On September 25, 2017 a
Answer
was filed
involving a dispute between
and
for INTERSTATE - NO TX CAUSE IV-D
in the District Court of Tarrant County.
Preview
231-626348-17 FILED
TARRANT COUNTY
3/27/2018 12:00 AM
NOTICE: THIS DOCUMENT THOMAS A. WILDER
DISTRICT CLERK
CONTAINS SENSITIVE DATA
NO. 231-626348-17
IN THE INTEREST OF § IN THE DISTRICT COURT
§
LILYAN A. GEORGE § 231ST JUDICIAL DISTRICT
§
A CHILD § TARRANT COUNTY, TEXAS
RESPONDENT'S ORIGINAL ANSWER
Respondent, JUAN MANUEL SERRATO, files this Original Answer. The last three
numbers of Respondent's driver's license number are 904.
1. Original Answer and Request for Genetic Testing
Respondent denies the allegations of the petition in this case and requests that this Court
order genetic testing.
2. Required Information about Child
Information required by section 152.209 of the Texas Family Code will be provided.
Information required by section 154.181(b) of the Texas Family Code will be provided.
3. Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Respondent to secure the services of Daniel R. Bacalis, P.C., licensed
attorneys, to prepare and defend this suit. Judgment for reasonable 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 order in the attorney's own name. Respondent requests postjudgment interest
as allowed by law.
4. Prayer
Respondent prays that the Court grant the relief requested above.
RESPONDENT’S ORIGINAL ANSWER – PAGE 1
Respondent prays for attorney's fees, expenses, costs, and interest as requested above.
Respondent prays for general relief.
DANIEL R BACALIS PC
669 Airport Freeway, Suite 307
Hurst, Texas 76053
Tel: (817) 498-4105
Fax: (817) 282-0634
By:/s/ Rachel L. Ponder
Daniel R. Bacalis, P.C.
State Bar No. 01487550
dbacalis@dbacalis.com
Rachel L. Ponder
State Bar No. 00786172
rponder@dbacalis.com
Attorneys 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 March 26, 2018.
/s/ Rachel L. Ponder
Rachel L Ponder
Attorney for Respondent
RESPONDENT’S ORIGINAL ANSWER – PAGE 2
Document Filed Date
March 27, 2018
Case Filing Date
September 25, 2017
Category
INTERSTATE - NO TX CAUSE IV-D
Status
FINAL JUDGMENT AFTER NON-JURY TRIAL
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231-626348-17 FILED TARRANT COUNTY 3/27/2018 12:00 AM NOTICE: THIS DOCUMENT THOMAS A. WILDER DISTRICT CLERK CONTAINS SENSITIVE DATA NO. 231-626348-17 IN THE INTEREST OF § IN THE DISTRICT COURT § LILYAN A. GEORGE § 231ST JUDICIAL DISTRICT § A CHILD § TARRANT COUNTY, TEXAS RESPONDENT'S ORIGINAL ANSWER Respondent, JUAN MANUEL SERRATO, files this Original Answer. The last three numbers of Respondent's driver's license number are 904. 1. Original Answer and Request for Genetic Testing Respondent denies the allegations of the petition in this case and requests that this Court order genetic testing. 2. Required Information about Child Information required by section 152.209 of the Texas Family Code will be provided. Information required by section 154.181(b) of the Texas Family Code will be provided. 3. Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of Daniel R. Bacalis, P.C., licensed attorneys, to prepare and defend this suit. Judgment for reasonable 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 order in the attorney's own name. Respondent requests postjudgment interest as allowed by law. 4. Prayer Respondent prays that the Court grant the relief requested above. RESPONDENT’S ORIGINAL ANSWER – PAGE 1 Respondent prays for attorney's fees, expenses, costs, and interest as requested above. Respondent prays for general relief. DANIEL R BACALIS PC 669 Airport Freeway, Suite 307 Hurst, Texas 76053 Tel: (817) 498-4105 Fax: (817) 282-0634 By:/s/ Rachel L. Ponder Daniel R. Bacalis, P.C. State Bar No. 01487550 dbacalis@dbacalis.com Rachel L. Ponder State Bar No. 00786172 rponder@dbacalis.com Attorneys 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 March 26, 2018. /s/ Rachel L. Ponder Rachel L Ponder Attorney for Respondent RESPONDENT’S ORIGINAL ANSWER – PAGE 2