HARRIS COUNTY BANDIT SIGN LITIGATION SUMMARY



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HARRIS COUNTY BANDIT SIGN LITIGATION SUMMARY CAUSE NO. 939928: HARRIS COUNTY, TEXAS V. TERRENCE MICHAELS; IN THE COUNTY CIVIL COURT AT LAW NO. 3 OF HARRIS COUNTY, TEXAS CA# 421479 BSR Bandit Sign Removal case for violations of Texas Transportation Code. 1 sign/1 day located at Boudreaux @ SH 249 advertising "Painting." Non-suited original defendant Terrence Michaels and added proper defendant Raju Vargese. STATUS: Waiting on citation for Mr. Vargese. Discovery is ready to go also. CAUSE NO. 2008-40720: HARRIS COUNTY, TEXAS V. ROBERT B. HINSLEY. IN THE 157 TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS. C.A. FILE NO. 415089-BSR. Sign Rangers observed and reported not less than 26 signs advertising "Credit Card Debt & Bankruptcy" in the public rights-of-way along FM 1960 at the intersections of Aldine Westfield Rd., Woodcreek North Dr. and Treaschwig Rd. Signs were also found at the Louetta Rd. @ Lexington Rd., Aldine Westfield Rd. @ Bellchase Dr., Cypresswood Dr., Old Cypreswood Dr., Old Aldine Westfield Rd., Trailing Vine Rd., Wood River Dr., and Hirschfield Rd. in the unincorporated area of Northern Harris County, Texas. Defendant filed a general denial. STATUS: Parties entered and Agreed Permanent Injunction to remove all such signs and agree to not violate the bandit sign laws. Defendant paid a civil penalty of $1,000.00 plus $280.00 in Court costs. CAUSE NO. 939925: HARRIS COUNTY, TEXAS V. DANIEL PLOOF; IN THE COUNTY CIVIL COURT AT LAW NO. 2 OF HARRIS COUNTY, TEXAS. CA# 421389 BSR and 421408 BSR. Bandit Sign Removal case for signs advertising "Pressure Washing and Mr. Handyman". Mr. Ploof made appointments to meet with Assistant County Attorney Gale to discuss this case. He has/had at least 4 signs in the area of Grant and Jones Roads 1 day. STATUS: Our investigators were unable to obtain service. I have filed a Motion for Substitute Service and am waiting on the judge to sign the order. Discovery is ready to go also.

NO. 911,000: HARRIS COUNTY, TEXAS v. HAMMERSMITH GROUP, INC. IN THE COUNTY CIVIL COURT AT LAW NO. 4 OF HARRIS COUNTY, TEXAS. CA FILE NO. 408749. Law enforcement officers observed and documented one or more bandit signs advertising Espree Homes and Roycebuilders.com that were placed in the public right-of-way along Grant Road and Grants Trace Trail in violation of state law. STATUS: Suit was dismissed because land upon which signs were placed was owned by Defendants. CAUSE NO. 939927: HARRIS COUNTY, TEXAS V. THREADGILL SHEET METAL WORKS, INC. IN THE COUNTY CIVIL COURT AT LAW NO. 1 OF HARRIS COUNTY, TEXAS CA #424391 BSR. Bandit Sign Removal case for signs advertising "Sheetmetal work". 2 signs/1 day at Boudreau Road and SH249. President of company came in promptly after being served. STATUS: Agreed settlement for $250.00 in civil penalties which he paid at that time. NO. 2008-64377: HARRIS COUNTY, TEXAS V. BEAZER HOMES TEXAS HOLDINGS, INC. d/b/a BEAZER HOMES TEXAS, L.P. and YW HOLDINGS LLC d/b/a CASTLEROCK COMMUNITIES, L.P.; CASTLEROCK COMMUNITIES, L.P., L.L.P. and NEWLAND DEVELOPMENT LLC, d/b/a 80 HUFFSMITH VENTURE LTD. IN THE 125 TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS. C.A. FILE NO. 408788 BSR Approximately 8 signs were observed and reported advertising Ashford Place, CastleRock and Beazer Homes in the public right-of-way along Huffsmith-Kohrville Road at Lacey Drive, in violation of state law. STATUS: Suit was dismissed because land upon which signs were placed was owned by Defendants. No. 914,094: HARRIS COUNTY, TEXAS v. KB HOME LONE STAR, INC. d/b/a KB HOME HOUSTON. IN THE COUNTY CIVIL COURT AT LAW NO. 4 OF HARRIS COUNTY, TEXAS. C.A. FILE NO. 408830. Law enforcement officers observed one or more bandit signs advertising KB Home, Northern Point, that was placed in the public right-of-way along Huffsmith-Kohrville Road south of Boudreaux Road. Defendants filed a General Denial. Discovery was exchanged. STATUS: Suit was dismissed because land upon which signs were placed was owned by Defendants.

