DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 1 of 10

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS 

SHERMAN DIVISION

KATHRYN SNEED and SNEED, §

EQUESTRIAN ESTATES, LLC, §

§ 

 Plaintiffs, §

§

v. § CIVIL ACTION NO. 4:23-cv-00871-ALM

§

JEFFREY GIBBS, CALLI ROUSE, §

GIBBS SHOW HORSES, CALLI ROUSE §

SHOW HORSES, BLACK BIRD RANCH, §

THE BONAPARTE FAMILY LIVING §

TRUST, FRANK BONAPARTE, §

PATRICIA BONAPARTE, JUSTIN §

SCHMIDT, and JEANNIE SCHMIDT, §

 §

 Defendants. §

DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER

Defendant, The Bonaparte Family Living Trust (“Defendant”), files this Original Answer 

to Plaintiffs’, Kathryn Sneed and Sneed Equestrian Estates, LLC (collectively “Plaintiffs”), 

Original Complaint (“Complaint”).

A. 

ADMISSIONS & DENIALS

I. NATURE OF THE CASE

1. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 1 of Plaintiffs’ Complaint.

2. Defendant admits that Plaintiffs filed their Complaint seeking damages in 

connection with their five horses, but denies the remaining allegations in paragraph 2 of Plaintiffs’ 

Complaint. 
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 2 of 10

3. Defendant admits that Plaintiffs’ horses were periodically stabled on the 

Defendant’s property from December 15, 2022 through August 2023, and that Plaintiffs’ horse, 

Ava, was euthanized. Otherwise, Defendant denies the remaining allegations asserted in paragraph 

3 of Plaintiffs’ Complaint. 

II. JURISDICTION & VENUE

4. Defendant admits the allegations asserted in paragraph 4 of Plaintiffs’ Complaint. 

5. Defendant admits the allegations asserted in paragraph 5 of Plaintiffs’ Complaint. 

III. PARTIES

6. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 6 of Plaintiffs’ Complaint.

7. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 7 of Plaintiffs’ Complaint.

8. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 8 of Plaintiffs’ Complaint.

9. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 9 of Plaintiffs’ Complaint.

10. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 10 of Plaintiffs’ Complaint.

11. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 11 of Plaintiffs’ Complaint.

12. Defendant admits that Black Bird Ranch is an equestrian facility that is operated by 

Defendant’s trustees under a fictitious and/or assumed name in Denton County, Texas, as alleged 

in paragraph 12 of Plaintiffs’ Complaint. Plaintiffs sued Black Bird Ranch in the wrong capacity 
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 3 of 10

because Black Bird Ranch does not have the capacity to be sued as Black Bird Ranch is not an 

individual or an entity incorporated under the laws of any jurisdiction in the United States of 

America.

13. Plaintiffs sued Defendant in the wrong capacity because Defendant does not have 

the capacity to sue or be sued under Texas law. As such, Defendant denies the allegations in 

paragraph 13 of Plaintiffs’ Complaint.

14. Defendant admits the allegations asserted in paragraph 14 of Plaintiffs’ Complaint.

15. Defendant admits the allegations asserted in paragraph 15 of Plaintiffs’ Complaint.

16. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 16 of Plaintiffs’ Complaint.

17. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 17 of Plaintiffs’ Complaint.

IV. FACTS

18. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 18 of Plaintiffs’ Complaint.

19. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 19 of Plaintiffs’ Complaint.

20. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 20 of Plaintiffs’ Complaint.

21. To the extent that paragraph 21 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 21 of Plaintiffs’ Complaint. 
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 4 of 10

22. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 22 of Plaintiffs’ Complaint.

23. Defendant admits that Defendants Jeffrey Gibbs and Calli Rouse (collectively 

“Gibbs Defendants”) twenty-two (22) horses to the facility, named the Black Bird Ranch 

(“Ranch”), on December 15, 2022. Defendant also admits that it owns the Ranch, and that Frank 

Bonaparte and Patricia Bonaparte are co-trustees, settlors, and beneficiaries of the Trust. 

