Preview
Filed
4/3/2023 9:52 AM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Sylvie Le
CAUSE NO. 23-DCV-302764
JOHNNIE MARIE GREEN
Plaintiff,
vs.
WALMART, INC, D/B/A SAM?S CLUB
#8246
Deféendant.
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IN THE DISTRICT COURT OF
Fort Bend County - 458th Judicial District Court
____ JUDICIAL DISTRICT
FORT BEND COUNTY, TEXAS
PLAINTIFF’S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, JOHNNIE GREEN, Plaintiff, complaining of WALMART, INC, D/B/A
SAM’S CLUB #8246, “SAM’S CLUB”, and would respectfully show the Court the following:
L DICOVERY CONTROL PLAN
1. Plaintiffs intends that discovery be conducted under LEVEL 3 of RULE 190 of the TEXAS
RULES OF CIVIL PROCEDURE. Pursuant to Rule 47 of the Texas Rules of Civil Procedure,
Plaintiff seeks monetary relief over $1,000,000.00 and a demand for judgment for all other
relief to which Plaintiff may justly be entitled.
IL
PARTIES
2. Plaintiff JOHNNIE MARIE GREEN (Last three (3) DL NOMI SSN [fH is an
individual residing in Refugio, Texas.
3. Defendant WALMART, INC, D/B/A SAM’S CLUB #8246 is a corporation conducting
business in the State of Texas and can be served with process at with their registered agent,
Corporation Service Company. CSC-Lawyers Incorporating Service Company. 211
E. 7" St., Ste. 620, Austin, Texas 78701III. JURISDICTION anp VENUE
4. This Court has jurisdiction over the parties because the amount in controversy is within the
jurisdictional limits of this Court. Additionally, this Court has jurisdiction over the parties
because Defendant is a Texas resident and/or does business in the State of Texas,
5. Venue is proper in Fort Bend County in this cause pursuant to § 15.002(a)(1) of the CiviL
PRACTICE & REMEDIES CODE because Fort Bend County, Texas was the county in which
all or a substantial part of the events or omissions giving rise to the claim occurred.
IV. FACTS
6. On or about the 24" day of September 2021, Plaintiff was a business invitee to whom
Defendant owed a duty of care to protect her from injury. Plaintiff was in the store
walking when she slipped on a smeared Alvera plant leave that was smeared in to the
Defendant’s floor. The slipping motion caused Plaintiff to collide with the floor, which
resulted in severe bodily injuries. The unreasonably dangerous condition caused by the
wet surface on Defendant’s premises proximately caused Plaintiff’s injuries and the need
for her subsequent medical treatment.
7. Defendant breached the duty of care they owed to Plaintiff as a business invitee and were
both negligent and grossly negligent in their failure to exercise ordinary care in the safety
of the Plaintiff. Consequently, Plaintiff was an invitee to whom Defendant owed a duty to
use ordinary care, including the duty to protect and safeguard Plaintiff from unreasonably
dangerous conditions on the premises, or to warn of their existence. Plaintiff seeks all
applicable damages available under Texas law.
Vv. NEGLIGENCE OF DEFENDANT SAM’S CLUB
8, The occurrence made the basis of this suit, reflected in the above paragraph, and the resulting
injuries and damages of Plaintiffs were proximately caused by the negligent conduct of the
Defendant SAM’S CLUB, and their agents, servants, and employees were by violating the
duty which he owed the Plaintiffs to exercise ordinary care in the operation of their premises
in one or more of the following respects:
a, in failing to keep to warm invitees, including Plaintiff, of the hazards of an
unreasonably dangerous condition on Defendant’s’ premises;
Failure to inspect the store and properly maintain it;
Allowing a dangerous condition to exist, so that Plaintiff: would fall and be injured;
Failing to provide safety of Plaintiff under the circumstances;
Failing to warn invitees, including Plaintiff, that the area in question should be
approached with caution;
es ae se
2.f. Negligently maintaining the area in question in such a way as to constitute a
negligent activity;
g. Failing to warn invitees, including the Plaintiff that there was a dan gerous condition
which required extra care to be taken while walking through that area;
h. Failing to maintain the premises in a reasonably safe condition for the Plaintiff and
other invitees;
i. Failing to remove the dangerous condition or warn of its existence;
Failing to properly train agents, servants, and employees; and
k. Failing to properly supervise and instruct agents, servants, and employees.
ow
9. Defendant’s negligence was a proximate cause of Plaintiffs injuries alleged herein, Each
of these acts and/or omissions, whether taken singularly or in any combination constitutes
negligence which proximately caused the collision and injuries and other losses as
specifically set forth herein.
