Complaint,Petition: Jeronimo Sales vs. Paul Porrovecchio

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Cause       23-05-06616
                                                          oe

Jeronimo Sales                                                                                     District Court

Plaintiff

                                                                                       284th Judicial District

Paul Porrovecchio

Defendant                                                                          Montgomery County, Texas
                            Plaintiff     Original Petition and Jury Demand

        Plaintiff Jeronimo        Sales     Plaintiff     complains            Defendant   Paul       Porrovecchio

  Defendant”) and would respectfully                    Court


                                          Discovery Control

        Plaintiff intends        conduct discovery       this matter under Level                  Texas Rules

 ivil Procedure.


                                          Jurisdiction and Venu

               claims asserted arise under        common              Texas.         Court has jurisdiction and

venue       proper because all       substantial part           events     omissions giving                  claim

occurred       Montgomery County, Texas.


                            Statement Regarding Monetary Relief Sought

        Pursuant       Texas Rule         Civil Procedure 47(c), Plaintiff seeks monetary relief over

                                                         including damages           any          penalties, costs,

expenses, pre judgment interest, and judgment for all                     relief      which Plaintiff        justly

entitled. Plaintiff expressly reserves                  amend this Rule        statement     relief     necessary.
Parties

        Plaintiff Jeronimo Sales                individual           resides    Harris County, Texas.

        Defendant Paul Porrovecchio                    individual          resides      Montgomery County, Texas.

Defendant              served              residence                       Conroe, Texas 77301              wherever

        found.


                                                           Facts

                 lawsuit       necessary         result         personal injuries                Plaintiff received

about                            that time, Plaintiff was traveling southbound                                        North

Frazier Street       Montgomery County, Texas. Subsequently, Defendant failed

way                        left           and struck Plaintiffs vehicle.                result            crash, Plaintiff

suffered bodily injuries and                    damage           which Defendant        liable.


                                               Negligence          Defendant

        Defendant had                      exercise ordinary care and operate              motor vehicle reasonably

and prudently              day             incident        forms        basis       this lawsuit. Defendant breached

                                                       ways:

                      Failed       control vehicle’s speed;

                      Failed       operate        vehicle safely;

                      Failed       keep      proper lookout;

                      Failed       timely apply brakes;

                      Failed               proper evasive action;

                      Failed                              way

                      Other acts          deemed negligent.
Defendant       acts         omission           and commission,         which    constituted negligence,     were

              ause     Plaintiff      injuries.


                                                               Damag

                                 actions and conduct                       Defendant      set forth above,     Plaintiff was

seriously injured and          entitled         recover                       damages:

                     Past and future medical expenses;

                     Past and future pain, suffering and mental anguish;

                     Past and future physical impairment;

                     Past and future physical                   igurement;

                     Past         wages and future                       eaming capacity.

                     Property damages (including                            use, cost     repairs, and diminished value).

        For      above reasons, Plaintiff                 entitled       recover damages from            Defendant   jointly

and severally,          amount within                   jurisdictional              this Court     well        pre and

judgment interest.


                                                          Jury Demand

        Plaintiff hereby demands                trial             and pays the appropriate              fee.


                                                        Rule           Notice

        Plaintiff hereby             actual notice              Defendant that any and all documents produced

   used against Defendant                 any           trial proceeding and/or          trial   this

necessity     authenticating              documents.
Designated    _ Service        Mail Address

                                        undersigned attomey         designated          service email address          all

 erved documents and notices, filed and unfiled, pursuant                         Tex.        Civ.      21(£)(2)      21(a):

eservice@ thehuynhlawfirm.com.                               undersigned                   service email address,          and

service              any              email address            considered


                                                 Required Disclosures

          Pursuant         Texas Rules         Civil Procedure 194(a),             Defendant          required

within thirty          days                              first answer,          information          material described

Rule 194.2(b)1                   Defendant               served       otherwise joined after                        the first

answer                     their initial disclosures within thirty              days after being served          joined.


                                                          Prayel

          For     above reasons, Plaintiff prays                     obtains judgment against Defendant              jointly

and severally,             interest           judgment            legal rate,       judgment interest, costs          court,

and       such other relief,                     and equity,                Plaintiff     justly entitled.
Respectfully submitted,

                           THE HUYNH LAW FIRM, PLLC




                            Fax: (281) 730-8929


                           ATTORNEYS FOR PLAINTIFF


IF YOU HAD INSURANCE AT THE TIME
FORWARD A COPY THIS ORIGINAL
           COMPANY FOR