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

Size: px
Start display at page:

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

Transcription

1 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 TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER AND GMRI, INC. D/B/A RED LOBSTER #884 AND BEN E. KEITH COMPANY TH JUDICIAL DISTRICT Defendants. PLAINTIFFS ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, JUSTIN GROGG (hereinafter, Plaintiff ), and files this Plaintiff s Original Petition against RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER, and GMRI, INC. D/B/A RED LOBSTER #884 and BEN E. KEITH COMPANY (hereinafter, jointly referred to as Defendants ) and for cause of action and grounds for recovery would respectfully show unto the Court the following: I. DISCOVERY CONTROL PLAN 1. Plaintiff intends that discovery be conducted under Level 2 of Texas Rule of Civil Procedure and affirmatively pleads that it seeks monetary relief aggregating more than $50,000.00, excluding court costs, prejudgment interest and attorney fees. II. PARTIES 2. Plaintiff, JUSTIN GROGG, is an individual who resides in Panama City Beach, Florida. 1

2 3. Defendant, RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF TEXAS 0884, is a Texas domestic for-profit corporation that may be served with citation and process through its registered agent, Corporate Creations Network, Inc., 4265 San Felipe, Suite 1100, Houston, TX Defendant, DARDEN SW LLC D/B/A RED LOBSTER is a foreign limited liability company authorized to do business within the State of Texas, may be served with process through its registered agent, Corporate Creations Network, Inc., 4265 San Felipe, Suite 1100, Houston, TX Defendant, GMRI, INC. D/B/A RED LOBSTER # 884 is a foreign for profit corporation authorized to do business within the State of Texas, may be served with process through its registered agent, Corporate Creations Network, Inc., 4265 San Felipe, Suite 1100, Houston, TX Defendant, BEN E. KEITH COMPANY is a Texas company and may be served with process by serving its registered agent, Stewart E. Greenlee, 601 E. 7 th Street, Ft. Worth, TX III. JURISDICTION & VENUE 7. This Court has jurisdiction over the subject matter of the controversy in this case because Plaintiff s asserted claims and causes of action are being brought under Texas law and because the amount in controversy in this case is within the jurisdictional limits of this Court. 8. This Court has personal jurisdiction over each Defendant because each Defendant is doing business in the State of Texas and also because all acts giving rise to the present litigation occurred in the State of Texas. 9. Venue is proper and maintainable in Dallas County, Texas, pursuant to TEX. CIV. PRAC. 2

3 & REM. CODE (a)(1) since all or a substantial part of the events or omissions giving rise to this lawsuit occurred in Dallas County, Texas. IV. FACTS 10. The injuries and damages suffered by Plaintiff that made the basis of this lawsuit occurred at the Red Lobster Restaurant 0884 located at E. Technology Blvd. Dallas, TX (hereinafter referred to as the Incident Restaurant ). Plaintiff contends that at all times material and relevant herein, that Defendants RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER, and GMRI, INC. D/B/A RED LOBSTER #884 jointly and/or severally owned and/or operated the Incident Restaurant. 11. At approximately 11:00 am on Wednesday, May 4, 2011, Plaintiff, as a business invitee customer, met a colleague for lunch at the Incident Restaurant. Plaintiff ordered a Draft Budweiser beer that came from the tap, not the bottle. Immediately after drinking the beer Plaintiff felt a burning sensation in his throat, esophagus and stomach. 12. Plaintiff immediately alerted the onsite Manager of the Red Lobster who advised him to drink water and go to the hospital because of exposure to Penetrate, a caustic solution (mostly composed of potassium hydroxide) used to clean the keg lines of the beers on tap at the Incident Restaurant, including the Budweiser Draft that was consumed by Plaintiff. Penetrate is known for being the strongest beer line cleaner in the industry and uses a higher concentration of potassium hydroxide than other line cleaners in the industry. 13. Subsequently, it was discovered that the Incident Restaurant uses a company, Defendant BEN E. KEITH, to service and supply their beers, including the Draft Budweiser beer that Plaintiff ordered. As a part of their duties, Defendant BEN E. KEITH is required to properly 3

4 clean the keg lines with the Penetrate solution, and then to properly flush those lines with water (to ensure all the corrosive and caustic solution is rinsed away and thus safe to use). Plaintiff later confirmed with the manager on duty that day at the Incident Restaurant that Defendant BEN E. KEITH had in fact serviced the lines on the morning of May 4, As a result of the ingestion of the harmful and dangerous chemical potassium hydroxide, Plaintiff was rushed to Denton Regional Medical Center and treated for inflammation and ulceration of his upper esophagus and posterior pharynx. Not only did Plaintiff suffer severe pain as a result of these injuries, but he also incurred significant medical costs. Further, as a result of this incident, Plaintiff has been informed by his physicians that he may develop esophageal strictures, esophageal reflux changes, and/or pharyngeal infection in the future as a result of the ingestion of the potassium hydroxide. Upon the recommendation of the medical staff at Denton Medical Center, Plaintiff saw a gastroenterologist for follow up treatment. V. CAUSES OF ACTION A. NEGLIGENCE: AGAINST DEFENDANTS RED LOBSTER OF TEXAS, INC., D/B/A RED LOBSTER OF TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER, AND GMRI, INC., D/B/A RED LOBSTER # Plaintiff incorporates Paragraph Nos of Plaintiff s Original Petition, as if fully set out herein, and contends that he was a business invitee at the time of the serious injuries that he sustained because he was a customer of the Incident Restaurant on May 4, Because the Incident Restaurant s business was open to the public, Plaintiff contends that the Incident Restaurant extended an invitation to Plaintiff to drink and/or eat from the drink and good menu of the Incident Restaurant. Plaintiff further contends that because he was a business invitee customer of the Incident Restaurant at the time of his serious injuries, the Incident Restaurant owed Plaintiff a duty of reasonable care to warn Plaintiff and/or make reasonably safe any 4