10. As a direct and proximate result of the collision and the negligent conduct of the
Defendants, plaintiffs have suffered serious bodily injury.
VI. PREMISES LIABILITY
11. On or about the 24th day of September 2021, Defendant SAM’S CLUB was in possession
of the premises WALMART, INC, D/B/A SAM?’S CLUB #8246 located at 12300 SW
Fwy in Stafford, TX. As a customer on the premises, Plaintiff was an invitee on the
premises because she entered onto the Defendant’s property with the express consent of
the Defendant, and it was for the mutual benefit of both Plaintiff and Defendant. As such,
Defendant owed a duty of care to adequately warn her of conditions on the premises posing
an unreasonable risk of harm or to make the condition reasonably safe protect her from
injury performing an extermination job at the home of the Defendant. Defendant knew or
should have known that the area where the Alvera plant leaf was present—where Plaintiff
fell—had not been properly inspected or maintained, such that it created a dangerous
condition, posing an unreasonable risk of harm to the Plaintiff or others similarly situated.
However, Defendant breached their duty of ordinary care to Plaintiff by both failing to
warn the Plaintiff of the dangerous condition and failing to make the condition reasonably
safe. Plaintiff seeks all applicable damages available under Texas law.
12, This negligence proximately caused the Plaintiff's fall and injuries and other losses as set
forth herein.
38VII. GROSS NEGLIGENCE oF SAM’S CLUB
13. Defendants SAM’S CLUB negligent conduct was more than a momentary thoughtlessness
or inadvertence. Rather, the Defendant’s conduct involved an extreme degree of risk,
considering the probability and magnitude of the potential harm to any person that may be in
the path of the Defendant’s actions. Defendant had actual subjective awareness of the risk
involved but nevertheless, proceeded in such conscious indifference to the rights, safety, or
welfare of the Plaintiff or others similarly situated. §41.001(11) Texas Civil Practice &
Remedies Code.
14. Each of these acts and/or omissions, whether taken singularly or in any combination
Constitutes negligence which proximately caused the collision and injuries and other losses
as specifically set forth herein, all of which Plaintiff sufferedand which Plaintiff will
continue to suffer in the future, if not for the remainder of his natural life.
VIII. EXEMPLARY DAMAGES
15. The above-referenced acts and/or omissions by Defendants SAM’S CLUB constitutes
malice as that term is defined in Section 41.001(7) of the Texas Civil Practice and
Remedies Code and gross negligence as the term is defined by Section 41.001(11).
16. The Defendants’ act or omissions described above, when viewed objectively from the
standpoint of SAM’S CLUB at the time of the act or omission, involved an extreme degree
of risk, considering the probability of harm to Plaintiff and others.
17, Defendant SAM’S CLUB had actual, subjective awareness of the risk involved in the
above-described acts or omissions, but nevertheless proceeded with conscious indifference
to the rights, safety, or welfare of Plaintiff and others.
_ 18. The above acts and/or omissions were singularly and cumulatively the proximate cause of
the occurrence in question and the resulting injuries and damages sustained by Plaintiff.
19. Therefore, because of such acts of malice and gross negligence on behalf of Defendant
SAM’S CLUB. Plaintiff sues for exemplary damages in an amount to be determined at
trial.
TX. CAUSATION anp DAMAGES
20. Each of the acts and omissions described above, taken singularly or in any combination,
constitutes negligence and gross negligence which proximately caused the collision,
injuries, and damages as specifically set forth herein, all of which Plaintiff JOHNNIE
MARIE GREEN suffered.21. Asa direct and proximate result of the collision and the negligent conduct of Defendants,
Plaintiff suffered severe bodily injuries to her knee, neck and other parts of her body
generally. Her entire body was bruised, battered, and contused and she suffered great
shock to her entire nervous system. The injuries are permanent in nature. The injuries
have had a serious effect on the Plaintiff's health and well-being. Some of the effects will
abide with the Plaintiff for a long time into the future, if not for his entire life. These
specific injuries and their ill effects have, in turn, caused the Plaintiff's physical and
mental condition to generally deteriorate, and the specific injuries and ill effects alleged
have caused and will, in all reasonable probability, cause the Plaintiff to suffer
consequences and ill effects of this deterioration throughout his body for a long time in
the future, if not for the balance of his natural life. As a further result of the nature and
consequences of his injuries, the Plaintiff suffered great physical and mental pain,
suffering and mental anguish, and in all reasonable probability, will continue to suffer in
this manner for a long time into the future, if not for the balance of his natural life.
