On December 27, 2018 a
Original Petition- First Supplement - No Fee Documents
was filed
involving a dispute between
Vinet, Terra,
and
Mckenzie, Colin Donald,
Mckenzie, Louise Margaret,
for Inj/Damage-Other Injury or Damage >$200,000
in the District Court of Montgomery County.
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Received and E-Filed for Record
5/30/2019 9:26 PM
Melisa Miller, District Clerk
Montgomery County, Texas
Deputy Clerk, Megan Shiflett
Cause No. 18-12-16948
Terra Vinet § In the District Court of
§
vs. § Montgomery County, Texas
§
Louise Margaret McKenzie and §
Colin Donald McKenzie § 284th Judicial District
Original Petition – First Supplement
Terra Vinet (“Tenant” or “Ms. Vinet” or “Plaintiff”) makes this First
Supplement to her Original Petition adding to that petition by this supplement, the
following statement under Rule 47 in response to Defendants’ special exceptions
seeking a statement of the total maximum amount of damages sought:
1. Pursuant to Rule 47(c)(4), at this time Ms. Vinet seeks monetary relief of
more than $200,000 but not more than $1,000,000.
PRAYER
Wherefore, premises considered, Plaintiff Terra Vinet prays that this
supplement be added to her Original Petition to satisfy the special exceptions filed
by Defendants and that upon final trial or hearing that Plaintiff have judgment
against Defendants for all amounts due, for her actual damages, for additional
damages, for attorney’s fees and costs, and for such other and further relief to
which she may show herself justly entitled.
Respectfully submitted,
/s/ Brad Beers .
Brad Beers
State Bar No. 02041400
BEERS LAW FIRM
ORIGINAL PETITION – FIRST SUPPLEMENT PAGE 1
5020 Montrose Blvd., Suite 700
Houston, Texas 77006
Telephone: 713-654-0700
Facsimile: 713-654-9898
BBeers@BeersLaw.net
Attorney for Terra Vinet
Certificate of Service
This pleading was served on May 30, 2019, on counsel of record pursuant to
Rules 21 and 21a.
Brad Beers .
Brad Beers
ORIGINAL PETITION – FIRST SUPPLEMENT PAGE 2
Document Filed Date
May 30, 2019
Case Filing Date
December 27, 2018
Category
Inj/Damage-Other Injury or Damage >$200,000
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Received and E-Filed for Record 5/30/2019 9:26 PM Melisa Miller, District Clerk Montgomery County, Texas Deputy Clerk, Megan Shiflett Cause No. 18-12-16948 Terra Vinet § In the District Court of § vs. § Montgomery County, Texas § Louise Margaret McKenzie and § Colin Donald McKenzie § 284th Judicial District Original Petition – First Supplement Terra Vinet (“Tenant” or “Ms. Vinet” or “Plaintiff”) makes this First Supplement to her Original Petition adding to that petition by this supplement, the following statement under Rule 47 in response to Defendants’ special exceptions seeking a statement of the total maximum amount of damages sought: 1. Pursuant to Rule 47(c)(4), at this time Ms. Vinet seeks monetary relief of more than $200,000 but not more than $1,000,000. PRAYER Wherefore, premises considered, Plaintiff Terra Vinet prays that this supplement be added to her Original Petition to satisfy the special exceptions filed by Defendants and that upon final trial or hearing that Plaintiff have judgment against Defendants for all amounts due, for her actual damages, for additional damages, for attorney’s fees and costs, and for such other and further relief to which she may show herself justly entitled. Respectfully submitted, /s/ Brad Beers . Brad Beers State Bar No. 02041400 BEERS LAW FIRM ORIGINAL PETITION – FIRST SUPPLEMENT PAGE 1 5020 Montrose Blvd., Suite 700 Houston, Texas 77006 Telephone: 713-654-0700 Facsimile: 713-654-9898 BBeers@BeersLaw.net Attorney for Terra Vinet Certificate of Service This pleading was served on May 30, 2019, on counsel of record pursuant to Rules 21 and 21a. Brad Beers . Brad Beers ORIGINAL PETITION – FIRST SUPPLEMENT PAGE 2