No. 45TH. Plaintiff EDGEWOOD INDEPENDENT SCHOOL DISTRICT files its Original Petition

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "No. 45TH. Plaintiff EDGEWOOD INDEPENDENT SCHOOL DISTRICT files its Original Petition"

Transcription

1 FILED 9/24/ :11:33 AM Donna Kay McKinney Bexar County District Clerk Accepted By: Roxanne Mujica 2014CI15241 No. W/ JD EDGEWOOD INDEPENDENT SCHOOL DISTRICT v. Plaintiff, KOONTZ/MCCOMBS CONSTRUCTION, LTD. Defendant. IN THE DISTRICT COURT OF 45TH JUDICIAL DISTRICT BEXAR COUNTY, TEXAS PLAINTIFF S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff EDGEWOOD INDEPENDENT SCHOOL DISTRICT files its Original Petition complaining of Defendant KOONTZ/MCCOMBS CONSTRUCTION, LTD. and respectfully shows the Court as follows: I. DISCOVERY LEVEL: 1.1 Discovery in this case is intended to be conducted under Level 3 of Rule 190 of the TEXAS RULES OF CIVIL PROCEDURE. II. VENUE: 2.1 Venue is proper in Bexar County pursuant to TEXAS CIVIL PRACTICE AND REMEDIES CODE in that all or part of as all or a substantial part of the facts giving rise to this action occurred in Bexar County, a contract was entered into in Bexar County, and the Plaintiff and the property which is the subject of this suit are located in Bexar County.

2 III. PARTIES: 3.1 Plaintiff EDGEWOOD INDEPENDENT SCHOOL DISTRICT ( Plaintiff or EISD ) is a local governmental entity, organized under the laws of the State of Texas, having its principal office in San Antonio, Bexar County, Texas. 3.2 Defendant, KOONTZ/MCCOMBS CONSTRUCTION, LTD., is a domestic for profit limited partnership doing business in the State of Texas. Defendant may be served with process by serving its registered agent, Bart C. Koontz, 755 E. Mulberry Avenue, Suite 100, San Antonio, TX Plaintiff requests that citation be issued so that service may be made by private process server. IV. CONSTRUCTION DEFECTS 4.1 Suit is brought against Defendant Koontz/McCombs Construction, Ltd. (referred to herein as Koontz McCombs or Defendant ) for property damage resulting from deficiencies in the construction of Roosevelt Elementary School located at 3823 Fortuna, San Antonio, Texas (hereinafter referred to as the School ). Plaintiff hereby sues for breach of the construction agreement between Koontz/McCombs and Plaintiff pertaining to the subject school construction, for breaches of the warranty of good and workmanlike performance, breach of the warranty of commercial habitability, and under common law. In the alternative, this suit is brought for common law negligence and/or negligent misrepresentation as to the Defendant in that they performed substandard supervision and/or construction and/or made subsequent substandard repairs to the School. At no time has Defendant advised Plaintiff of the problems with the original construction of the School, the need to repair all or portions of the School, the existence of problems which could cause and did cause significant property damage to the School, or the fact that the repairs were substandard and caused more damage to existing work. PLAINTIFF S ORIGINAL PETITION PAGE 2 OF 7

3 4.2 Koontz McCombs was the general contractor/construction manager hired by Plaintiff to perform the construction of the School. Plaintiff and Koontz McCombs entered into an agreement for the work to be performed by Koontz McCombs. The actions set forth in this Petition were committed by Koontz McCombs, its employees or its actual or apparent agents. As general contractor/construction manager for the construction of the School, and pursuant to the agreement, Koontz McCombs was responsible for any and all defects, improper construction practices, negligent construction or faulty work performed by any subcontractors, agents or third parties retained by Koontz McCombs or working under its direction and supervision on the project, including but not limited to the additions and renovations to the existing Roosevelt Elementary School in the Edgewood ISD. 4.3 Plaintiff s property sustained damage to various areas of the School including, but not limited to, the cost of destruction, repairs, replacement and/or restoration of the foundation system, the roofing system, the wall system, the civil grading system and also resulted in damage to equipment and property within the structure, as well as the cost of fixing the components and systems which are deficient and which are not fully functioning. These damages include the costs associated with the restoration and build back due to the development of the damage in and around the School. These damages are alleged to be the result of substandard and deficient construction of the School. 4.4 Plaintiff has further experienced other construction-related problems with the structure as the result of improper manufacture, construction and/or installation of the construction components and the restoration and repairs performed to the existing structures and the systems contained therein. Construction issues include, but are not limited to the following areas: PLAINTIFF S ORIGINAL PETITION PAGE 3 OF 7

4 Defective civil grading system; Defective exterior flatwork and sidewalk system; Defective wall system; Defective foundation system; Defective roofing system; and Ongoing construction issues related to construction warranty activities, and service and follow-up activities by the Defendant. 4.5 Defendant, expressly or impliedly, individually or through their agent or agents, made one or more of the following representations or warranties: (a) That the construction in question would be performed in conformance with the contract documents and be free from defects ; (b) That the construction in question would be performed in a good and workmanlike manner, and would be commercially habitable, i.e., free from unsafe, unhealthy, or unsanitary conditions; (c) That the School, and all related improvements and all relevant construction, installation, sealing, sizing, settings, and components, would be made, done, or constructed properly and in a good and workmanlike manner; (d) Other representations or warranties. 4.6 Plaintiff further alleges that each and every one of the representations of Defendant concerned material facts. Defendant s express or implied representations were relied upon by Plaintiff or its agents to Plaintiff s substantial injury and damage. In this connection, Plaintiff further alleges that Defendant purported to have and did have superior knowledge concerning the subject matter of the transaction described above, and Plaintiff justifiably relied upon such superior knowledge. 4.7 As a result of all such conduct of the Defendant, Plaintiff has been damaged in an amount in excess of the minimum jurisdictional limits of this Court. Such conduct of the Defendant was negligent and tortious. The conduct of Defendant constituted misrepresentation PLAINTIFF S ORIGINAL PETITION PAGE 4 OF 7