22. Additionally, as a direct and proximate result of the occurrence made the basis of this
lawsuit, Plaintiff JOHNNIE MARIE GREEN incurred the following damages:
a Medical care and expenses incurred in the past;
b. medical care and expenses that will in all reasonable probability be incurred
in the future;
Cc, Physical pain and suffering sustained in the past;
d. Physical pain and suffering that will in all reasonable probability be
sustained in the future;
e Physical impairment and disability in the past;
es Physical impairment and disability that will in all reasonable probability be
sustained in the future;
g. Loss of wages in the past;
7 Loss of past and future earning capacity;
i. Mental anguish in the past;
j. Mental anguish that will in all reasonable probability be suffered in the
future;
k. Physical disfigurement in the past;
Ls Physical disfigurement that will in all reasonable probability be suffered in
the future; and
m. Attorney’s fees.
23. Plaintiff further requests both pre-judgment and post-judgment interest on all his
damages as allowed by law.
24. Plaintiff seeks monetary relief over $1,000,000 and demands a judgment for all other
relief to which he deems to be justly entitled.X. INTEREST
25. Plaintiff further request both pre-judgment and post-judgment interest on all his damages as
allowed by law.
XI, RULE 193.7 NOTICE
26. Pursuant to Rule 193.7 of the Texas Rules of Civil Procedure, Defendant is hereby missthat
the production of any document in response to written discovery authenticates the
document for use against that part in any pretrial proceeding or at trial.
XII. DEMAND FOR JURY TRIAL
27. Plaintiff demands atrial by jury. Plaintiff acknowledges payment tidate of the required jury
fee.
XIII. REQUEST PURSUANT To RULE 28 FoR SUBSITUTION ofr TRUE NAME
28. To the extent that the above-named Defendants and Parties are conducting business
pursuant to a trade name or assumed name, then relief is sought against them pursuant to
the terms of Rule 28 of the Texas Rules of Civil Procedure, and Plaintiff hereby demands
upon answering this suit, that the Defendants and Parties answer in their correct legal and
assumed names.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiffs prays that Defendant be cited in
terms of law to appear and answer herein, and that upon final trial and hearing hereof, Plaintiffs’
recover damages in accordance with the evidence, costs of Court herein expended, interest to
which Plaintiffs are justly entitled under the law, and that the Court grants Plaintiffs such other
and further relief, both general and special, at law and in equity, to which Plaintiffs may be justly
entitled as a matter of law, equity , and including but not limited to:
Pain and Suffering in the past;
Pain and suffering in the future;
Mental anguish in the past;
Mental anguish in the future;
Past medical expenses;
Future medical expenses;
Physical impairment in the past;
Physical impairment in the future;
Physical disfigurement in the past;
10. Physical disfigurement i in the future;
11. Lost wages in the past;
PEN Ava!
-6-12. Loss of future wage-earning capacity;
