Preview
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
CAUSE NO. _______________
ROSALINDA HERNANDEZ § IN THE DISTRICT COURT
Plaintiff §
§
v. § ____ JUDICIAL DISTRICT
§
DORA CRUZ AND LOWER RIO §
GRANDE VALLEY §
DEVELOPMENTAL COUNCIL CORP. §
D/B/A VALLEY METRO §
Defendants § HIDALGO COUNTY, TEXAS
PLAINTIFF’S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF THE COURT:
NOW COMES ROSALINDA HERNANDEZ (hereafter referred to as “Plaintiff”)
complaining of DORA CRUZ (hereafter referred to as “Cruz”) and LOWER RIO GRANDE
VALLEY DEVELOPMENTAL COUNCIL CORP. D/B/A VALLEY METRO (hereafter referred
to as “Valley Metro”) (Cruz and Valley Metro hereafter collectively referred to as “Defendants”)
in the above-styled and numbered cause. In support thereof, Plaintiff would respectfully show the
Court as follows:
PARTIES
1. Plaintiff ROSALINDA HERNANDEZ is an individual who resides in Hidalgo County,
Texas.
2. Defendant DORA CRUZ is an individual for which service may be perfected via process
at 510 S. Pleasantview Drive, Weslaco, TX, 78596, or wherever she may be found. CITATION IS
REQUESTED.
3. Defendant VALLEY METRO is a corporation doing business in the State of Texas and
service of process may be perfected by serving its registered agent: Manuel Cruz, 301 W. Railroad
Street, Weslaco, TX, 78596, or wherever he may be found. CITATION IS REQUESTED.
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
DISCOVERY LEVEL
4. Plaintiff intends to conduct discovery in this matter under Level 3 of Rule 190 of the Texas
Rules of Civil Procedure.
VENUE & JURISDICTION
5. This suit is brought in accordance with the laws of the State of Texas for the recovery of
damages which are in excess of the minimal jurisdictional limits of this Court, to which Plaintiff
is entitled to receive as compensation for the injuries described below.
6. Venue is proper in Hidalgo County, Texas pursuant to the Texas Civil Practice and
Remedies Code because all or a substantial part of the events giving rise to this claim occurred in
Edinburg, Hidalgo County, Texas.
7. Accordingly, the Court has jurisdiction over this matter and Venue is proper in Hidalgo
County, Texas.
FACTUAL ALLEGATIONS
8. On or about July 14, 2023, Plaintiff was exiting the parking lot located at or near 443 East
Trenton Road, Edinburg, Hidalgo County, Texas, 78539. At the same time, Defendant Cruz
operated a vehicle owned or leased by Defendant Valley Metro which was also traveling at or near
the 443 East Trenton Road, Edinburg, Hidalgo County, Texas, 78539, Texas. Suddenly and
without warning, Defendant Cruz, among other negligent acts, failed to control her speed thus
striking the Plaintiff’s vehicle from behind. The collision caused Plaintiff to sustain personal
injuries and damages as set forth below. At all times relevant to this suit, Defendant Cruz was
operating a vehicle owned or leased by Defendant Valley Metro and was within the regular course
and scope of her employment with Defendant Valley Metro.
2
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
9. Nothing Plaintiff did, or failed to do, caused the occurrence in question. Rather, it was the
negligence of Defendants that proximately and directly caused the occurrence in question and
Plaintiff’s resulting injuries and damages.
