Plaintiff's Petition - Employment Agreement - Fraud

NO. _______________
















_______________, TEXAS



COMES NOW plaintiff, complaining of defendants, and for cause of action would respectfully show the Court as follows:

Discovery Control Plan

Plaintiff shall conduct discovery under Level 2 as provided in Rule 190.3, Texas Rules of Civil Procedure.


  1. Plaintiff is an individual residing in _______________, Texas.

  2. Defendant is an individual residing in _______________, Texas. Defendant has appeared and filed an answer herein.

  3. Defendant is a _______________ based in _______________, Texas. No service of process is necessary.

    Jurisdiction and Venue

  4. This Court has jurisdiction of the parties and of the subject matter of this suit.

  5. Venue is proper in _______________, Texas by reason of the provisions of SectionÊ15.002(a)(1), Texas Civil Practice and Remedies Code, since all events forming the basis of this suit occurred in this county.

    Facts Common to All Counts

  6. At all material times defendant owned a substantial interest in, and was _______________ of, a _______________ known as _______________. _______________ changed its name to _______________ on _______________.

  7. The partnership vested defendant with virtually unlimited authority with respect to management of _______________’s business operations and financial affairs.

  8. For _____ years prior to _______________, _______________ owned and operated a business in _______________, Texas, which sold gel products, resins and materials used in manufacturing fiberglass boats. Defendant hired plaintiff for _______________ on _______________ and promoted him/her to the position of _______________ in ______. In that position, plaintiff was responsible for _______________’s _______________ efforts and for all _______________ in _______________. Plaintiff remained employed as _______________ of _______________ until the partnership sold the business effective _______________. As a direct result of plaintiff’s efforts and abilities, _______________ expanded from a $_______________ business with ___ employees in ______ to a $___ ______ business with ___ employees in ________.

  9. In ______, _______________ began planning to sell the business if and when a viable purchaser could be found. Beginning in _______________, defendant made numerous promises to plaintiff that he/she would pay plaintiff a bonus in the net amount of $_______________ when defendant’s partnership sold the business. The gross amount of the promised bonus was approximately $_______________. Defendant’s reason for making this financial commitment was that plaintiff was primarily responsible for the substantial growth of the business and that plaintiff should, and would, receive substantial compensation if he continued working for...

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