CAUSE NO. 2009-39283: HARRIS COUNTY V. ROBERT B. HINSLEY. IN THE 334 TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS. C.A. FILE NO. 08-TRL- 0130 (415089BSR). On or about June 5, 2009, Sign Rangers observed and reported not less that 21 bandit signs advertising "Credit Card Debt & Bankruptcy" on SH 2920 at Rhoden Rd., Gosling Rd., Kuykendahl Road. Defendant filed a General Denial. STATUS: On July 21, 2009 amended pleadings to name sign mule, Stephanie Jaeger, as a Defendant. Jaeger agreed to cooperate with investigation and signed a Waiver of Citation. Informal discovery revealed Houston Varner as another sign mule. Will prepare Second Amended Original Petition to include Varner as Defendant. On 8.20.2009, Defendant Hinsley entered into an Agreed Interlocutory Permanent Injunction to settle his liability in this case. Mr. Hinsley agreed, and did pay, a civil penalty of $4,000.00 plus $1,000.00 in attorney's fees and $220.00 in costs of Court. Will continue to prosecute this action as to Sign Mules Jaeger and Varner. No. 2009-51863: HARRIS COUNTY, TEXAS vs. LINDA HUTCHINSON, D/B/A MY DREAM PLACE, 133 RD DISTRICT COURT, CA# 423890 BSR. Bandit Sign Removal case for violations of Texas Transportation Code for placement of one sign over five days advertising "Ballroom/Meeting Facilities/Banquets, Weddings, Family Reunions" located at 7206 Fox Club Lane, Humble, Tx 77338. STATUS: Waiting on citation to be served on Ms. Hutchinson. Request for admissions sent out with petition. No. 2009-47656: HARRIS COUNTY V. SHANNA LEWIS; IN THE 55 TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS. CA FILE NO. 421126 BSR. Sign Rangers observed and reported 1 sign/1 day advertising "Pool Services & Repairs" at corner of Louetta and Terranova West Dr. STATUS: Citation filed. Investigator unable to personally serve Defendant. Investigator to provide Rule 106 Affidavit. No. 936917: HARRIS COUNTY, TEXAS v. TXROOFINGANDSIDINGLLC; IN THE COUNTY CIVIL COURT AT LAW NO.1; CA# 421086 BSR. Law enforcement observed and reported multiple signs advertising "Need a Roof?" for one or more days at multiple locations primarily in the Atascocita South subdivision.

STATUS: Petition and Request for Disclosures filed and served on Defendant, additional Discovery sent out, Objection to Fee-Paid Mediation being prepared, Jury Trial 10/19/2009. CAUSE NO. 937817: HARRIS COUNTY, TEXAS V. MADISON EMILY GREGORY dba MONSTERS POOL SERVICE AKA MONSTERS POOLS POOL REPAIR AND SERVICE AKA MONSTER POOLS AKA MONSTER CONSTRUCTION; IN THE COUNTY CIVIL COURT AT LAW NO. 2; CA# 421122 BSR. Sign Ranger reported and observed one sign on one occasion advertising "MONSTER POOLS POOL REPAIR AND PLASTERING" at the intersection of Louetta at Terranova West Drive. STATUS: Petition and Request for Disclosures filed and served on Defendant, additional discovery sent out, Mediation scheduled10/1/2009, Jury Trial 11/2/2009. CAUSE NO. 937567: HARRIS COUNTY, TEXAS V. JORGE VALLE DBA VALLE TREE SERVICES, IN THE COUNTY CIVIL COURT AT LAW NO. 2; CA#421124. Sign Ranger reported and observed one sign on one occasions advertising "Tree Trimming and Removal Free Estimates Insured" at Cypresswood and Kuykendahl. STATUS: Petition and Request for Disclosures filed and served on Defendant. Additional discovery drafted. Obtained Agreed Judgment and Permanent Injunction from Defendant. Defendant paid $376.00 ($125.00 for civil penalties and $251.00 for court costs). CAUSE NO. 2009-24553: HARRIS COUNTY, TEXAS v. SHANNA LEWIS AKA MISTY LEWIS, INDIVIDUALLY, AND DOING BUSINESS AS CRYSTAL CLEAR POOLS OF THE WOODLANDS, CRYSTAL CLEAR POOLS OF THE WDLN, AND CRYSTAL CLEAR POOLS; IN THE 55TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, CA# 421126 BSR. Sign Ranger reported and observed and reported one sign on one occasion advertizing "Pool Service & Repairs 281.528.6599 " located at the intersection of Louetta at Terranova West Drive. Based on information and documentation received, non-suited previous defendant and brought suit against Shanna Lewis aka Misty Lewis individually and doing business as Crystal Clear Pools of the Woodlands, Crystal Clear Pools of the WDLN, and Crystal Clear Pools. STATUS: Petition and Request for Disclosures filed. Civil Investigative Coordinator is trying to effect service.