5 of fact. The conduct of Defendant was the proximate and/or producing cause of the injuries and damages to Plaintiff for which it herein sues. Plaintiff seeks actual damages from Defendant for the costs and expenses necessary to fully and completely repair any problems or defects in the project and for recovery of any incidental costs or expenses incurred as a result of the required repairs. V. CONDITIONS PRECEDENT 5.1 All of the conditions precedent to bringing this suit under the contract(s) and to Defendant s liability to Plaintiff for the claims stated above have been performed or have occurred. All notices, complaints or demands were timely and properly given in such a manner as to fully comply with the terms and conditions of the relevant contract(s) and applicable law. In the alternative, Plaintiff alleges that as to any such terms, conditions, notices, or requirements, Defendant waived them, Defendant is estopped from asserting them, and/or Plaintiff substantially complied with them. Plaintiff makes the same allegations of waiver or estoppel as to every defense or exclusion pleaded by the Defendant. VI. DISCOVERY 6.1 In response to a defense of limitations, if any is asserted, Plaintiff pleads the discovery rule, latent defect, fraudulent concealment, equitable estoppel and other matters of excuse and avoidance. In addition, Plaintiff pleads that it is exempt from the statute of limitations pursuant to section of the Texas Civil Practice and Remedies Code. VII. DAMAGES; ATTORNEY S FEES 7.1 Plaintiff seeks damages for the repair and replacement of the property damage from the defective work on the Project. Damages sought are within the jurisdictional limits of the Court. Those damages exceed $1,000,000, and Plaintiff seeks monetary relief over $1,000,000. Plaintiff reserves the right to amend the amount of relief sought as its investigation continues. PLAINTIFF S ORIGINAL PETITION PAGE 5 OF 7

6 7.2 Plaintiff and its attorneys are entitled to attorney s fees in connection with the bringing of this action for breach of contract, warranty or other legal theory. Plaintiff hereby makes demand for payment of its attorney s fees and expenses incurred in connection with bringing and prosecuting these claims. 7.3 Plaintiff reserves the right to amend this pleading in accordance with the TRCP and as discovery and investigation continue. VIII. JURY DEMAND 8.1 Pursuant to Rule 216 of the Texas Rules of Civil Procedure, Plaintiff hereby demands a trial by jury on all contested issues of material fact. Along with the filing of the Original Petition, Plaintiff tendered the requisite jury fee to the Clerk of the Court. IX. REQUEST FOR DISCLOSURE 9.1 Pursuant to Texas Rules of Civil Procedure 194, Plaintiff requests that Defendant disclose the information or material described in Rule 194.2(a) - (i) and 194.2(l). WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays that upon trial of this matter, the Court grant: 1. Judgment against Defendant for actual damages, as set forth above, in an amount in excess of the minimum jurisdictional limits of this Honorable Court; 2. Incidental damages caused by Defendant s breaches; 3. Interest on said Judgment at the legal rate from the date of Judgment; 4. Pre-judgment interest as allowed by law; 5. Post-judgment interest at the legal rate; 6. Attorney s fees; PLAINTIFF S ORIGINAL PETITION PAGE 6 OF 7

7 7. Any additional damages under the facts set forth in this or any amended pleading; 8. Costs of suit; and 9. All such other and further relief to which Plaintiff may show itself to be entitled, at law or in equity. Respectfully submitted, GRAVELY & PEARSON, L.L.P. 425 Soledad, Suite 600 San Antonio, Texas Telephone: (210) Facsimile: (210) By: Marc E. Gravely State Bar No Michael M. Gavito Texas Bar No Jonathan C. Lisenby Texas Bar No and ESCAMILLA & PONECK, L.L.P Douglas A. Poneck State Bar No Philip Marzec State Bar No North St. Mary s Street San Antonio, Texas Telephone: (210) Facsimile: (210) ATTORNEYS FOR PLAINTIFF PLAINTIFF S ORIGINAL PETITION PAGE 7 OF 7

FILED 15 JUL 27 AM 9:22

FILED 15 JUL 27 AM 9:22 FILED JUL AM : KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --- KNT JUDITH JORGENSEN, vs. SUPERIOR COURT OF WASHINGTON KING COUNTY Plaintiff, JAMES WONG and TYRA WONG, husband and wife creating

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO GENERAL ALLEGATIONS

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO GENERAL ALLEGATIONS COOLEY LLP PATRICK P. GUNN ( ) ( PGUNN@COOLEY.COM) ABIGAIL E. PRINGLE () APRINGLE@COOLEY.COM) 1 California Street, th Floor San Francisco, CA 1-00 FILED Telephone: ( ) -00 SAN MATEO COUNY Facsimile: (

More information

CAUSE NO. DC-12-07825

CAUSE NO. DC-12-07825 CAUSE NO. DC-12-07825 Filed 13 September 9 P4:46 Gary Fitzsimmons District Clerk Dallas District CADE MANNETTI, v. Plaintiff, VISIONARY RESTAURANTS LLC, VISIONARY STAFFING LLC, WILLIAM McCROREY, AND THOMAS