13. Loss of use; \
14. Pre-judgment interest;
15. Post-judgment interest; and
16. Exemplary damages.
1.age
Respectfully Submitted,
Tuomas J. HENRY Law, PLLC
5711 University Heights Blvd. #101
San Antonio, Texas 78249
Tel, (210) 656-1000
Fax. (361) 985-0601
By:
Joshua L. Taylor
State Bar No. 24123266
jtaylor-sve@thomasjhenrylaw.com*
ATTORNEY FOR PLAINTIFF
*Service by email to this email address onlyAutomated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Joshua Taylor on behalf of Joshua Taylor
Bar No. 24125949
jtaylor-svc@thomasjhenrylaw.com
Envelope ID: 74254143
Filing Code Description: Petition
Filing Description: Plaintiffs Original Petition
Status as of 4/3/2023 10:33 AM CST
Case Contacts
Name BarNumber | Email TimestampSubmitted
Status
Joshua Taylor jtaylor-svc@thomasjhenrylaw.com | 4/3/2023 9:52:46 AM
SENT
Preview
Filed 4/3/2023 9:52 AM Beverley McGrew Walker District Clerk Fort Bend County, Texas Sylvie Le CAUSE NO. 23-DCV-302764 JOHNNIE MARIE GREEN Plaintiff, vs. WALMART, INC, D/B/A SAM?S CLUB #8246 Deféendant. § § § § § § § § § § § IN THE DISTRICT COURT OF Fort Bend County - 458th Judicial District Court ____ JUDICIAL DISTRICT FORT BEND COUNTY, TEXAS PLAINTIFF’S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, JOHNNIE GREEN, Plaintiff, complaining of WALMART, INC, D/B/A SAM’S CLUB #8246, “SAM’S CLUB”, and would respectfully show the Court the following: L DICOVERY CONTROL PLAN 1. Plaintiffs intends that discovery be conducted under LEVEL 3 of RULE 190 of the TEXAS RULES OF CIVIL PROCEDURE. Pursuant to Rule 47 of the Texas Rules of Civil Procedure, Plaintiff seeks monetary relief over $1,000,000.00 and a demand for judgment for all other relief to which Plaintiff may justly be entitled. IL PARTIES 2. Plaintiff JOHNNIE MARIE GREEN (Last three (3) DL NOMI SSN [fH is an individual residing in Refugio, Texas. 3. Defendant WALMART, INC, D/B/A SAM’S CLUB #8246 is a corporation conducting business in the State of Texas and can be served with process at with their registered agent, Corporation Service Company. CSC-Lawyers Incorporating Service Company. 211 E. 7" St., Ste. 620, Austin, Texas 78701III. JURISDICTION anp VENUE 4. This Court has jurisdiction over the parties because the amount in controversy is within the jurisdictional limits of this Court. Additionally, this Court has jurisdiction over the parties because Defendant is a Texas resident and/or does business in the State of Texas, 5. Venue is proper in Fort Bend County in this cause pursuant to § 15.002(a)(1) of the CiviL PRACTICE & REMEDIES CODE because Fort Bend County, Texas was the county in which all or a substantial part of the events or omissions giving rise to the claim occurred. IV. FACTS 6. On or about the 24" day of September 2021, Plaintiff was a business invitee to whom Defendant owed a duty of care to protect her from injury. Plaintiff was in the store walking when she slipped on a smeared Alvera plant leave that was smeared in to the Defendant’s floor. The slipping motion caused Plaintiff to collide with the floor, which resulted in severe bodily injuries. The unreasonably dangerous condition caused by the wet surface on Defendant’s premises proximately caused Plaintiff’s injuries and the need for her subsequent medical treatment. 7. Defendant breached the duty of care they owed to Plaintiff as a business invitee and were both negligent and grossly negligent in their failure to exercise ordinary care in the safety of the Plaintiff. Consequently, Plaintiff was an invitee to whom Defendant owed a duty to use ordinary care, including the duty to protect and safeguard Plaintiff from unreasonably dangerous conditions on the premises, or to warn of their existence. Plaintiff seeks all applicable damages available under Texas law. Vv. NEGLIGENCE OF DEFENDANT SAM’S CLUB 8, The occurrence made the basis of this suit, reflected in the above paragraph, and the resulting injuries and damages of Plaintiffs were proximately caused by the negligent conduct of the Defendant SAM’S CLUB, and their agents, servants, and employees were by violating the duty which he owed the Plaintiffs to exercise ordinary care in the operation of their premises in one or more of the following respects: a, in failing to keep to warm invitees, including Plaintiff, of the hazards of an unreasonably dangerous condition on Defendant’s’ premises; Failure to inspect the store and properly maintain it; Allowing a dangerous condition to exist, so that Plaintiff: would fall and be injured; Failing to provide safety of Plaintiff under the circumstances; Failing to warn invitees, including Plaintiff, that the area in question should be approached with caution; es ae se 2.f. Negligently maintaining the area in question in such a way as to constitute a negligent activity; g. Failing to warn invitees, including the Plaintiff that there was a dan gerous condition which required extra care to be taken while walking through that area; h. Failing to maintain the premises in a reasonably safe condition for the Plaintiff and other invitees; i. Failing to remove the dangerous condition or warn of its existence; Failing to properly train agents, servants, and employees; and k. Failing to properly supervise and instruct agents, servants, and employees. ow 9. Defendant’s negligence was a proximate cause of Plaintiffs injuries alleged herein, Each of these acts and/or omissions, whether taken singularly or in any combination constitutes negligence which proximately caused the collision and injuries and other losses as specifically set forth herein. 