On June 23, 2021 a
Answer
was filed
involving a dispute between
Pca Acquisitions V, Llc,
and
Jeffords, Sam,
for Contract - Debt
in the District Court of Galveston County.
Preview
Sam Jeffords
F I L. E D
106 Lazy Hollow Dr
TX 202i JUL -7 AH 8= 33
League City, 77573
samjeffords@gmail.com
Defendant is self-represented
y(gg 1:)
DJSTPJCT
\ka
CLERK
GA! VES’ICP-E CF31?!" TF‘XAS
‘v’.
IN THE 10TH DISTRICT COURT
GALVESTON COUNTY, TEXAS
PCA Acquisitions V. LLC, ANSWER
Plaintiff,
Civil No.: 21-CV—0903
vs.
Judge:
Sam Jeffords,
Defendant(s).
Defendant answers Plaintiff’s Complaint as follows.
RESPONSE TO ALLEGATIONS
1. Defendant denies the allegation in paragraph 1 for lack of knowledge sufficient to
know the truth or falsity thereof.
2. Defendant denies the allegation in paragraph 2.
3. Defendant denies the allegation in paragraph 3 for lack of knowledge sufficient to
know the truth or falsity thereof.
4. Defendant denies the allegation in paragraph 4.
5. Defendant denies the allegation in paragraph 5.
6. Defendant denies the allegation in paragraph 6.
7. Defendant denies the allegation in paragraph 7.
1
21—cv-ogoa
oconANsw
OriginalAnswer
2221041
Hll ||l| lllllflllllllmlllllWI
Defendant denies the allegation in paragraph 8.
Defendant denies the allegation in paragraph 9.
10. Defendant denies the allegation in paragraph 10.
11. Defendant denies the allegation in paragraph 11.
12. Defendant denies the allegation in paragraph 12.
13. Defendant denies the allegation in paragraph 13 for lack of knowledge sufficient to
know the truth or falsity thereof.
14. Defendant denies the allegation in paragraph 14.
15. Defendant denies the allegation in paragraph 15.
16. Defendant denies the allegation in paragraph 16.
17. Defendant denies the allegation in paragraph l7.
18. Defendant denies the allegation in paragraph 18.
19. Defendant denies the allegation in paragraph 19.
20. Defendant denies the allegation in paragraph 20.
21. Defendant denies the allegation in paragraph 2 1.
22. Defendant denies the allegation in paragraph 22.
23. Defendant denies the allegation in paragraph 23.
24. Defendant denies the allegation in paragraph 24.
25. Defendant denies the allegation in paragraph 25 for lack of knowledge sufficient to
know the truth or falsity thereof.
26. Defendant denies the allegation in paragraph 26.
27. Defendant denies the allegation in paragraph 27.
28. Defendant denies the allegation in paragraph 28.
2
Defendant denies each and every allegation in the Complaint that is not expressly
admitted herein.
With respect to all paragraphs in which Plaintiff prays for damages or other relief,
Defendant denies that Plaintiff is entitled to such relief under law.
AFFIRMATIVE DEFENSES
. Plaintiff’s claims are barred in whole or in part by the doctrines of laches, equitable
estoppel, and unclean hands.
Plaintiff’s claims are barred in whole or in part because of a failure to mitigate damages.
Plaintiff‘s claims are barred in whole or in part by the statute of limitations.
Plaintiff’s claims are barred in whole or in part because of improper service.
Plaintiff’s claims are barred in whole or in part for a failure to follow the law regarding
lending t0 veterans.
WHEREFORE, Defendant requests the following relief:
1. That Plaintiff’s Complaint be dismissed with prejudice, and Plaintiff take nothing
therefrom;
The Defendant recover its reasonable fees and costs incurred in defending against this
lawsuit;
For such other and further relief as this Court may deem just and proper.
DATED 07/05/202 l.
