FILED

DALLAS COUNTY
1 CIT ES / JURY DEMAND 12/5/2017 9:08 AM
FELICIA PITRE
DISTRICT CLERK

DC-17-16588 Manuel Rodriguez

CAUSE NO. _________________

P AULA B ECKER and B ARRON B ROWN ,

Individually and on behalf of the ESTATE OF
HUNTER BROWN, IN THE DISTRICT COURT OF
Plaintiffs,
DALLAS COUNTY, TEXAS
vs.
_____ JUDICIAL DISTRICT
GREYHOUND LINES, INC.,
Defendant.

P LAINTIFFS O RIGINAL P ETITION ,

R EQUEST FOR D ISCLOSURE AND J URY D EMAND

Plaintiffs Paula Becker and Barron Brown, Individually and on behalf of The Estate of Hunter
Brown, file this Original Petition and assert the following allegations and claims against Defendant
Greyhound Lines, Inc. and pray for their damages as follows:
I.
P ARTIES

1. Plaintiffs Paula Becker and Barron Brown are residents of Washington and the natural parents
of Hunter Brown, who is deceased.
2. Defendant Greyhound Lines, Inc. (Greyhound) is a Delaware company authorized to do
business in Texas with its principle place of business in Dallas County, Texas. Greyhound may be
served through its registered agent: CT Corporation System, 1999 Bryan St., Suite 900, Dallas, TX
75201. Greyhound is a motor carrier as defined by Federal and Texas law and is engaged in both
intrastate and interstate travel.
II.
D ISCOVERY P LAN

3. Pursuant to TEXAS RULE OF CIVIL PROCEDURE 190, Plaintiffs request that this action be
conducted pursuant to Level 3 of TEXAS RULE OF CIVIL PROCEDURE 190.4. Upon answering, Plaintiffs
will submit a proposed scheduling order to Defendant and present it to the Court for entry.

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 1 of 13
 III.
V ENUE AND J URISDICTION

4. Venue is proper in Dallas County pursuant to TEXAS CIVIL PRACTICE & REMEDIES CODE
15.002(a)(3) because Dallas County is the county of Defendant Greyhounds principal office in this
state. Venue is proper in Dallas County pursuant to TEXAS CIVIL PRACTICE & REMEDIES CODE
15.002(a)(1) because Dallas County is a county in which all or a substantial part of the events or
omissions giving rise to the claim occurred, including but not limited to corporate decision making and
dispatching.
5. This court has personal jurisdiction over Defendant because it maintains its headquarters in the
State and conducts business on a regular and systematic basis in the State of Texas. Further, Defendant
Greyhound has its principal place of business in the State of Texas.
6. This Court has jurisdiction because the amount in controversy exceeds the minimum
jurisdictional amounts of the Court.
IV.
F ACTUAL B ACKGROUND

7. This lawsuit involves the death of a young man, Hunter Brown, who trusted Dallas-based
Greyhound Lines to provide him with a safe bus ride. Sadly, Greyhound violated Hunters trust when
it failed to provide him with the safe, rested, and responsible bus driver that he reasonably expected, and
as a result, Hunter lost his life at age twenty-five. Had Greyhound acted responsibly as a good corporate
citizen and common carrier to enforce safe driver practices, Hunter would not have died. This lawsuit
seeks accountability of this corporation and a change in how it does business to protect our
communities and so that other passengers do not have to endure what Hunter suffered.
8. Greyhound is in the business of transportation. The primary purpose of its business is carrying
passengers over the road in exchange for a fare. Every year, Greyhound buses travel 5.4 billion miles
sharing the road with the motoring public and carrying nearly 18 million people that pay Greyhound
as passengers.1 Greyhound knows the safety of passengers, the motoring public, and its own employees
should be the companys number one priority. And it knows that Greyhound bus drivers play a critical
role in the safety of its transportation business.
9. To ensure safe transport of passengers, Greyhound not only has to make sure its drivers are
qualified and experienced, it has to make sure those drivers are not fatigued, follow federal law, and
comply with Greyhounds policies.