10. As a direct and proximate result of the collision and the negligent conduct of the Defendants, plaintiffs have suffered serious bodily injury. VI. PREMISES LIABILITY 11. On or about the 24th day of September 2021, Defendant SAM’S CLUB was in possession of the premises WALMART, INC, D/B/A SAM?’S CLUB #8246 located at 12300 SW Fwy in Stafford, TX. As a customer on the premises, Plaintiff was an invitee on the premises because she entered onto the Defendant’s property with the express consent of the Defendant, and it was for the mutual benefit of both Plaintiff and Defendant. As such, Defendant owed a duty of care to adequately warn her of conditions on the premises posing an unreasonable risk of harm or to make the condition reasonably safe protect her from injury performing an extermination job at the home of the Defendant. Defendant knew or should have known that the area where the Alvera plant leaf was present—where Plaintiff fell—had not been properly inspected or maintained, such that it created a dangerous condition, posing an unreasonable risk of harm to the Plaintiff or others similarly situated. However, Defendant breached their duty of ordinary care to Plaintiff by both failing to warn the Plaintiff of the dangerous condition and failing to make the condition reasonably safe. Plaintiff seeks all applicable damages available under Texas law. 12, This negligence proximately caused the Plaintiff's fall and injuries and other losses as set forth herein. 38VII. GROSS NEGLIGENCE oF SAM’S CLUB 13. Defendants SAM’S CLUB negligent conduct was more than a momentary thoughtlessness or inadvertence. Rather, the Defendant’s conduct involved an extreme degree of risk, considering the probability and magnitude of the potential harm to any person that may be in the path of the Defendant’s actions. Defendant had actual subjective awareness of the risk involved but nevertheless, proceeded in such conscious indifference to the rights, safety, or welfare of the Plaintiff or others similarly situated. §41.001(11) Texas Civil Practice & Remedies Code. 14. Each of these acts and/or omissions, whether taken singularly or in any combination Constitutes negligence which proximately caused the collision and injuries and other losses as specifically set forth herein, all of which Plaintiff sufferedand which Plaintiff will continue to suffer in the future, if not for the remainder of his natural life. VIII. EXEMPLARY DAMAGES 15. The above-referenced acts and/or omissions by Defendants SAM’S CLUB constitutes malice as that term is defined in Section 41.001(7) of the Texas Civil Practice and Remedies Code and gross negligence as the term is defined by Section 41.001(11). 16. The Defendants’ act or omissions described above, when viewed objectively from the standpoint of SAM’S CLUB at the time of the act or omission, involved an extreme degree of risk, considering the probability of harm to Plaintiff and others. 17, Defendant SAM’S CLUB had actual, subjective awareness of the risk involved in the above-described acts or omissions, but nevertheless proceeded with conscious indifference to the rights, safety, or welfare of Plaintiff and others. _ 18. The above acts and/or omissions were singularly and cumulatively the proximate cause of the occurrence in question and the resulting injuries and damages sustained by Plaintiff. 19. Therefore, because of such acts of malice and gross negligence on behalf of Defendant SAM’S CLUB. Plaintiff sues for exemplary damages in an amount to be determined at trial. TX. CAUSATION anp DAMAGES 20. Each of the acts and omissions described above, taken singularly or in any combination, constitutes negligence and gross negligence which proximately caused the collision, injuries, and damages as specifically set forth herein, all of which Plaintiff JOHNNIE MARIE GREEN suffered.21. Asa direct and proximate result of the collision and the negligent conduct of Defendants, Plaintiff suffered severe bodily injuries to her knee, neck and other parts of her body generally. Her entire body was bruised, battered, and contused and she suffered great shock to her entire nervous system. The injuries are permanent in