/s/ gam jeforc/c
Sam Jeffords
Self-represen ted
Original 0f the forgoing was caused t0 be filed via mail on 07/05/2021 to:
The court
Copy caused to be sent via mail on this day to:
David Lippman
P.O. Box 13928
Tucson AZ 85732
/s/ gmn jeforc/C
Sam Jeffords
Self-represented
Document Filed Date
July 07, 2021
Case Filing Date
June 23, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Sam Jeffords F I L. E D 106 Lazy Hollow Dr TX 202i JUL -7 AH 8= 33 League City, 77573 samjeffords@gmail.com Defendant is self-represented y(gg 1:) DJSTPJCT \ka CLERK GA! VES’ICP-E CF31?!" TF‘XAS ‘v’. IN THE 10TH DISTRICT COURT GALVESTON COUNTY, TEXAS PCA Acquisitions V. LLC, ANSWER Plaintiff, Civil No.: 21-CV—0903 vs. Judge: Sam Jeffords, Defendant(s). Defendant answers Plaintiff’s Complaint as follows. RESPONSE TO ALLEGATIONS 1. Defendant denies the allegation in paragraph 1 for lack of knowledge sufficient to know the truth or falsity thereof. 2. Defendant denies the allegation in paragraph 2. 3. Defendant denies the allegation in paragraph 3 for lack of knowledge sufficient to know the truth or falsity thereof. 4. Defendant denies the allegation in paragraph 4. 5. Defendant denies the allegation in paragraph 5. 6. Defendant denies the allegation in paragraph 6. 7. Defendant denies the allegation in paragraph 7. 1 21—cv-ogoa oconANsw OriginalAnswer 2221041 Hll ||l| lllllflllllllmlllllWI Defendant denies the allegation in paragraph 8. Defendant denies the allegation in paragraph 9. 10. Defendant denies the allegation in paragraph 10. 11. Defendant denies the allegation in paragraph 11. 12. Defendant denies the allegation in paragraph 12. 13. Defendant denies the allegation in paragraph 13 for lack of knowledge sufficient to know the truth or falsity thereof. 14. Defendant denies the allegation in paragraph 14. 15. Defendant denies the allegation in paragraph 15. 16. Defendant denies the allegation in paragraph 16. 17. Defendant denies the allegation in paragraph l7. 18. Defendant denies the allegation in paragraph 18. 19. Defendant denies the allegation in paragraph 19. 20. Defendant denies the allegation in paragraph 20. 21. Defendant denies the allegation in paragraph 2 1. 22. Defendant denies the allegation in paragraph 22. 23. Defendant denies the allegation in paragraph 23. 24. Defendant denies the allegation in paragraph 24. 25. Defendant denies the allegation in paragraph 25 for lack of knowledge sufficient to know the truth or falsity thereof. 26. Defendant denies the allegation in paragraph 26. 27. Defendant denies the allegation in paragraph 27. 28. Defendant denies the allegation in paragraph 28. 2 Defendant denies each and every allegation in the Complaint that is not expressly admitted herein. With respect to all paragraphs in which Plaintiff prays for damages or other relief, Defendant denies that Plaintiff is entitled to such relief under law. AFFIRMATIVE DEFENSES . Plaintiff’s claims are barred in whole or in part by the doctrines of laches, equitable estoppel, and unclean hands. Plaintiff’s claims are barred in whole or in part because of a failure to mitigate damages. Plaintiff‘s claims are barred in whole or in part by the statute of limitations. Plaintiff’s claims are barred in whole or in part because of improper service. Plaintiff’s claims are barred in whole or in part for a failure to follow the law regarding lending t0 veterans. WHEREFORE, Defendant requests the following relief: 1. That Plaintiff’s Complaint be dismissed with prejudice, and Plaintiff take nothing therefrom; The Defendant recover its reasonable fees and costs incurred in defending against this lawsuit; For such other and further relief as this Court may deem just and proper. DATED 07/05/202 l. /s/ gam jeforc/c Sam Jeffords Self-represen ted Original 0f the forgoing was caused t0 be filed via mail on 07/05/2021 to: The court Copy caused to be sent via mail on this day to: David Lippman P.O. Box 13928 Tucson AZ 85732 /s/ gmn jeforc/C Sam Jeffords Self-represented