
(713) 780-4135
(713) 780-4549 Telecopier
Attorneys for Defendant
106798/2358/80002
Thig RRDER'S HEWORANDUy
the time of °Fint Boor quai
at
og
or
~ en
CERTIFICATE OF COMPLIANCE
This is to certify that a true and correct photocopy of Original Answer of Defendant
Harvest Bend, Section I Association and Disclaimer of Defendant Harvest Bend, Section I
Association has been served upon all attorney(s) of record and/or pro se parties by depositing
Sha
same with the United States Postal Service by first class mail, co: rectly addressed and postage
prepaid, or in the manner indicated, on this the 0 day of 2005, to such
attorney(s) and/or parties;
Pankaj R. Parmar (CMRRR 7002 2410 0004 9245 1605)
1301 Travis, Suite 300
Houston, Texas 77002
and the original was filed with the District Clerk of Harris County, Texas, pursuant to Rules 21
and 21a of the Texas Rules of Civil Procedure.
Cc
~™ on
Cause No. 2005-01965
HARRIS COUNTY IN THE DISTRICT COURT
ETAL,
Plaintiffs,
VS. OF HARRIS COUNTY, TEXAS
GENARO C. GARCIA,
ETAL.
Defendants. § 151* JUDICIAL DISTRICT ‘ F
ORIGINAL ANSWER OF DEFENDANT HARVEST BEND, SECTION rasshcRnols5
we OS
Zar -
TO THE HONORABLE JUDGE OF SAID COURT:
“47 =
ago, &
COMES NOW, Harvest Bend, Section I Association (Association), one of eget
YES o
nk
above entitled and numbered cause, and files this its Original Answer to vi Zein
< S=
Petition. a
General Denial
The Association denies each and every allegation set forth in Plaintiff's Original Petition.
Prayer
For these reasons, the Association asks the court to render a take-nothing judgment against
plaintiffs, assess costs against plaintiffs, and award the Association all other relief to which it is
entitled.
Respectfully submitted,
BUTLER& Y, P.C.
avis
TBN: 00792447
Roy D. Hailey
TBN: 08706400
1616 South Voss, Suite 500
Houston, Texas 77057-2631
(713) 780-4135
106798/2358/80002
(713) 780-4549 Telecopier
Attorneys for Defendant Co Py
- ~ on
CERTIFICATE OF COMPLIANCE
This is to certify that a true and correct photocopy of Original Answer of Defendant
Harvest Bend, Section I Association and Disclaimer of Defendant Harvest Bend, Section I
Association has been served upon all attorney(s) of record and/or pro se parties by depositing
hu
same with the United States Postal Service by first clclas: s mail, correctly addressed and postage
prepaid, or in the manner indicated, on this the \o day of 2005, to such
attomey(s) and/or parties;
Pankaj R. Parmar (CMRRR 7002 2410 0004 9245 1605)
1301 Travis, Suite 300
Houston, Texas 77002
and the original was filed with the District Clerk of Harris County, Texas, pursuant to Rules 21
and 21a of the Texas Rules of Civil Procedure.
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Sf ~ nm w NX Cause No. 2005-01965 HARRIS COUNTY IN THE DISTRICT COURT ETAL, Plaintiffs, VS. OF HARRIS COUNTY, TEXAS + se GENARO C. GARCIA, E ETAL. Defendants. 151* JUDICIAL DISTRICT= = « > yeu = a | ORIGINAL ANSWER OF DEFENDANT HARVEST BEND, SECTION Lgssoctr S55 oO TO THE HONORABLE JUDGE OF SAID COURT. OTe Theo Eee COMES NOW, Harvest Bend, Section I Association (Association), one ofthe etary Sal above entitled and numbered cause, and files this its Original Answer to Plaintiff's tigiit Petition. General Denial The Association denies each and every allegation set forth in Plaintiff's Original Petition. Prayer For these reasons, the Association asks the court to render a take-nothing judgment against plaintiffs, assess costs against plaintiffs, and award the Association all other relief to which it is entitled, Respectfully submitted, BUTLER& Y, P.C, avis TBN: 00792447 Roy D. Hailey TBN: 08706400 1616 South Voss, Suite 500 Houston, Texas 77057-2631 (713) 780-4135 (713) 780-4549 Telecopier Attorneys for Defendant 106798/2358/80002 Thig RRDER'S HEWORANDUy the time of °Fint Boor quai at og or ~ en CERTIFICATE OF COMPLIANCE This is to certify that a true and correct photocopy of Original Answer of Defendant Harvest Bend, Section I Association and Disclaimer of Defendant Harvest Bend, Section I Association has been served upon all attorney(s) of record and/or pro se parties by depositing Sha same with the United States Postal Service by first class mail, co: rectly addressed and postage prepaid, or in the manner indicated, on this the 0 day of 2005, to such attorney(s) and/or parties; Pankaj R. Parmar (CMRRR 7002 2410 0004 9245 1605) 1301 Travis, Suite 300 Houston, Texas 77002 and the original was filed with the District Clerk of Harris County, Texas, pursuant to Rules 21 and 21a of the Texas Rules of Civil Procedure. Cc ~™ on Cause No. 2005-01965 HARRIS COUNTY IN THE DISTRICT COURT ETAL, Plaintiffs, VS. OF HARRIS COUNTY, TEXAS GENARO C. GARCIA, ETAL. Defendants. § 151* JUDICIAL DISTRICT ‘ F ORIGINAL ANSWER OF DEFENDANT HARVEST BEND, SECTION rasshcRnols5 we OS Zar - TO THE HONORABLE JUDGE OF SAID COURT: “47 = ago, & COMES NOW, Harvest Bend, Section I Association (Association), one of eget YES o nk above entitled and numbered cause, and files this its Original Answer to vi Zein < S= Petition. a General Denial The Association denies each and every allegation set forth in Plaintiff's Original Petition. Prayer For these reasons, the Association asks the court to render a take-nothing judgment against plaintiffs, assess costs against plaintiffs, and award the Association all other relief to which it is entitled. Respectfully submitted, BUTLER& Y, P.C. avis TBN: 00792447 Roy D. Hailey TBN: 08706400 1616 South Voss, Suite 500 Houston, Texas 77057-2631 (713) 780-4135 106798/2358/80002 (713) 780-4549 Telecopier Attorneys for Defendant Co Py - ~ on CERTIFICATE OF COMPLIANCE This is to certify that a true and correct photocopy of Original Answer of Defendant Harvest Bend, Section I Association and Disclaimer of Defendant Harvest Bend, Section I Association has been served upon all attorney(s) of record and/or pro se parties by depositing hu same with the United States Postal Service by first clclas: s mail, correctly addressed and postage prepaid, or in the manner indicated, on this the \o day of 2005, to such attomey(s) and/or parties; Pankaj R. Parmar (CMRRR 7002 2410 0004 9245 1605) 1301 Travis, Suite 300 Houston, Texas 77002 and the original was filed with the District Clerk of Harris County, Texas, pursuant to Rules 21 and 21a of the Texas Rules of Civil Procedure. Cc 4 9245 DBDsfelo 2 2uio 000) 700) Ene oo & Bk |e rE +s be Ea Ee i \i EN ko eed ‘ 37 wom EY Foes) 4 sow A Fe ra a) Eas Bae] Fa El ca tere) oa eal reed rma) Aa i