Preview
FILED
7/16/2021 3:35 PM
FELICIA PITRE
2 CIT/ ES DISTRICT CLERK
DALLAS 00., TEXAS
Gay Lane DEPUTY
DC-21 -09308
CAUSE N0.
MELISSA TARVER, Individually § IN THE DISTRICT COURT OF
and as Representative of the Estate of §
DERIC TARVER, and as next friend §
of B.T., and K.T., Minors, RANDY §
TARVER and DEBBIE TARVER §
§
Plaintififs, §
§
V. § DALLAS COUNTY, TEXAS
§
ATMOS ENERGY CORPORATION §
and BOBCAT CONTRACTING, LLC § 192nd
§
Defendants. § JUDICIAL DISTRICT
PLAINTIFFS’ ORIGINAL PETITION
NOW COME Plaintiffs Melissa Tarver, Individually and as Representative of The Estate of
Deric Tarver, and as next friend of B.T., K.T., Minors, Randy Tarver and Debbie Tarver (collectively
“Plaintiffs”) complaining of Defendants Atmos Energy Corporation (“Atmos Energy”) and Bobcat
Contracting, LLC (“Bobcat”) (collectively “Defendants”) and for cause of action would respectfully
show this Honorable Court as follows:
DISCOVERY PLAN
Plaintiffs intend to conduct discovery under Level 2 of the Texas Rule of Civil Procedure
190.3 and affirmatively plead that they seek monetary relief in excess of the jurisdictional limits
of this Honorable Court.
PARTIES
Deric Tarver is deceased.
Plaintiff Melissa Tarver is Deric Tarver’s surviving widow and is a resident of the State of
Texas.
Plaintiff B.T. is the natural offspring of Deric and Melissa Tarver and is a resident of the State
of Texas.
Plaintiff K.T. is the natural offspring of Deric and Melissa Tarver and is a resident of the State
of Texas.
Plaintiff Randy Tarver is Den'c Tarver’s surviving father and is a resident of the State of
Texas.
Plaintiff Debbie Tarver is Deric Tarver’s surviving mother and is a resident of the State of
Texas.
Defendant Atmos Energy Corporation is a foreign for-profit, publicly traded corporation doing
business in the State of Texas. Defendant maintains its principal office in Dallas County, Texas,
located at: 1800 Three Lincoln Centre, 5430 LBJ Freeway, Dallas, Texas 75240. Defendant Atmos
Energy Corporation may be served by and through its registered agent: Corporation Service
Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701.
Defendant Bobcat Contracting, LLC is a domestic limited liability company doing business
in the State of Texas. Defendant maintains its principal office in the State of Texas. Defendant Bobcat
Contracting, LLC may be served by and through itsregistered agent: Roy M. Young, 1721 HCR
3106, Hillsboro, Texas 76645.
VENUE AND JURISDICTION
Venue and jurisdiction are proper in this County. Defendant Atmos Energy Corporation
maintains its principal place of business in this County. Defendant Atmos Energy Corporation is
not a natural person; therefore, venue is proper in this County. TEX. R. CIV. P. 15.002(a)(3). The
relief requested herein is within the jurisdictional limits of this Court. This case is not removable
because there is not complete diversity amongst the parties under 28 U.S.C. § 1332 as Plaintiffs
are Texas residents and Defendant Bobcat Contracting, LLC is a Texas-chartered entity comprised
of at least one Texas resident (Roy Young) as a member.
MISNOMER/ALTER EGO
In the event any parties are misnamed or not included herein, itis Plaintiffs’ contention
3’
such was a “misidentification, misnomer” and/or such parties are/were “alter egos” of the parties
66
named herein. Alternatively, Plaintiffs contend such “corporate veils” should be pierced to hold
such parties properly included in the interest of justice.
FACTUAL BACKGROUND
On June 28, 2021, Deric Tarver reported to work at or near the Atmos Energy Facility
located in the 14000 block of FM 2756, Farmersville, Texas on behalf of his employer, Fesco
Petroleum Ltd. Fesco Petroleum had been hired to perform a “pigging” operation (the use of a
pipeline inspection gauge, or “pig”) on a portion of the natural gas pipeline at Atmos Energy’s
Facilityl alongside another fellow contractor, Bobcat Contracting, LLC. The purpose of this
“pigging” procedure was to perform a diagnostic on the condition and integrity of a particular
portion of pipe at the Facility. Generally, this is done by placing the “pig” into a “launcher trap”
at one “end” of the pipe segment, and either by the use of magnets, pressure or manual force, the
“pig” is “launched” down the pipeline to the “receiver trap.” Crucially, an important aspect of
“trap” configuration is that they are to be grounded to avoid the risk of static electrical discharge,
especially with natural gas pipelines.
