Courts have held that responses by a party that contain some, but not all, of the elements outlined in Lippmann qualify as an answer. See, e.g. , Guadalupe Econ. Servs. Corp. v. Dehoyos , 183 S.W.3d 712, 717 (Tex. App.—Austin 2005, no pet.) (holding that letter failing to state the cause number and the additional defendants nonetheless provided sufficient information about the case to allow the district clerk's office to identify and file it correctly, and therefore constituted an answer sufficient to entitle party to notice of proceedings); Harris v. Harris , 850 S.W.2d 241, 242–43 (Tex. App.—Houston [1st Dist.] 1993, no writ) (letter constituted answer when address was not contained in the body of the letter but was on the accompanying envelope); Beard v. Uriostegui , 426 S.W.3d 178, 182 (Tex. App.—Houston [1st Dist.] 2012, no pet.) (citing Harris and holding same). In Gales v. Denis , the appellant acknowledged service of the lawsuit, correctly named most of the other defendants and one of the plaintiffs, denied the allegations against him, signed it and had it notarized. 260 S.W.3d 22, 30 (Tex. App.—Houston [1st Dist.] 2008, no pet.).
In addition, following Lippmann, this Court held that a pro se letter was an answer when the defendant's address was only included on the envelope the letter was mailed in and it was unclear whether the case number identification was written by the defendant or by a district clerk's office employee. Harris v. Harris, 850 S.W.2d 241, 242-43 (Tex.App.-Houston [1st Dist.] 1993, no writ); see also N803RA 11 S.W.3d at 366 (likewise following Lippmann in context of waiver of special appearance). Subsequently, the Third Court of Appeals pointed out in Guadalupe Economic Services:
Id. at 182 (quoting Harris v. Harris, 850 S.W.2d 241, 243 (Tex. App.- Houston [1st Dist.] 1993, no writ)).
This Court has clarified that if the Lippmann criteria are otherwise met, the defendant's current address need not be set forth in the body of the defendant's letter; it is enough if, as in this case, “the envelope [bearing a return address] accompanies the letter and is filed by the clerk.” Harris v. Harris, 850 S.W.2d 241, 242–43 (Tex.App.-Houston [1st Dist.] 1993, no pet.). Beard sent a signed letter to the trial court identifying the parties, the case number, the style of the case, and the issues in the case.
on." Lippman, 826 S.W.2d at 138; see Gales v. Denis, 260 S.W.3d 22, 30 (Tex.App.-Houston [1st Dist.] 2008, no pet.) (pro se letter filed with trial court and signed by defendant was an answer even though it did not contain address or telephone number because it acknowledged service, contained the cause number, correctly named most of the defendants and one of the plaintiffs, denied the accusations against him, and did not express any objections to jurisdiction); Guadalupe Econ. Services Corp. v. Dehoyos, 183 S.W.3d 712, 716 (Tex.App.-Austin 2005, no pet.) (pro se letter acknowledging receipt and acceptance of citation and petition and denying plaintiff's allegations was answer even though it failed to state cause number and additional defendants); Terehkov v. Cruz, 648 S.W.2d 441, 443 (Tex.App.-San Antonio 1983, no writ) (pro se answer was sufficient even though it contained only the defendant's signature, address, and assertion that it was not liable for plaintiff's claims); see also Harris v. Harris, 850 S.W.2d 241, 242-43 (Tex.App.-Houston [1st Dist.] 1993, no writ) (pro se letter was answer when defendant's address was included only on envelope letter was mailed in and it was unclear whether case number identification was written by defendant or by clerk's office employee). Citing N803RA, however, Green argues that his letter should not be construed to waive his special appearance.
Although GES's letter failed to state the cause number and the additional defendants, the information it provided about the case was sufficient to allow the district clerk's office to identify it and file it correctly. See Harris v. Harris, 850 S.W.2d 241, 242-43 (Tex.App.-Houston [1st Dist] 1993, no writ) (information in pro se letter sufficient to identify case number constituted answer). We conclude that the letter constituted an answer sufficient to entitle GES to notice of proceedings in this case.
But a letter from a pro se party to the trial court clerk stating that he does not want a divorce qualifies as an answer. See Harris v. Harris, 850 S.W.2d 241, 242-43 (Tex.App.-Houston [1st Dist.] 1993, no writ). Therefore, the trial court had acquired personal jurisdiction over Juan, and the divorce decree is not void.