- Home
- Books and Journals
- James Publishing Practical Law Books Archive
- Texas Employment Law. Volume 2 - 2017
- Appendices
- Substantive
Plaintiff's Petition - Employment Agreement - Fraud
NO. _______________
Plaintiff
v.
Defendants
§
§
§
§
§
§
§
§
§
§
§
IN THE DISTRICT COURT
_______________, TEXAS
______ JUDICIAL DISTRICT
PLAINTIFF’S FIRST AMENDED ORIGINAL PETITION
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.
Parties
-
Plaintiff is an individual residing in _______________, Texas.
-
Defendant is an individual residing in _______________, Texas. Defendant has appeared and filed an answer herein.
-
Defendant is a _______________ based in _______________, Texas. No service of process is necessary.
Jurisdiction and Venue
-
This Court has jurisdiction of the parties and of the subject matter of this suit.
-
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
-
At all material times defendant owned a substantial interest in, and was _______________ of, a _______________ known as _______________. _______________ changed its name to _______________ on _______________.
-
The partnership vested defendant with virtually unlimited authority with respect to management of _______________’s business operations and financial affairs.
-
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 ________.
-
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...
To continue reading
Request your trial- Appendices
- Substantive
- Defendant's Motion for Summary Judgment: Mitigation of Damages
- General Complete Release in Favor of Defendant (With Mutuality Option)
- Plaintiff's Original Petition
- Settlement Agreement and Release (Includes OWBPA Language)
- Separation and Release Agreement (For Unrepresented Employee)
- Petition to Compel Arbitration (State Court)
- Motion to Compel Arbitration, Dismiss, and Stay (State Court)
- Defendant's Standard Brief in Support of Motion to Stay Pending Arbitration (Federal Court)
- Notice of Intent to Use Discovery Products
- Defendant's Standard Brief in Support of Motion to Compel Arbitration, Dismiss and Stay Proceedings (State Court)
- Special exception & answer (State Court)
- Motion to Stay Pending Arbitration, Alternatively Motion to Dismiss (Federal Court)
- Joinder in/ consent to removal
- Defendant's Motion for Summary Judgment: After-Acquired Evidence, Wrongful Discharge, Constructive Discharge, IIED, Retaliation, Whistleblowing
- Consolidation Motion (Fed.)
- Response to EEOC Charge of Discrimination
- Opposition to MTN. To vacate arbitration award; MTN and brief to confirm arbitration award
- Brief supporting MTN to expedite appeal
- Unopposed Mtn Expedite 5th Cir. Appeal
- Brief for emer. MTN for temp stay pend appeal to fifth circuit
- Amended Complaint - TCHRA - Age Discrimination
- Emergency MTN for temp stay pending appeal to 5th CIR
- AFFIDAVIT-Business Records
- Order Granting Objections to Summary Judgment Evidence
- Defendant's Motion to Dismiss for Lack of Subject Matter Jurisdiction and Supporting Brief - Title VII - Federal Court
- Affidavit - Authentication of Deposition Excerpts
- Affidavit - Discovery Authentication
- Plaintiff's Response to Defendant Employer's Motion for Summary Judgment - Workers' Compensation Retaliation Case
- Plaintiff's Motion to Dismiss Pursuant to Settlement
- Plaintiff’s Original Petition-Sabine Pilot/Refusal to Perform Illegal Act
- Plaintiff's Original Petition-FMLA, ADEA
- Motion for Summary Judgment (by Employer) for False Imprisonment and Breach of Contract
- Plaintiff's Petition - Workers' Compensation Retaliation
- Plaintiff's Petition - Employment Agreement - Fraud
- Plaintiff's letter brief-gender discrimination-cat's paw doctrine
- Plaintiff's brief in support of motion for summary judgment-adea-federal court
- Defendant's Plea to Jurisdiction
- Order of Dismissal
Subscribers can access the reported version of this case.
You can sign up for a trial and make the most of our service including these benefits.
Why Sign-up to vLex?
-
Over 100 Countries
Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more.
-
Thousands of Data Sources
Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
-
Find What You Need, Quickly
Advanced A.I. technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research.
-
Over 2 million registered users
Founded over 20 years ago, vLex provides a first-class and comprehensive service for lawyers, law firms, government departments, and law schools around the world.
Subscribers are able to see a list of all the cited cases and legislation of a document.
You can sign up for a trial and make the most of our service including these benefits.
Why Sign-up to vLex?
-
Over 100 Countries
Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more.
-
Thousands of Data Sources
Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
-
Find What You Need, Quickly
Advanced A.I. technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research.
-
Over 2 million registered users
Founded over 20 years ago, vLex provides a first-class and comprehensive service for lawyers, law firms, government departments, and law schools around the world.
Subscribers are able to see a list of all the documents that have cited the case.
You can sign up for a trial and make the most of our service including these benefits.
Why Sign-up to vLex?
-
Over 100 Countries
Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more.
-
Thousands of Data Sources
Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
-
Find What You Need, Quickly
Advanced A.I. technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research.
-
Over 2 million registered users
Founded over 20 years ago, vLex provides a first-class and comprehensive service for lawyers, law firms, government departments, and law schools around the world.
Subscribers are able to see the revised versions of legislation with amendments.
You can sign up for a trial and make the most of our service including these benefits.
Why Sign-up to vLex?
-
Over 100 Countries
Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more.
-
Thousands of Data Sources
Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
-
Find What You Need, Quickly
Advanced A.I. technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research.
-
Over 2 million registered users
Founded over 20 years ago, vLex provides a first-class and comprehensive service for lawyers, law firms, government departments, and law schools around the world.
Subscribers are able to see any amendments made to the case.
You can sign up for a trial and make the most of our service including these benefits.
Why Sign-up to vLex?
-
Over 100 Countries
Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more.
-
Thousands of Data Sources
Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
-
Find What You Need, Quickly
Advanced A.I. technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research.
-
Over 2 million registered users
Founded over 20 years ago, vLex provides a first-class and comprehensive service for lawyers, law firms, government departments, and law schools around the world.
Subscribers are able to see a visualisation of a case and its relationships to other cases. An alternative to lists of cases, the Precedent Map makes it easier to establish which ones may be of most relevance to your research and prioritise further reading. You also get a useful overview of how the case was received.
Why Sign-up to vLex?
-
Over 100 Countries
Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more.
-
Thousands of Data Sources
Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
-
Find What You Need, Quickly
Advanced A.I. technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research.
-
Over 2 million registered users
Founded over 20 years ago, vLex provides a first-class and comprehensive service for lawyers, law firms, government departments, and law schools around the world.
Subscribers are able to see the list of results connected to your document through the topics and citations Vincent found.
You can sign up for a trial and make the most of our service including these benefits.
Why Sign-up to vLex?
-
Over 100 Countries
Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more.
-
Thousands of Data Sources
Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
-
Find What You Need, Quickly
Advanced A.I. technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research.
-
Over 2 million registered users
Founded over 20 years ago, vLex provides a first-class and comprehensive service for lawyers, law firms, government departments, and law schools around the world.