While a complaint need not contain detailed factual allegations, it must set forth more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do. Twombly, 550 U.S. at 555 (citation omitted). P. 12(f). 28. Trusts and the Lyda Hill Trusts, and to prevent dissipation, concealment, and further transfer of such assets, and preservation of all records relating to such trusts and actions affecting them. Finally, one place to get all the court documents we need. 999 at 12-13, 8.f.i and 8.f.ii; Doc. Plaintiffs take issue with Defendants' labelling Hill III as a vexatious litigant and accuse Defendants of seeking to avoid the Court's consideration of the specific claims in the Complaint. Id. Under Texas law, quasi-estoppel precludes a party from asserting, to another's disadvantage, a right inconsistent with a position previously taken. Sonnier v. State Farm Mutual Auto. Although Defendants do not specify, the court concludes this case primarily concerns injury in fact, the [f]irst and foremost of standing's three elements. He says he simply wants to know. Galatyn is a mid-ranked weapon for . . Here, as the Hill Jr. 18), filed March 3, 2021; Motion to Dismiss and Supporting Brief of Defendant Lyda Hill (Doc. Among other things, Hill III alleged wrongdoing in the management and administration of the MHTE and HHTE by their respective trustees and violations of the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C 1961, et seq. He was 72. In United States ex rel. Lyda Hill opposes Plaintiffs' Motion to Strike and, in her reply brief, she argues: Lyda Hill's Reply 2, Doc. 1990, no writ)). The case status is Pending - Other Pending. of Pardons & Parole, 114 Fed.Appx. 31; Lyda Hill's Reply 2-3, Doc. In this regard, a document that is part of the record but not referred to in a plaintiff's complaint and not attached to a motion to dismiss may not be considered by the court in ruling on a 12(b)(6) motion. illustration by Steve BrodnerTom Hunt sits at an executive desk downtown at Hunt Petroleum Corporation, on the 49th floor of Thanksgiving Tower, studying a thick stack of paper that has his lawyer worried. In the GSA, and as confirmed by the Final Judgment, Hill III covenanted not to reassert any released claims against Lyda Hill. It is well-established and clearly proper in deciding a 12(b)(6) motion [that a court may] take judicial notice of matters of public record. 2020 Action, Doc. personal injury; Boolean (richard or dick) and cheney . A claim meets the plausibility test when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. 1997) (en banc). The decision is available here. Contest Clause, and (3) violating the GSA and the Final Judgment by asserting claims concerning the Hill Jr. As the court has granted dismissal under Rule 12(b)(1), it need not consider the remaining arguments in support of the pending motions to dismiss. Here, the court intends to follow its legal standard and consider the Complaint, documents Plaintiffs attach to their Complaint, and documents that Defendants attach to their respective motions to dismiss if they are referred to in Plaintiffs' Complaint and are central to their claims. The doctrine of mootness is embedded in Article III's case or controversy requirement and requires that an actual, ongoing controversy exist at all stages of federal court proceedings. Dismissal for lack of subject matter jurisdiction or standing is usually without prejudice, while dismissal for failure to state a claim is with prejudice. 8 (214) 681-3171. ALBERT G. HILL, III and ERIN NANCE HILL, Plaintiffs, v. THE ESTATE OF ALBERT G. HILL JR.; MARGARET KELIHER; TYREE B. MILLER; LYDA HILL; HEATHER HILL WASHBURNE; ELISA HILL SUMMERS; CHESTER J. DONNALLY, JR.; THE ESTATE OF IVAN IRWIN JR.; CAROL E. ERWIN; and THOMAS P. TATHAM, Defendants. Kokkonen v. Guardian Life Ins. In December 2007, Hill III brought a lawsuit in Texas state court in his individual capacity and on behalf of the MHTE and HHTE against specific beneficiaries of the MHTE and HHTE, including his father (Hill Jr.), Hill Jr.'s siblings, and the trustees and members of the advisory boards of the MHTE and HHTE. For questions call 1-877-256-2472 or contact us at [emailprotected], By