Plaintiff's Original Petition - Sabine Pilot/Refusal to Perform Illegal Act

CAUSE NO. _____________________

IN THE DISTRICT COURT OF

____________________ County, ____________________

_______ JUDICIAL DISTRICT

____________________, §

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Plaintiff, §

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VS. §

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____________________, §

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Defendant. §

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF THE COURT:

____________ (hereafter “Plaintiff”) files this Original Petition complaining of ____________ (hereafter “____________” or “Defendant”) and would show the Court the following:

I.

LEVEL III DISCOVERY CONTROL PLAN

1. Discovery is intended to be conducted under Level III, pursuant to Rule 190.4 of the Texas Rules of Civil Procedure.

II.

THE PARTIES

2. Plaintiff is an individual residing at ____________.

3. Defendant is a Texas corporation, whose principal office is located at ____________.

III.

JURISDICTION AND VENUE

4. Plaintiff is a resident of ____________ County, Texas. Defendant is a Texas corporation with its principal office in ____________ County, Texas. Further, all or a substantial part of the events and/or omissions on which Plaintiff’s claims are based occurred in ____________ County, Texas. Finally, Defendant has caused Plaintiff damages in ____________ County, Texas that are the subject of this lawsuit that are in excess of the minimum jurisdictional limit of this Court.

5. Therefore, jurisdiction and venue are proper in this Court.

IV.

SERVICE OF PROCESS

6. Service of process may be had on Defendant by serving its registered agent for service of process as follows:

[Name and Address of Registered Agent]

V.

FACTS

[Briefly discuss facts in separately numbered paragraphs. For example:

7. This a clear and simple case of corporate greed. Despite the well-publicized wrongdoing of the top executives at ENRON, WorldCom and other corporations, ____________’s top executives knowingly made false and misleading bookkeeping entries in a fraudulent attempt to “pump up” the company’s earnings, hide losses and not pay monies that the company owed to its customers.

8. This case is emblematic of corporate irresponsibility and the extreme and improper actions that a corporation will take to punish an employee who is merely trying to follow the law and do the right thing.

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25. Less than three weeks after Plaintiff found and reported Defendant’s irregularities in customer billing and financial results and refused to illegally falsify Defendant’s...