On September 14, 2018 a
Answer
was filed
involving a dispute between
Nabavi, Amir,
and
Garcia, Jaime,
Lesser, David,
Wide-World Entertainment Llc,
World-Wide Entertainment And Concerts Llc,
for Debt/Contract - Debt/Contract
in the District Court of Harris County.
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Defendant David Lesser ”), and file First Amended
general denial generally denying each and every material
egation contained in Plaintiff? Petition and any subsequent amendments and/or
Pleading further and in the alternative, Defendant is not liable to Plaintiff because
Pleading further and in the alternative intiff’s claims are barred by the lack of
Pleading further and in the alternative, in the unlikely event Plaintiff obtains any
recovery from this Defendant, Defendant is entitled to a credit for all amounts Plaintiff
IH. VERIFIED DENIAL
Pleading further, and in the alternative, pursuant to Tex. R. Civ. P. 93(2) Plaintiff's
claims fail in whole or in part because Defendant is not liable in the capacity in which he is sued.
Specifically, Defendant signed the agreement at issue only in his capacity as the representative for
a corporate entity, and not individually.
. USE OF DOCUMENTS
Defendant hereby gives notice to Plaintiff and all other parties that any and all
documents produced during discovery may be used against Plaintiff and any other party at any
pretrial proceeding and/or trial of this matter without the necessity of authenticating the document.
This notice is given pursuant to Rule 7 of the Texas Rules of Civil Procedure.
WHEREFORE PREMISES CONSIDERED, Defendant David Lesser pray that Plaintiff
take nothing against Defendant and assess all costs against Plaintiff and award all other relief to
which Defendant justly entitled.
Respectfully submitted,
MURRAY | LOBB, P
/s/ Kyle L. Dickson
Kyle L. Dickson
State Bar No. 05841310
700 Gemini, Suite 115
Houston, Texas 77058
Ph:
Fx:
kdickson@murray lobb.com
ATTORNEYS FOR DEFENDANT DAVID
LESSER, INDIVIDUALLY AND DBA
WIDE WORLD ENTERTAINMENT AND
CONCERT, LLC
CERTIFICATE OF SERVI
Thereby certify that a true and correct copy of the foregoing document has been delivered
in the appropriate manner to all known parties and/or counsel of record on October 18, 2019
/s/ Kyle L. Dickson
Kyle L. Dickson
Michael R. Harris
HE ARRIS AW IRM
1200 Smith St., Suite 1550
Houston, TX 77002
mharris@theharrislawfirm.com
Document Filed Date
October 18, 2019
Case Filing Date
September 14, 2018
Category
Debt/Contract - Debt/Contract
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Defendant David Lesser ”), and file First Amended general denial generally denying each and every material egation contained in Plaintiff? Petition and any subsequent amendments and/or Pleading further and in the alternative, Defendant is not liable to Plaintiff because Pleading further and in the alternative intiff’s claims are barred by the lack of Pleading further and in the alternative, in the unlikely event Plaintiff obtains any recovery from this Defendant, Defendant is entitled to a credit for all amounts Plaintiff IH. VERIFIED DENIAL Pleading further, and in the alternative, pursuant to Tex. R. Civ. P. 93(2) Plaintiff's claims fail in whole or in part because Defendant is not liable in the capacity in which he is sued. Specifically, Defendant signed the agreement at issue only in his capacity as the representative for a corporate entity, and not individually. . USE OF DOCUMENTS Defendant hereby gives notice to Plaintiff and all other parties that any and all documents produced during discovery may be used against Plaintiff and any other party at any pretrial proceeding and/or trial of this matter without the necessity of authenticating the document. This notice is given pursuant to Rule 7 of the Texas Rules of Civil Procedure. WHEREFORE PREMISES CONSIDERED, Defendant David Lesser pray that Plaintiff take nothing against Defendant and assess all costs against Plaintiff and award all other relief to which Defendant justly entitled. Respectfully submitted, MURRAY | LOBB, P /s/ Kyle L. Dickson Kyle L. Dickson State Bar No. 05841310 700 Gemini, Suite 115 Houston, Texas 77058 Ph: Fx: kdickson@murray lobb.com ATTORNEYS FOR DEFENDANT DAVID LESSER, INDIVIDUALLY AND DBA WIDE WORLD ENTERTAINMENT AND CONCERT, LLC CERTIFICATE OF SERVI Thereby certify that a true and correct copy of the foregoing document has been delivered in the appropriate manner to all known parties and/or counsel of record on October 18, 2019 /s/ Kyle L. Dickson Kyle L. Dickson Michael R. Harris HE ARRIS AW IRM 1200 Smith St., Suite 1550 Houston, TX 77002 mharris@theharrislawfirm.com