Thomas Ciarlone Jr. and Demetri Economou, By Grant Nakayama, Ilana Saltzbart, Amina S. Dammann, Arlene Hennessey, Ani M. Esenyan, Shearman and Hogan Lovells Call Off Merger Talks, Early Reports: 2023 Am Law 200 Financials, Beyond Excess Capacity, Pooled Services and Automation Expedite Staff Layoffs, Dozens of Law Firms Grew Their Equity Partner Tier, Even as Profits and Demand Plummeted. Lyda Hill's Motion to Dismiss Based on Judicial Estoppel. On December 28, 1935, H.L. Lyda Hill contends that Plaintiffs are judicially estopped from asserting that she, as the current beneficiary of the Lyda Hill trusts, lacks powers of appointment to do what she wishes with the Lyda Hill Trusts, including were she to choose to dissolve the trusts. Co. v. Dallas Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. See Pls.' Site Map, Advertise| Law.com Compass delivers you the full scope of information, from the rankings of the Am Law 200 and NLJ 500 to intricate details and comparisons of firms financials, staffing, clients, news and events. Rule 12(b)(6) - Failure to State a Claim. Plaintiffs contend that because Defendants' respective motions improperly make factual assertions that exist outside the pleadings and rely on matters outside the pleadings, the court must convert their motions to dismiss into motions for summary judgment. albert galatyn hill iii - sery-avocat.fr Your article was successfully shared with the contacts you provided. Hilllost his appeal in litigation with his sisters over a dispute about their fathers will. As part of the Final Judgment, the court, incorporating the No. In response to the pending motions to dismiss, Plaintiffs do not request to amend their pleadings in the event the court dismisses their claims pursuant to Rule 12(b)(1) for lack of subject matter jurisdiction or Rule 12(b)(6) for failure to state a claim. The court does not intend to consider any other matter arising out of the GSA, the Final Judgment, the MHTE, or the HHTE, except for what is pending in the 2020 Action. 26. denied); Royalco Oil & Gas Corp. v. Stockhome Trading Corp., 361 S.W.3d 725, 732 (Tex. Albert Galatyn Hill Jr - Add Relationship - LittleSis See generally Hill v. Schilling, 495 Fed.Appx. She Was Murdered On Her Way To College Fifty Eight Years In The Past Cops Lastly Know Her Killer He accuses them of placing Boo's life history on show for the edification of the neighborhood. Family. Co. v. Allied Pilots Ass'n, 262 S.W.3d 773, 778 (Tex. See 2020 Action, Doc. ' Funk v. Stryker Corp., 631 F.3d 777, 783 (5th Cir. Contest Clause from the GSA, ordered Hill III and Erin Hill (in all their capacities) and the Grandchildren not to contest Hill Jr.'s will or challenge the disposition of his property: Finally, consistent with the Settlement Agreement, Judge O'Connor retained continuing jurisdiction over the implementation and enforcement of the Final Judgment. See 2020 Action, Doc. 2001) (citation omitted). On December 22, 2017, Hill III entered the probate proceedings, challenging the terms of the will that appointed executors to [the Hill Jr. This case was filed in Dallas County Texas Courts, Dallas County Probate Court located in Dallas, Texas. Plaintiffs themselves state in their Response at heading F: The Parties Agreed that this Action Must be Brought in this Court. Pls.' Albert Galatyn Hill Jr Investments, A. G. Hill Partners; eldest grandson of H.L. Albert Galatyn Hill 1904-1988 - Ancestry add relationship edit flag. Thus, as Hill III released these claims, he lacks standing to raise them in this civil action. The industry-leading media platform offering competitive intelligence to prepare for today and anticipate opportunities for future success. Dallas Petroleum Club Will Move to Hunt Building in January 2023. 2000). 2012) (citation omitted). 31. Things got ugly and complicated as family conflicts are wont to do. and the court's rulings. 