On October 09, 2020 a
Answer
was filed
involving a dispute between
Diamond, Jeffrey,
Diamond, Stacey,
and
Collier, Bradford Wood,
Everett Financial, Inc.,
Pu Pineda, Henrry Adonias,
Texas Ally Real Estate Group, Llc,
for Other Civil - Cases
in the District Court of Galveston County.
Preview
Filed: 8/25/2021 1:56 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 56647817
By: Shailja Dixit
8/25/2021 2:09 PM
CAUSE NO: 20-CV-1458
STACEY
DIAMOND AND JEFFREY § IN THE DISTRICT COURT
DIAMOND §
§
Plaintiffs, §
§
v. § GALVESTON COUNTY, TEXAS
§
BRADFORD WOOD COLLIER §
Defendant. § 122Nn DISTRICT COURT
DEFENDANT, HENRRY ADONIAS PU PINEDA'S ORIGINAL ANSWER
COMES NOW, Defendant, HENRRY ADONIAS PU PINEDA, and submits this
Original Answer to Plaintiffs' Original Petition, and would respectfully show the Court and Jury
as follows:
I. GENERAL DENIAL
Subject to such stipulations as may hereafter be made, this Defendant asserts a general
denial as is authorized by TEX. R. CIV. P. 92 and respectfully requests that Plaintiffs be required to
prove their charges and allegations against this Defendant by a preponderance of the evidence, as
is required by the Constitution and laws of the State of Texas.
WHEREFORE, PREMISES CONSIDERED, Defendant HENRRY ADONIAS PU
PINEDA, prays that he be released, discharged and acquitted of the charges filed against him, that
Plaintiffs take nothing by reason of this suit, and that the Court award this Defendant such other
and further relief to which it is justly entitled.
Respectfully submitted,
SHEINESS, GLOVER & GROSSMAN, LLP
Steven D. Grossman
State Bar of Texas: 0854 7800
4544 Post Oak Place Dr., Ste. 270
Houston, Texas 77027
(713) 374-7015- Telephone
(713) 374-7049- Facsimile
Email: sgrossman@hou-law.com
Attorney for Defendant,
HENRRY ADONIAS PU PINEDA
CERTIFICATE OF SERVICE
On August 25, 2021, I, the undersigned counsel, electronically submitted the foregoing
document to all counsel of record viae-filing.
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.
Janean Brooks on behalf of Steven Grossman
Bar No. 8547800
jbrooks@hou-law.com
Envelope ID: 56647817
Status as of 8/25/2021 2:10 PM CST
Associated Case Party: Stacey Diamond
Name BarNumber Email TimestampSubmitted Status
Taylor Diamond 24109809 service@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT
Alyssa Gibson JDAP013@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Keith Anderson 24075789 kanderson@bradley.com 8/25/2021 1:56:25 PM SENT
Robert Ford 24074219 rford@bradley.com 8/25/2021 1:56:25 PM SENT
Gabriella Alonso 24113527 galonso@bradley.com 8/25/2021 1:56:25 PM SENT
Matthew Hu mhu@bradley.com 8/25/2021 1:56:25 PM SENT
Cindy Lopez clopez@bradley.com 8/25/2021 1:56:25 PM SENT
Yolanda ZRodriguez yrodriguez@bradley.com 8/25/2021 1:56:25 PM SENT
Taylor Diamond taylor@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT
Laura Garcia JDAP013@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT
Carla S.Courtney carla@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT
Rebeka Harricharran jdap4@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT
Associated Case Party: BradfordWoodCollier
Name BarNumber Email TimestampSubmitted Status
Steven D.Grossman sgrossman@hou-law.com 8/25/2021 1:56:25 PM SENT
Associated Case Party: Texas Ally Real Estate Group, LLC
Name
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.