More information

CAUSE NO. JUSTIN GROGG IN THE DISTRICT COURT OF Plaintiff, vs. DALLAS COUNTY, TEXAS

CAUSE NO. JUSTIN GROGG IN THE DISTRICT COURT OF Plaintiff, vs. DALLAS COUNTY, TEXAS CAUSE NO. Filed 13 May 7 P9:22 Gary Fitzsimmons District Clerk Dallas District JUSTIN GROGG IN THE DISTRICT COURT OF Plaintiff, vs. DALLAS COUNTY, TEXAS RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF

More information

THIRD JUDICIAL DISTRICT COURT IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

THIRD JUDICIAL DISTRICT COURT IN AND FOR SALT LAKE COUNTY, STATE OF UTAH James W. McConkie #2156 PARKER & McCONKIE Attorneys for Plaintiffs City Center I, Suite 900 175 East 400 South Salt Lake City, Utah 84111 Telephone (801) 264-1950 Facsimile (801) 328-4988 THIRD JUDICIAL

More information

Information or instructions: Defendant s Cross-claims and counterclaims PREVIEW

Information or instructions: Defendant s Cross-claims and counterclaims PREVIEW Information or instructions: Defendant s Cross-claims and counterclaims 1. The purpose of counterclaims and cross-actions is to join persons and actions, as permitted by TRCP 39, 40, 41, 49, 50, and 51,

More information

NO. PLAINTIFFS' ORIGINAL PETITION FOR DECLARATORY JUDGMENT. Now comes, Tommy Adkisson, individually, in his official capacity as Bexar County

NO. PLAINTIFFS' ORIGINAL PETITION FOR DECLARATORY JUDGMENT. Now comes, Tommy Adkisson, individually, in his official capacity as Bexar County NO. Filed 10 June 24 P12:29 Amalia Rodriguez-Mendoza District Clerk Travis District D-1-GN-10-002120 TOMMY ADKISSON, INDIVIDUALLY AND OFFICIALLY ON BEHALF OF BEXAR COUNTY, TEXAS, AS COUNTY COMMISSIONERPCT.4

More information

CIVIL DICTRICT COURT PARISH OF ORLEANS STATE OF LOUISIANA

CIVIL DICTRICT COURT PARISH OF ORLEANS STATE OF LOUISIANA CIVIL DICTRICT COURT PARISH OF ORLEANS STATE OF LOUISIANA LESTER ANSARDI, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED SUIT NO. PLAINTIFF VERSUS UNITED STATES MARITIME SERVICES, INC., UNITED

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION SIMON DOMINGUEZ, PEDRO DOMINGUEZ, JOSE FRANCISCO BRIONES, and ROBERT PEREZ On Behalf of Themselves and All

More information

14-05313-16 CAUSE NO. JULIE TORBERT, as next friend of IN THE DISTRICT COURT PHILIP ORMSTON V. DENTON COUNTY, TEXAS

14-05313-16 CAUSE NO. JULIE TORBERT, as next friend of IN THE DISTRICT COURT PHILIP ORMSTON V. DENTON COUNTY, TEXAS 14-05313-16 CAUSE NO. FILED: 7/15/2014 1:32:23 PM SHERRI ADELSTEIN Denton County District Clerk By: Heather Goheen, Deputy JULIE TORBERT, as next friend of IN THE DISTRICT COURT PHILIP ORMSTON Plaintiff

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Harvey C. Berger (SBN POPE & BERGER 0 West "C" Street, Suite 100 San Diego, California 1 Telephone: (1-1 Facsimile: (1 - Attorneys for Plaintiff PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER Case 1:14-cv-05919-JEI-KMW Document 19 Filed 02/13/15 Page 1 of 11 PageID: 84 Frank L. Corrado, Esquire Attorney ID No. 022221983 BARRY, CORRADO & GRASSI, PC 2700 Pacific Avenue Wildwood, NJ 08260 (609)

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ) ) ) ) ) ) ) ) ) ) ) Case No. 06-3755 CLASS ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ) ) ) ) ) ) ) ) ) ) ) Case No. 06-3755 CLASS ACTION Case 2:06-cv-03755-ER Document 136 Filed 04/25/2008 Page 1 of 26 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA A.D. ALBERTON and MARK C. KESSLER, on behalf of themselves

More information

Case No.: CLASS ACTION COMPLAINT FOR BREACH OF IMPLIED WARRANTY OF WORKMANSHIP AND HABITABILITY. Plaintiffs,

Case No.: CLASS ACTION COMPLAINT FOR BREACH OF IMPLIED WARRANTY OF WORKMANSHIP AND HABITABILITY. Plaintiffs, 1 1 1 1 1 1 0 1 Stephen L. Weber, Esq. (AZ SBN 01) Michael J. White, Esq. (AZ SBN 01) James W. Fleming, Esq. (AZ SBN 0) KASDAN SIMONDS WEBER & VAUGHAN LLP 00 N. Central Ave., Suite 0 Phoenix, AZ 0 E-Mail:

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. INFANT SWIMMING RESEARCH, INC., v. Plaintiff, FAEGRE & BENSON, LLP, MARK FISCHER, JUDY HEUMANN, NORMAN HEUMANN, BOULDER

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA ) ) ) ) ) ) ) ) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA 1 1 In re LONGS DRUG STORES CORP. SHAREHOLDER LITIGATION This Document Relates To: ALL ACTIONS. Lead Case No. C-0-0 CLASS ACTION FINAL JUDGMENT