CAUSE OF ACTION:
NEGLIGENCE OF DEFENDANT CRUZ
10. Plaintiff hereby incorporates the allegations contained in the paragraphs set forth above as
if fully set forth herein. Defendant Cruz had common-law and statutory duties to use ordinary care
in the operation of her vehicle. Defendant Cruz was negligent by failing to exercise ordinary care
in the operation of a vehicle on the above-described occasion. Such negligence includes, but is
not limited to (a) failing to control speed; (b) failing to drive as a reasonably prudent driver would
drive in the same or similar circumstances; (c) failing to keep a proper lookout for Plaintiff’s safety,
the safety of others, and the safety of herself that would have been maintained by a person of
ordinary prudence under the same or similar circumstances; (d) failing to timely apply the brakes
of her vehicle in order to avoid striking Plaintiff’s vehicle as a reasonably prudent driver would
under the same or similar circumstances; (e) failing to properly control her vehicle as a reasonably
prudent driver would under the same or similar circumstances; (f) failing to timely and safely veer
and avoid the collision; (g) failing to maintain a safe distance between her vehicle and Plaintiff’s
vehicle; (h) driving inattentively; and (i) other violations of the Texas Transportation Code. Such
negligence by Defendant Cruz was the direct and proximate cause of the occurrence in question
and the severe bodily injuries of Plaintiff and all Plaintiff’s damages resulting therefrom.
3
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
CAUSE OF ACTION:
NEGLIGENCE OF DEFENDANT VALLEY METRO
11. Plaintiff hereby incorporates the allegations contained in the paragraphs set forth above as
if fully set forth herein. Defendant Valley Metro is legally responsible to Plaintiff for the negligent
conduct of his driver under the legal doctrines of respondeat superior, agency and/or ostensible
agency because Defendant Cruz was at all times material hereto an agent, ostensible agent, servant
and/or employee of Defendant Valley Metro and was acting within the regular course and scope
of such agency or employment at the time of the collision described above. As a result thereof,
Defendant Valley Metro is liable for all negligence of Defendant Cruz.
CAUSE OF ACTION:
NEGLIGENT HIRING, TRAINING, SUPERVISION AND RETENTION BY
DEFENDANT VALLEY METRO
12. Plaintiff hereby incorporates the allegations contained in the paragraphs set forth above as
if fully set forth herein. Defendant Valley Metro is also negligent in hiring an incompetent or unfit
employee and/or in failing to properly train, instruct, and supervise Defendant Cruz. Furthermore,
Defendant Valley Metro failed to provide the proper training and instruction to Defendant Cruz,
which would have provided him with the proper skills and knowledge to avoid the collision which
forms the basis of this lawsuit. Defendant Valley Metro’s negligent hiring of and failure to
properly instruct and train its driver was a proximate cause of the incident and Plaintiff’s resulting
injuries and damages.
4
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
CAUSE OF ACTION: NEGLIGENT ENTRUSTMENT
AGAINST DEFENDANT VALLEY METRO
13. Plaintiff hereby incorporates the allegations contained in paragraphs set forth above as if
fully set forth herein. Defendant Valley Metro’s acts and omissions outlined herein constitute
negligent entrustment. Defendant Valley Metro is liable to Plaintiff for the negligent entrustment
of one of her vehicles to an unlicensed, incompetent and unfit driver, namely Defendant Cruz. At
the time of the car crash, Defendant Valley Metro was the owner of the vehicle involved in this
crash. On or about July 14, 2023, Defendant Valley Metro allowed the above-mentioned vehicle
to be operated by Defendant Cruz for the purpose of operating it on the public streets and highways
of Texas and Defendant Cruz did operate the vehicle with the knowledge, consent and permission
of Defendant Valley Metro. At such time, Defendant Cruz was incompetent and unfit to safely
operate a motor vehicle on the public streets and highways. Defendant Valley Metro knew, or in
the exercise of due care should have known, that Defendant Cruz was an incompetent, and unfit
driver and would create an unreasonable risk of danger to persons and property on the public streets
and highways of Texas. Furthermore, Defendant Valley Metro’s acts and omissions complained
of are the proximate cause of Plaintiff’s damages as described hereafter, which are the natural,
probable, and foreseeable consequences of Defendant Valley Metro’s said acts and omissions.
5
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
DAMAGES
14. The actions and conduct of Defendants set forth above are the direct and proximate cause
of Plaintiff’s injuries.
