Baron’s Supplemental Answer

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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