More information

The Honorable Chairman and Members of the Board of County Commissioners

The Honorable Chairman and Members of the Board of County Commissioners TO: FROM: The Honorable Chairman and Members of the Board of County Commissioners James L. Bennett, County Attorney ~ COMMISSION AGENDA,#':.ett~ -:# /H, SUBJECT: DATE: Notice ofnew Lawsuit and Defense

More information

Civil Suits: The Process

Civil Suits: The Process Jurisdictional Limits The justice courts have exclusive jurisdiction or the authority to hear all civil actions when the amount involved, exclusive of interest, costs and awarded attorney fees when authorized

More information

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA DEAN KUMANCHIK, vs. Plaintiff, Case No.: UNIVERSAL CITY DEVELOPMENT PARTNERS, LTD d/b/a UNIVERSAL STUDIOS, a Florida

More information

D-1-GN CAUSE NO. THE STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff. v. TRAVIS COUNTY, TEXAS. 53RD Defendant JUDICIAL DISTRICT

D-1-GN CAUSE NO. THE STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff. v. TRAVIS COUNTY, TEXAS. 53RD Defendant JUDICIAL DISTRICT D-1-GN-16-000360 CAUSE NO. 1/25/2016 1:01:27 PM Velva L. Price District Clerk Travis County D-1-GN-16-000360 Ruben Tamez THE STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff v. TRAVIS COUNTY, TEXAS MILLENNIUM

More information

Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1

Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1 Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TRAVELERS CASUALTY AND SURETY COMPANY

More information

ORDER OF THE SUPREME COURT OF TEXAS. MiSc Docket No. 99m 9047

ORDER OF THE SUPREME COURT OF TEXAS. MiSc Docket No. 99m 9047 ORDER OF THE SUPREME COURT OF TEXAS MiSc Docket No. 99m 9047 Appointment of a District Judge to Preside in a State Bar Disciplinary Action The Supreme Court of Texas hereby appoints the Honorable John

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL

More information

ORDER OF THE SUPREME COURT OF TEXAS

ORDER OF THE SUPREME COURT OF TEXAS ORDER OF THE SUPREME COURT OF TEXAS Misc. Docket No. 0g----- ---- Appointment of a District Judge to Rule on a Motion to Recuse filed in a State Bar Disciplinary Action The Supreme Court of Texas hereby

More information

ORDER OF THE SUPREME COURT OF TEXAS

ORDER OF THE SUPREME COURT OF TEXAS ORDER OF THE SUPREME COURT OF TEXAS Misc Docket No. 96-9196 Appointment of a District Judge to Preside in a State Bar Disciplinary Action The Supreme Court of Texas hereby appoints the Honorable Mark Davidson,

More information

IN THE UNITED STATES DISTRICT COURT DISTRICT OF

IN THE UNITED STATES DISTRICT COURT DISTRICT OF IN THE UNITED STATES DISTRICT COURT DISTRICT OF UNITED STATES OF AMERICA ) Civil Action No. Ex rel. ) ) FILED IN CAMERA AND Plaintiff, ) UNDER SEAL ) vs. ) FALSE CLAIMS ACT ) MEDICAID FRAUD, ), and ) JURY

More information

-1- SECOND AMENDED COMPLAINT

-1- SECOND AMENDED COMPLAINT VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

More information

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DESTINY ANNMARIE RIOS Plaintiff VS. CIVIL ACTION NO. 5:14-cv-00590

More information

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Calvin L. Keith, OSB No. 814368 CKeith@perkinscoie.com Sarah J. Crooks, OSB No. 971512 SCrooks@perkinscoie.com PERKINS COIE LLP

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA Jack Anderson, Esq. SBN 0 JACK ANDERSON, ESQ., APLC Balboa Avenue, Suite E San Diego, California Tel.: ( - Fax: ( 0- jackandersonaplc@yahoo.com Attorney for Defendant and Cross-Complainant Starline Windows,

More information

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CAROL PARKER, on behalf of herself and all others similarly situated, v. Plaintiff, PARADE ENTERPRISES, LLC, No. 3:14-CV-08084-MAS-DEA AMENDED COMPLAINT

More information

Personal Property Title Insurance Owner s Policy (PPT-1)

Personal Property Title Insurance Owner s Policy (PPT-1) Personal Property Title Insurance (PPT-1) Any notice of claim and any other notice or statement in writing required to be given to the Company under this Policy must be given to the Company at the address

More information

Case 3:13-cv-01461-G Document 8 Filed 04/25/13 Page 1 of 9 PageID 182

Case 3:13-cv-01461-G Document 8 Filed 04/25/13 Page 1 of 9 PageID 182 Case 3:13-cv-01461-G Document 8 Filed 04/25/13 Page 1 of 9 PageID 182 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION HILARY LONGSTREET, individually and on behalf

More information

Attorneys for Plaintiff People of the State of California FOR THE COUNTY OF ORANGE. Defendants.