Upon information and belief, Fesco Petroleum was to conduct the “pigging” operation,
while the traps and instruments related thereto were under Bobcat’s purview. As the operator of
the pipeline, Atmos Energy was responsible for, inter alia, safety and operating procedure at the
Facility specifically with respect to minimization of accidental ignition of product. And so, in the
1
Atmos Energy Corporation is the operator of the subject pipeline underlying this lawsuit.
afternoon of June 28, 2021, Mr. Tarver began work at the Atmos Energy Facility not knowing that
he would never be able to see his family—his wife, his two young children and his parents—ever
again. On this day, Defendants’ catastrophic negligence Violently ripped Deric Tarver away from
his family and in doing so, gashed a wound that will scar Plaintiffs’ souls for the rest of their lives.
At some point, the progress of the operation required Mr. Tarver and another Fesco
employee to utilize a pushrod or “pig pusher” to manually propel the “pig” onward through the
pipeline. This required Mr. Tarver to work in the immediate Vicinity of the pipeline. However,
Bobcat contractors failed to properly ground at least one or both traps, which resulted in a static
discharge.
The discharge ignited residual product in the pipeline, which triggered a massive explosion.
The sheer force and destruction caused by the explosion quickly claimed Deric Tarver’s life.
Each day, Plaintiffs must face the idea of their husband, father, and son, perishing in the explosion.
Each Plaintiff faces a long road to recovery and their lives will never be the same. Indeed, because
of Deric Tarver’s impact on this Earth, many of those close to him will never be the same.
3 Derek Gold
July lat 8:18 PM -8
Words just can't describe what me, my Fesco brothers and the Tarver family are going through
right now. The moment |heard what happened the whole world stopped turning and |
kept
telling myself that it’sjust dream and you‘ll wake up from this nightmare. But God only takes the
great 1's and to me Den" Tamer was 1 helluva man, amazing father and husband. andjust an all
around great guy. No matter what kind of day you were having, he was going to make it a helluva
lot better. And l may not have any pictures with him to show the memories have with him. but
stillhave the memories in mind to carry on till the end of my time. And thinking of the great times
we‘ve had together will always lift my spirits knowing that you're watching over us all that miss
you and love you so damn much brotha. And soon we will see you again but until then bud you
just fly high and keep those bud lights poppin and keep that sun shining down on us. love you
|
brotha man
288 45 Comments
This is a tragedy. Plaintiffs’ daily, waking nightmare is the direct and natural consequence
of Defendants’ failures. As set forth herein, Plaintiffs bring cause of action against Defendants for
their acts and omissions which proximately caused the death of Deric Tarver.
‘ _
’ "
i
i
l"-
l.
-..m‘
“
‘5
r-
w
A..._;
,4
r. i
L
CAUSES OF ACTION
A. NEGLIGENCE
Plaintiffs incorporate all preceding paragraphs herein. At the time of the accident,
Defendants owed Mr. Tarver a duty related to his work at the pipeline. As such, Defendants owed
Mr. Tarver the duty of ordinary care as established by standard operating procedures, industry
standards, applicable safety policies and all other obligations imposed by law. Specifically,
Defendants had a duty to exercise ordinary care in providing a safe workplace for Mr. Tarver as
the operator of the pipeline (Atmos) and a fellow contractor (Bobcat) working alongside Mr.
Tarver and the rest of the Fesco Petroleum crew. By various acts and omissions, Defendants’ duties
were breached, each of which singularly or in combination was the proximate cause of the
occurrence in question:
l. Failing to warn of inherent dangers, leaks or malfunctions of the pipeline;
2. Failing to properly inspect, maintain and repair the subject pipeline;
Failing to timely detect leaks, ruptures or other malfunctions of the pipeline which
might lead to explosions;
Failing to properly inspect, maintain or repair the subject pipeline;
Failing to comply with statutes, rules and regulations of applicable federal, state,
local, or other governmental agencies;
Failing to follow the duties imposed upon operator and contractors of gas pipelines
by laws, statutes, rules or regulations, and in failing to exercise every precaution to
ensure that the gas pipelines were properly maintained and safe for the flow of
inherently dangerous gas;
Failing to train their employees to meet industry standards or their own policies,
rules or standards;
Failing to require their employees to comply with industry standards or their own
policies, rules or standards.
