The Dansby Tract Partition Suit
Answer deadline
Monday, August 31, 2026 — 10:00 a.m. Central
The matter, in plain terms
Bernard Black says he owns a small share of family land in Gregg County, and he is asking the court to divide it or sell it. He claims one sixteenth. He says everyone else named in the suit — which includes the four of us — holds the other fifteen sixteenths together.
We were each served individually, so each of us is separately a defendant. A defendant who does not file a written answer by the deadline can have a default judgment entered against them, meaning decisions get made about their share without them present.
Filing an answer prevents that. It is not an agreement to anything. It is an appearance.
Documents
Your Answer is ready. Download it, fill in the four blanks — signature, date, telephone, email — and file the PDF. Word is easier to complete on a computer; the PDF is there if you would rather print and sign by hand.
Who files what
Each defendant answers for themselves. One of us cannot answer for the others — that is the one rule here with no workaround.
Tizoc Strong
Named at paragraph 20
Answer drafted- Served Aug 7, 2026, 1:15 p.m.
- Deadline confirmed: Mon Aug 31, 10:00 a.m.
- Original Answer prepared
- Sign, date, add telephone and email
- File through eFileTexas
Eric J. Strong
Named at paragraph 19 · “Jerbran”
Confirm service date- Original Answer prepared
- Certificate of service completed
- Check your own citation for your service date
- Sign, date, add telephone and email
- File through eFileTexas
Destiny Townley
Named at paragraph 22 as “Destine Townley”
Confirm service date- Original Answer prepared
- Check your own citation for your service date
- Sign, date, add telephone and email
- Send Tizoc your email address
- File through eFileTexas
Tamitra Taylor
Named at paragraph 21
Address needed- Original Answer prepared
- Check your own citation for your service date
- Add your mailing address — the petition lists it as unknown
- Sign, date, add telephone and email
- File through eFileTexas
Each defendant's deadline runs from their own date of service, not Tizoc's. His citation shows August 7 at 1:15 p.m., which produces the Monday, August 31 deadline. Check the handwritten date on the officer's return on your own citation. If yours differs, your deadline differs.
How to file
Attorneys are required to e-file in Texas. Self-represented parties are permitted to, and with the deadline this close it is the only route that reliably arrives in time.
- Go to
efiletexas.govand create a free account. Register as a self-represented filer, not as an attorney. - Choose File Into Existing Case. Location: Gregg County — District Clerk. Search case number
2025-2095-A. - Leave the filing-attorney field blank.
- Filing code: Answer — it may appear as “Original Answer” or “Answer — General Denial.”
- Description: Defendant [Your Name]'s Original Answer.
- Upload your signed Answer as a PDF. A typed
/s/ Your Nameis a valid signature in Texas. - Under eService, add plaintiff's counsel and the other counsel of record. That satisfies the certificate of service at the end of your Answer.
- Submit, then keep all three emails: submission receipt, acceptance, and the file-marked copy. If the clerk returns it for correction, correct and resubmit immediately.
File Saturday, not Monday morning. The clerk's office opens at 8:00 a.m. and the deadline is 10:00. A filing returned for correction leaves no room in that window. There is normally no fee for a defendant's original answer; the clerk can confirm.
Status
- August 5, 2026
Third Amended Petition filed
Black files to partition the property, pleading it as heirs' property under Chapter 23A.
- August 7, 2026
Tizoc served
Citation delivered in person in Amarillo at 1:15 p.m., starting the twenty-day period.
- August 28, 2026
First attorney contacted
Kristen Reid LaFreniere, Vander-Plas LaFreniere, Lubbock. No concrete direction yet; a detailed follow-up with the full case file has been sent.
- August 28, 2026
District Clerk contacted
Asked the clerk's office to confirm the filing method for pro se answers and the deadline of record.
- August 28, 2026
Four Answers prepared
Individual Original Answers for all four defendants, certificates of service completed. Each requires a signature, date, telephone and email.
- By Monday, August 31, 10:00 a.m.
File the Answers
Four separate filings through eFileTexas. This is the step that protects everyone.
- Approximately 30 days after filing
Initial disclosures due
Flagged on the citation under Rule 194. The next calendar item once the Answers are in.
- Ongoing
Retain counsel
Filing now does not foreclose this. An attorney retained later may amend freely.
Our position
The Answer is a general denial — the standard defensive opening in Texas, and deliberately narrow.
- We are appearing in the case, so no default judgment can be taken against any of us.
- We deny the allegations and demand strict proof. Under Rule 92 we need not argue why the claimed split is wrong — we decline to admit it and put Black to his proof.
- We preserve the mineral question. The Answer states that filing waives no mineral, oil, gas, royalty, surface or leasehold interest, and asks that those be identified before any disposition.
- We hold Black to Chapter 23A. He pleaded heirs' property himself; we ask the court to apply it — the appraisal, the cotenant buyout right, and the preference for partition in kind over a forced sale.
- We do not agree to any ownership percentage, concede a sale, accept a buyout, or sign anything — not until we understand what came down through Dad's side and whether minerals attach to this land.
What Plaintiff claims
| Interest | Share | Value pleaded |
|---|---|---|
| Bernard Black | 1/16 undivided | $62,500 |
| All defendants together | 15/16 undivided | $937,500 |
| Property total | — | $1,000,000 |
The land is pleaded as Tracts I through XXV in Gregg County, across the W. P. Chisum, Solomon Slaughter and A. M. Coleman surveys. The metes-and-bounds tracts run 82.67, 30, 14, 58.35, 7, 2, 65 and 6 acres, followed by a list of Gregg County Appraisal District property IDs that may duplicate those same tracts. Paragraph 42 asserts there are no liens of record and that no one outside this suit holds an interest — another matter we have not admitted.
Counsel and the court
Court — where filings go
Gregg County District Clerk
Trey Hattaway, District Clerk101 E. Methvin St., Suite 334
Longview, TX 75601
Mail: P.O. Box 711, Longview, TX 75606
(903) 237-2663 · fax (903) 807-0394
THattaway@greggcounty.texas.gov
Mon–Fri, 8–12 and 1–5
Counsel for Plaintiff
Dakota J. Wrinkle
Texas Landowner Law Firm, PLLCState Bar No. 24118592
1910 Pacific Ave., Suite 8005
Dallas, TX 75201
(469) 833-3380
dakota@texaslandownerfirm.com
Counsel for Defendant Karen Bey
John R. Jarvis
State Bar No. 00798280326 S. Fannin
Tyler, TX 75702
(903) 592-6576
john@jarvis.biz
Attorney approached
Kristen Reid LaFreniere
Vander-Plas LaFreniere, PLLCLubbock, TX
(806) 786-9022
Contacted — awaiting a concrete response.
Next: East Texas counsel handling heirs' property and mineral partition.
Outstanding
- Each defendant confirms their own date of service from their own citation.
- Destiny and Tamitra send Tizoc their email addresses for copying on court correspondence.
- Tamitra supplies a mailing address for her Answer.
- Confirm with the clerk whether any fee applies to an answer.
- Response from Kristen LaFreniere; if none, proceed to the next attorney.
- Calendar initial disclosures for approximately thirty days after filing.
Last updated August 28, 2026. This is a family reference, not legal advice — none of us is an attorney. The Answers are documents we are filing on our own behalf; read yours before signing it. The password on this page deters a casual visitor and nothing more, so treat the link itself as the thing worth guarding.