[Answer to Motion for Summary Judgement and Affidavit, American Express vs. LULAC - 1977-04-01] Page: 3 of 8
8 p. ; 36 cm.View a full description of this legal document.
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Texas corporation, which was named a Defendant in the litigation
was not served or otherwise properly made a party in said suit
for the> reason that the proper service on the said corporation
was never had. That Plaintiff failed to state the full amount
of his claim in his offered default judgment herein.
Defendant would also allege and show that a full' itemized
bill of Plaintiff's claimed debt should be made into the record
herein toward the end that proper agency and authorization be
shown by the Plaintiff for the incurring of the aforesaid debt
according to the Constitution and by-laws of the LEAGUE OF UNITED
LATIN AMERICAN CITIZENS.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plain-
tiff's Motion for Summary Judgment be in all things denied.
RESPECTFULLY SUBMITTED,
1r±u>l
J. HERRER|
Attorney for. D^efendant
7QJ'' Scanlan Building
Houston, Texas 77002
Phone: (713) 228-4341
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Herrera, John J. [Answer to Motion for Summary Judgement and Affidavit, American Express vs. LULAC - 1977-04-01], legal document, April 1, 1977; (https://texashistory.unt.edu/ark:/67531/metapth251531/m1/3/: accessed May 21, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu; crediting Hoston History Research Center at Houston Public Library.