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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
