CASE NO.

JS15-30865A

COLBY HARLOW ' IN THE DALLAS COUNTY

PLAINTIFF '
' JUSTICE COURT
VS. '
' PRECINCT 3, PLACE 1
ALEJANDRO PEREZ '
DEFENDANT ' DALLAS, TEXAS

DEFENDANTS PLEA IN ABATEMENT,

ORIGINAL ANSWER
AND
REQUEST FOR CIVIL HARASSMENT RESTRAINING ORDER

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW ALEJANDRO PEREZ, who has been named as a Defendant in the above styled cause, and in
answer to the Plaintiff's Original Petition filed therein would respectfully show the Court and jury the following:

1. PLEA IN ABATEMENT

1.1 In answer to Plaintiff's Original Petition, Defendant would show the Court that ROLANDO GARCIA,

does not appear in Plaintiff's Original Petition as a party to this suit, and that that person in that capacity is a

necessary and indispensable party to this action, without whom a just adjudication cannot be made. For

nonjoinder of the necessary party this Defendant moves for abatement of this suit.

2. GENERAL DENIAL

2.1 Subject to the above special exceptions and Plea in Abatement and without waiving the same, in answer

to Plaintiff's Petition, Defendant exercises his statutory right as is authorized by Rule 92 of the Texas Rules of

Civil Procedure to require Plaintiff to prove all material allegations contained in the Plaintiff's Original Petition

and for this purpose, he generally denies them all. Defendant respectfully requests that the Plaintiff be required

to prove the 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.

Page 1 Original Answer

 3. RESERVATION OF RIGHT TO AMEND

3.1 Defendant expressly reserves the right to amend this pleading at a later date, in order to assert

additional matters which may become apparent during the course of discovery.

4. REQUEST FOR CIVIL HARASSMENT RESTRAINING ORDER

4.1 Defendant respectfully requests this Court to issue and Order enjoining Plaintiff and his agents from:

Harass, intimidate, molest, attack, strike, stalk, threat, assault, hit abuse, destroy personal property of

Defendant, or disturb the peace of Defendant.

Contact Defendant, either directly or indirectly, in any way, including but not limited to, in person at his

place of employment of residence, by telephone, in writing, by public of private mail, by e-mail, text messages.

Peaceful written contact with legal papers related to the court case shall be allowed and shall not

constitute a violation.

PRAYER

Defendant respectfully prays for judgment of the Court on his Plea in Abatement, and that Defendant

be dismissed with his costs; or, in the alternative, Defendant respectfully prays that the Court strike the portions

of Plaintiff's Original Petition specially excepted to herein and prays for judgment of the Court that the Plaintiff

take nothing by this suit, for costs, and for such other and further relief to which Defendant may be justly

entitled, either at law or in equity.

Respectfully submitted,

_______________________________
ALEJANDRO PEREZ,
Defendant
2674 Myrtle Springs Ave.
Dallas, TX 75220
Tel.: 469/254-7909
Juakin123@hotmail.com

Page 2 Original Answer

 CERTIFICATE OF SERVICE

In accordance with the Rules of Civil Procedure on this ________ day of September, 2015, a true and correct
copy of the foregoing instrument was served upon Plaintiff, via U.S. mail and e-mail provided by plaintiff
and in record with this Court

COLBY HARLOW _____ Via facsimile

Plaintiff ____ Via e-mail
5910 North Central Expressway #1660 ____ Via Regular Mail
Dallas, TX 75206 _____ Via Certified Mail
COLBYHARLOW@GMAIL.COM

_______________________________
ALEJANDRO PEREZ

_____ (initial) I consent to email service of the answer and any other motions or pleadings, to my email
address:

juakin123@hotmail.com_.
Email address

Page 3 Original Answer