Plaintiffs would show that such negligence proximately caused damages to all the Plaintiffs
involved in this suit, as more fully described below.
B. GROSS NEGLIGENCE
Plaintiffs will further show that the acts and/or omissions of Defendants, as described
above, when viewed objectively from Defendants’ standpoint, involve an extreme degree of risk
considering the probability and magnitude of the potential harm to others. Defendants had actual
subjective awareness of the risk involved, but nevertheless proceeded in conscious indifference to
the rights, safety, and/or welfare of the others including Mr. Tarver. As such, Defendants’ actions
and omissions constitute gross negligence and malice as those terms are understood by law. Such
gross negligence entitles all Plaintiffs to exemplary damages under Texas law.
WRONGFUL DEATH ACT
This cause of action is brought pursuant to Texas Civil Practice and Remedies Code §
77.001, et. seq. (“The Wrongful Death Act”). Plaintiff Melissa Tarver was married to Deric Tarver
at the time of the incident. Plaintiffs B.T. and K.T. are the natural children of Deric Tarver.
Plaintiffs Randy Tarver and Debbie Tarver are the parents of Deric Tarver. As such, Plaintiffs are
the proper parties to bring this action, and bring suit for all allowable damages under the Wrongful
Death Act.
SURVIVAL ACTION OF DERIC TARVER
Plaintiff, Melissa Tarver, as the Administratrix of the Estate of Deric Tarver, deceased, is
the proper party to represent Deric Tarver in his claim for funeral expenses and for the physical
pain and mental anguish he suffered prior to his death. As such, Plaintiff brings suit on behalf of
Deric Tarver’s behalf for all allowable damages under the Survival Statute.
DAMAGES
As a result of this catastrophic incident, Plaintiffs’ lives have been shattered. A wife has
been left alone without the love and support of her husband to jointly face life’s difficulties.
Children have been deprived the opportunity to hug their father, seek advice and counsel from
their father, and to share life’s memories with their father. Parents have been forced to suffer the
ultimate pain—the death of a child. This incident has ripped apart the fabric binding a young,
blossoming family; the light of their lives has been snuffed out by the inevitable consequence of
Defendants’ negligent and grossly negligent conduct.
As such Plaintiffs seek the following damages as the result of the explosion: pre-death
physical pain and suffering, mental anguish, past and future; medical expenses, past and future;
loss of consortium, loss of companionship and society, loss of inheritance, lost wages, loss of
future earning capacity, and all other damages authorized by law. Because of the egregious nature
of Defendants’ actions, Plaintiffs seek punitive damages.
PRAYER
By reason of all the above and forgoing, and on account of the injuries suffered by Plaintiffs
as a result of this tragic incident, Plaintiffs are entitled to have and recover from Defendants, jointly
and severally, damages as set forth in this petition, both actual and exemplary, which are within
the jurisdictional limits of this Court. Plaintiffs seek damages in excess of $250,000,000. Plaintiffs
also seek pre- and post-judgment interest and any other relief, both at law and in equity, to which
Plaintiffs may be justly entitled.
[Signatures on Following Page].
Respectfully submitted,
ABRAHAM, WATKINS, NICHOLS,
AGOSTO, AZIZ & STOGNER
/s/ Benny Agosto Jr.
Benny Agosto, Jr.
