Defendant's second Amended Answer and Counterclaim

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CAUSE NO . 2013

OSAMA ABDULLATIF, individually,                               IN THE DISTRICT COURT OF
ABDULLATIF & COMPANY, LLC,




ALI CHOUDHRI and HOUSTON REAL
ESTATE PROPERTIES, LLC,




                   Ali Choudhri (“Choudhri’”’) and Houston Real Estate Properties, LLC (“HREP”)

file this Second Amended Answer and                Counterclaim to Plaintiff's Original Petition




                          each and every, all and singular, the material allegations contained in

               Petition and demand strict proof thereof by a preponderance of the evidence. This




       Defendants were justified in filing documents in the real property records regarding their




       Claimant   Ali Choudhri                                       asserts the following   Counter




       On February 10, 2010,              signed a promissory note (the “Note”)

Abdullatif’s signature is notarized on a page denoted “3 of    of the Note, and he has acknowledged
his execution of th…