Otherwise, Defendant denies the remaining allegations in paragraph 23 of Plaintiffs’ Complaint.

24. To the extent that paragraph 24 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 24 of Plaintiffs’ Complaint.

25. Defendant denies the allegations in paragraph 25 of Plaintiffs’ Complaint.

26. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 26 of Plaintiffs’ Complaint.

27. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 27 of Plaintiffs’ Complaint.

28. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 28 of Plaintiffs’ Complaint.

29. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 29 of Plaintiffs’ Complaint.

30. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 30 of Plaintiffs’ Complaint.
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 5 of 10

31. Defendant admits that text message correspondences were exchanged by and 

between Darrell Sneed and Frank Bonaparte regarding photographs and videos of Ava and Ava’s 

stall, but otherwise denies the remaining allegations asserted in paragraph 31 of Plaintiffs’ 

Complaint.

32. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 32 of Plaintiffs’ Complaint.

33. Defendant denies the allegations asserted in paragraph 33 of Plaintiffs’ Complaint. 

34. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 34 of Plaintiffs’ Complaint.

35. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 35 of Plaintiffs’ Complaint.

36. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 36 of Plaintiffs’ Complaint.

37. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 37 of Plaintiffs’ Complaint.

38. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 38 of Plaintiffs’ Complaint.

39. Defendant admits that, on and after December 15, 2022, the Gibbs Defendants 

stabled twenty-two (22) horses at the facility located on the Trust’s property, and that the twentytwo (22) horses were in the Gibbs Defendants’ care and training. Otherwise, Defendant denies the 

remaining allegations in paragraph 39 of Plaintiffs’ Complaint. 
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 6 of 10

V. CAUSES OF ACTION

Count 1: Breach of Contract (against Jeffrey Gibbs, Calli Rouse, Gibbs Show Horses, and 

Calli Rouse Show Horses)

40. In response to Plaintiffs’ preemptory paragraph under Count 1, Defendant realleges and incorporates by reference all answers and Affirmative Defenses to all prior allegations 

in Plaintiffs’ Complaint as though specifically set forth herein.

41. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 41 of Plaintiffs’ Complaint.

42. Defendant lacks sufficient knowledge or information to form a belief about the truth 

of paragraph 42 of Plaintiffs’ Complaint.

43. Defendant denies the allegations asserted in paragraph 43 of Plaintiffs’ Complaint.

Count 2: Negligence: Injury to Sneed’s Horses (against all Defendants)

44. In response to Plaintiffs’ preemptory paragraph under Count 2, Defendant realleges and incorporates by reference all answers and Affirmative Defenses to all prior allegations 

in Plaintiffs’ Complaint as though specifically set forth herein.

45. To the extent that paragraph 45 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 45 of Plaintiffs’ Complaint. 

46. To the extent that paragraph 46 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 46 of Plaintiffs’ Complaint.

47. To the extent that paragraph 47 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 48 of Plaintiffs’ Complaint. 
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 7 of 10

48. To the extent that paragraph 48 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 48 of Plaintiffs’ Complaint.

49. Defendant denies the allegations set forth in paragraph 49 of Plaintiffs’ Complaint. 

Count 3: Gross Negligence: Animal Abuse and Injury to Sneed’s Horses (against Jeffrey

Gibbs, Calli Rouse, Gibbs Show Horses, and Calli Rouse Show Horses)

50. In response to Plaintiffs’ preemptory paragraph under Count 3, Defendant realleges and incorporates by reference all answers and Affirmative Defenses to all prior allegations 

in Plaintiffs’ Complaint as though specifically set forth herein.

51. To the extent that paragraph 51 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 51 of Plaintiffs’ Complaint.

52. To the extent that paragraph 52 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 52 of Plaintiffs’ Complaint.

53. To the extent that paragraph 53 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 53 of Plaintiffs’ Complaint.

54. To the extent that paragraph 54 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 54 of Plaintiffs’ Complaint

55. Defendant denies the allegations set forth in paragraph 55 of Plaintiffs’ Complaint.
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 8 of 10

VI. DAMAGES

56. Defendant denies the allegations set forth in paragraph 56 et seq. of Plaintiffs’ 

Complaint. 