15. As a direct, proximate, and foreseeable result of Defendants’ conduct, Plaintiff suffered
injuries and damages including the following:
(1) Medical, hospital, and pharmaceutical charges and expenses in the past;
(2) Medical, hospital, and pharmaceutical charges and expenses that, in reasonable medical
probability, will be incurred in the future;
(3) Pain and suffering in the past;
(4) Pain and suffering that, in reasonable probability, will be suffered in the future;
(5) Mental anguish in the past;
(6) Mental anguish that, in reasonable probability, will be suffered in the future;
(7) Disability and impairment in the past;
(8) Disability and impairment that, in reasonable probability, will occur in the future; and
(9) Physical disfigurement in the past and future.
16. As discussed above, Plaintiff has suffered not only easily quantifiable economic damages,
but also other forms of damage such as mental anguish and pain and suffering, which Plaintiff will
likely continue to suffer in the future.
17. Damages sought are within the jurisdictional limits of the Court.
6
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
REQUEST FOR JURY TRIAL
18. Pursuant to Rule 216 of the Texas Rules of Civil Procedure, Plaintiff requests a trial by
jury. A jury fee is being paid along with the filing fees simultaneously with the filing of Plaintiff’s
Original Petition.
STATEMENT PURSUANT TO T.R.C.P. 47
19. The amount of Plaintiff’s damages is substantial and well in excess of the jurisdictional
minimums of this Court. Many elements of damage, including pain, suffering and mental anguish
in the past and future, past and future impairment and cannot be determined with mathematical
precision. The determination of many of these elements of damages is particularly within the
province of the jury. Plaintiff does not at this time seek any certain amount of damages for any of
these particular elements of damage but would instead rely upon the collective wisdom of the jury
to determine an amount that would fairly and reasonably compensate each. However, pursuant to
Texas Rule of Civil Procedure 47, Plaintiff specifies and pleads to the Court only that he is seeking
monetary relief over $1,000,000.00 and judgment for all other relief to which Plaintiff deems
herself entitled.
MISNOMER/ALTER EGO
20. In the event any parties are misnamed or are not included herein, it is Plaintiff’s contention
that such was a “misidentification” or “misnomer” and/or such parties are/were “alter egos” of
parties named herein. Alternatively, Plaintiff contends that such “corporate veils” should be
pierced to hold such parties properly included in the interest of justice.
7
Electronically Filed
10/31/2023 4:47 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
C-4544-23-B
PRAYER
21. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendants be cited to
appear and answer and that, upon final trial hereof, Plaintiff have judgment against Defendants,
that Plaintiff recover damages in accordance with the evidence, that Plaintiff recover costs of
Court herein expended, that Plaintiff recover interest, both pre- and post-judgment, to which
Plaintiff is entitled under the law, and for such other and further relief, both general and
special, legal and equitable, to which Plaintiff may be justly entitled.
Respectfully submitted,
TIJERINA LEGAL GROUP, P.C.
1200 S. 2nd St. Suite 4A
McAllen, Texas 78501
Telephone No. (956) 777-7000
Facsimile No. (956) 972-0144
Litigation Email: TijerinaLit@tlegalgroup.com
BY:
HUMBERTO TIJERINA, III
State Bar No. 24028040
CESAR PALMA
State Bar No. 24094884
DEREK I. SALINAS
State Bar No. 24093098
GERARDO L. GARCIA, JR.
State Bar No. 24123059
JAMES O. ALANIZ
State Bar No. 24118602
WILLIAM S. LEGGETT
State Bar No. 2410759
ATTORNEYS FOR PLAINTIFF
8
Automated 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.