5 known dangerous condition, and/or reduce or eliminate any unreasonable risk of harm to Plaintiff while a business invitee customer of the Incident Restaurant. 16. Plaintiff would show that the Incident Restaurant owned and/or operated by Defendants RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER, and GMRI, INC. D/B/A RED LOBSTER #884 jointly and/or severally, breached the duty of ordinary care owed to Plaintiff as a business invitee customer of the Incident Restaurant. More specifically, Plaintiff contends that the incident made the basis of this action occurred because the Defendants listed above committed various acts or omissions that were a proximate cause of the injuries and damages sustained by the Plaintiff, which include, but are not limited to, the following: i. Failing to ensure that the beverages served at the Incident Restaurant were safe for human consumption and free from harmful chemicals; ii. Negligently failing to warn or give notice to Plaintiff of any unreasonable risk of harm to Plaintiff and negligently failed to make reasonably safe any unknown dangerous condition in serving Plaintiff a beverage (Dft. Budwesier) not fit for human consumption that Plaintiff, without warning or notice consumed, which as a direct and proximate result, caused Plaintiff to sustain serious bodily injury; iii. Failing to maintain t h e i r responsibility in regards to servicing beverages to its patrons and to protect the safety of its patrons. iv. Failing to follow and/or implement National, State of Texas and/or City of Denton, Texas food safety and health policies, procedures, regulations and/or rules that would prevent serving to the public at large, including Plaintiff, beverages that would cause harm or injury. 17. Defendants RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER, and GMRI, INC. D/B/A RED LOBSTER #884 5

6 negligent conduct and/or omissions, as described above, taken singularly or in any combination, was the proximate cause of the accident and Plaintiff s injuries. 18. Further, Defendants RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER, and GMRI, INC. D/B/A RED LOBSTER #884, jointly and/or severally, as the owners and/or operator of the Incident Restaurant, should be held responsible for the negligent actions and conduct of one or more of its employees, agents or servants of the Incident Restaurant, which directly and proximately caused the serious injuries of which Plaintiff now complains. B. NEGLIGENCE: AGAINST BEN E. KEITH COMPANY 19. According to information and knowledge, Defendant Ben E. Keith was responsible for the servicing of the draft keg lines at the Incident Restaurant, whose duties includes sanitizing the lines with the Penetrate solution, then properly flushing them to make sure that no harmful chemicals remained in the lines. As such, Plaintiff will show that the incident made the basis for this action occurred because Defendant Ben E. Keith committed various acts or omissions that were a proximate cause of the injuries and damages sustained by the Plaintiff. These negligent acts and/or omissions include, but are not limited to, the following: i. Failing to maintain and safely clean the beverage lines including that of the Budweiser Beer keg lines at the Incident Restaurant on the date in question. ii. Failing to properly flush the draft beer keg lines, including the Dft. Budweiser Beer Plaintiff consumed, thereby leaving the chemical, potassium hydroxide, present to be ingested by the patrons of the restaurant, which Plaintiff did ingest and which caused serious injury to Plaintiff. iii. Failing to properly check the lines to make sure that they were free of potassium hydroxide after cleaning. 6

7 iv. Failing to ensure that the beverages that Ben E. Keith is responsible for providing and servicing at the Incident Restaurant was safe for human consumption. 20. Defendant Ben E. Keith s negligent conduct and/or omissions, as described above, taken singularly or in any combination, was the proximate cause of the incident and Plaintiff s injuries. C. GROSS NEGLIGENCE: AGAINST ALL DEFENDANTS 21. The wrongful acts and omissions of Defendants as described above is the type of conduct for which the law allows the imposition of exemplary damages in that it constitutes gross negligence. When viewed objectively from Defendant s standpoint at the time of the occurrence, Defendants conduct involved an extreme degree of risk, considering the probability and magnitude of the potential harm to others, and Defendants had actual, subjective awareness of the risk involved, but nevertheless preceded with conscious indifference to the rights, safety, or welfare of others, including Plaintiff. Plaintiff therefore seeks exemplary damages from Defendants in amounts to be determined by the trier of fact. D. PREMISES LIABILITY: AGAINST DEFENDANTS RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF TEXAS 0884, DARDEN SW LLC D/B/A RED LOBSTER, AND GMRI, INC. D/B/A RED LOBSTER # Plaintiff will show that at the time of the incident he was a business invitee of the Incident Restaurant and thus should have been shown the highest duty of care. Defendant failed to meet this level of care in that they did not ensure that the Beer that he purchased was safe to drink. Defendant failed to properly test the lines and ensure that the liquid that was flowing through them was safe for human consumption. 7