Attorneys for Plaintiff People of the State of California FOR THE COUNTY OF ORANGE. Defendants. BILL LOCKYER, Attorney General of the State of California HERSCHEL T. ELKINS Senior Assistant Attorney General ALBERT NORMAN SHELDEN Supervising Deputy Attorney General HOWARD WAYNE (State Bar No. ) Deputy

More information

Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM

Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM PENELOPE BELVOIR, as Executor de son Tort for the Pending Estate of Robert Belvoir, Deceased, vs. Plaintiff, ROPES COURSES, INC., FB ORLANDO

More information

OR1lJJEJR OF 1['HE SUPREME COURT OF TEXAS

OR1lJJEJR OF 1['HE SUPREME COURT OF TEXAS OR1lJJEJR OF 1['HE SUPREME COURT OF TEXAS Misc. Docket No. 02-91.07 Appointment of a District Judge to Preside in a State Bar Disciplinary Action The Supreme Court oftexas hereby appoints the Honorable

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their CASE 0:13-cv-00873-RHK-TNL Document 1 Filed 04/15/13 Page 1 of 4 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Michael A. Ofor, Case No: Plaintiff, v. Steven Lecy, and City of Minneapolis, NOTICE

More information

ORDER OF THE SUPREME COURT OF TEXAS

ORDER OF THE SUPREME COURT OF TEXAS ORDER OF THE SUPREME COURT OF TEXAS tt C^ Misc. i[ Docket No. OIl- 2-?^ ^ Appointment of a District Judge to Preside in a State Bar Disciplinary Action The Supreme Court of Texas hereby appoints the Honorable

More information

COMPLAINT AND JURY DEMAND

COMPLAINT AND JURY DEMAND DISTRICT COURT, JEFFERSON COUNTY, COLORADO 100 Jefferson County Parkway Golden, CO 80401 (303) 271-6145 Plaintiffs: NORMAN NEWELL and LINDA NEWELL, v. Defendants: COURT USE ONLY APRIA HEALTHCARE, INC.;

More information

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION Form 2:40-2 Complaint Negligence, Motor Vehicle IN THE CIRCUIT COURT OF THE ## JUDICIAL CIRCUIT IN AND FOR [COUNTY], FLORIDA [PLAINTIFF], Plaintiff, CASE NO.: ##-##### ## ## GENERAL JURISDICTION vs. [DEFENDANT

More information

vs. JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Plaintiff JAMES SCHAIRER, by and through undersigned counsel, hereby sues

vs. JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Plaintiff JAMES SCHAIRER, by and through undersigned counsel, hereby sues IN THE CIRCUIT COURT OF THE th 16 JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. JAMES SCHAIRER, individually, Plaintiff, vs. JURY TRIAL DEMANDED PAUL KERCHER,

More information

Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS HOSPITAL DISTRICT NO.1 OF CRAWFORD COUNTY, KANSAS, d/b/a, GIRARD MEDICAL

More information

AMENDED CLASS ACTION COMPLAINT

AMENDED CLASS ACTION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. KIM WALLANT and LOUIS BOREK, on behalf of themselves and all others similarly situated, vs. Plaintiffs, FREEDOM

More information

CAUSE NO. PLAINTIFF S ORIGINAL PETITION, APPLICATION FOR EX PARTE TEMPORARY RESTRAINING ORDER, AND TEMPORARY AND PERMANENT INJUNCTION

CAUSE NO. PLAINTIFF S ORIGINAL PETITION, APPLICATION FOR EX PARTE TEMPORARY RESTRAINING ORDER, AND TEMPORARY AND PERMANENT INJUNCTION CAUSE NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff v. HARRIS COUNTY, TEXAS JACOB R. HORN; BENTON RAWLON BARBER (A.K.A. RANDY BARBER); d/b/a 1 DAY ROOF; ROOF ALL TEXAS; JUDICIAL DISTRICT ROOFTEAMS

More information

Filing # 40778264 E-Filed 04/27/2016 11:43:26 AM

Filing # 40778264 E-Filed 04/27/2016 11:43:26 AM Filing # 40778264 E-Filed 04/27/2016 11:43:26 AM THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA VILLAS AT CYPRESS SPRINGS HOMEOWNERS ASSOCIATION, INC. Case No.: Plaintiff,

More information

PREVIEW. 1. The following form may be used to file a personal injury lawsuit.

PREVIEW. 1. The following form may be used to file a personal injury lawsuit. Information or instructions: Plaintiff's original petition-auto accident 1. The following form may be used to file a personal injury lawsuit. 2. It assumes several plaintiffs were rear-ended by an employee

More information

Case 5:07-cv-00971-XR Document 66 Filed 09/12/2008 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 5:07-cv-00971-XR Document 66 Filed 09/12/2008 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Case 5:07-cv-00971-XR Document 66 Filed 09/12/2008 Page 1 of 5 INTERNATIONAL WOMEN'S DAY MARCH PLANNING COMMITTEE, AN UNINCORPORATED ASSOCIATION, AND SAN ANTONIO FREE SPEECH COALITION, AN UNICORPORATED

More information

IN THE CIRCUIT COURT OF THE THIRD CIRCUIT STATE OF HAWAII ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

IN THE CIRCUIT COURT OF THE THIRD CIRCUIT STATE OF HAWAII ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF ROBERT D.S. KIM A Law Corporation Attorney At Law ROBERT D.S. KIM 4255-0 77-6400 Nalani Street, Suite A-1 Kailua-Kona, Hawaii 96740 Telephone (808 329-6611 Attorney for Plaintiffs IN THE CIRCUIT COURT

More information

Case 8:13-cv-01060-EAK-TBM Document 14 Filed 05/20/13 Page 1 of 7 PageID 49 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

Case 8:13-cv-01060-EAK-TBM Document 14 Filed 05/20/13 Page 1 of 7 PageID 49 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION Case 8:13-cv-01060-EAK-TBM Document 14 Filed 05/20/13 Page 1 of 7 PageID 49 SUZANNE RAWLINS, Plaintiff, UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION v. Case No.: 8:13-cv-1060-EAK-TBM

More information

UNITED STATES OF AMERICA DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT OFFICE OF ADMINISTRATIVE LAW JUDGES

UNITED STATES OF AMERICA DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT OFFICE OF ADMINISTRATIVE LAW JUDGES UNITED STATES OF AMERICA DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT OFFICE OF ADMINISTRATIVE LAW JUDGES The Secretary, United States ) Department of Housing and Urban ) Development, on behalf of ) Fair

More information

Illinois Association of Defense Trial Counsel Springfield, Illinois www.iadtc.org 800-232-0169 IDC Quarterly Volume 24, Number 3 (24.3.