Humberto Tijerina on behalf of Derek Salinas
Bar No. 24093098
TijerinaLit@tlegalgroup.com
Envelope ID: 81169223
Filing Code Description: Petition
Filing Description:
Status as of 10/31/2023 4:54 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Derek IvanSalinas TijerinaLit@tlegalgroup.com 10/31/2023 4:47:30 PM SENT
Preview
Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B CAUSE NO. _______________ ROSALINDA HERNANDEZ § IN THE DISTRICT COURT Plaintiff § § v. § ____ JUDICIAL DISTRICT § DORA CRUZ AND LOWER RIO § GRANDE VALLEY § DEVELOPMENTAL COUNCIL CORP. § D/B/A VALLEY METRO § Defendants § HIDALGO COUNTY, TEXAS PLAINTIFF’S ORIGINAL PETITION TO THE HONORABLE JUDGE OF THE COURT: NOW COMES ROSALINDA HERNANDEZ (hereafter referred to as “Plaintiff”) complaining of DORA CRUZ (hereafter referred to as “Cruz”) and LOWER RIO GRANDE VALLEY DEVELOPMENTAL COUNCIL CORP. D/B/A VALLEY METRO (hereafter referred to as “Valley Metro”) (Cruz and Valley Metro hereafter collectively referred to as “Defendants”) in the above-styled and numbered cause. In support thereof, Plaintiff would respectfully show the Court as follows: PARTIES 1. Plaintiff ROSALINDA HERNANDEZ is an individual who resides in Hidalgo County, Texas. 2. Defendant DORA CRUZ is an individual for which service may be perfected via process at 510 S. Pleasantview Drive, Weslaco, TX, 78596, or wherever she may be found. CITATION IS REQUESTED. 3. Defendant VALLEY METRO is a corporation doing business in the State of Texas and service of process may be perfected by serving its registered agent: Manuel Cruz, 301 W. Railroad Street, Weslaco, TX, 78596, or wherever he may be found. CITATION IS REQUESTED. Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B DISCOVERY LEVEL 4. Plaintiff intends to conduct discovery in this matter under Level 3 of Rule 190 of the Texas Rules of Civil Procedure. VENUE & JURISDICTION 5. This suit is brought in accordance with the laws of the State of Texas for the recovery of damages which are in excess of the minimal jurisdictional limits of this Court, to which Plaintiff is entitled to receive as compensation for the injuries described below. 6. Venue is proper in Hidalgo County, Texas pursuant to the Texas Civil Practice and Remedies Code because all or a substantial part of the events giving rise to this claim occurred in Edinburg, Hidalgo County, Texas. 7. Accordingly, the Court has jurisdiction over this matter and Venue is proper in Hidalgo County, Texas. FACTUAL ALLEGATIONS 8. On or about July 14, 2023, Plaintiff was exiting the parking lot located at or near 443 East Trenton Road, Edinburg, Hidalgo County, Texas, 78539. At the same time, Defendant Cruz operated a vehicle owned or leased by Defendant Valley Metro which was also traveling at or near the 443 East Trenton Road, Edinburg, Hidalgo County, Texas, 78539, Texas. Suddenly and without warning, Defendant Cruz, among other negligent acts, failed to control her speed thus striking the Plaintiff’s vehicle from behind. The collision caused Plaintiff to sustain personal injuries and damages as set forth below. At all times relevant to this suit, Defendant Cruz was operating a vehicle owned or leased by Defendant Valley Metro and was within the regular course and scope of her employment with Defendant Valley Metro. 2 Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B 9. Nothing Plaintiff did, or failed to do, caused the occurrence in question. Rather, it was the negligence of Defendants that proximately and directly caused the occurrence in question and Plaintiff’s resulting injuries and damages. CAUSE OF ACTION: NEGLIGENCE OF DEFENDANT CRUZ 10. Plaintiff hereby incorporates the allegations contained in the paragraphs set forth above as if fully set forth herein. Defendant Cruz had common-law and statutory duties to use ordinary care in the operation of her vehicle. Defendant Cruz was negligent by failing to exercise ordinary care in the operation of a vehicle on the above-described occasion. Such negligence includes, but is not limited to (a) failing to control speed; (b) failing to drive as a reasonably prudent driver would drive in the same or similar circumstances; (c) failing to keep a