1. Hear Ye, Hear Ye - (defendant's rebuttal, followed by mine)

 Hear Ye, Hear Ye

The defendant's attorneys will now speak!
1
Defendant specially excepts to plaintiff's original petition because it does not state the residences of the plaintiffs, as required by rule 783 (a), Texas rules of civil procedure.
2
Defendant specially excepts to plaintiff's original petition because it does not state the undivided interest claimed by the plaintiffs, and the amount thereof as required by rule 783 (c) of the Texas rules of civil procedure.
3
Defendant specially excepts to the following allegations contained in the opening paragraph of plaintiff's original petition. The grounds of this exception are as follows: (a) Neither in such allegations nor elsewhere in plaintiffs original petition do plaintiffs state the names and residences of the other direct descendants of Manual Becerra as required by rule 783 (a) of the Texas rules of Civil Procedure; (b) Neither in such allegations nor elsewhere in plaintiffs original petition do plaintiffs state the undivided interest claimed in the premises by other descendants of Manuel Becerra and the amount thereof as required by rule 783 (c) of the Texas rules of Civil Procedure; (c) neither in such allegations nor elsewhere in plaintiffs original petition or any facts stated which showed that the named plaintiffs are entitled to represent other direct descendants of Manuel Becerra in this cause; (d) other direct descendants of Manuel Becerra have not properly been made parties to this cause.

My Rebuttal
1
Defendant specially excepts to plaintiff's original petition because it does not state the residences of the plaintiffs, as required by rule 783 (a), Texas rules of civil procedure.
Me:
Boring, just a technical maneuver. However, they're right, it was supposed to be included.
2
Defendant specially excepts to plaintiff's original petition because it does not state the undivided interest claimed by the plaintiffs, and the amount thereof as required by rule 783 (c) of the Texas rules of civil procedure.
Me:
Another technical maneuver. They're being technical, suggesting that the plaintiff's did not give a precise or exact definition of location of land grant as a collective whole. In other words, they didn't clearly state in plain english that they were acting in an undivided manner to claim this land grand. They want specifics...
3
Defendant specially excepts to the following allegations contained in the opening paragraph of plaintiff's original petition. The grounds of this exception are as follows: (a) Neither in such allegations nor elsewhere in plaintiffs original petition do plaintiffs state the names and residences of the other direct descendants of Manual Becerra as required by rule 783 (a) of the Texas rules of Civil Procedure; (b) Neither in such allegations nor elsewhere in plaintiffs original petition do plaintiffs state the undivided interest claimed in the premises by other descendants of Manuel Becerra and the amount thereof as required by rule 783 (c) of the Texas rules of Civil Procedure; (c) neither in such allegations nor elsewhere in plaintiffs original petition or any facts stated which showed that the named plaintiffs are entitled to represent other direct descendants of Manuel Becerra in this cause; (d) other direct descendants of Manuel Becerra have not properly been made parties to this cause.
Me:
(a) Boring, just a technical maneuver. However, they're right, it was supposed to be included. (b) Same as above, applied to the collective whole of all Becerra descendants. They're using the correct technical form and reminding the attorneys of that. Still boring. (c) Boring, they're looking for a statement that clearly states that Rubio, Martinez and de la Garza are representing the Becerra descendants. (d) Boring, they're looking for a statement that states the appropriate language that makes the Becerra descendants parties to the cause (lawsuit).




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