Illinois Association of Defense Trial Counsel Springfield, Illinois www.iadtc.org 800-232-0169 IDC Quarterly Volume 24, Number 3 (24.3. Illinois Association of Defense Trial Counsel Springfield, Illinois www.iadtc.org 800-232-0169 IDC Quarterly Volume 24, Number 3 (24.3.52) Property Insurance Catherine A. Cooke Robbins, Salomon & Patt,

More information

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION SUSAN CARNABY V. C IVIL ACTION NUMBER H-08-1366 C ITY

More information

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13 Case -00-LT Filed 0// Entered 0// :: Doc Pg. of NANCY L. STAGG, CA Bar No. 0 nstagg@foley.com MATTHEW J. RIOPELLE, CA Bar No. 0 mriopelle@foley.com FOLEY & LARDNER LLP VALLEY CENTRE DRIVE, SUITE 00 SAN

More information

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I.

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I. CAUSE NO. STATE OF TEXAS, Plaintiff, v. OLD UNITED LIFE INSURANCE COMPANY, Defendant. IN THE DISTRICT COURT OF TRAVIS COUNTY, TEXAS JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION TO THE HONORABLE JUDGE

More information

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

More information

Case 2:15-cv-02235-SHL-dkv Document 1 Filed 04/09/15 Page 1 of 16 PageID 1 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE

Case 2:15-cv-02235-SHL-dkv Document 1 Filed 04/09/15 Page 1 of 16 PageID 1 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE Case 2:15-cv-02235-SHL-dkv Document 1 Filed 04/09/15 Page 1 of 16 PageID 1 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE FIRST HORIZON NATIONAL ) CORPORATION and ) FIRST TENNESSEE

More information

NC General Statutes - Chapter 1A Article 3 1

NC General Statutes - Chapter 1A Article 3 1 Article 3 Pleadings and Motions. Rule 7. Pleadings allowed; motions. (a) Pleadings. - There shall be a complaint and an answer; a reply to a counterclaim denominated as such; an answer to a crossclaim,

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case :-cv-000-jah -CAB Document Filed 0// Page of 0 Joshua B. Swigart, Esq. (SBN: ) josh@westcoastlitigation.com Robert L. Hyde, Esq. (SBN: ) bob@westcoastlitigation.com Hyde & Swigart Camino Del Rio South,

More information

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY STATE OF UTAH. Case No. : Judge:

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY STATE OF UTAH. Case No. : Judge: Alan W. Mortensen (6616) DEWSNUP, KING & OLSEN 36 South State Street, Ste. 2400 Salt Lake City, UT 84111 Telephone (801) 533-0400 Facsimile (801) 363-4218 Attorneys for Plaintiffs IN THE THIRD JUDICIAL

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION PLAINTIFF MCAFEE, INC. S THIRD AMENDED COMPLAINT

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION PLAINTIFF MCAFEE, INC. S THIRD AMENDED COMPLAINT UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION McAFEE, INC. v. Plaintiff, WILMER, CUTLER, PICKERING, HALE AND DORR, L.L.P JURY REQUESTED No. 4:08-cv-160 MHS-DDB Defendant.

More information

NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff, v. LIBERTY COUNTY, TEXAS. CVS PHARMACY, INC. Defendant. JUDICIAL DISTRICT

NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff, v. LIBERTY COUNTY, TEXAS. CVS PHARMACY, INC. Defendant. JUDICIAL DISTRICT NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff, v. LIBERTY COUNTY, TEXAS CVS PHARMACY, INC. Defendant. JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION AND APPLICATION FOR INJUNCTION TO THE HONORABLE

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION. Plaintiff, Defendants, Nominal Defendant.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION. Plaintiff, Defendants, Nominal Defendant. 1 1 1 1 1 1 1 1 0 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION In re ORACLE CORPORATION DERIVATIVE LITIGATION SCOTT OZAKI, derivatively and on behalf of ORACLE CORPORATION,

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:13-cv-02282-RWS Document 1 Filed 07/09/13 Page 1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION DE ANGELO BENTLEY, ) MARQUES ROBERTSON, ) IKEYMA MCKENTRY, ) individually,

More information

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA H.L. WATKINS AND COMPANY, INC., ) ) PLAINTIFF, ) ) CIVIL ACTION FILE NO. v. ) ) 06-CV8980-3 THE HOT LEAD COMPANY, LLC, ) ROBERT MICHAEL HORNE, )

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual,

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual, VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

ORDER OF THE SUPREME COURT OF TEXAS. Misc Docket No. 97-_go I

ORDER OF THE SUPREME COURT OF TEXAS. Misc Docket No. 97-_go I ORDER OF THE SUPREME COURT OF TEXAS Misc Docket No. 97-_go I Appointment of a District Judge to Preside in a State Bar Disciplinary Action The Supreme Court of Texas hereby appoints the Honorable George