VII. EXEMPLARY DAMAGES

57. To the extent that paragraph 57 of Plaintiffs’ Complaint contains conclusions of 

law and not statements of fact, no response is required. Otherwise, Defendant denies the allegations 

in paragraph 57 of Plaintiffs’ Complaint.

58. Defendant denies that any act or omission of Defendant, Black Bird Ranch, Patricia 

Bonaparte, and/or Frank Bonaparte entitles Plaintiffs to punitive or exemplary damages under § 

41.008 of the Texas Civil Practices and Remedies Code as alleged in paragraph 58 of Plaintiffs’ 

Complaint. 

B. 

DEFENSES & AFFIRMATIVE DEFENSES

59. This action is subject to the proportionate responsibility provisions of Chapters 32 

and 33 of the Texas Civil Practice and Remedies Code, including (without limitation) the 

requirement of §33.003 thereof that the trier of fact determine the relative responsibility of each 

plaintiff, defendant, settling person, and responsible third-party that may be designated in the suit. 

Defendant specifically reserves any actions for contribution or indemnity against such parties, 

persons and/or entities, and/or third-parties and reserves its rights under §§33.001 et. seq. of the 

Texas Civil Practice and Remedies Code.

60. Regardless of any negligence of Defendant, which Defendant expressly denies, new 

and independent causes intervened which severed any causal relationship between any alleged act 

or omission of Defendant, Black Bird Ranch, Patricia Bonaparte, and/or Frank Bonaparte and the 

damages allegedly sustained by Plaintiffs. 
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 9 of 10

61. The damages, if any, recoverable by Plaintiffs must be limited to a market valuation 

of the value of Plaintiffs’ horses at the time their damages were sustained. 

62. Defendant is entitled to an offset or credits for any settlements or other amounts 

received by Plaintiffs from any source whatsoever related to the damages at issue in this suit 

pursuant to the Texas Civil Practice & Remedies Code and other applicable state law. Defendant 

is entitled to an offset equal to the sum of the dollar amount of all settlements. See Tex. Civ. Prac. 

& Rem. Code §33.012.

C.

PRAYER

For these reasons, Defendant The Bonaparte Family Living Trust asks the Court to enter 

judgment that Plaintiffs Kathryn Sneed and Sneed Equestrian Estates, LLC take nothing from 

Defendant, dismiss Plaintiffs’ complaint with prejudice, assess costs against Plaintiffs, and award 

Defendant all other relief the Court deems appropriate.
DEFENDANT THE BONAPARTE FAMILY LIVING TRUST’S ORIGINAL ANSWER - Page 10 of 10

Respectfully submitted,

GLAST, PHILLIPS & MURRAY, P.C.

By: /s/ James C. Erdle, Jr.

James C. Erdle, Jr.

State Bar No. 24069680

Glast, Phillips & Murray, P.C.

14801 Quorum Drive, Suite 500 

Dallas, TX 75254-1449

972.419.8300

972.419.8329 facsimile

jerdle@gpm-law.com

ATTORNEY IN CHARGE FOR 

DEFENDANT THE BONAPARTE

FAMILY LIVING TRUST

Of Counsel:

Joseph D. Zopolsky

State Bar No. 24033500

Glast, Phillips & Murray, P.C.

14801 Quorum Drive, Suite 500 

Dallas, TX 75254-1449

972.419.8300

972.419.8329 facsimile

jzopolsky@gpm-law.com

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing document was served upon 

all counsel of record in the above-captioned cause, pursuant to FED. R. CIV. P. 5(b)(2)(E) on 

November 20, 2023 by:

Hand Delivery:

Electronic Service/Email: XX

Fax Transmittal:

/s/ James C. Erdle, Jr.

James C. Erdle, Jr.