3/20/2020 3:49 PM

Marilyn Burgess - District Clerk Harris County

Envelope No. 41831142
By: Devanshi Patel
Filed: 3/20/2020 3:49 PM

No. 2020-11192

ROGER CONTRERAS, on behalf of himself § IN THE DISTRICT COURT OF

and all others similarly situated, §
§
Plaintiffs, §
v. § HARRIS COUNTY, TEXAS
§

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HOUSTON ASTROS, LLC and §
HOUSTON ASTROS MANAGEMENT, §

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INC., §

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§
Defendants. §

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§ 127th JUDICIAL DISTRICT

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DEFENDANTS’ ORIGINAL ANSWER

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Defendants Houston Astros, LLC and Houston Astros Management, Inc. (“Defendants”)

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file this Original Answer to Plaintiffs’ Original Class Action Petition (“Petition”) as follows:
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INTRODUCTION
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The “sign-stealing” controversy has been a source of great disappointment to Astros fans
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as well as to the Astros organization. On several occasions, members of the Astros organization –
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including individual players and its Owner, Jim Crane – have expressed their sincere apologies
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and remorse for the events described in the report by the Commissioner of Major League Baseball.
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There is, however, no legal standing for season ticket holders like the Plaintiff to recover damages
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for their disappointment over the Astros performance for any of the seasons that may have been
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implicated in the controversy. As many courts have held, a ticket holder has only the right to enter
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a venue and to have a seat for the ticketed game, and cannot complain afterwards that the game
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should have been played differently. The Plaintiff here does not allege that he was deprived of

those rights, and he was not. Therefore, Defendants deny that the Plaintiff is entitled to any relief

in a court of law.
 GENERAL DENIAL

1. Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Defendants deny each

and every allegation contained in the Petition and request that the Court require Plaintiff to prove

his allegations by a preponderance of the evidence as required by the Constitution and laws of the

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State of Texas.

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2. Defendants reserve the right to amend their answer to Plaintiff’s allegations, as is

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their right and privilege under the Texas Rules of Civil Procedure and the laws of the State of

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Texas.

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AFFIRMATIVE DEFENSES

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3. Plaintiff’s claims are barred, in whole or in part, because Plaintiff has failed to state

a claim upon which relief may be granted.

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4. Plaintiff’s claims are barred, in whole or in part, because of lack of standing.

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5. Plaintiff’s claims are barred, in whole or in part, due to the statute of limitations.
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PRAYER
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Defendants Houston Astros, LLC and Houston Astros Management, Inc. pray that this
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Court render judgment that Plaintiff take nothing in this suit and that Defendants be awarded their
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costs, and for such other and further relief, general or special, at law or in equity, to which they
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may be justly entitled.

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Dated: March 20, 2020 Respectfully submitted,

/s/ Reagan W. Simpson

Reagan W. Simpson
State Bar No. 18404700
Bryce L. Callahan
State Bar No. 24055248

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YETTER COLEMAN LLP

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811 Main Street, Suite 4100

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Houston, Texas 77002
(713) 632-8000

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(713) 632-8002

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rsimpson@yettercoleman.com
bcallahan@yettercoleman.com

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Attorneys for Defendants Houston Astros, LLC

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and Houston Astros Management, Inc.
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Certificate of Service
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I hereby certify that on this 20th day of March 2020 the foregoing was served by email
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and/or by electronic filing service on the following counsel of record:

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HILLIARD MARTINEZ GONZALES LLP

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Robert C. Hilliard
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bobh@hmglawfirm.com
Rudy Gonzales, Jr.
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rudy@hmglawfirm.com
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Catherine D. Tobin
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Catherine@hmglawfirm.com
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John B. Martinez
john@hmglawfirm.com
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Bradford P. Klager
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brad@hmglawfirm.com
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Marion Reilly
marion@hmglawfirm.com
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Jessica J. Pritchett
jpritchett@hmglawfirm.com
John C. Duff
jduff@hmglawfirm.com
Alex Hilliard
alex@hmglawfirm.com

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HILLIARD MARTINEZ GONZALES LLP
719 S. Shoreline Blvd.
Corpus Christi, Texas 78411
(361) 882-1612
(361) 882-3015 Fax
HMGService@hmglawfirm.com

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/s/ Bryce L. Callahan
Bryce L. Callahan

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