8 VI. DAMAGES 23. As a direct and proximate result of the negligent actions and/or inactions of Defendants, Plaintiff sustained serious physical injuries. These injuries have caused Plaintiff to suffer the following damages: i. Physical pain suffered immediately at the time of ingestion of the potassium hydroxide including burning sensation of the mouth, esophagus, and stomach; ii. Emotional distress suffered from the date and time of injury and which will, in all reasonable probability, Plaintiff will continue to suffer from in the future; iii. Mental anguish suffered from the date and time of injury and which will, in all reasonable probability, Plaintiff will continue to suffer from in the future; iv. Medical expenses incurred from the date and time of injury and, in all reasonable probability, will continue to accrue in the future; VII. EXEMPLARY DAMAGES 24. Plaintiff seeks exemplary damages caused by Defendants gross negligence and omissions. Exemplary damages are sought under Section (a)(2) of the Texas Civil Practices and Remedies Code, as defined by Section (7). Plaintiff also seeks exemplary damages under Section (a)(3) of the Texas Civil Practices and Remedies Code. VIII. JURY DEMAND 25. Plaintiff requests a trial by jury on all issues set forth herein. 8

9 IX. REQUEST FOR DISCLOSURE Additionally, pursuant to Rule 194 of the Texas Rules of Civil Procedure, Defendants are formally requested and required to disclose, within 50 days of service of the request, the information or material described in Rule of the Texas Rules of Civil Procedure X. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that citation be issued and served upon the above-named Defendants, commanding Defendants to appear and answer herein and that upon final hearing of this cause, and trial on the merits, judgment be entered for Plaintiff and against Defendants for compensatory damages in an amount within the jurisdictional limits of the Court, together with pre-judgment interest (from the date of injury through the date of judgment) at the maximum rate allowed by law; post-judgment interest at the legal rate; costs of court, and for such other and further relieve, at law or in equity, both general and special, to which Plaintiff may be justly entitled. Respectfully submitted, TORRY LAW GROUP, PLLC By: /s/ Jordan M. Torry TSBN: San Felipe, Suite 1000 Houston, Texas Telephone: (713) Facsimile: (713) ATTORNEY FOR PLAINTIFF 9

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

"\ll, NO.&A $ $ ' jf, _ [ $ , TEXA$1T. ':":,s /d:!.' f::{ 'i.jl. ANGELA BISHOFF and HEATH BISHOFF. DISTRICT COURT PLAINTIFFS, VS.

\ll, NO.&A $ $ ' jf, _ [ $ , TEXA$1T. '::,s /d:!.' f::{ 'i.jl. ANGELA BISHOFF and HEATH BISHOFF. DISTRICT COURT PLAINTIFFS, VS. NO.&A I t)t^ ' jf, _ "\ll, I ANGELA BISHOFF and HEATH BISHOFF. VS. PLAINTIFFS, ROADTIOUSE OF TEMPLE, LTD d/b/a TEXAS ROADHOUSE and STEVE LEE ORTIZ DEFENDANTS. DISTRICT COURT FJ 3 s c9 qp rf 1l co L.i x):'*

More information

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

No. 45TH. Plaintiff EDGEWOOD INDEPENDENT SCHOOL DISTRICT files its Original Petition FILED 9/24/2014 10:11:33 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,

More information

PREVIEW PLEASE DO NOT COPY THIS DOCUMENT THANK YOU. LegalFormsForTexas.Com

PREVIEW PLEASE DO NOT COPY THIS DOCUMENT THANK YOU. LegalFormsForTexas.Com Form: Plaintiff's original petition-wrongful Death [Name], PLAINTIFF vs. [Name], DEFENDANT [ IN THE [Type of Court] COURT [Court number] PLAINTIFF'S ORIGINAL PETITION 1. DISCOVERY CONTROL PLAN 1.1 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

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

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

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

CASE NO.: CIVIL DIVISION COMPLAINT. through undersigned counsel, and hereby sues Defendant, Winn-Dixie Stores, Inc., a Florida GENERAL ALLEGATIONS

CASE NO.: CIVIL DIVISION COMPLAINT. through undersigned counsel, and hereby sues Defendant, Winn-Dixie Stores, Inc., a Florida GENERAL ALLEGATIONS IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA, vs. Plaintiff, CASE NO.: CIVIL DIVISION WINN-DIXIE STORES, INC., Defendant, / COMPLAINT COMES NOW Plaintiff,,

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

COMES NOW, Plaintiff, John Doe, and files this Original Petition and Request for

COMES NOW, Plaintiff, John Doe, and files this Original Petition and Request for DC-14-07436 NO. FILED DALLAS COUNTY 7/14/2014 4:48:09 PM GARY FITZSIMMONS DISTRICT CLERK Sacheen Anthony JOHN DOE, vs. Plaintiff, TSAS, INC. DBA THE ST. ANTHONY SCHOOL and DAVID GREEN Defendants. IN THE

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

IN THE CIRCUIT COURT OF THE NINTH JUDICAL CIRCUIT IN AND FOR ORANGE COUNTY FLORIDA. Case No.