1
About Greyhound available at https://www.greyhound.com/en/about/facts-and-figures (last visited Oct. 28, 2017).

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 2 of 13
10. Greyhound knows unqualified and inexperienced bus drivers can be dangerous to passengers,
the public, and themselves. Greyhound knows drivers that violate federal laws and Greyhound policies
can cause harm when they drive. And Greyhound knows driver fatigue is dangerous. Fatigued drivers
put Greyhounds passengers, the public, and themselves at risk of serious harm.
11. In its Customer Bill of Rights, Greyhound pledges that every passenger who purchases tickets
from Greyhound will experience a safe and reliable bus ride with a professional and courteous driver:2

12. Greyhound did not honor its pledge to Hunter Brown or the other passengers on his bus when
it assigned its employee Arthur Coley, Sr. to be their driver from Portland, Oregon to Los Angeles,
California on June 28, 2016. Instead of arriving on time, rested, and calm for the driving assignment,
Coley was late, fatigued, and hostile to the passengers he was supposed to keep safe. His behaviors
throughout the trip were erratic, unsafe, and eventually proved deadly to Hunter.
13. As a Greyhound driver, Coley was issued a Drivers Rule Book and instructed to consider the
Rule Book hisBible on company policies. On the trip at issue, Coley ignored those rules repeatedly
according to Greyhound customers aboard the bus with Hunter.
14. Hunter was a passenger on a Greyhound bus which left Seattle, Washington on June 28, 2017.
On June 28, 2017, the bus made a scheduled stop in Portland, Oregon. The bus was supposed to leave
the station at approximately 6:00 p.m., but Coley arrived to take over as the bus driver approximately

2
https://www.greyhound.com/-/media/greyhound/pdf/legal/intercity-motorcoach-customer-bill-of-rights-10-30-15.pdf
(last visited Oct. 30, 2017).

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 3 of 13
90 minutes late. His exhaustion and agitated demeanor were immediately apparent to the Greyhound
passengers.
15. Before passengers boarded, Coley got into a shouting match with a passenger over an unopened
beer, and Coley refused to let the customer continue on his trip. Witnesses to the exchange found
Coleys reaction disproportional and hostile. Greyhounds Rule Book prohibits hostile conduct but
Coley was either not trained or not supervised to ensure that he complied with the policy:

Hostile or aggressive actions, whether verbal, physical, by gesture, or otherwise, towards the Company,
its employees, patrons, or agents are cause for discipline, up to and including termination.

16. Once the continuing passengers were seated, Coley began his pre-trip announcements. Those
announcements started with Coley informing the entire bus that he was so exhausted that he might fall
asleep and warning them not to do anything that would further agitate him. The bus finally left Portland
around 8:00 p.m. It was approximately two hours behind schedule.
17. Greyhounds Rule Book requires drivers to take safety stops every 150 miles, but Greyhound
did not ensure that Coley complied with this standard :

Drivers are to stop approximately every 150 miles to check tires

and walk around the bus for a safety stop at roadside rests.

18. Greyhounds central dispatch in Dallas is responsible for assigning driver routes nationwide.
The dispatchers have access to driver route histories and they would have known that Coley had already
driven 9.5 hours on June 28 when they assigned him the route from Portland that evening.
Greyhounds executives have testified under oath in previous matters that Greyhound relies on its
drivers to police their own fatigue. Greyhounds custom and practice is for dispatchers to accept a
drivers word that he/she is rested and can complete the route assignment without violating federal
hours of operation laws.
19. Not long after leaving the station, Coley shocked his passengers by putting the bus in park on
the road to take a bathroom break prior to entering a highway. The bus remained in park in its lane near

