NO.

141-214752-05

In Re: Order for Foreclosure § IN THE DISTRICT COURT

Concerning §
§
ABID H. SHEIKH AND SHAKEEM §
SHEIKH §
(Respondents) §
§
and §
§ 141ST JUDICIAL DISTRICT
205 Mill Crossing West §
Colleyville, Texas 76034 §
(Property Mailing Address) §
§
and §
§
WELLS FARGO BANK, N.A. §
(Applicant) § OF TARRANT COUNTY, TEXAS

RESPONDENTS' ORIGINAL ANSWER

NOW COME Respondents, Abid H. Sheikh and Shakeem A. Sheikh, named

Respondents in the above-entitled and numbered cause, and file this Original Answer, and show

the Court:

I.

GENERAL DENIAL

Respondents deny each and every allegation of Applicant’s Application to Foreclose, and

demand strict proof by a preponderance of the credible evidence thereof as required by the Texas

Rules of Civil Procedure.

II.

VERIFIED DENIALS

A. Conditions precedent to the filing of suit have not been satisfied as alleged.

Payments on this account have been made.

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Respondents’ Original Answer - Page 1 of 6
 III.

AFFIRMATIVE DEFENSES

A. Respondents claim Applicant’s suit is barred by estoppel.

B. Respondents claim Applicant’s suit is barred by mistake of fact.

C. Respondents claim Applicant’s suit is barred, in whole or in part, by its failure to

mitigate damages and offset the amount of payments made.

D. Respondents claim Applicant’s suit is barred by contract contingencies.

E. Respondents claim Applicant’s suit is barred by the release of Defendants by

Plaintiffs, and/or Plaintiff’s waiver.

IV.

ATTORNEY’S FEES

Respondents have retained the services of Larry E. Meadows, of Meadows & Associates,

L.L.P., to protect Defendants’ rights in this matter. Respondents have agreed to pay the

reasonable and necessary fees charged by said attorney. Respondents request that all fees

incurred as a result of this representation be paid by Plaintiffs and attached as costs or that

judgment be rendered against Plaintiffs and in favor of Respondents for attorney’s fees, if and

when Respondents are determined the prevailing party in this suit.

PRAYER

Respondents pray the Court, and after notice and hearing or trial, enters judgment in

favor of Respondents, awards Respondents the costs of court, attorney's fees, and such other and

further relief as Respondents may be entitled to in law or in equity.

Respectfully submitted,
_____________________________________________________________________________
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Respondents’ Original Answer - Page 2 of 6
 MEADOWS & ASSOCIATES, L.L.P.

By:
Larry E. Meadows
Texas Bar No. 24010835
Kelly C. Gent
Texas Bar No. 24038916
P.O. Box 77045
Fort Worth, Texas 76177
Tel. (817) 745-1550
Fax. (817) 745-1551
Attorneys for Respondents
Abid H. Sheikh and Shakeem A. Sheikh

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Respondents’ Original Answer - Page 3 of 6
 NO. 141-214752-05

In Re: Order for Foreclosure § IN THE DISTRICT COURT

Concerning §
§
ABID H. SHEIKH AND SHAKEEM §
SHEIKH §
(Respondents) §
§
and §
§ 141ST JUDICIAL DISTRICT
205 Mill Crossing West §
Colleyville, Texas 76034 §
(Property Mailing Address) §
§
and §
§
WELLS FARGO BANK, N.A. §
(Applicant) § OF TARRANT COUNTY, TEXAS

VERIFICATION

BEFORE ME, the undersigned authority, personally appeared Abid H. Sheikh, who

being duly sworn, deposed as follows:

"My name is Abid H. Sheikh. I am at least 18 years of age and of sound mind. I am

personally acquainted with the facts alleged in Respondents' Verified Denials. I hereby swear

that the statements in support of Respondents' Verified Denials are true and correct."

Abid H. Sheikh

SUBSCRIBED AND SWORN TO BEFORE ME on , by

.

Notary Public, State of Texas

_____________________________________________________________________________
_
Respondents’ Original Answer - Page 4 of 6
 NO. 141-214752-05

In Re: Order for Foreclosure § IN THE DISTRICT COURT

Concerning §
§
ABID H. SHEIKH AND SHAKEEM §
SHEIKH §
(Respondents) §
§
and §
§ 141ST JUDICIAL DISTRICT
205 Mill Crossing West §
Colleyville, Texas 76034 §
(Property Mailing Address) §
§
and §
§
WELLS FARGO BANK, N.A. §
(Applicant) § OF TARRANT COUNTY, TEXAS

VERIFICATION

BEFORE ME, the undersigned authority, personally appeared Shakeem A. Sheikh, who

being duly sworn, deposed as follows:

"My name is Shakeem A. Sheikh. I am at least 18 years of age and of sound mind. I am

personally acquainted with the facts alleged in Respondents' Verified Denials. I hereby swear

that the statements in support of Respondents ' Plea in Verified Denials are true and correct."

Shakeem A. Sheikh

SUBSCRIBED AND SWORN TO BEFORE ME on , by

.

Notary Public, State of Texas

CERTIFICATE OF SERVICE
_____________________________________________________________________________
_
Respondents’ Original Answer - Page 5 of 6
 I certify that on January 13, 2006, a true and correct copy of Respondents' Original
Answer was served by certified mail, return receipt requested on the following:

Bridget A. Braithwaite
Barrett, Burke, Willson, Castle, Daffin and Frappier, LLP
15000 Surveyor Blvd.
Suite 100
Addison, Texas 75001
972.341.0673 (Fax)

Larry E. Meadows

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Respondents’ Original Answer - Page 6 of 6