IN THE CIRCUIT COURT OF THE NINTH JUDICAL CIRCUIT IN AND FOR ORANGE COUNTY FLORIDA. Case No. IN THE CIRCUIT COURT OF THE NINTH JUDICAL CIRCUIT IN AND FOR ORANGE COUNTY FLORIDA SUZANNE MATTEIS, Plaintiff, DARDEN CORPORATION, a Florida Corporation. v. Case No. COMPLAINT FOR DAMAGES FOR PERSONAL

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

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

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

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

CAUSE NO. D-1-GN-08-003432. BRYN DUFFY, MD and IN THE DISTRICT COURT SUSANNE MATTSSON DUFFY. Defendant. TRAVIS COUNTY, TEXAS

CAUSE NO. D-1-GN-08-003432. BRYN DUFFY, MD and IN THE DISTRICT COURT SUSANNE MATTSSON DUFFY. Defendant. TRAVIS COUNTY, TEXAS CAUSE NO. D-1-GN-08-003432 BRYN DUFFY, MD and IN THE DISTRICT COURT SUSANNE MATTSSON DUFFY Plaintiffs, v. 353 RD JUDICIAL DISTRICT OF TEXAS MEDICAL LIABILITY TRUST Defendant. TRAVIS COUNTY, TEXAS PLAINTIFFS

More information

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI JANE DOE INDIVIDUALLY ) and on BEHALF OF ) THE CLASS OF PERSONS ) DESIGNATED BY 537.080, ) ) Plaintiff, ) ) Case Number *************** vs. ) ) DEFENDANT

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

In the United States District Court for the Western District of Texas

In the United States District Court for the Western District of Texas Case 5:13-cv-00960-XR Document 14 Filed 12/06/13 Page 1 of 6 In the United States District Court for the Western District of Texas Christine Barreras v. Wal-Mart Stores, Inc. SA-13-CV-960 ORDER On this

More information

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO DAVID ASHE Plaintiff, CIVIL NO. 10-2236 ( DRD ) vs. DISTRIBUIDORA NORMA,

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

GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent

GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent POMPELIO, FOREMAN & GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent HENRY KENT, vs. Plaintiff, SMILES II RESTAURANT,

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION NANCY PRITCHARD, v. Plaintiff, Case No.: KAPLAN HIGHER EDUCATION CORPORATION; KAPLAN HIGHER EDUCATION CORPORATION, as PLAN ADMINISTRATOR;

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 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION JASON LONG, Plaintiff, v. NO. 0:00-CV-000 ABC THE CHABON GROUP, INC., Defendant. DEFENDANT S MOTION FOR SUMMARY JUDGMENT

More information

CAUSE NO. DC-14-10061 JANA WECKERLY IN THE DISTRICT COURT. Defendants. DALLAS COUNTY, TEXAS PLAINTIFF S FIRST AMENDED ORIGINAL PETITION

CAUSE NO. DC-14-10061 JANA WECKERLY IN THE DISTRICT COURT. Defendants. DALLAS COUNTY, TEXAS PLAINTIFF S FIRST AMENDED ORIGINAL PETITION FILED DALLAS COUNTY 9/22/2014 1:59:03 PM GARY FITZSIMMONS DISTRICT CLERK CAUSE NO. DC-14-10061 JANA WECKERLY IN THE DISTRICT COURT Plaintiff, vs 134 TH JUDICIAL DISTRICT JERRY JONES, DALLAS COWBOYS FOOTBALL

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

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

STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH CASE NO. Plaintiff,

STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH CASE NO. Plaintiff, STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH Denis W. Stearns, Wis. Bar No. 1020675 MARLER CLARK, L.L.P., P.S. 701 Fifth Avenue, Suite 6600 Seattle, WA 98104 Telephone: (206) 346-1888 Facsimile:

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES Fernando F. Chavez, Esq. SBN 0 CHAVEZ LAW GROUP 00 West Beverly Blvd., Montebello, Ca 00 Phone: () 00-0, Facsimile: (0) 1-01 E-mail: ffchavez0@gmail.com Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE

More information

IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA. v. Civil Action No.:CL12-1617 Plaintiff Demands Trial by Jury COMPLAINT

IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA. v. Civil Action No.:CL12-1617 Plaintiff Demands Trial by Jury COMPLAINT IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA MIGUEL RUIZ, HUSAIN SALAH, MOHAMED ABDELWAHAM, ANDREW BRZEZINSKI, MARIO CLOTTER, HECTOR SANCHEZ, CLIFFORD LACON, and JIMMY SABGA, RICHARD HICKS Plaintiff,

More information

IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI

IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI STEPHANIE BRUNO, 3900 NW 60 th Place Kansas City, Missouri 64151 and JOHN AND C.D. BRUNO, 4702 NW Linden Rd Kansas City,

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

Complaint - Walmart Substance on Floor in Frozen Food Dept.