2003) (citation omitted). Relationships Interlocks Giving Data. Factual Background and Procedural History. On this record, the court agrees with Lyda Hill that the doctrine of judicial estoppel bars Hill III and Erin Hill from now taking the inconsistent position that Hill Jr. and Lyda Hill do not have a power of appointment, a sine qua non to Plaintiffs' claims challenging Lyda Hill's ability to dissolve her separate trusts, should she wish to do so. and over a hundred references to the Settlement Agreement and Final Judgment in the 2020 Action, which are central to this suit. Lyda Hill's Mot. It is time to move beyond partisanship and?build a stronger tomorrow." 2020 Action, Doc. In accordance with the GSA, the Final Judgment dismissed the released claims with prejudice. Which memorial do you think is a duplicate of Albert Hill (30891234)? Resp. Albert Galatyn Hill found inU.S., Social Security Applications and Claims Index, 1936-2007 Albert Galatyn Hill found inU.S., Find A Grave Index, 1600s-Current Albert Galatyn Hill found in1940 United States Federal Census Albert Galatyn Hill found in1920 United States Federal Census View more historical records forAlbert Galatyn Hill 2014), squabbling over the trusts was supposedly ended by a settlement agreement confected in 2010. In light of its rulings herein, the court need not address any other argument made by the parties. LexisNexis and Bloomberg Law are third party online distributors of the broad collection of current and archived versions of ALM's legal news publications. Thus, unlike a Rule 12(b)(6) motion to dismiss for failure to state a claim, the district court is entitled to consider disputed facts as well as undisputed facts in the record and make findings of fact related to the jurisdictional issue. As recognized by the Fifth Circuit in 2014, litigation involving the management and beneficiaries of the MHTE and HHTE has been protracted, complicated, and, most importantly, settled with a Global Settlement and Mutual Release Agreement (the settlement) implemented by a final judgment from the district court. Hill v. Schilling, 593 Fed.Appx. Den Norske Stats Oljeselskap As, 241 F.3d at 424. Compl., Doc. Although often treated as effectively jurisdictional, statutory standing relates to the merits of a cause of action and not subject matter jurisdiction. Id. The [f]actual allegations of [a complaint] must be enough to raise a right to relief above the speculative level . Trusts not in favor of Hill III. The plausibility standard is not akin to a probability requirement,' but it asks for more than a sheer possibility that a defendant has acted unlawfully. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal citations omitted). Steubner Realty 19, Ltd. v. Cravens Rd. App.-Houston [1st Dist.] Squabbling over the trust was supposed to be put to rest with a settlement agreement in 2010. Reply 7, Doc. 25, 2022). MISC. Trusts. Thus, if events after a case is filed resolve the parties' dispute, the case must be dismissed as moot because federal courts do not have the constitutional authority to decide moot cases. Contact Us| Learn more about merges . Law.com Compass includes access to our exclusive industry reports, combining the unmatched expertise of our analyst team with ALMs deep bench of proprietary information to provide insights that cant be found anywhere else. B. Our Team Account subscription service is for legal teams of four or more attorneys. Dismiss 15, Doc. Trinity LLC is the general. Plaintiffs' claims will be dismissed with prejudice. 1876. 2015), the Fifth Circuit stated, [W]e have not hesitated to apply judicial estoppel to dismiss claims under Rules 12(b)(6) or 12(c) while affirming dismissal of claims based on judicial estoppel. . A string of three losses over the past three months have ended with orders for litigious Texas oil and gas heir Albert G. Hill III to pay attorney fees to winning defendantsat whom he lobbed lawsuits. For these reasons, the court denies Plaintiffs' Motion to Strike. 1-2 at 10 Art. R2 Invs. 999-1 at 7-8. Inc., 342 F.3d 563, 566 (5th Cir. A primary focus of the lawsuit was Hill III's claim to be a current beneficiary of the MHTE pursuant to Hill Jr.'s 2005 Disclaimer. 