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION INSTITUTE FOR CREATION RESEARCH GRADUATE SCHOOL, Plaintiff, v. CAUSE NO. A:09 CA 382 TEXAS HIGHER EDUCATION COODINATING

More information

SHORT FORM STANDARD SUBCONTRACT

SHORT FORM STANDARD SUBCONTRACT SHORT FORM STANDARD SUBCONTRACT This Agreement is made this day of, 20, between (Contractor) and (Subcontractor). The work described in Section I below shall be performed in accordance with the prime contract

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 1 1 1 1 1 1 1 1 0 1 LAW OFFICES OF RONALD A. MARRON RONALD A. MARRON (SBN 10) ron@consumersadvocates.com ALEXIS WOOD (SBN 000) alexis@consumersadvocates.com KAS GALLUCCI (SBN 0) kas@consumersadvocates.com

More information

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION COMPLAINT

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, CASE NUMBER: JUDGE: vs. Defendant. / COMPLAINT COMES NOW, Plaintiff,, and hereby sues

More information

CAUSE NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff LIFESTREAM PURIFICATION SYSTEMS, LLC. DALLAS COUNTY, T E X A S

CAUSE NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff LIFESTREAM PURIFICATION SYSTEMS, LLC. DALLAS COUNTY, T E X A S CAUSE NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff VS. LIFESTREAM PURIFICATION SYSTEMS, LLC. DALLAS COUNTY, T E X A S Defendant. JUDICIAL DISTRICT FINAL JUDGMENT AND AGREED PERMANENT INJUNCTION

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO 1 0 1 MARC D. ADELMAN Attorney at Law State Bar No. Liberty Station Historic Decatur Road, Suite 00 San Diego, CA - (1) -0 Phone (1) -0 Fax Email: AdelmanMD@aol.com Attorney for Plaintiff SUPERIOR COURT

More information

Case 5:14-cv-00631 Document 1 Filed 07/11/14 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 5:14-cv-00631 Document 1 Filed 07/11/14 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Case 5:14-cv-00631 Document 1 Filed 07/11/14 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION CAROLE RIELEY Plaintiff, CIVIL ACTION NO. 5:14 cv 00631

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MICROSOFT CORPORATION, a Washington Corporation v. Plaintiff, SALESFORCE.COM, INC., a Delaware Corporation Defendants. UNITED STATES DISTRICT

More information

Interactive Brokers Hong Kong Agreement for Advisors Providing Services to Interactive Brokers Clients

Interactive Brokers Hong Kong Agreement for Advisors Providing Services to Interactive Brokers Clients Interactive Brokers Hong Kong Agreement for Advisors Providing Services to Interactive Brokers Clients This Agreement is entered into between Interactive Brokers Hong Kong Ltd ("IB") and the undersigned

More information

Case4:14-cv-04322-PJH Document1 Filed09/25/14 Page1 of 34

Case4:14-cv-04322-PJH Document1 Filed09/25/14 Page1 of 34 Case4:14-cv-04322-PJH Document1 Filed09/25/14 Page1 of 34 1 2 3 4 5 6 GLYNN & FINLEY, LLP CLEMENT L. GLYNN, Bar No. 57117 JONATHAN A. ELDREDGE, Bar No. 238559 One Walnut Creek Center 100 Pringle Avenue,

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DIVISION

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DIVISION UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA, TAMPA DIVISION Consumer Financial Protection Bureau and Office of the Attorney General, State of Florida, Department of Legal Affairs, Case No.

More information

Maronda Homes Limited Warranty Agreement

Maronda Homes Limited Warranty Agreement Maronda Homes Limited Warranty Agreement {23668310;4} TABLE OF CONTENTS I. INTRODUCTION... 1 II. ONE YEAR WARRANTY... 1 A. COVERAGE... 1 B. REQUESTING WARRANTY SERVICE... 1 C. LIMITATION OF LIABILITY...

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION JAMES C. STURDEVANT (SBN 94551 JESPER I. RASMUSSEN (SBN 121001 THE STURDEVANT LAW FIRM A Professional Corporation 475 Sansome Street, Suite 1750 San Francisco, California 94111 Telephone: (415 477-2410

More information

The Judges of the Fulton Superior Court hereby create a "Business Case Division" (hereinafter referred to as the "Division").

The Judges of the Fulton Superior Court hereby create a Business Case Division (hereinafter referred to as the Division). SUPREME COURT OF GEORGIA Atlanta October 11, 2012 The Honorable Supreme Court met pursuant to adjournment. The following order was passed: It is ordered that Paragraph 5 of Atlanta Judicial Circuit Rule

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION FUTUREVISION.COM, LLC, Plaintiff, v. TIME WARNER CABLE, INC., TIME WARNER CABLE, LLC, CEQUEL COMMUNICATIONS, LLC DBA

More information

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:13-cv-00364-ODE Document 14 Filed 05/31/13 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION KIMBERLY L. HARRIS, MALIA COLEMAN, BETTY CURRY, ELSIE STATHAM,

More information

1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION Case 2:12-cv-00604-MHS-CMC Document 1 Filed 09/18/12 Page 1 of 16 PageID #: 1 CAPITAL SECURITY SYSTEMS, INC., IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION Plaintiff,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE MOBILE TRANSFORMATION LLC, Plaintiff, v. Civil Case No. A&E TELEVISION NETWORKS, LLC JURY TRIAL DEMANDED Defendant. COMPLAINT Plaintiff

