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

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1 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 V. DENTON COUNTY, TEXAS CAUSEY EGLOFF, and ROADHOUSE 380 LLC d/b/a VARSITY ROADHOUSE and MOOSE RANCH of TEXAS LLC Defendants JUDICIAL DISTRICT PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND RULE NOTICE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES JULIE TORBERT, AS NEXT FRIEND OF PHILIP ORMSTON, and files this Original Petition, complaining of and about Defendants, Roadhouse 380 LLC d/b/a Varsity Roadhouse and Moose Ranch of Texas LLC and Causey Egloff and in support thereof, show the Court the following: I. DISCOVERY CONTROL PLAN 1.1 Pursuant to Texas Rules of Civil Procedure 190 the discovery of this case is to be conducted under Level 3. II. PARTIES AND SERVICE 2.1 Julie Torbert, as next friend of Philip Ormston is an individual and resident of the State of Texas. Plaintiff s address is 1920 Blue Ridge Ct. Savannah, TX

2 2.2 Defendant, Roadhouse 380 LLC d/b/a Varsity Roadhouse and Moose Ranch of Texas LLC (hereinafter, Roadhouse ), is a Texas corporation whose registered office address is U.S. 380, Aubrey, Texas Service of process may be had upon Roadhouse by personal service to its registered agent, Kenneth Long, 124 Rose Lane, Bldg. #6, Suite 601, Frisco, TX Defendant, Causey Egloff Jr., (hereinafter Egloff ) is an individual, and resident of Denton County, Texas. Service of process may be had upon Egloff by personal service at 1512 Cotton Gin Dr., Savannah, Texas III. JURISDICTION AND VENUE 3.1 The subject matter in controversy is within the jurisdictional limits of this court. Further, both Defendants, by residing in and organizing under the laws of the State of Texas, are subject to the personal jurisdiction of this Court. 3.2 Venue in Denton County is proper in this cause under Sections (a)(1) of the Texas Civil Practice and Remedies Code because all or a substantial part of the events or omissions giving rise to this lawsuit occurred in this county. IV. ALCOHOL TRANSACTION 4.1 On or about the evening of May 17, 2014, Defendant Egloff went to Roadhouse, located at U.S. 380, Aubrey, Texas Roadhouse, both on May 17, 2014 and since, was also a 2

3 provider of alcoholic beverages under the Texas Dram Shop statute Tex. Code Ann (b)(1). 4.2 As a provider of alcoholic beverages, Roadhouse served an excessive number of alcoholic beverages to Defendant Causey Egloff, even though it was apparent to Roadhouse that Egloff was obviously intoxicated to the extent that he presented a clear danger to himself and others. After Roadhouse chose to sell substantial amounts of alcohol to Egloff, rather than refusing the sale, calling the police, or calling a cab, Roadhouse allowed Egloff to leave its establishment whereupon he proceeded to get into his vehicle in the parking lot of the Roadhouse establishment, and drive. 4.3 Thereafter, due to his grossly intoxicated state, Egloff failed to look where he was going and failed to yield to traffic in a prudent and reasonable fashion and caused an extremely frightening, dangerous, and devastating collision. After pulling out in front of the Plaintiff causing a T-bone collision with the vehicle Plaintiff was in, he fled the scene of the collision. Plaintiffs were seriously injured in the collision. The collision was caused by Egloff s highly intoxicated state that rendered him unable drive and handle his vehicle as a reasonably prudent driver would under similar circumstances. Specifically, he was unable to properly maneuver his vehicle in and out of traffic, to yield the right a way, to keep a proper lookout, or even appreciate the risks involved in his actions. V. INJURY TO PLAINTIFFS 5.1 As a result of Defendant Egloff s reckless driving itself, a direct and proximate result of his severe intoxication, Plaintiff was seriously injured. Plaintiff suffered, among other injuries, brain 3