Complaint - Walmart Substance on Floor in Frozen Food Dept. Home Slip and Fall - Pleadings Main Index - Complaint Walmart Frozen Food Dept Complaint - Walmart Substance on Floor in Frozen Food Dept. IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD

More information

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI JANE DOE, Plaintiff, vs. Case Number 1131-********* MISSOURI COMPANY, and INDIANA COMPANY Defendants. FIRST AMENDED PETITION FOR DAMAGES COMES NOW Plaintiff,

More information

Case 3:11-cv-00671-B Document 1 Filed 04/01/11 Page 1 of 11 PageID 1

Case 3:11-cv-00671-B Document 1 Filed 04/01/11 Page 1 of 11 PageID 1 Case 3:11-cv-00671-B Document 1 Filed 04/01/11 Page 1 of 11 PageID 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION PAULA BUNTON Plaintiff, V. WALGREENSCOMPANY Defendant.

More information

CAUSE NO. V. WILLIAMSON COUNTY, TEXAS. Defendant. JUDICIAL DISTRICT PLAINTIFFS ORIGINAL PETITION

CAUSE NO. V. WILLIAMSON COUNTY, TEXAS. Defendant. JUDICIAL DISTRICT PLAINTIFFS ORIGINAL PETITION CAUSE NO. MARY DOE and IN THE DISTRICT COURT JOHN DOE, Plaintiffs, V. WILLIAMSON COUNTY, TEXAS STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. JUDICIAL DISTRICT PLAINTIFFS ORIGINAL PETITION

More information

CONUMONWEALTHOFKENTUCKY FA VETTE CIRCUIT COURT CASE NO. ;V -{ l-7031 DIVISIONS:-. 306 W Main Street, Suite 512 C. T. CORPORATION SYSTEM

CONUMONWEALTHOFKENTUCKY FA VETTE CIRCUIT COURT CASE NO. ;V -{ l-7031 DIVISIONS:-. 306 W Main Street, Suite 512 C. T. CORPORATION SYSTEM .:" \ ".. "!~'._. '1 I CONUMONWEALTHOFKENTUCKY FA VETTE CIRCUIT COURT CASE NO. ;V -{ l-7031 DIVISIONS:-. ANTONIO TAYLOR, JR., a minor, and by his next friend and mother, JERRISHA COOMER PLAINTIFF v. COMPLAINT

More information

CASE NO.: COMPLAINT. Plaintiff, [PLAINTIFF S NAME], by and through her parent and natural guardian

CASE NO.: COMPLAINT. Plaintiff, [PLAINTIFF S NAME], by and through her parent and natural guardian Form 2:150 Dog Bite Sample Complaint IN THE CIRCUIT COURT OF THE TH JUDICIAL CIRCUIT IN AND FOR COUNTY, FLORIDA [PLAINTIFF S NAME], by and through her parent and natural guardian, [PLAINTIFF S PARENT S

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

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES (SPACE BELOW FOR FILING STAMP ONLY) LAW FIRM OF KAISER, DEBIASO. ANDREW AND SWINDELLS SUMfTOMO TOWER NINTH FLOOR 444 WEST OCEAN BOULEVARD LONG BEACH, CALIFORNIA 90802-4516 (310) 590-8471 ERIC C. DEMLER

More information

COMPLAINT. COMES NOW the Plaintiffs, JERRY BYNUM, as Personal Representative of the Estate

COMPLAINT. COMES NOW the Plaintiffs, JERRY BYNUM, as Personal Representative of the Estate IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JERRY BYNUM, as Personal Representative of the Estate of REGINA BYNUM, deceased; and JERRY BYNUM, individually, Plaintiffs,

More information

1.1 Pursuant to Tex. R. Civ. P. 190.4, plaintiffs move the Court for a Level 3 II. PARTIES

1.1 Pursuant to Tex. R. Civ. P. 190.4, plaintiffs move the Court for a Level 3 II. PARTIES CAUSE NO. VALERIE REDUS, INDIVIDUALLY, AND IN THE DISTRICT COURT AND ROBERT M. REDUS, INDIVIDUALLY AND AS ADMINISTRATOR OF THE ESTATE OF ROBERT CAMERON REDUS OF BEXAR COUNTY, TEXAS V. UNIVERSITY OF INCARNATE

More information

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R NO. MELISSA ROWE, Individually and as Mother and Next Friend of E.R VS. COMPLAINT JEFFERSON CIRCUIT COURT JUDGE DIVISION PLAINTIFF LANA KAELIN c/o Eastern High School 12400 Old Shelbyville Road Louisville,

More information

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) )

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) Case :-cv-00-loa Document Filed 0// Page of 0 Bradley Jardis, vs. Keith M. Knowlton, L.L.C. SBN 0 S. Rural Road, Suite 0, PMB# Tempe, Arizona -00 (0 -; FAX (0 - Keith M. Knowlton - SBN 0 Attorney for Plaintiff

