On April 19, 2021 a
Answer
was filed
involving a dispute between
Bng Management Group, Llc,
Pk Restaurant Group Inc,
and
Cho, Jimmy,
Giant Blue Inc,
Tozee Construction Inc,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
5/26/2021 11:47 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Daniel Macias DEPUTY
NO. DC-21-04907
PK RESTAURANT GROUP, INC., AND § IN THE DISTRICT COURT
BNG MANAGEMENT GROUP, LLC, §
§
Plaintiffs, §
§
v. § IOIST JUDICIAL DISTRICT
§
TOZEE CONSTRUCTION, INC., §
GIANT BLUE, INC., AND JIMMY §
CH0, §
Defendants. § DALLAS COUNTY, TEXAS
DEFENDANTS’ ORIGINAL ANSWER & REQUESTS FOR DISCLOSURE
TO THE HONORABLE COURT
TOZEE CONSTRUCTION, INC., GIANT BLUE, INC, AND JIMMY CHO, Defendants
in the above numbered and styled action, brings this DEFENDANTS’ ORIGINAL ANSWER,
complains of the conduct of Plaintiffs, and would show the court the following:
I.
GENERAL DENIAL
l. Defendants generally deny each and every allegation, claim, and cause of action in
Plaintiffs’ petition and demands strict proof thereof. See TEX. R. CIV. P. 92.
II.
OBJECTION TO ASSOCIATE JUDGE
2. Defendants object to assignment of this Matter to any associate judge for any dispositive
hearings or hearings where de novo rehearing is not permitted.
PRAYER FOR RELIEF
WHEREFORE, Premises Considered, Defendants pray that this Court denies all relief Plaintiffs
seek and issues a take nothing judgment in favor of Defendants.
ORIGINAL ANSWER
PAGE 1 0F 2
RESPECTFULLY SUBMITTED,
/s/ William Chu
William Chu
SBOT: 04241000
wmchulaw@aol.com
LAW OFFICES 0F WILLIAM CHU
4455 LBJ Freeway, Suite. 1008
Dallas Texas, 75244
(Tel) 972-392-9888
(Fax) 972-392-9889
ATTORNEY FOR DEFENDAN TS
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of this document was E-Served on all parties
(or their counsel of record) on MAY 26, 2021, through the Texas E-File system to their email
address on file in accordance with Rule 21a of the Texas Rules of Civil Procedure.
/s/William Chu
ORIGINAL ANSWER
PAGE 2 0E 2
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
William Chu
Bar No. 04241000
wmchulaw@aol.com
Envelope ID: 53829167
Status as of 5/27/2021 9:50 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
William Chu wmchulaw@aol.com 5/26/2021 11:47:23 AM SENT
Jordan Whiddon 24093350 jwhiddon@tailimsong.com 5/26/2021 11:47:23 AM SENT
william Knisley knisley.wmchulaw@gmail.com 5/26/2021 11:47:23 AM SENT
Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 5/26/2021 11:47:23 AM SENT
Office Efiles wmchulawefile@gmail.com 5/26/2021 11:47:23 AM SENT
Document Filed Date
May 26, 2021
Case Filing Date
April 19, 2021
Category
CNTR CNSMR COM DEBT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 5/26/2021 11:47 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Daniel Macias DEPUTY NO. DC-21-04907 PK RESTAURANT GROUP, INC., AND § IN THE DISTRICT COURT BNG MANAGEMENT GROUP, LLC, § § Plaintiffs, § § v. § IOIST JUDICIAL DISTRICT § TOZEE CONSTRUCTION, INC., § GIANT BLUE, INC., AND JIMMY § CH0, § Defendants. § DALLAS COUNTY, TEXAS DEFENDANTS’ ORIGINAL ANSWER & REQUESTS FOR DISCLOSURE TO THE HONORABLE COURT TOZEE CONSTRUCTION, INC., GIANT BLUE, INC, AND JIMMY CHO, Defendants in the above numbered and styled action, brings this DEFENDANTS’ ORIGINAL ANSWER, complains of the conduct of Plaintiffs, and would show the court the following: I. GENERAL DENIAL l. Defendants generally deny each and every allegation, claim, and cause of action in Plaintiffs’ petition and demands strict proof thereof. See TEX. R. CIV. P. 92. II. OBJECTION TO ASSOCIATE JUDGE 2. Defendants object to assignment of this Matter to any associate judge for any dispositive hearings or hearings where de novo rehearing is not permitted. PRAYER FOR RELIEF WHEREFORE, Premises Considered, Defendants pray that this Court denies all relief Plaintiffs seek and issues a take nothing judgment in favor of Defendants. ORIGINAL ANSWER PAGE 1 0F 2 RESPECTFULLY SUBMITTED, /s/ William Chu William Chu SBOT: 04241000 wmchulaw@aol.com LAW OFFICES 0F WILLIAM CHU 4455 LBJ Freeway, Suite. 1008 Dallas Texas, 75244 (Tel) 972-392-9888 (Fax) 972-392-9889 ATTORNEY FOR DEFENDAN TS CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of this document was E-Served on all parties (or their counsel of record) on MAY 26, 2021, through the Texas E-File system to their email address on file in accordance with Rule 21a of the Texas Rules of Civil Procedure. /s/William Chu ORIGINAL ANSWER PAGE 2 0E 2 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. William Chu Bar No. 04241000 wmchulaw@aol.com Envelope ID: 53829167 Status as of 5/27/2021 9:50 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status William Chu wmchulaw@aol.com 5/26/2021 11:47:23 AM SENT Jordan Whiddon 24093350 jwhiddon@tailimsong.com 5/26/2021 11:47:23 AM SENT william Knisley knisley.wmchulaw@gmail.com 5/26/2021 11:47:23 AM SENT Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 5/26/2021 11:47:23 AM SENT Office Efiles wmchulawefile@gmail.com 5/26/2021 11:47:23 AM SENT