JBs Second Supplemental Answer to First Amended Counterclaim

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No. DC-10-11915 
JEFF BARON, 
        Plaintiff, 
 
v. 
 
GERRIT M. PRONSKE, Individually, 
AND PRONSKE, GOOLSBY & 
KATHMAN, P.C. f/k/a PRONSKE & 
PATEL, P.C., 
        Defendants. 
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IN THE DISTRICT COURT 
 
 
 
OF DALLAS COUNTY, TEXAS    
 
 
 
193
RD
 JUDICIAL DISTRICT 
JEFFREY BARON’S SECOND SUPPLEMENTAL ANSWER TO FIRST AMENDED 
COUNTERCLAIM 
TO THE HONORABLE CARL GINSBERG: 
  COMES NOW Jeffrey Baron (“Baron
"
)
,
 Plaintiff and Counter-Defendant, and files this Sup-
plement  to  Ans wer  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 respect-
fully show the Court as follows: 
Supplement to Affirmative Defenses 
  Baron asserts the Counter-Plaintiff’s claims are barred by prior material breach of the un-
derlying contract, thus excusing Baron from performing the same. 
  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  sus-
                                                        
1
 This supplements the Answer filed by Plaintiff on or about June 5, 2014. 
FILED
DALLAS COUNTY
8/18/2014 10:42:51 PM
GARY FITZSIMMONS
DISTRICT CLERK

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tained  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 fur-
ther relief, in law and equity, general or special, to which Baron may be entitled.   
Respectfully Submitted, 
Pendergraft & Simon, LLP 
2777 Allen Parkway, Suite 800 
Houston, TX 77019 
Tel. (713) 528-8555 
Fax. (713) 868-1267 
/s/ William P. Haddock 
By: Leonard H. Simon 
Texas Bar No. 18387400 
lsimon@pendergraftsimon.com 
William P. Haddock 
Texas Bar No. 00793875 
whaddock@pendergraftsimon.com 
Counsel for Jeff Baron 
 
Certificate of Service 
I hereby certify that a true and correct copy of the above Jeffrey Baron’s Second Supplemental 
Answer to First Amended Counterclaim has been served on the following counsel/parties of rec-
ord in accordance with TEX. R. CIV. P. 21a and local rules for electronic filing and service on this 
18
th
 day of August 2014. 
Gerrit M. Pronske 
Jason P. Kathman 
Melanie P. Goolsby 
Pronske Goolsby & Kathman, PC 
2200 Ross Ave., Suite 5350 
Dallas, TX 75201 
Fax. 214-658-6509 
 
/s/ William P. Haddock 
William P. Haddock