More information

FULTON COUNTY STATE COURT STATE OF GEORGIA * * * * * * * * * *

FULTON COUNTY STATE COURT STATE OF GEORGIA * * * * * * * * * * FULTON COUNTY STATE COURT STATE OF GEORGIA JENNIFER GARRISON, vs. Plaintiff, MONTAG REALTY COMPANY, LLC d/b/a VERONA APARTMENTS, THE REALTY FUND III, L.P. and JOHN DOES 1-5, JURY TRIAL DEMANDED CASE NUMBER:

More information

AN OVERVIEW OF DAMAGES IN GEORGIA. By Craig R. White

AN OVERVIEW OF DAMAGES IN GEORGIA. By Craig R. White AN OVERVIEW OF DAMAGES IN GEORGIA By Craig R. White SKEDSVOLD & WHITE, LLC. 1050 Crown Pointe Parkway Suite 710 Atlanta, Georgia 30338 (770) 392-8610 FAX: (770) 392-8620 EMAIL: cwhite@skedsvoldandwhite.com

More information

Case 3:14-cv-02361-P Document 1 Filed 06/30/14 Page 1 of 9 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

Case 3:14-cv-02361-P Document 1 Filed 06/30/14 Page 1 of 9 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION Case 3:14-cv-02361-P Document 1 Filed 06/30/14 Page 1 of 9 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION JAMES MICHAEL CLINE, Plaintiff VS. Civil Action No. 3:14-cv-2361

More information

4. Whole Foods Market, Inc. is a Texas Corporation whose principal office in

4. Whole Foods Market, Inc. is a Texas Corporation whose principal office in 4. Whole Foods Market, Inc. is a Texas Corporation whose principal office in this state is 601 North Lamar Blvd, Austin, Texas 78703. It may be served with process by serving CT Corporation System, 1021

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION. Plaintiffs, C. A. NO. VS.

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION. Plaintiffs, C. A. NO. VS. Case 4:12-cv-02469 Document 1 Filed in TXSD on 08/17/12 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION INDEMNITY INSURANCE COMPANY OF NORTH AMERICA;

More information

Case 4:09-cv-00502-RCC Document 1 Filed 09/04/09 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff,

Case 4:09-cv-00502-RCC Document 1 Filed 09/04/09 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, Case :0-cv-000-RCC Document Filed 0/0/0 Page of DAVID MONROE QUANTZ, P.L.C. E. Camp Lowell Dr. Tucson, Arizona ( -00 David Monroe Quantz State Bar No: 000 david@quantzlawfirm.com Attorney for Plaintiff

More information

1416-CV14463. 1. Plaintiff is a resident of Jackson County, Missouri and is the biological mother of

1416-CV14463. 1. Plaintiff is a resident of Jackson County, Missouri and is the biological mother of IN THE CIRCUIT COURT FOR JACKSON COT]NTY, MISSOURI AT INDEPENDENCE TAMMY BRYANT, Natural Mother of Kevin'Wahlers, Deceased, vs. Plaintiff ASRA, LLC dlbla 40 HIGHV/AY SINCLAIR Serve Registered Agent: Rizwan

More information

Case 1:13-cv-00001-SEB-TAB Document 1 Filed 01/02/13 Page 1 of 7 PageID #: 1

Case 1:13-cv-00001-SEB-TAB Document 1 Filed 01/02/13 Page 1 of 7 PageID #: 1 Case 1:13-cv-00001-SEB-TAB Document 1 Filed 01/02/13 Page 1 of 7 PageID #: 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION JAIME MILLER, Plaintiff v. No.: 1:13-cv-1 CITY

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

CAUSE NO. RICHARD SANCHEZ, HEATHER IN THE DISTRICT COURT SANCHEZ, TODD KING AND LACI KING, Plaintiffs,

CAUSE NO. RICHARD SANCHEZ, HEATHER IN THE DISTRICT COURT SANCHEZ, TODD KING AND LACI KING, Plaintiffs, CAUSE NO. RICHARD SANCHEZ, HEATHER IN THE DISTRICT COURT SANCHEZ, TODD KING AND LACI KING, Plaintiffs, v. OF UNION PACIFIC RAILROAD, INC., AND SMITH INDUSTRIES, INC. Defendants. MIDLAND COUNTY, TEXAS PLAINTIFFS

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

DISTRICT COURT CLARK COUNTY, NEVADA

DISTRICT COURT CLARK COUNTY, NEVADA 1 1 1 CRAIG MURPHY MURPHY & MURPHY LAW OFFICES 1 Park Run Drive, Suite 0 Las Vegas, Nevada 1 0.. 0..0 WILLIAM D. MARLER, ESQ. MARLER CLARK 1 Second Avenue, Suite 00 Seattle, WA 1 Telephone: () - Facsimile:

More information

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ELECTRONICALLY FILED 5/18/2012 2:30 PM CV-2012-901583.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ZACHARY

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

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

CAUSE NO. THE CITY OF AUSTIN, TEXAS IN THE DISTRICT COURT OF VS. TRAVIS COUNTY, TEXAS NEDITH TORRES JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION

CAUSE NO. THE CITY OF AUSTIN, TEXAS IN THE DISTRICT COURT OF VS. TRAVIS COUNTY, TEXAS NEDITH TORRES JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION CAUSE NO. THE CITY OF AUSTIN, TEXAS IN THE DISTRICT COURT OF VS. TRAVIS COUNTY, TEXAS NEDITH TORRES JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES THE CITY

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

Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION CHRISTOPHER M. JENSEN, v. Plaintiff, LEON COUNTY, FLORIDA,

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

CAUSE NO. IN THE DISTRICT COURT. Xxxxx Yyyyy Plaintiffs JUDICIAL DISTRICT. Aaaaa Bbbbb Cccccc Ddddd WHAT COUNTY, TEXAS. Defendants

CAUSE NO. IN THE DISTRICT COURT. Xxxxx Yyyyy Plaintiffs JUDICIAL DISTRICT. Aaaaa Bbbbb Cccccc Ddddd WHAT COUNTY, TEXAS. Defendants CAUSE NO. Xxxxx Yyyyy Plaintiffs V. Aaaaa Bbbbb Cccccc Ddddd Defendants IN THE DISTRICT COURT JUDICIAL DISTRICT WHAT COUNTY, TEXAS PLAINTIFF S ORIGINAL PETITION AND APPLICATION FOR TEMPORARY RESTRAINING

More information

THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANTS: the Complaint which is herewith served upon you within twenty (20) days after the service of

THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANTS: the Complaint which is herewith served upon you within twenty (20) days after the service of STATE OF MINNESOTA COUNTY OF DAKOTA DISTRICT COURT FIRST JUDICIAL DISTRICT CASE TYPE: Personal Injury ERIC GUSTAFSON and JENNIFER GUSTAFSON, Individually and as parents and natural guardians for CALLIE

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

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * *

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * * IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA vs. Plaintiffs, CIVIL ACTION NUMBER CV-99-792 Defendants. COMPLAINT 1. Plaintiffs, Bryan K. Bunten and Lisa Bunten, are over the age of nineteen (19) years

More information

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION. Plaintiff, Defendant. JURISDICTION 1.

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION. Plaintiff, Defendant. JURISDICTION 1. RICHARD A. MANN, OSB No. 001640 Internet Email Address: rmann@brownsteinrask.com BROWNSTEIN RASK SWEENY LLP 1200 SW Main Street Portland, OR 97205 Telephone: (503) 412-6735 Facsimile: (503) 221-1074 DEVIN

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO. Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO. Defendant William D. Marler Marler Clark LLP PS 01 Second Ave, Suite 00 Seattle, WA 1-0 Ph: IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE DOROTHY H. PEARCE, vs. Plaintiff,

More information

IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH

IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH LAURIE PAUL, individually and on behalf of all other similarly-situated individuals, Plaintiff, vs. PROVIDENCE HEALTH SYSTEMS-

More information

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) IN THE SUPERIOR COURT OF THE STATE OF DELAWARE IN RE ASBESTOS LITIGATION: STEVEN P. SCHULTZ and KIMBERLY S. SCHULTZ, Plaintiffs, v. COLGATE-PALMOLIVE COMPANY; COTY, INC.; CYPRUS AMAX MINERALS COMPANY (sued

More information

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY, UTAH

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY, UTAH Robert G. Gilchrist (3715) Jeff M. Sbaih (14014) EISENBERG GILCHRIST & CUTT 900 Parkside Tower 215 South State Street Salt Lake City, Utah 84111 Phone: (801) 366-9100 Email: rgichrist@egclegal.com Email:

More information

Haro was at home with his family when they saw an intruder lurking in their backyard. When

Haro was at home with his family when they saw an intruder lurking in their backyard. When 500 Yam hill Plaza Building 815 S.W. Second Avenue Portland, Oregon 97204 Phone: (503) 1-1792 Fax: (503) 1516 Of Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON ADALBERTO

More information

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION LAURA HIMES-RUETH, CASE NO.: Plaintiff, vs. DR. MANUEL ABREU and ALL CARE MEDICAL CONSULTANTS PA, a

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

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

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DECLARATORY JUDGMENT Case 1:15-cv-02184-ODE Document 1 Filed 06/17/15 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION BANKERS STANDARD INSURANCE COMPANY, Plaintiff, v.

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO 1 1 1 1 1 1 1 1 0 1 LAW OFFICES OF FERNANDO F. CHAVEZ Fernando Fabela Chavez, Esq., (SBN: 0 10 The Alameda #01 San Jose, CA 1 (0 1-0 Telephone / (0 1-0 Facsimile Attorneys for Plaintiffs GUILLERMINA MORALES

More information

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL. Plaintiff, TARIN SAROKA, individually, and as the Personal Representative of the

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL. Plaintiff, TARIN SAROKA, individually, and as the Personal Representative of the IN THE CIRCUIT COURT FOR THE 15 TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA TARIN SAROKA, individually and as the Personal Representative of the Estate of ALAN BAZINET, CIVIL DIVISION CASE