999 39, 36. albert galatyn hill iii - dev.decourbaine.com IV 3 (MHTE); Exhibit C to Pls.' PR-08-830-2 (the HHTE Probate Suit), that in his Will, Hassie Hunt exercised his general power of appointment under the HHTE to an on behalf of the lineal descendants of [his] sister, Margaret Hunt Hill, per stirpes. Lyda Hill's App., Doc. Access to additional free ALM publications, 1 free article* across the ALM subscription network every 30 days, Exclusive discounts on ALM events and publications. Sam A. Lindsay, United States District Judge. Hill III appealed the Final Judgment challenging, among other things, the addition of provisions that were not part of the GSA. 2005) (citations omitted). Stated another way, when a court deals with a Rule 12(b)(6) motion, its task is to test the sufficiency of the allegations contained in the pleadings to determine whether they are adequate enough to state a claim upon which relief can be granted. Not a Bloomberg Law Subscriber?Subscribe Now. 2010) (citation omitted); see also Ulico Cas. Plaintiff opposes the grant of a motion to stay because it is not warranted under existing legal standards and is being sought here for reasons inconsistent . The CEO of Hunt Investment Holdings on his under-the-radar favorite restaurant and why he is learning Turkish. 1996). Transfer From: Transfer In: Transfer Case: Transfer To: Transfer Out: Pub Service: West Publishing . In his Will, Hill Jr. exercised his Powers of Appointment over his equitable interests in the Hill Jr. Left Nothing by Tycoon Father, Albert Hill is Now on the Hook for Hefty 2004). Updated: June 20, 2015 Albert Galatyn Hill JrAlbert Hill(born 1945) Jump to: BiographyFamily Photos Date Event Type Description Document; 03/21/2017: Reply brief filed: State [ PDF/68 KB ] State Reply Brief [ PDF/85 KB ] Notice: 02/15/2017: By Posted does sonny's bbq serve alcohol In rule breaker snacks net worth PR-17-04117-2, Probate Court No. Clark v. Tarrant Cnty., 798 F.2d 736, 741 (5th Cir. 2, Dallas County, Texas (the "Estate Action"), seeking to admit the Will to probate, and to appoint an independent executor. Trusts under the Waiver of Standing clause. Plaintiffs further argue that both Motions are replete with the sort of name calling and character assassination that should be excluded from pleadings. Id. Back on November 8, 2007, Albert G. Hill III sued his father, his sisters, his aunts, and Tom Hunt over the management of Hunt Petroleum and the familys trusts. District courts should freely give leave [to amend] when justice so requires, Fed.R.Civ.P. While well-pleaded facts of a complaint are to be accepted as true, legal conclusions are not entitled to the assumption of truth. Iqbal, 556 U.S. at 679 (citation omitted). IV 3 (HHTE). On CandysDirt, I told you about Al and Erin Hill, that's Al Three, who recently moved their family to Atlanta. 2001). Defendants contend that Plaintiffs lack standing to challenge the dissolution of the Hill Jr. As previously explained, Hill III contractually agreed in the GSA, which was incorporated into the Final Judgment, that Hill Jr.'s Disclaimer was valid and enforceable. Separately, the court concludes that Hill III lacks standing to assert any claims against Lyda Hill related to the HHTE because he released these claims in open court as part of the settlement. She had six siblings Caroline Rose Hunt (born 1923), H. L. Hunt III ( EVENT; Comment: REQUEST FOR LETTERS, DocketINVENTORY AND APPRAISEMENT REMINDER, DocketNOTICE - APPEARANCE; Comment: NOTICE OF APPEARANCE OF COUNSEL FOR ALBERT G. HILL, III, DocketMOTION - WITHDRAW ATTORNEY; Comment: MOTION TO WITHDRAW AS COUNSEL, DocketPOSTED NOTICE; Served: 12/11/2017; Anticipated Server: CONSTABLE 1; Anticipated Method: CONSTABLE; Actual Server: CONSTABLE 1; Returned: 12/12/2017; Comment: RTN: 12/12/17, DocketWILL; Comment: ORIGINAL WILL DATED: 12-20-14 DOD: 12-2-17 AGE: 72, DocketISSUE POSTED NOTICES; Comment: COURT RTN: 12/25/2017, FinancialFinancial info for MILLER, TYREE B. : CREDIT CARD - TEXFILE (CC); Receipt # PR-2017-23318; MILLER, TYREE B. 879 at 39-40; Doc. ' Id. They bought a $9 million dollar estate in swanky Buckhead (think Highland Park on Strait Lane in Dallas), closed on it in July. Lyda Hill makes similar arguments pertaining to the Lyda Hill trusts. Foman v. Davis, 371 U.S. 178, 182 (1962); Norman v. Apache Corp., 19 F.3d 1017, 1021 (5th Cir. 2007); Martin K. Eby Constr. Carr v. Saucier, 582 F.2d 14, 15 (5th Cir. when a narcissist wants you back albert galatyn hill iii. All Rights Reserved. Margaret Hunt Hill Wikipedia Republished // WIKI 2 999 at 8-9, 8.a and at 20-22, 9.a. is candy a common or proper noun; Tags . Galatyn is a great sword that provides 85 damage and 494 delay. 