State Bar No. 00794981
Ben Agosto III
State Bar No. 24091926
Lena Laurenzo
State Bar N0. 24097973
Edward Festeryga
State Bar No. 24105857
800 Commerce Street
Houston, Texas 77002
(713) 222-721 1 —
Telephone
225 -0827 — Facsimile
(713)
bagosto@awtxlaw.com
ben.agosto@awtxlaw.com
llaurenzo@awtxlaw.com
efesteryga@awtxlaw.com
-AND-
THE KARAM LAW OFFICE, PLLC
/s/ Jacob M. Karam
Jacob M. Karam
State Bar No. 24105653
One Sugar Creek Center Boulevard, Suite 1010
Sugar Land, Texas 77478
(281) 302-5272 — Telephone
(832) 201 -0480 — Facsimile
jacob@thekaram1awoffice.com
ATTORNEYS FOR PLAINTIFFS
Preview
FILED 7/16/2021 3:35 PM FELICIA PITRE 2 CIT/ ES DISTRICT CLERK DALLAS 00., TEXAS Gay Lane DEPUTY DC-21 -09308 CAUSE N0. MELISSA TARVER, Individually § IN THE DISTRICT COURT OF and as Representative of the Estate of § DERIC TARVER, and as next friend § of B.T., and K.T., Minors, RANDY § TARVER and DEBBIE TARVER § § Plaintififs, § § V. § DALLAS COUNTY, TEXAS § ATMOS ENERGY CORPORATION § and BOBCAT CONTRACTING, LLC § 192nd § Defendants. § JUDICIAL DISTRICT PLAINTIFFS’ ORIGINAL PETITION NOW COME Plaintiffs Melissa Tarver, Individually and as Representative of The Estate of Deric Tarver, and as next friend of B.T., K.T., Minors, Randy Tarver and Debbie Tarver (collectively “Plaintiffs”) complaining of Defendants Atmos Energy Corporation (“Atmos Energy”) and Bobcat Contracting, LLC (“Bobcat”) (collectively “Defendants”) and for cause of action would respectfully show this Honorable Court as follows: DISCOVERY PLAN Plaintiffs intend to conduct discovery under Level 2 of the Texas Rule of Civil Procedure 190.3 and affirmatively plead that they seek monetary relief in excess of the jurisdictional limits of this Honorable Court. PARTIES Deric Tarver is deceased. Plaintiff Melissa Tarver is Deric Tarver’s surviving widow and is a resident of the State of Texas. Plaintiff B.T. is the natural offspring of Deric and Melissa Tarver and is a resident of the State of Texas. Plaintiff K.T. is the natural offspring of Deric and Melissa Tarver and is a resident of the State of Texas. Plaintiff Randy Tarver is Den'c Tarver’s surviving father and is a resident of the State of Texas. Plaintiff Debbie Tarver is Deric Tarver’s surviving mother and is a resident of the State of Texas. Defendant Atmos Energy Corporation is a foreign for-profit, publicly traded corporation doing business in the State of Texas. Defendant maintains its principal office in Dallas County, Texas, located at: 1800 Three Lincoln Centre, 5430 LBJ Freeway, Dallas, Texas 75240. Defendant Atmos Energy Corporation may be served by and through its registered agent: Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701. Defendant Bobcat Contracting, LLC is a domestic limited liability company doing business in the State of Texas. Defendant maintains its principal office in the State of Texas. Defendant Bobcat Contracting, LLC may be served by and through itsregistered agent: Roy M. Young, 1721 HCR 3106, Hillsboro, Texas 76645. VENUE AND JURISDICTION Venue and jurisdiction are proper in this County. Defendant Atmos Energy Corporation maintains its principal place of business in this County. Defendant Atmos Energy Corporation is not a natural person; therefore, venue is proper in this County. TEX. R. CIV. P. 15.002(a)(3). The relief requested herein is within the jurisdictional limits of this Court. This case is not removable because there is not complete diversity amongst the parties under 28 U.S.C. § 1332 as Plaintiffs are Texas residents and Defendant Bobcat Contracting, LLC is a Texas-chartered entity comprised of at least one Texas resident (Roy Young) as a member. MISNOMER/ALTER EGO In the event any parties are misnamed or not included herein, itis Plaintiffs’ contention 3’ such was a “misidentification, misnomer” and/or such parties are/were “alter egos” of the parties 66 named herein. Alternatively, Plaintiffs contend such “corporate veils” should be pierced to hold such parties properly included in the interest of justice. FACTUAL BACKGROUND On June 28, 2021, Deric Tarver reported to work at or near the Atmos Energy Facility located in the 14000 block of FM 2756, Farmersville, Texas on behalf of his employer, Fesco Petroleum Ltd. Fesco Petroleum had been hired to perform a “pigging” operation (the use of a pipeline inspection gauge, or “pig”) on a portion of the natural gas pipeline at Atmos Energy’s Facilityl alongside another fellow contractor, Bobcat Contracting, LLC. The purpose of this “pigging” procedure was to perform a diagnostic on the condition and integrity of a particular portion of pipe at the Facility. Generally, this