CAUSE NO. 2009-23507: HARRIS COUNTY, TEXAS V. JEFFREY L. KAITSHUCK INDIVIDUALLY AND DBA ALL AMERICAN POOL SERVICES AND POOL SERVICE & REPAIRS, AND CHANTELLE M. KAITSCHUCK AKA CHANTELLE MARIE OUELLETTE AKA CHANTELLE DUELLETTE, INDIVIDUALLY AND DBA ALL AMERICAN POOL SERVICES AND POOL SERVICE REPAIRS; IN THE 80TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS; CA# 421127 BSR. Sign Rangers observed and reported and a Civil Investigative Coordinator observed three or more signs on one or more occasions advertising "Pool Service & Repairs 832-889-2817" at Louetta and Champions Forest Drive and Cutten Road and FM 1960. STATUS: Petition and Request for Disclosures filed and served on Defendants. Additional discovery being drafted. CAUSE NO. 09-22135: HARRIS COUNTY, TEXAS V. SHANDRA CHAMPAGNE INDIVIDUALLY AND DBA THE CREDIT REPAIR PROGRAM, CARAVAN CREDIT SERVICES, AND CREDISOURCE LLC, AND JERRY CHAMPAGNE INDIVIDUALLY AND DBA C1-SOURCE AND CARAVAN CREDIT SERVICES, AND CARAVAN INC.; IN THE 151 ST JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS; CA# 421128 BSR. Sign Ranger observed and reported and a Civil Investigative Coordinator observed two signs on one or more occasions advertising "Credit Repair $ No Money Down $" at Boudreaux Rd. and SH 249 and FM 1960 near Stuebner Airline. STATUS: Petition, Request for Disclosures filed and served, as well as additional discovery on initial Defendant Shandra Champagne. Amending petition and drafting discovery to also be served on Defendants Jerry Champagne and Caravan Inc. CAUSE NO. 2009-21846: HARRIS COUNTY, TEXAS V. LISA ARGEL DBA LISA'S FURNITURE BARN AND JOHN ARGEL; IN THE 270TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS, CA# 421232. Sign Ranger observed and reported and a Civil Investigative Coordinator observed three signs on one or more occasions advertising "Lisa's Furniture Barn" at Boudreaux and SH 249. STATUS: Petition and Request for Disclosures filed and served on and/or received by Defendants (Defendant John Argel cooperated and signed a Waiver of Service). Obtained Agreed Judgment and Permanent Injunction from Defendants. Defendants paid $500.00 for civil penalties.

CAUSE NO. 200931391: HARRIS COUNTY, TEXAS V. BROWN & WHITE PROPERTY SERVICES, LLC, IN THE 125TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS.CA# 421233. Sign Ranger observed and reported a signs on one occasion advertising "LEASE/PURCHASE 3 BED 2 BATH" at Boudreaux Rd. and SH 249. STATUS: Petition and Request for Disclosures filed and served on Defendant. Obtained Agreed Judgment and Permanent Injunction from Defendant. Defendant paid $535.00 ($250.00 for civil penalties and $285.00 for court costs). CAUSE NO. 2009-25797: HARRIS COUNTY, TEXAS V. STEVEN TELAROLI DBA RV PARK, IN THE 55TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS. CA# 421234. Sign Ranger reported and observed a sign on one occasion advertising "RV Park Monthly Rates" at Boudreaux Rd. and SH 249. STATUS: Petition and Request for Disclosures filed and served on Defendant. Obtained Agreed Judgment and Permanent Injunction from Defendant. Defendant paid $345.00 ($125.00 for civil penalties and $220.00 for court costs). CAUSE NO. 09-24553: HARRIS COUNTY, TEXAS V. PAUL GABRIEL DBA AKC YORKIES & DACHSHUNDS AND TOP-DAWGS.COM; IN THE 333RD JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS; CA# 421236 BSR Sign Ranger observed and reported and a Civil Investigative Coordinator observed two signs on one or more occasions advertising "AKC YORKIES & DACHSHUNDS" Boudreaux Rd. and SH 249. STATUS: Petition and Request for Disclosures filed, and after resolving some service questions/issues, Defendant was served after more than one attempt on August 10, 2009. CAUSE NO. 2009-22345: HARRIS COUNTY, TEXAS V. CHRIS TROUTMAN DBA AFFORDABLE HEALTH INSURANCE, TEXAS ROOFING AND REMODELING, TEXAS FENCES, TEXAS TREES, AND TEXAS TREE AND STUMP REMOVERS, IN THE 11TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS. CA# 421238. Sign Ranger observed and reported and a Civil Investigative Coordinator observed at least four signs on one or more occasions advertising "Affordable Health Insurance, Texas Roofing and Remodeling, Texas Fences, and Texas Trees" at Boudreaux Rd. and SH 249.

STATUS: Petition and Request for Disclosures filed and served on Defendant. Obtained Agreed Judgment and Permanent Injunction from Defendant. Defendant paid $1,285.00 ($1,000.00 for civil penalties and $285.00 for court costs).