On August 11, 2017 a
Answer
was filed
involving a dispute between
and
for MODIFICATION-CUSTODY
in the District Court of Tarrant County.
Preview
233-623981-17 FILED
TARRANT COUNTY
8/24/2017 8:26 AM
THOMAS A. WILDER
NO. 233-623981-17 DISTRICT CLERK
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
SONIA PALOMINOS §
AND § 233RD JUDICIAL DISTRICT
ISMAEL OROSCO PALOMINOS §
§
AND IN THE INTEREST OF §
ALEXA NICOLE PALOMINOS, §
A CHILD § TARRANT COUNTY, TEXAS
RESPONDENT'S ORIGINAL ANSWER
Ismael Orosco Palominos, Respondent, files this Original Answer to Original Petition for
Divorce. The last three numbers of Ismael Orosco Palominos's driver's license number are 069.
The last three numbers of Ismael Orosco Palominos's Social Security number are 518.
1. General Denial
Respondent enters a general denial.
2. Information about Child
Information required by section 154.181(b) of the Texas Family Code will be provided, if
requested.
3. Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Respondent to secure the services of Jefferson R. Branch, a licensed
attorney, to prepare and prosecute this suit. To effect an equitable division of the estate of the
parties and as a part of the division, and for services rendered in connection with conservatorship
and support of the child, judgment for attorney's fees, expenses, and costs through trial and
appeal should be granted against Petitioner and in favor of Respondent for the use and benefit of
Respondent's attorney and be ordered paid directly to Respondent's attorney, who may enforce
the judgment in the attorney's own name. Respondent requests postjudgment interest as allowed
RESPONDENT'S ORIGINAL ANSWER Page 1 of 2
by law.
4. Prayer
Respondent prays that Petitioner take nothing and that Respondent be granted all relief
requested in this Original Answer.
Respondent also prays for attorney's fees, expenses, costs, and interest as requested
above.
Respondent prays for general relief.
Respectfully submitted,
THE WYNNE LAW FIRM
128 East Texas Street
Grapevine, Texas 76051
Tel: (817) 329-5573
Fax: (817) 329-7196
www.davidwynnelaw.com
By: /s/ Jefferson R. Branch_____
JEFFERSON R. BRANCH
State Bar No. 24006887
E-Mail: jeff@davidwynnelaw.com
Attorney for Respondent
Certificate of Service
I certify that a true copy of the above was served on each attorney of record or party in
accordance with the Texas Rules of Civil Procedure on August 24 , 2017.
/s/ Jefferson R. Branch_____________
Jefferson R. Branch
Attorney for Respondent
RESPONDENT'S ORIGINAL ANSWER Page 2 of 2
Document Filed Date
August 24, 2017
Case Filing Date
August 11, 2017
Category
MODIFICATION-CUSTODY
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233-623981-17 FILED TARRANT COUNTY 8/24/2017 8:26 AM THOMAS A. WILDER NO. 233-623981-17 DISTRICT CLERK IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § SONIA PALOMINOS § AND § 233RD JUDICIAL DISTRICT ISMAEL OROSCO PALOMINOS § § AND IN THE INTEREST OF § ALEXA NICOLE PALOMINOS, § A CHILD § TARRANT COUNTY, TEXAS RESPONDENT'S ORIGINAL ANSWER Ismael Orosco Palominos, Respondent, files this Original Answer to Original Petition for Divorce. The last three numbers of Ismael Orosco Palominos's driver's license number are 069. The last three numbers of Ismael Orosco Palominos's Social Security number are 518. 1. General Denial Respondent enters a general denial. 2. Information about Child Information required by section 154.181(b) of the Texas Family Code will be provided, if requested. 3. Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of Jefferson R. Branch, a licensed attorney, to prepare and prosecute this suit. To effect an equitable division of the estate of the parties and as a part of the division, and for services rendered in connection with conservatorship and support of the child, judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Petitioner and in favor of Respondent for the use and benefit of Respondent's attorney and be ordered paid directly to Respondent's attorney, who may enforce the judgment in the attorney's own name. Respondent requests postjudgment interest as allowed RESPONDENT'S ORIGINAL ANSWER Page 1 of 2 by law. 4. Prayer Respondent prays that Petitioner take nothing and that Respondent be granted all relief requested in this Original Answer. Respondent also prays for attorney's fees, expenses, costs, and interest as requested above. Respondent prays for general relief. Respectfully submitted, THE WYNNE LAW FIRM 128 East Texas Street Grapevine, Texas 76051 Tel: (817) 329-5573 Fax: (817) 329-7196 www.davidwynnelaw.com By: /s/ Jefferson R. Branch_____ JEFFERSON R. BRANCH State Bar No. 24006887 E-Mail: jeff@davidwynnelaw.com Attorney for Respondent Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on August 24 , 2017. /s/ Jefferson R. Branch_____________ Jefferson R. Branch Attorney for Respondent RESPONDENT'S ORIGINAL ANSWER Page 2 of 2