Complaint,Petition: Robert Williams, Michelle Williams VS. Precision Homes Custom Builders, Inc., JW Clovis III, Ltd., JW Conroe I, Ltd.

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                                Received ant      E-Filed for Ri     rd
                                                                                                     1418/20;        i 31 PM
                                                                                            Melisa Mi       “District Clerk
                                                                                           Montg:         County, Texas

                                               24-03 -04222_                                Deptity Clerk, Tony Beltran

                                         NO. 26=62=64949

ROBERT WILLIAMS AND                               §     IN THE DISTRICT COURT
MICHELLE WILLIAMS


Plaintiffs

Vv.                                                     284" TH JUDICIAL DISTRICT

PRECISION HOMES CUSTOM
BUILDERS, INC., JW CLOVIS III,
LTD., AND JW CONROE J, LTD.

Defendants                                              MONTGOMERY         COUNTY, TEXAS



              PLAINTIFFS’? SUPPLEMENT TO FOURTH AMENDED PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

       NOW COME Plaintiffs, husband and wife Robert Williams and Michelle Williams, who

complain of Defendants, Precision Homes Custom Builders, Inc., JW Clovis Ill, Ltd., and JW

Conroe I, Ltd., and supplement their Fourth Amended Petition, as follows:

         Ix.     CAUSE OF ACTION FOR TRESPASS AGAINST DEFENDANTS

        9.7     Plaintiffs also suffered loss of use damages.


                                              PRAYER

        WHEREFORE,         PREMISES CONSIDERED, Plaintiffs, Robert and Michelle Williams,

respectfully request that Plaintiffs be declared or adjudicated an appurtenant access easement that

runs with Plaintiffs’ Property;

        In addition, that the Easement Agreement be canceled and declared and adjudged void with
respect to Plaintiffs’ Property;

        In addition, that Defendant(s) responsible for destroying the access to Plaintiffs’ Property

be ordered to restore the Access Road and Access Easement property or, alternatively, that
Plaintiffs recover damages from the Defendant(s) responsible for destroying Plaintiffs’ access for

the cost to restore an access road, or pay the value of the easement to Plaintiffs’ Property, or pay

loss of use damages;

        In addition, that once      Plaintiffs’   access     has been   restored,   that Defendants   and   their

successors-in-interest be enjoined from further abuse to or interference with Plaintiffs’ usage and

enjoyment of the access easement and access road;

        In addition, that Plaintiffs recover exemplary damages;

        In addition, that Plaintiffs recover costs and reasonable and necessary attorney’s fees and

for any other relief at law or in equity to which Plaintiffs are entitled.



                                                               Respectfully submitted,

                                                               TouGuH LAW Firm, PLLC



                                                               /s/ Bruce C. Tough
                                                               Bruce C. Tough
                                                               State Bar No. 20151500
                                                               Fed. Adm ID No. 513
                                                               51 Rolling Stone Place
                                                               Spring, Texas 77373
                                                               btoughi toughlawfirm.net
                                                               Telephone: (281) 681-0808
                                                               Facsimile: (281) 681-0809
                                                               ATTORNEYS      FOR PLAINTIFF
                                                               ROBERT    AND MICHELLE      WILLIAMS




Plaintiff's Supplement to Fourth Amended Original Petition
CERTIFICATE OF SERVICE

       I certify that on December 18, 2020 a true and correct copy of Plaintiffs’ Supplement to
Fourth Amended Petition was served on the following in the manner indicated:

Travis Owens                                             C] by certified mail, return receipt
OWENS LAw Grovp, P.L.L.C.                                requested
P.O. Box 8605                                            C] by first class mail
The Woodlands, Texas 77387                               0]           by overnight delivery
travis@owens-lawgroup.com                                C]           by hand delivery
ATTORNEY     FOR PRECISION      HOMES     CUSTOM.        C]           by facsimile
BUILDERS, INC.                                           [x]          by electronic service



Bradford W. Irelan                                           C] by certified mail, return receipt
Trelan McDaniel P.L.L.C.                                 requested
Jeffrey M. Smith                                         C] by first class mail
2520 Caroline, Second Floor                              0] by overnight delivery
Houston, Texas 77004                                         0]       by hand delivery
birelan@IMTexasLaw.com                                       C]       by facsimile
jsmith@IMTexasLaw.com                                        [x]      by electronic service
ATTORNEY FOR JW CLovis II, LTD AND
JW Conroe I, LTD



                                                                          /s/Bruce C. Tough
                                                                   Bruce C. Tough




Plaintiff's Supplement to Fourth Amended Original Petition