1998) (citing Veldhoen v. United States Coast Guard, 35 F.3d 222, 225 (5th Cir. Growing Mineola firm with national practice seeks associate (with 3-6 years experience) to handle complex general liability matters.Competit CASH KRUGLER & FREDERICKS LLC is Celebrating Our 20th Anniversary & Newest Partners! The Hill Jr. In her reply brief, Lyda Hill asserts that, in ruling on her motion to dismiss, the court is entitled to consider its own prior rulings on Plaintiffs' numerous baseless post-judgment filings. Lyda Hill's Reply 2 note 1, Doc. Resp. See Fed. The court stated in a memorandum opinion and order issued on December 10, 2018: 2. Consistent with the GSA, the Final Judgment declared Hill Jr.'s 2005 Disclaimer valid and partitioned portions of the MHTE and the HHTE, as to which Hill Jr. did not disclaim any of his equitable interests, into the Hill Jr. See 2020 Action, Doc. ' Funk, 631 F.3d at 783 (quoting Norris, 500 F.3d at 461 n.9) (citation omitted); see also Cinel, 15 F.3d at 1341, 1343 n.6 (court may consider matters of public record, including a consent judgment, in deciding a Rule 12(b)(6) motion). Otherwise stated, in the HHTE Probate Suit, in 2008, Hill III acknowledged that the trust instrument for the HHTE, which is the same as the trust instrument for the MHTE, provided the beneficiary (Hassie) with powers of appointment. App.-Houston [14th Dist.] Legalweek New York explores Business and Regulatory Trends, Technology and Talent drivers impacting law firms. We know that Albert Galatyn Hill Jr had been residing in Dallas County, Texas. Hill III sought an injunction to preserve the assets of the Hill Jr. Defendants correctly note, the filings at issue are motions, not pleadings. Fifth Circuit Tells Albert G. Hill III to Stop Challenging His Fathers Will. After the Probate Court had conducted hearings on those motions, Hill III nonsuited his claims without prejudice. III 3 (MHTE); Exhibit C to Pls.' Albert G. Hill III . Two of Dallas County, Texas in Estate of Albert Galatyn Hill, Jr., Deceased, PR-17-04117-2; and (3) appealing the October 11, 2018 Order Admitting Will to Probate and Authorizing Letters Testamentary issued by Judge Ingrid M. Warren in Probate Court No. 1. Although the court lacks subject matter jurisdiction over Plaintiffs' claims and dismissals for lack of jurisdiction are ordinarily without prejudice, and in light of this court's ruling, there is no court, state or federal, that has jurisdiction to hear Plaintiffs' claims. Id. In addition to parsing through the terms of the trusts, the court is required, yet again, to revisit the Global Settlement and Mutual Release Agreement (the GSA) and the final judgment (the Final Judgment) issued on November 8, 2010, by the Honorable Reed O'Connor (Judge O'Connor) of the United States District Court for the Northern District of Texas (Dallas Division) in the lawsuit styled Hill v. Hunt et al., Civil Action No. 28 U.S.C. The court is also seriously considering imposing sanctions on Hill III's attorneys pursuant to 28 U.S.C. An alert FrontBurnian gave me a heads up that the Fifth Circuit Court of Appeals issued a decision on Tuesday that looks like it might put a period at the end of that saga. The appellate court upheld the terms of the lower courts order prohibiting Hill III from contesting Hill Jr.s will in any matter, in any court, in any future world. Pursuant to Federal Rule of Civil Procedure 12(f), Plaintiffs move to strike the pending motions to dismiss. Based on the foregoing, the court grants Defendants' Motion to Dismiss Pursuant to Federal Rule of Civil Procedure 12(b) (Doc. and Mot. 999 at 22-23. 28. Before turning to the pending motions to dismiss, the court must address Plaintiffs' Motion to Strike and their associated request that the court convert the pending motions to dismiss into motions for summary judgment. 