4 damage which placed him into a coma requiring full time care. Plaintiff has experienced substantial pain and suffering, disfigurement and permanent disability as a result of these injuries and will continue to do so for the remainder of his life. Due to the extensive nature of the collision, Plaintiff has also been forced to incur substantial medical bills and loss of income and will be forced to incur further such economic losses in the future including full time medical care. VI. PROXIMATE CAUSE 6.1 Defendant Egloff s intoxication and Roadhouse s sale of alcoholic beverages to Egloff after it was apparent that he was obviously intoxicated was a proximate cause of the injuries and damages suffered by the Plaintiffs. VII. DEFENDANT ROADHOUSE VIOLATED THE TEXAS ALCOHOLIC BEVERAGE CODE AND WAS NEGLIGENT 7.1 Defendant Roadhouse, its agents, servants, and /or employees, at all times material were in direct violation of the Texas Alcoholic Beverage Code, Chapter 2, in their provision of alcoholic beverages to Egloff. In particular: 1) Roadhouse was a provider of alcoholic beverages as defined in TEX. ALCO. BEV. CODE ANN. 2.01(1)(Vernon 1987); 2) The service and/or sale of alcoholic beverages to Egloff was a provision of alcoholic beverages as defined in TEX. ALCO. BEV. CODE ANN. 4

5 2.01(2)(Vernon 1987). 3) At the time the provision of alcohol occurred, it was apparent to Roadhouse by and through its agents, servants and/or employees, that Egloff, the person to whom Roadhouse sold, served and/or provided alcoholic beverages, was obviously intoxicated to the extent that he presented a clear danger to himself and others; and 4) Egloff s intoxication and Roadhouse s sale of alcoholic beverages to Egloff after it was apparent that he was obviously intoxicated was a proximate cause of the injuries and damages suffered by Plaintiff. 7.2 When a provider of intoxicants sells, serves or otherwise provides an alcoholic beverage to an obviously intoxicated person thereby contributing to his already dangerously intoxicated state, the provider becomes liable for any harm caused by the intoxicated person due to his intoxication. Egloff s conduct of operating a motor vehicle while intoxicated combined with Roadhouse s provision of alcohol to Egloff while he was obviously intoxicated, was a proximate cause of the injuries and damages suffered by the Plaintiffs. Roadhouse is directly liable to the Plaintiffs for its violation of the Texas Alcoholic Beverage Code and resulting injuries caused to Plaintiff as a result of Roadhouse s over-service of alcohol and Egloff s intoxication. VIII. PLAINTIFFS CLAIM OF NEGLIGENCE AGAINST CAUSEY EGLOFF 8.1 Defendant Egloff had a duty to exercise the degree of care that a reasonably careful person would use to avoid harm to others under circumstances similar to those described herein. 5

6 8.2 Plaintiff s injuries were proximately caused by Defendant Egloff s negligent, careless and reckless disregard of said duty. 8.3 The negligent, careless and reckless disregard of duty of Defendant Egloff consisted of, but is not limited to, the following acts and omissions: A. In that Defendant Egloff failed to yield the right of way and control the direction of his vehicle to avoid striking other objects; B. In that Defendant Egloff failed to apply his brakes at an appropriate time in order to avoid colliding with other objects; and C. In that Defendant Egloff was highly intoxicated while operating his motor vehicle. IX. PLAINTIFFS CLAIM OF NEGLIGENCE PER SE AGAINST CAUSEY EGLOFF 9.1 Defendant Egloff s conduct described herein constitutes an unexcused breach of duty imposed by Section of the Texas Transportation Code. 9.2 Specifically, Section of the Texas Transportation Code provides that (a) An operator of a vehicle involved in an accident resulting in the injury or death of a person or damage to a vehicle that is driven or attended by a person shall (1) give the operator s name and address, the registration number of the vehicle the operator was driving, and the name of the 6

