COATS HOMES, LLC vs. THOMAS DANIELS d/b/a RELIABLE PLUMBING CONTRACTORS

COATS hired RELIABLE to perform plumbing work on a home located at 11620

Wander Lane in Dallas, Texas (the “Project”). COATS files this lawsuit to recover damages caused

by RELIABLE’s failure to comply with applicable building codes, RELIABLE’s Proposal (the

“Proposal”), and the COATS’ Purchase Order (the “Purchase Order”).

RELIABLE’s Proposal and the Purchase Order required RELIABLE’s work to

conform to applicable codes. The applicable City of Dallas building codes required pipes in attics

(or any other place subject to freezing) to be insulated, heated, or both. Here, RELIABLE failed

to insulate or heat the plumbing pipe in an area subject to freezing. RELIABLE’s failure to insulate

or heat the pipe was a deviation from the applicable code.

RELIABLE’s failure to insulate or heat the pipe constitutes negligence and breach

of contract.

Causes of Action

VII. CAUSES OF ACTION

Count 1: Breach of Contract

Count 2: Negligence