is done by placing the “pig” into a “launcher trap” at one “end” of the pipe segment, and either by the use of magnets, pressure or manual force, the “pig” is “launched” down the pipeline to the “receiver trap.” Crucially, an important aspect of “trap” configuration is that they are to be grounded to avoid the risk of static electrical discharge, especially with natural gas pipelines. Upon information and belief, Fesco Petroleum was to conduct the “pigging” operation, while the traps and instruments related thereto were under Bobcat’s purview. As the operator of the pipeline, Atmos Energy was responsible for, inter alia, safety and operating procedure at the Facility specifically with respect to minimization of accidental ignition of product. And so, in the 1 Atmos Energy Corporation is the operator of the subject pipeline underlying this lawsuit. afternoon of June 28, 2021, Mr. Tarver began work at the Atmos Energy Facility not knowing that he would never be able to see his family—his wife, his two young children and his parents—ever again. On this day, Defendants’ catastrophic negligence Violently ripped Deric Tarver away from his family and in doing so, gashed a wound that will scar Plaintiffs’ souls for the rest of their lives. At some point, the progress of the operation required Mr. Tarver and another Fesco employee to utilize a pushrod or “pig pusher” to manually propel the “pig” onward through the pipeline. This required Mr. Tarver to work in the immediate Vicinity of the pipeline. However, Bobcat contractors failed to properly ground at least one or both traps, which resulted in a static discharge. The discharge ignited residual product in the pipeline, which triggered a massive explosion. The sheer force and destruction caused by the explosion quickly claimed Deric Tarver’s life. Each day, Plaintiffs must face the idea of their husband, father, and son, perishing in the explosion. Each Plaintiff faces a long road to recovery and their lives will never be the same. Indeed, because of Deric Tarver’s impact on this Earth, many of those close to him will never be the same. 3 Derek Gold July lat 8:18 PM -8 Words just can't describe what me, my Fesco brothers and the Tarver family are going through right now. The moment |heard what happened the whole world stopped turning and | kept telling myself that it’sjust dream and you‘ll wake up from this nightmare. But God only takes the great 1's and to me Den" Tamer was 1 helluva man, amazing father and husband. andjust an all around great guy. No matter what kind of day you were having, he was going to make it a helluva lot better. And l may not have any pictures with him to show the memories have with him. but stillhave the memories in mind to carry on till the end of my time. And thinking of the great times we‘ve had together will always lift my spirits knowing that you're watching over us all that miss you and love you so damn much brotha. And soon we will see you again but until then bud you just fly high and keep those bud lights poppin and keep that sun shining down on us. love you | brotha man 288 45 Comments This is a tragedy. Plaintiffs’ daily, waking nightmare is the direct and natural consequence of Defendants’ failures. As set forth herein, Plaintiffs bring cause of action against Defendants for their acts and omissions which proximately caused the death of Deric Tarver. ‘ _ ’ " i i l"- l. -..m‘ “ ‘5 r- w A..._; ,4 r. i L CAUSES OF ACTION A. NEGLIGENCE Plaintiffs incorporate all preceding paragraphs herein. At the time of the accident, Defendants owed Mr. Tarver a duty related to his work at the pipeline. As such, Defendants owed Mr. Tarver the duty of ordinary care as established by standard operating procedures, industry standards, applicable safety policies and all other obligations imposed by law. Specifically, Defendants had a duty to exercise ordinary care in providing a safe workplace for Mr. Tarver as the operator of the pipeline (Atmos) and a fellow contractor (Bobcat) working alongside Mr. Tarver and the rest of the Fesco Petroleum crew. By various acts and omissions, Defendants’ duties were breached, each of which singularly or in combination was the proximate cause of the occurrence in question: l. Failing to warn of inherent dangers, leaks or malfunctions of the pipeline; 2. Failing to properly inspect, maintain and repair the subject pipeline; Failing to timely detect leaks, ruptures or other malfunctions of the pipeline which might lead to explosions; Failing to properly inspect, maintain or repair the subject pipeline; Failing to comply with statutes, rules and regulations