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Plaintiff’s Original Petition-Sabine Pilot/Refusal to Perform Illegal Act
CAUSE NO. _____________________
IN THE DISTRICT COURT OF
____________________ County, ____________________
_______ JUDICIAL DISTRICT
____________________, §
§
Plaintiff, §
§
VS. §
§
____________________, §
§
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.
* * *
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...
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- Substantive
- Notice of intent to use discovery products
- Plaintiff's original petition
- Petition to compel arbitration (State Court)
- General complete release in favor of defendant (with mutuality option)
- Defendant's standard brief in support of motion to compel arbitration, dismiss and stay proceedings (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)
- Settlement agreement and release (includes owbpa language)
- Affidavit - Discovery Authentication
- Motion to stay pending arbitration, alternatively motion to dismiss (Federal Court)
- Special exception & answer (State Court)
- Defendant's motion for summary judgment: mitigation of damages
- Separation and release agreement (for unrepresented employee)
- Consolidation Motion (Fed.)
- Unopposed Mtn Expedite 5th Cir. Appeal
- Brief supporting MTN to expedite appeal
- Brief for emer. MTN for temp stay pend appeal to fifth circuit
- Emergency MTN for temp stay pending appeal to 5th CIR
- AFFIDAVIT-Business Records
- Opposition to MTN. To vacate arbitration award; MTN and brief to confirm arbitration award
- Order granting objections to summary judgment evidence
- AFFIDAVIT - Authentication of deposition excerpts
- Defendant's motion for summary judgment: after-acquired evidence, wrongful discharge, constructive discharge, IIED, retaliation, whistleblowing
- Response to EEOC Charge of Discrimination
- Joinder in/ consent to removal
- Plaintiff’s Original Petition-Sabine Pilot/Refusal to Perform Illegal Act
- Plaintiff's original petition-FMLA, ADEA
- Plaintiff's brief in support of motion for summary judgment-adea-federal court
- Plaintiff's petition - employment agreement - FRAUD
- Plaintiff's petition - workers' compensation retaliation
- Plaintiff's letter brief-gender discrimination-cat's paw doctrine
- Plaintiff's response to defendant employer's motion for summary judgment - workers' compensation retaliation case
- Defendant's plea to jurisdiction
- Defendant's motion to dismiss for lack of subject matter jurisdiction and supporting brief - title VII - Federal Court
- Order of dismissal
- Amended complaint - TCHRA - age discrimination
- Motion for summary judgment (by employer) for false imprisonment and breach of contract
- Plaintiff's motion to dismiss pursuant to settlement
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