7 operator s motor vehicle liability insurer to any person injured or the operator or occupant of or person attending a vehicle involved in the collision; and (3) provide any person injured in the accident reasonable assistance, including transporting or making arrangements for transporting the person to a physician or hospital for medical treatment if it is apparent that treatment is necessary, or if the injured person requests the transportation. 9.3 Defendant Egloff s conduct described herein constitutes an unexcused breach of duty imposed by Section 49.04(a) of the Texas Penal Code. 9.4 Specifically, Defendant Egloff breached the duty imposed by Texas Penal Code 49.04(a), which provides that a person commits an offense if the person is intoxicated while operating a motor vehicle in a public place. 9.5 Plaintiffs are members of the class that the Texas Transportation Code and Section of the Texas Penal Code were designed to protect. 9.6 Defendant Egloff s unexcused breach of the duties imposed by Section , of the Texas Transportation Code and Section of the Texas Penal Code were a proximate cause of the injuries and damages to the Plaintiffs described herein. X. MALICE AND EXEMPLARY DAMAGES 10.1 The wrong done by Defendants was aggravated by the kind of gross negligence, malice, and callous disregard for which the law allows the imposition of exemplary damages. 7

8 The conduct of the Defendants, when viewed objectively from the standpoint of Defendants at the time of the conduct, involved an extreme degree of risk, considering the probability and magnitude of the potential harm to others, and the Defendants were actually, subjectively aware of the risk involved, but nevertheless proceeded with conscious indifference to the rights, safety, or welfare to others. The Defendants acts of omission and commission, which collectively and severally constituted malice, were a proximate cause of the injuries and damages suffered by the Plaintiffs. As such, Plaintiffs seek exemplary damages in an amount to be determined by a jury. XI. INTOXICATION ASSAULT 11.1 Defendant Egloff s conduct amounts to the offense of intoxication assault, because Defendant Egloff, by accident or mistake, while operating a motor vehicle in a public place while intoxicated, by reason of that intoxication caused serious bodily injury to Plaintiff in violation of Texas Penal Code 49.07(a). Each of the stated acts and/or omissions constitutes intoxication assault, and the same are a direct and proximate cause of the injuries and damages sustained by Plaintiff. XII. DAMAGES FOR PLAINTIFF 12.1 As a direct and proximate result of the occurrence made the basis of this lawsuit, Plaintiff has been caused to suffer severe injuries, including but not limited to, those injuries described above and to incur the following damages: A. Medical care expenses; 8

9 B. Physical pain and mental anguish; C. Loss of earning capacity; D. Disfigurement; and E. Physical impairment. XIII. PAST AND FUTURE DAMAGES 13.1 All damages mentioned in the above paragraphs are in the past and future where applicable. XIV. RULE NOTICE 14.1 Pursuant to Rule of the Texas Rules of Civil Procedure, Plaintiff hereby gives actual notice to Defendants that any and all documents produced may be used against the Defendants producing the document at any pre-trial proceeding and/or at the trial of this matter without the necessity of authenticating the documents. XV. REQUESTS FOR DISCLOSURE 15.1 Pursuant to Rule 194 of the Texas Rules of Civil Procedure, all parties named herein as Defendants are requested to disclose, within fifty (50) days of service of this request, the information or material described in Texas Rule of Civil Procedure 194.2(a)-(l). 9

10 XVI. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiffs respectfully pray that the Defendants be cited to appear and answer herein, and that upon a final hearing of the cause, judgment be entered for the Plaintiffs against Defendants, jointly and severally, for damages in an amount within the jurisdictional limits of the Court; exemplary damages, as addressed to Defendants per Section , Chapter 41, Texas Civil Practice and Remedies Code, excluding interest, and as allowed by Sec , Chapter 41, Texas Civil Practice and Remedies Code, 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 such other and further relief to which the Plaintiffs may be entitled at law or in equity. Respectfully submitted, /s/ Hunt Bonneau. Hunt Bonneau State Bar Number: PO Box 2351 Frisco, TX Telephone: (469) Facsimile: (469) ATTORNEY FOR PLAINTIFF 10

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