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CAUSE NO. DC-10-11915
JEFFREY BARON § IN THE DISTRICT COURT
§
Plaintiff/Counterclaim Defendant, §
§
v. § 193
rd
JUDICIAL DISTRICT
§
GERRIT PRONSKE, PRONSKE & PATEL §
P.C. a/k/a PRONSKE, GOOLSBY §
&KATHMAN, P.C. §
§
Defendant/Counterclaim Plaintiff, § DALLAS COUNTY, TEXAS
§
v. §
JEFFREY BARRON’S SUPPLEMENTAL
ANSWER TO FIRST AMENDED COUNTERCLAIM
COMES NOW Jeffrey Baron (“Baron
"
)
,
Plaintiff and Counter-Defendant, and files this
Supplement to Answer to First Amended Counterclaim filed by Gerrit M. Pronske (“Pronske”) and
Pronske and Patel P.C. n/k/a Pronske, Goolsby & Kathman, P.C. (“PG&K”),
1
and would respectfully
show the Court as follows:
I. SUPPLEMENT TO AFFIRMATIVE DEFENSES
1.
Baron asserts payment. Tex. R. Civ. P. 94 and Tex. R. Civ. P. 95. Specifically, the terms
of the engagement of the PG&K firm were negotiated among PG&K, Baron and AsiaTrust Limited,
which at the time was acting as the trustee of The Village Trust (“AsiaTrust”).
2
Baron understood that
PG&K’s fee for such services rendered would be $75,000, and that no additional fees would be incurred
unless PG&K undertook additional matters for Baron, before which time a modified fee arrangement
1
This supplements the Answer filed by Plaintiff on or about June 5, 2014.
2
The Village Trust is a valid Spendthrift Trust organized under the laws of the Cook Islands in 2005, in which Jeffrey Baron
is a primary beneficiary.
FILED
DALLAS COUNTY
6/30/2014 10:09:59 PM
GARY FITZSIMMONS
DISTRICT CLERK
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would be negotiated among PG&K, AsiaTrust and Baron prior to Pronske or PG&K undertaking such
matters. The $75,000 was paid to PG&K by wire transfer.
WHEREFORE, PREMISES CONSIDERED, Baron respectfully requests
that
Pronske and
PG&K take nothing by reason of this suit; that all costs be adjudged against Pronske and PG&K;
that Baron’s Special Exceptions to Pronske and PG&K’s Amended Counterclaim be sustained and
that Pronske and PG&K be ordered to re-plead with particularity or that Pronske and PG&K’s
allegations, in their general scope, be
stricken. Baron requests such other and further relief, in law and
equity, general or special, to which Baron may be entitled.
Dated: June 30, 2014
Respectfully submitte
d
,
Pendergraft & Simon, LLP
/s/ Leonard H. Simon
Leonard H. Simon
Texas Bar No. 18387400
S.D.Tex. Adm. No. 8200
William P. Haddock
Texas Bar No. 00793875
S.D.Tex. Adm. No. 19637
Robert L. Pendergraft
Texas Bar No. 15743500
2777 Allen Parkway, Suite 800
Houston, Texas 77019
Tel. (713) 528-8555
Fax. (713) 868-1267
Counsel for Jeffrey Baron
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CERTIFICATE OF SERVICE
I hereby certify that on June 30, 2014, I electronically filed the foregoing with the Clerk of
the Court using the Court’s electronic filing system, which will send notification of such filing to all
counsel of record.
/s/ Leonard H. Simon