of applicable federal, state, local, or other governmental agencies; Failing to follow the duties imposed upon operator and contractors of gas pipelines by laws, statutes, rules or regulations, and in failing to exercise every precaution to ensure that the gas pipelines were properly maintained and safe for the flow of inherently dangerous gas; Failing to train their employees to meet industry standards or their own policies, rules or standards; Failing to require their employees to comply with industry standards or their own policies, rules or standards. Plaintiffs would show that such negligence proximately caused damages to all the Plaintiffs involved in this suit, as more fully described below. B. GROSS NEGLIGENCE Plaintiffs will further show that the acts and/or omissions of Defendants, as described above, when viewed objectively from Defendants’ standpoint, involve an extreme degree of risk considering the probability and magnitude of the potential harm to others. Defendants had actual subjective awareness of the risk involved, but nevertheless proceeded in conscious indifference to the rights, safety, and/or welfare of the others including Mr. Tarver. As such, Defendants’ actions and omissions constitute gross negligence and malice as those terms are understood by law. Such gross negligence entitles all Plaintiffs to exemplary damages under Texas law. WRONGFUL DEATH ACT This cause of action is brought pursuant to Texas Civil Practice and Remedies Code § 77.001, et. seq. (“The Wrongful Death Act”). Plaintiff Melissa Tarver was married to Deric Tarver at the time of the incident. Plaintiffs B.T. and K.T. are the natural children of Deric Tarver. Plaintiffs Randy Tarver and Debbie Tarver are the parents of Deric Tarver. As such, Plaintiffs are the proper parties to bring this action, and bring suit for all allowable damages under the Wrongful Death Act. SURVIVAL ACTION OF DERIC TARVER Plaintiff, Melissa Tarver, as the Administratrix of the Estate of Deric Tarver, deceased, is the proper party to represent Deric Tarver in his claim for funeral expenses and for the physical pain and mental anguish he suffered prior to his death. As such, Plaintiff brings suit on behalf of Deric Tarver’s behalf for all allowable damages under the Survival Statute. DAMAGES As a result of this catastrophic incident, Plaintiffs’ lives have been shattered. A wife has been left alone without the love and support of her husband to jointly face life’s difficulties. Children have been deprived the opportunity to hug their father, seek advice and counsel from their father, and to share life’s memories with their father. Parents have been forced to suffer the ultimate pain—the death of a child. This incident has ripped apart the fabric binding a young, blossoming family; the light of their lives has been snuffed out by the inevitable consequence of Defendants’ negligent and grossly negligent conduct. As such Plaintiffs seek the following damages as the result of the explosion: pre-death physical pain and suffering, mental anguish, past and future; medical expenses, past and future; loss of consortium, loss of companionship and society, loss of inheritance, lost wages, loss of future earning capacity, and all other damages authorized by law. Because of the egregious nature of Defendants’ actions, Plaintiffs seek punitive damages. PRAYER By reason of all the above and forgoing, and on account of the injuries suffered by Plaintiffs as a result of this tragic incident, Plaintiffs are entitled to have and recover from Defendants, jointly and severally, damages as set forth in this petition, both actual and exemplary, which are within the jurisdictional limits of this Court. Plaintiffs seek damages in excess of $250,000,000. Plaintiffs also seek pre- and post-judgment interest and any other relief, both at law and in equity, to which Plaintiffs may be justly entitled. [Signatures on Following Page]. Respectfully submitted, ABRAHAM, WATKINS, NICHOLS, AGOSTO, AZIZ & STOGNER /s/ Benny Agosto Jr. Benny Agosto, Jr. State Bar No. 00794981 Ben Agosto III State Bar No. 24091926 Lena Laurenzo State Bar N0. 24097973 Edward Festeryga State Bar No. 24105857 800 Commerce Street Houston, Texas 77002 (713) 222-721 1 — Telephone 225 -0827 — Facsimile (713) bagosto@awtxlaw.com ben.agosto@awtxlaw.com llaurenzo@awtxlaw.com efesteryga@awtxlaw.com -AND- THE KARAM LAW OFFICE, PLLC /s/ Jacob M. Karam Jacob M. Karam State Bar No. 24105653 One Sugar Creek Center Boulevard, Suite 1010 Sugar Land, Texas 77478 (281) 302-5272 — Telephone (832) 201 -0480 — Facsimile jacob@thekaram1awoffice.com ATTORNEYS FOR PLAINTIFFS