nature. The injuries have had a serious effect on the Plaintiff's health and well-being. Some of the effects will abide with the Plaintiff for a long time into the future, if not for his entire life. These specific injuries and their ill effects have, in turn, caused the Plaintiff's physical and mental condition to generally deteriorate, and the specific injuries and ill effects alleged have caused and will, in all reasonable probability, cause the Plaintiff to suffer consequences and ill effects of this deterioration throughout his body for a long time in the future, if not for the balance of his natural life. As a further result of the nature and consequences of his injuries, the Plaintiff suffered great physical and mental pain, suffering and mental anguish, and in all reasonable probability, will continue to suffer in this manner for a long time into the future, if not for the balance of his natural life. 22. Additionally, as a direct and proximate result of the occurrence made the basis of this lawsuit, Plaintiff JOHNNIE MARIE GREEN incurred the following damages: a Medical care and expenses incurred in the past; b. medical care and expenses that will in all reasonable probability be incurred in the future; Cc, Physical pain and suffering sustained in the past; d. Physical pain and suffering that will in all reasonable probability be sustained in the future; e Physical impairment and disability in the past; es Physical impairment and disability that will in all reasonable probability be sustained in the future; g. Loss of wages in the past; 7 Loss of past and future earning capacity; i. Mental anguish in the past; j. Mental anguish that will in all reasonable probability be suffered in the future; k. Physical disfigurement in the past; Ls Physical disfigurement that will in all reasonable probability be suffered in the future; and m. Attorney’s fees. 23. Plaintiff further requests both pre-judgment and post-judgment interest on all his damages as allowed by law. 24. Plaintiff seeks monetary relief over $1,000,000 and demands a judgment for all other relief to which he deems to be justly entitled.X. INTEREST 25. Plaintiff further request both pre-judgment and post-judgment interest on all his damages as allowed by law. XI, RULE 193.7 NOTICE 26. Pursuant to Rule 193.7 of the Texas Rules of Civil Procedure, Defendant is hereby missthat the production of any document in response to written discovery authenticates the document for use against that part in any pretrial proceeding or at trial. XII. DEMAND FOR JURY TRIAL 27. Plaintiff demands atrial by jury. Plaintiff acknowledges payment tidate of the required jury fee. XIII. REQUEST PURSUANT To RULE 28 FoR SUBSITUTION ofr TRUE NAME 28. To the extent that the above-named Defendants and Parties are conducting business pursuant to a trade name or assumed name, then relief is sought against them pursuant to the terms of Rule 28 of the Texas Rules of Civil Procedure, and Plaintiff hereby demands upon answering this suit, that the Defendants and Parties answer in their correct legal and assumed names. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiffs prays that Defendant be cited in terms of law to appear and answer herein, and that upon final trial and hearing hereof, Plaintiffs’ recover damages in accordance with the evidence, costs of Court herein expended, interest to which Plaintiffs are justly entitled under the law, and that the Court grants Plaintiffs such other and further relief, both general and special, at law and in equity, to which Plaintiffs may be justly entitled as a matter of law, equity , and including but not limited to: Pain and Suffering in the past; Pain and suffering in the future; Mental anguish in the past; Mental anguish in the future; Past medical expenses; Future medical expenses; Physical impairment in the past; Physical impairment in the future; Physical disfigurement in the past; 10. Physical disfigurement i in the future; 11. Lost wages in the past; PEN Ava! -6-12. Loss of future wage-earning capacity; 13. Loss of use; \ 14. Pre-judgment interest; 15. Post-judgment interest; and 16. Exemplary damages. 1.age Respectfully Submitted, Tuomas J. HENRY Law, PLLC 5711 University Heights Blvd. #101 San Antonio, Texas 78249 Tel, (210) 656-1000 Fax. (361) 985-0601 By: Joshua L. Taylor State Bar No. 24123266 jtaylor-sve@thomasjhenrylaw.com* ATTORNEY FOR PLAINTIFF *Service by email to this email address onlyAutomated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Joshua Taylor on behalf of Joshua Taylor Bar No. 24125949 jtaylor-svc@thomasjhenrylaw.com Envelope ID: 74254143 Filing Code Description: Petition Filing Description: Plaintiffs Original Petition Status as of 4/3/2023 10:33 AM CST Case Contacts Name BarNumber | Email TimestampSubmitted Status Joshua Taylor jtaylor-svc@thomasjhenrylaw.com | 4/3/2023 9:52:46 AM SENT