proper lookout for Plaintiff’s safety, the safety of others, and the safety of herself that would have been maintained by a person of ordinary prudence under the same or similar circumstances; (d) failing to timely apply the brakes of her vehicle in order to avoid striking Plaintiff’s vehicle as a reasonably prudent driver would under the same or similar circumstances; (e) failing to properly control her vehicle as a reasonably prudent driver would under the same or similar circumstances; (f) failing to timely and safely veer and avoid the collision; (g) failing to maintain a safe distance between her vehicle and Plaintiff’s vehicle; (h) driving inattentively; and (i) other violations of the Texas Transportation Code. Such negligence by Defendant Cruz was the direct and proximate cause of the occurrence in question and the severe bodily injuries of Plaintiff and all Plaintiff’s damages resulting therefrom. 3 Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B CAUSE OF ACTION: NEGLIGENCE OF DEFENDANT VALLEY METRO 11. Plaintiff hereby incorporates the allegations contained in the paragraphs set forth above as if fully set forth herein. Defendant Valley Metro is legally responsible to Plaintiff for the negligent conduct of his driver under the legal doctrines of respondeat superior, agency and/or ostensible agency because Defendant Cruz was at all times material hereto an agent, ostensible agent, servant and/or employee of Defendant Valley Metro and was acting within the regular course and scope of such agency or employment at the time of the collision described above. As a result thereof, Defendant Valley Metro is liable for all negligence of Defendant Cruz. CAUSE OF ACTION: NEGLIGENT HIRING, TRAINING, SUPERVISION AND RETENTION BY DEFENDANT VALLEY METRO 12. Plaintiff hereby incorporates the allegations contained in the paragraphs set forth above as if fully set forth herein. Defendant Valley Metro is also negligent in hiring an incompetent or unfit employee and/or in failing to properly train, instruct, and supervise Defendant Cruz. Furthermore, Defendant Valley Metro failed to provide the proper training and instruction to Defendant Cruz, which would have provided him with the proper skills and knowledge to avoid the collision which forms the basis of this lawsuit. Defendant Valley Metro’s negligent hiring of and failure to properly instruct and train its driver was a proximate cause of the incident and Plaintiff’s resulting injuries and damages. 4 Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B CAUSE OF ACTION: NEGLIGENT ENTRUSTMENT AGAINST DEFENDANT VALLEY METRO 13. Plaintiff hereby incorporates the allegations contained in paragraphs set forth above as if fully set forth herein. Defendant Valley Metro’s acts and omissions outlined herein constitute negligent entrustment. Defendant Valley Metro is liable to Plaintiff for the negligent entrustment of one of her vehicles to an unlicensed, incompetent and unfit driver, namely Defendant Cruz. At the time of the car crash, Defendant Valley Metro was the owner of the vehicle involved in this crash. On or about July 14, 2023, Defendant Valley Metro allowed the above-mentioned vehicle to be operated by Defendant Cruz for the purpose of operating it on the public streets and highways of Texas and Defendant Cruz did operate the vehicle with the knowledge, consent and permission of Defendant Valley Metro. At such time, Defendant Cruz was incompetent and unfit to safely operate a motor vehicle on the public streets and highways. Defendant Valley Metro knew, or in the exercise of due care should have known, that Defendant Cruz was an incompetent, and unfit driver and would create an unreasonable risk of danger to persons and property on the public streets and highways of Texas. Furthermore, Defendant Valley Metro’s acts and omissions complained of are the proximate cause of Plaintiff’s damages as described hereafter, which are the natural, probable, and foreseeable consequences of Defendant Valley Metro’s said acts and omissions. 5 Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B DAMAGES 14. The actions and conduct of Defendants set forth above are the direct and proximate cause of Plaintiff’s injuries. 