Janean Brooks on behalf of Steven Grossman
Bar No. 8547800
jbrooks@hou-law.com
Envelope ID: 56647817
Status as of 8/25/2021 2:10 PM CST
Associated Case Party: Texas Ally Real Estate Group, LLC
Thomas FO'Connell tom.oconnell@gkbwklaw.com 8/25/2021 1:56:25 PM SENT
Tonya Brantley tonya.brantley@gkbklaw.com 8/25/2021 1:56:25 PM SENT
Document Filed Date
August 25, 2021
Case Filing Date
October 09, 2020
Category
Other Civil - Cases
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Preview
Filed: 8/25/2021 1:56 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 56647817 By: Shailja Dixit 8/25/2021 2:09 PM CAUSE NO: 20-CV-1458 STACEY DIAMOND AND JEFFREY § IN THE DISTRICT COURT DIAMOND § § Plaintiffs, § § v. § GALVESTON COUNTY, TEXAS § BRADFORD WOOD COLLIER § Defendant. § 122Nn DISTRICT COURT DEFENDANT, HENRRY ADONIAS PU PINEDA'S ORIGINAL ANSWER COMES NOW, Defendant, HENRRY ADONIAS PU PINEDA, and submits this Original Answer to Plaintiffs' Original Petition, and would respectfully show the Court and Jury as follows: I. GENERAL DENIAL Subject to such stipulations as may hereafter be made, this Defendant asserts a general denial as is authorized by TEX. R. CIV. P. 92 and respectfully requests that Plaintiffs be required to prove their charges and allegations against this Defendant by a preponderance of the evidence, as is required by the Constitution and laws of the State of Texas. WHEREFORE, PREMISES CONSIDERED, Defendant HENRRY ADONIAS PU PINEDA, prays that he be released, discharged and acquitted of the charges filed against him, that Plaintiffs take nothing by reason of this suit, and that the Court award this Defendant such other and further relief to which it is justly entitled. Respectfully submitted, SHEINESS, GLOVER & GROSSMAN, LLP Steven D. Grossman State Bar of Texas: 0854 7800 4544 Post Oak Place Dr., Ste. 270 Houston, Texas 77027 (713) 374-7015- Telephone (713) 374-7049- Facsimile Email: sgrossman@hou-law.com Attorney for Defendant, HENRRY ADONIAS PU PINEDA CERTIFICATE OF SERVICE On August 25, 2021, I, the undersigned counsel, electronically submitted the foregoing document to all counsel of record viae-filing. 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. Janean Brooks on behalf of Steven Grossman Bar No. 8547800 jbrooks@hou-law.com Envelope ID: 56647817 Status as of 8/25/2021 2:10 PM CST Associated Case Party: Stacey Diamond Name BarNumber Email TimestampSubmitted Status Taylor Diamond 24109809 service@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT Alyssa Gibson JDAP013@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Keith Anderson 24075789 kanderson@bradley.com 8/25/2021 1:56:25 PM SENT Robert Ford 24074219 rford@bradley.com 8/25/2021 1:56:25 PM SENT Gabriella Alonso 24113527 galonso@bradley.com 8/25/2021 1:56:25 PM SENT Matthew Hu mhu@bradley.com 8/25/2021 1:56:25 PM SENT Cindy Lopez clopez@bradley.com 8/25/2021 1:56:25 PM SENT Yolanda ZRodriguez yrodriguez@bradley.com 8/25/2021 1:56:25 PM SENT Taylor Diamond taylor@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT Laura Garcia JDAP013@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT Carla S.Courtney carla@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT Rebeka Harricharran jdap4@jdiamondandassociates.com 8/25/2021 1:56:25 PM SENT Associated Case Party: BradfordWoodCollier Name BarNumber Email TimestampSubmitted Status Steven D.Grossman sgrossman@hou-law.com 8/25/2021 1:56:25 PM SENT Associated Case Party: Texas Ally Real Estate Group, LLC Name 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. Janean Brooks on behalf of Steven Grossman Bar No. 8547800 jbrooks@hou-law.com Envelope ID: 56647817 Status as of 8/25/2021 2:10 PM CST Associated Case Party: Texas Ally Real Estate Group, LLC Thomas FO'Connell tom.oconnell@gkbwklaw.com 8/25/2021 1:56:25 PM SENT Tonya Brantley tonya.brantley@gkbklaw.com 8/25/2021 1:56:25 PM SENT