More information

TITLE I REDUCTION OF ABUSIVE LITIGATION

TITLE I REDUCTION OF ABUSIVE LITIGATION 109 STAT. 737 Public Law 104 67 104th Congress An Act To reform Federal securities litigation, and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America

More information

NO. PLAINTIFF'S ORIGINAL PETITION. Plaintiff the STATE OF TEXAS, acting by and through the Attorney General of Texas,

NO. PLAINTIFF'S ORIGINAL PETITION. Plaintiff the STATE OF TEXAS, acting by and through the Attorney General of Texas, NO. STATE OF TEXAS, Plaintiff, v. ABIO FINANCIAL GROUP, INC. Defendant IN THE DISTRICT COURT OF TRAVIS COUNTY, TEXAS JUDICIAL DISTRICT PLAINTIFF'S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT:

More information

Notice of Proposed Class Action Settlement and Fairness Hearing

Notice of Proposed Class Action Settlement and Fairness Hearing Notice of Proposed Class Action Settlement and Fairness Hearing Minor, et al. v. Congoleum Corporation United States District Court District Of New Jersey Case No.: 3:13-cv-07727-PGS-LHG This is a Notice

More information

Case 1:10-cv-10494-WGY Document 1 Filed 03/23/10 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Case 1:10-cv-10494-WGY Document 1 Filed 03/23/10 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Case 1:10-cv-10494-WGY Document 1 Filed 03/23/10 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS KONINKLIJKE PHILIPS ELECTRONICS N.V. AND PHILIPS SOLID-STATE LIGHTING SOLUTIONS,

More information

NPSA GENERAL PROVISIONS

NPSA GENERAL PROVISIONS NPSA GENERAL PROVISIONS 1. Independent Contractor. A. It is understood and agreed that CONTRACTOR (including CONTRACTOR s employees) is an independent contractor and that no relationship of employer-employee

More information

RULE 4-1.5 FEES AND COSTS FOR LEGAL SERVICES

RULE 4-1.5 FEES AND COSTS FOR LEGAL SERVICES RULE 4-1.5 FEES AND COSTS FOR LEGAL SERVICES (a) Illegal, Prohibited, or Clearly Excessive Fees and Costs. [no change] (b) Factors to Be Considered in Determining Reasonable Fees and Costs. [no change]

More information

Case 3:13-cv-01686-JBA Document 1 Filed 11/14/13 Page 1 of 10

Case 3:13-cv-01686-JBA Document 1 Filed 11/14/13 Page 1 of 10 Case 313-cv-01686-JBA Document 1 Filed 11/14/13 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT Renee Wheeler, Individually and on behalf of other similarly situated individuals, Plaintiffs,

More information

CLARK COUNTY, NEVADA. ANSWER ) Defendant. ) )

CLARK COUNTY, NEVADA. ANSWER ) Defendant. ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ANS (NAME) (ADDRESS) (CITY, STATE, ZIP) (TELEPHONE) Defendant Pro Se DISTRICT COURT CLARK COUNTY, NEVADA ) ) Case No.: Plaintiff,

More information

SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, STATE OF CALIFORNIA

SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, STATE OF CALIFORNIA SETTLEMENT OFFICER INFORMATION: _ Telephone: 1 1 1 1 SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, STATE OF CALIFORNIA Case No: RELEASE AND SETTLEMENT AGREEMENT Date: Time: :0 a.m. Case Assigned

More information

Services Agreement between Client and Provider

Services Agreement between Client and Provider Services Agreement between Client and Provider This Services Agreement is part of the Member Contract between Client and Provider, effective upon Client s award and Provider s acceptance of a Job on the

More information

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION. In Re: Bankruptcy No. 09-26549. (Chapter 11) Filed Electronically

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION. In Re: Bankruptcy No. 09-26549. (Chapter 11) Filed Electronically Document Page 1 of 16 Steven C. Tycksen, #3300 Chad Shattuck, #9345 TYCKSEN & SHATTUCK, L.C. 12401 South 450 East, Unit E1 Draper, Utah 84020 Telephone: 801-748-4081 Facsimile: 801-748-4087 steve@tyshlaw.com

More information

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA Michael K Jeanes, Clerk of Court *** Electronically Filed *** E. Hailes, Deputy //01 :1:00 PM Filing ID 0 1 Norman C. Keyt () Christopher M. Bistany () KEYTLaw, LLC 001 E. Camelback Road, Suite Phoenix,

More information

Case 1:15-cv-01148 Document 1 Filed 06/02/15 USDC Colorado Page 1 of 5 IN THE UNITED STATES DISTRICT COURT DISTRICT OF COLORADO

Case 1:15-cv-01148 Document 1 Filed 06/02/15 USDC Colorado Page 1 of 5 IN THE UNITED STATES DISTRICT COURT DISTRICT OF COLORADO Case 1:15-cv-01148 Document 1 Filed 06/02/15 USDC Colorado Page 1 of 5 IN THE UNITED STATES DISTRICT COURT DISTRICT OF COLORADO D THREE ENTERPRISES, LLC, v. Plaintiff, RILLITO RIVER SOLAR LLC d/b/a ECOFASTEN

More information

ORDERED, ADJUDGED AND DECREED,

ORDERED, ADJUDGED AND DECREED, STEPHEN CALKINS General Counsel CAROLE A. PAYNTER (CP 4091) Federal Trade Commission 150 William Street, 13th floor New York, New York 10038 (212) 264-1225 Attorneys for Plaintiff UNITED STATES DISTRICT

More information