15. As a direct, proximate, and foreseeable result of Defendants’ conduct, Plaintiff suffered injuries and damages including the following: (1) Medical, hospital, and pharmaceutical charges and expenses in the past; (2) Medical, hospital, and pharmaceutical charges and expenses that, in reasonable medical probability, will be incurred in the future; (3) Pain and suffering in the past; (4) Pain and suffering that, in reasonable probability, will be suffered in the future; (5) Mental anguish in the past; (6) Mental anguish that, in reasonable probability, will be suffered in the future; (7) Disability and impairment in the past; (8) Disability and impairment that, in reasonable probability, will occur in the future; and (9) Physical disfigurement in the past and future. 16. As discussed above, Plaintiff has suffered not only easily quantifiable economic damages, but also other forms of damage such as mental anguish and pain and suffering, which Plaintiff will likely continue to suffer in the future. 17. Damages sought are within the jurisdictional limits of the Court. 6 Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B REQUEST FOR JURY TRIAL 18. Pursuant to Rule 216 of the Texas Rules of Civil Procedure, Plaintiff requests a trial by jury. A jury fee is being paid along with the filing fees simultaneously with the filing of Plaintiff’s Original Petition. STATEMENT PURSUANT TO T.R.C.P. 47 19. The amount of Plaintiff’s damages is substantial and well in excess of the jurisdictional minimums of this Court. Many elements of damage, including pain, suffering and mental anguish in the past and future, past and future impairment and cannot be determined with mathematical precision. The determination of many of these elements of damages is particularly within the province of the jury. Plaintiff does not at this time seek any certain amount of damages for any of these particular elements of damage but would instead rely upon the collective wisdom of the jury to determine an amount that would fairly and reasonably compensate each. However, pursuant to Texas Rule of Civil Procedure 47, Plaintiff specifies and pleads to the Court only that he is seeking monetary relief over $1,000,000.00 and judgment for all other relief to which Plaintiff deems herself entitled. MISNOMER/ALTER EGO 20. In the event any parties are misnamed or are not included herein, it is Plaintiff’s contention that such was a “misidentification” or “misnomer” and/or such parties are/were “alter egos” of parties named herein. Alternatively, Plaintiff contends that such “corporate veils” should be pierced to hold such parties properly included in the interest of justice. 7 Electronically Filed 10/31/2023 4:47 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo C-4544-23-B PRAYER 21. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendants be cited to appear and answer and that, upon final trial hereof, Plaintiff have judgment against Defendants, that Plaintiff recover damages in accordance with the evidence, that Plaintiff recover costs of Court herein expended, that Plaintiff recover interest, both pre- and post-judgment, to which Plaintiff is entitled under the law, and for such other and further relief, both general and special, legal and equitable, to which Plaintiff may be justly entitled. Respectfully submitted, TIJERINA LEGAL GROUP, P.C. 1200 S. 2nd St. Suite 4A McAllen, Texas 78501 Telephone No. (956) 777-7000 Facsimile No. (956) 972-0144 Litigation Email: TijerinaLit@tlegalgroup.com BY: HUMBERTO TIJERINA, III State Bar No. 24028040 CESAR PALMA State Bar No. 24094884 DEREK I. SALINAS State Bar No. 24093098 GERARDO L. GARCIA, JR. State Bar No. 24123059 JAMES O. ALANIZ State Bar No. 24118602 WILLIAM S. LEGGETT State Bar No. 2410759 ATTORNEYS FOR PLAINTIFF 8 Automated 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. Humberto Tijerina on behalf of Derek Salinas Bar No. 24093098 TijerinaLit@tlegalgroup.com Envelope ID: 81169223 Filing Code Description: Petition Filing Description: Status as of 10/31/2023 4:54 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Derek IvanSalinas TijerinaLit@tlegalgroup.com 10/31/2023 4:47:30 PM SENT