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA ORLANDO DIVISION COMPLAINT FOR DISABILITY INSURANCE BENEFITS

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA ORLANDO DIVISION COMPLAINT FOR DISABILITY INSURANCE BENEFITS UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA ORLANDO DIVISION FREDERICK FREEMAN, Plaintiff, CASE NO. v. MONARCH LIFE INSURANCE COMPANY; A foreign corporation. Defendant. / COMPLAINT FOR DISABILITY

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

No. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff,

No. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff, No. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff, V. THE CAPELLA GROUP, INC., D/B/A CARE ENTRÉE; EQUAL ACCESS HEALTH, INC., TRAVIS COUNTY, T E X A S D/B/A HEALTH BENEFITS OF AMERICA, E A H, EA HEALTH,

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION MARCIA OLSON, ) ) Plaintiff, ) ) Case No: v. ) ) HOWMEDICA OSTEONICS CORP. d/b/a ) STRYKER ORTHOPAEDICS, ) JURY TRIAL DEMANDED

More information

Fourth Court of Appeals San Antonio, Texas

Fourth Court of Appeals San Antonio, Texas Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION No. 04-13-00815-CV IN THE ESTATE OF Alvilda Mae AGUILAR From the Probate Court No. 2, Bexar County, Texas Trial Court No. 2012-PC-2802 Honorable

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

IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA VERIFIED COMPLAINT FOR PERSONAL INJURY DAMAGES AND DEMAND FOR TRIAL BY JURY

IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA VERIFIED COMPLAINT FOR PERSONAL INJURY DAMAGES AND DEMAND FOR TRIAL BY JURY IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA CARINA ROCK, Plaintiff, CIVIL ACTION FILE NO. v. JO-ANN L. MOORE, Defendant. VERIFIED COMPLAINT FOR PERSONAL INJURY DAMAGES AND DEMAND FOR TRIAL BY JURY

More information

2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County. No. CV05-045 (A)L. June 12, 2006. Second Amended Complaint

2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County. No. CV05-045 (A)L. June 12, 2006. Second Amended Complaint 2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County Charlene DUNN, Plaintiff, v. John A. MURPHY, Future Benefits, Inc. American Equity Investment Life Insurance Company,

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

FILED: NASSAU COUNTY CLERK 07/12/2013 INDEX NO. 601780/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/12/2013

FILED: NASSAU COUNTY CLERK 07/12/2013 INDEX NO. 601780/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/12/2013 FILED: NASSAU COUNTY CLERK 07/12/2013 INDEX NO. 601780/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/12/2013 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ----------------------------------------------------------------------}C

More information

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) )

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) ) CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA File No. Julius Chad Zimmerman, Plaintiff, v. Dave Bellows, in his individual and official

More information

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION Case 3:14-cv-03585-N Document 1 Filed 10/03/14 Page 1 of 16 PageID 1 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION DAVID HARRISON, Individually and as Personal Representative

More information

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY THE HONORABLE CAROL MURPHY 1 1 1 1 1 SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY TARVA LEE, ) ) No: --00- Plaintiff, ) ) v. ) COMPLAINT FOR BREACH OF ) CONTRACT, BAD FAITH, FARMERS INSURANCE COMPANY

More information

2009-55767 / Court: 190

2009-55767 / Court: 190 2009-55767 / Court: 190 C. A. No. Filed 09 August 31 P3:58 Loren Jackson - District Clerk Harris County ED101J015&0462 By: Sharon Carlton GIL COSTAS, DVM, IN THE DISTRICT COURT OF Plaintiff, HARRIS COUNTY,

More information

Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 Civil Action No. 12-CV-3270 BALBOA INSURANCE COMPANY, Plaintiff v. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

More information

CAUSE NO. PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE, INTERROGATORIES, AND REQUEST FOR PRODUCTION. A. Discovery Control Plan

CAUSE NO. PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE, INTERROGATORIES, AND REQUEST FOR PRODUCTION. A. Discovery Control Plan CAUSE NO. CHALALA GUTIERREZ, Individually THE DISTRICT COURT OF and as Representative of the Estate of RICHARD THOMAS VEGA, II, Deceased and as Next Friend for RICHARD THOMAS VEGA, III, a Minor Child and

More information

IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF TEXAS DIVISION

IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF TEXAS DIVISION IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF TEXAS DIVISION IN RE: * * [Debtor s Name] * (***-**-last four digits of SSN) * Case No. - [Joint Debtor s Name, if any * Chapter 13 (***-**-last

More information

Case 4:14-cv-00248-A Document 1 Filed 04/10/14 Page 1 of 4 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

Case 4:14-cv-00248-A Document 1 Filed 04/10/14 Page 1 of 4 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION Case 414-cv-00248-A Document 1 Filed 04/10/14 Page 1 of 4 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION Katrina Hilliard, v. Plaintiff, GTC Auto Sales, Inc. d/b/a

More information

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8 Case :0-cv-0-JCM-LRL Document Filed 0//0 Page of Reno, NV ( -00 Fax ( 0-0 0 Mark R. Thierman, NV# laborlawyer@pacbell.net THIERMAN LAW FIRM, P.C. Reno, Nevada Tel: ( -00 Fax: ( 0-0 David R. Markham, CAL#

More information