30305 (404) 351-9788. (citations omitted). Back on November 8, 2007, Albert G. Hill III sued his father, his sisters, his aunts, and Tom Hunt over the management of Hunt Petroleum and the family's trusts. In 2008, the family sold Margaret Hunt Hill's company, Hunt Petroleum, to XTO Energy for $4.2 billion. 1331, 1332. MOTION - EXCLUDE; Comment: APPLICANT'S MOTION TO EXCLUDE TRIAL EXHIBITS OF ALBERT G. HILL, III, ORDER - MISCELLANEOUS; Comment: GRANTING APPLICATION FOR ENLARGEMENT OF POWERS OF TEMPORARY ADMINISTRATOR RELATING TO THE 1298 LAWSUIT, OBJECTION; Comment: APPLICANT'S OBJECTION TO ALBERT G. HILL. There are instances, however, when a dismissal for lack of standing may be with prejudice. In determining whether to allow an amendment of the pleadings, a court considers the following: undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of amendment. Foman, 371 U.S. at 182; Schiller v. Physicians Res. If you do not agree with these terms, then do not use our website and/or services. Masgas v. Anderson, 310 S.W.3d 567, 571 (Tex. As recently summarized by the Fifth Circuit: The Fifth Circuit also recognized in Hill v. Washburne, After protracted [and] complicated' litigation, Hill v. Schilling, 593 Fed.Appx. Albert G Hill, III, individually, and as a Beneficiary of the Margaret Hunt Trust Estate, derivatively on behalf of the Margaret Hunt Trust Estate, individually, As a beneficiary of the Haroldson Lafayette Hunt Jr. Trust Estate, and derivately on Behalf of the Haroldson, Plaintiff, represented by Emil Lippe, Jr. , Law Offices of Lippe & Associates & Diana . On 12/07/2017 ESTATE OF ALBERT GALATYN HILL, Jr was filed as a Probate - Other Probate lawsuit. Often described as "America's Swiss Founding Father ", [3] [4] he was a leading figure in the early years of the United States, helping shape the new republic's financial system and foreign policy. Trusts and, for Hill III's benefit, his one-third interest in the Disclaimed Beneficial Interests, because of the 2005 Disclaimer, were partitioned into the Hill III Trusts. The provision of Rule 15(a)(2) of the Federal Rules of Civil Procedure that states [t]he court should freely give leave when justice so requires is not without limitation. The doctrine limits the category of litigants empowered to maintain a lawsuit in federal court to seek redress for a legal wrong. Id. The doctrine applies when it would be unconscionable to allow a person to maintain a position inconsistent with one to which he acquiesced, or from which he accepted a benefit. Hartford Fire Ins. Dismissal Based on Quasi-Estoppel (or Estoppel by Contract). 2020 Action, Doc. Sepulvado v. Louisiana Bd. Margaret Hunt Hill (19152007) was an American heiress and philanthropist. albert galatyn hill iii - simssuccessgroup.com 2020-01-27, Dallas County District Courts | Other | Samuel Gamble Bayne III. Margaret Hunt Hill - Alchetron, The Free Social Encyclopedia Article III, Section 3 of the 1935 Trust Instruments, however, provides a current MHTE and HHTE beneficiary with powers of appointment, as follows: Exhibit B to Pls.' Compl., Doc. Defendants, in their reply, maintain the court should deny Plaintiffs' Rule 12(f) motion to strike for the following three reasons: (i) the filing at issue is a motion, not a pleading; (ii) the Motion relates to the controversy before the Court as it specifically addresses Plaintiffs' claims; and (iii) Plaintiffs fail to note any specific language in the Motion they contend satisfies Rule 12(f)'s high standard to strike. Hill Jr. Public Records Policy. Having considered the motions, responses, replies, pleadings, record, and applicable law, the court grants Defendants' Motion to Dismiss Pursuant to Federal Rule of Civil Procedure 12(b) (Doc. On 01/25/2022 Albert Hill, III filed an Other lawsuit against Commissioner of Internal Revenue. Although Rule 12(f) authorizes the court to strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter, Rule 7(a) identifies the pleadings subject to being stricken under Rule 12(f): (1) a complaint; (2) an answer to a complaint; (3) an answer to a counterclaim designated as a counterclaim; (4) an answer to a crossclaim; (5) a third-party complaint; (6) an answer to a third-party complaint; and (7) if the court orders one, a reply to an answer. Id.