On December 31, 2020 a
Answer
was filed
involving a dispute between
Bodden Bajarano, Farrel,
and
Santos, Kareen,
for Divorce with Children
in the District Court of Montgomery County.
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Received and E-Filed for Record
2/26/2021 10:32 AM
Melisa Miller, District Clerk
Montgomery County, Texas
Deputy Clerk, Charlotte Forbes
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
NO. 20-12-16045
IN THE MATTER OF § IN COUNTY COURT AT LAW
THE MARRIAGE OF §
§ 418th JUDICIAL DISTRICT COURT
FARREL BODDEN BAJARANO §
AND § NUMBER 3
KAREEN GISELA SANTOS §
§
AND IN THE INTEREST OF §
ABIGAIL G. BODDEN AND § MONTGOMERY COUNTY, TEXAS
DIANY A. BODDEN, CHILDREN §
RESPONDENT'S ORIGINAL ANSWER
KAREEN GISELA SANTOS, Respondent, files this Original Answer to Original
Petition for Divorce. The last three numbers of KAREEN GISELA SANTOS's driver's license
number are 746. The last three numbers of KAREEN GISELA SANTOS's Social Security
number are 936.
1. General Denial
Respondent enters a general denial.
2. Objection to Assignment of Case to Associate Judge
Respondent objects to the assignment of this matter to an associate judge for a trial on the
merits or presiding at a jury trial.
3. Information about Children
Information required by section 154.181(b) and section 154.1815 of the Texas Family
Code will be provided at a later time prior to any hearing.
4. Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Respondent to secure the services of Juan M. Aldape, Jr., 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 children, 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
by law.
5. 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,
Law Office of Juan M. Aldape
11811 North Freeway, Ste. 618
Houston, Texas 77060
Tel: (281) 931-1250
Fax: (281) 931-1292
By:/s/Juan M. Aldape, Jr.
Juan M. Aldape, Jr.
State Bar No. 24045305
Aldapelaw@gmail.com
Attorney for Respondent
Page 2 of 3
Certificate of Service
I certify that a true copy of this Respondent's Original Answer was served in accordance
with rule 21a of the Texas Rules of Civil Procedure on the following on February 26, 2021:
Leslie A. Garcia by e-mail at lgarcia@lgarcialaw.com.
/s/Juan M. Aldape, Jr.
Juan M. Aldape, Jr.
Attorney for Respondent
Page 3 of 3
Document Filed Date
February 26, 2021
Case Filing Date
December 31, 2020
Category
Divorce with Children
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Received and E-Filed for Record 2/26/2021 10:32 AM Melisa Miller, District Clerk Montgomery County, Texas Deputy Clerk, Charlotte Forbes NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NO. 20-12-16045 IN THE MATTER OF § IN COUNTY COURT AT LAW THE MARRIAGE OF § § 418th JUDICIAL DISTRICT COURT FARREL BODDEN BAJARANO § AND § NUMBER 3 KAREEN GISELA SANTOS § § AND IN THE INTEREST OF § ABIGAIL G. BODDEN AND § MONTGOMERY COUNTY, TEXAS DIANY A. BODDEN, CHILDREN § RESPONDENT'S ORIGINAL ANSWER KAREEN GISELA SANTOS, Respondent, files this Original Answer to Original Petition for Divorce. The last three numbers of KAREEN GISELA SANTOS's driver's license number are 746. The last three numbers of KAREEN GISELA SANTOS's Social Security number are 936. 1. General Denial Respondent enters a general denial. 2. Objection to Assignment of Case to Associate Judge Respondent objects to the assignment of this matter to an associate judge for a trial on the merits or presiding at a jury trial. 3. Information about Children Information required by section 154.181(b) and section 154.1815 of the Texas Family Code will be provided at a later time prior to any hearing. 4. Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of Juan M. Aldape, Jr., 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 children, 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 by law. 5. 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, Law Office of Juan M. Aldape 11811 North Freeway, Ste. 618 Houston, Texas 77060 Tel: (281) 931-1250 Fax: (281) 931-1292 By:/s/Juan M. Aldape, Jr. Juan M. Aldape, Jr. State Bar No. 24045305 Aldapelaw@gmail.com Attorney for Respondent Page 2 of 3 Certificate of Service I certify that a true copy of this Respondent's Original Answer was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on February 26, 2021: Leslie A. Garcia by e-mail at lgarcia@lgarcialaw.com. /s/Juan M. Aldape, Jr. Juan M. Aldape, Jr. Attorney for Respondent Page 3 of 3