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 4 of 13
the light before the highway entrance until Coley finished using the bathroom. Greyhounds Rule Book
prohibits drivers from making unplanned stops of that nature.
20. Later in the trip, at a scheduled stop, Coley engaged in another altercation with passengers. The
altercation ended with Coley leaving three teenage Greyhound customers at the stop and continuing on
the route with their baggage aboard. Passengers on the bus worried for the teens being left at the
remote location well after dark without their belongings. Coley continued on driving.
21. At approximately 1:00 a.m. on June 29, 2017, the bus pulled into a Pilot truck stop in Central
Point, Oregon. Coley told the passengers the bus would be leaving at 1:30 a.m. and if the passengers
werent on the bus at that time, he would leave them behind.
22. Hunter and many of the other passengers got off the bus to go into the truck stop to get
something to eat. At some point prior to 1:30 a.m., Coley got back on the bus and honked the horn.
Several passengers complained that it wasnt 1:30 yet and that many passengers were still inside the truck
stop. The driver responded that he would go by his time, not theirs and proceeded to pull out of the
parking lot.
23. As Coley was making a wide right turn onto the adjoining roadway, Hunter ran up to the side
of the bus, banging on the door and begging Coley to stop the bus to let him on. Coley looked out the
door at Hunter, but instead of stopping, he kept turning to the right, directly towards Hunter.
24. The bus knocked Hunter off balance, he fell to the ground and was run over by the front right
side bus tires.
25. When everyone heard a thump thump, Coley finally stopped the bus and opened the door.
He walked down to the bottom step, looked out the door and said where the hell did he go? One of
the passengers screamed that Coley had run Hunter over.
26. Several of the passengers who had medical training offered to get off the bus to assist Hunter,
but Coley instructed them to stay on the bus. Coley called 911 and the police and ambulance arrived.
They found Hunter dead behind the wheels of the bus near the door. Blunt force trauma was the cause
of his death.
27. Greyhound has safety rules about meal stops and boarding passengers. Coley ignored those
rules. Had he followed them, Hunter would not have died.

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 5 of 13
 Drivers are responsible to make certain all passengers are accounted for
prior to departure from meal or rest stops.

28. The other passengers warned Coley that a passenger was not on board before he put the bus
in motion. Had he followed the rules, he would not have departed before accounting for Hunter and
Hunter would not have been run over. He also violated Greyhounds safety rule:

BOARDING AND ALIGHTING PASSENGERS: Drivers will bring their bus to a complete stop before
allowing passengers to board or alight....
Drivers must not place their bus in motion until the safety of passengers is assured...

29. As a result of the actions of Greyhound and its driver, Hunter Brown was killed. His parents
are seeking damages for his wrongful death.
V.
C AUSES OF A CTION AND C LAIMS FOR R ELIEF

A. Count One: Negligence Under the Highest Degree of Care Because Greyhound
Lines, Inc. is a Common Carrier
30. Plaintiffs incorporate all prior paragraphs in support of this cause.
31. At all relevant times, Greyhound and its agents and employees, including Coley, were acting as
a common carrier as Greyhound was in the business of carrying passengers and held itself out for hire
by the public. Greyhound solicits and operates a public transportation service. The business of
Greyhound is the transport for hire of paying public passengers, and that transportation is not incidental

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 6 of 13
to any other purpose for Greyhound but rather is the primary mode of making money. If the public
did not seek transportation for pay from Greyhound, Greyhound would have no business and would
not exist.
32. As a common carrier, Greyhound owed the highest degree of care in the operation of the
conveyance of its passengers and in the boarding and alighting of passengers. That degree of care is that
which would be exercised by a very cautious and prudent person under the same or similar
circumstances.
33. Greyhound publicly solicited and operated a vehicle for hire transportation service to and for
members of the public, including Hunter Brown and his fellow Greyhound passengers. Hunter Brown
purchased a ticket from Greyhound for bus transportation. Greyhound agreed and dispatched its driver
Coley. At all relevant times Greyhound controlled Coley as an employee, statutory employee, agent,
or joint venturer. Greyhound owed Hunter Brown the highest degree of care as a common carrier.
34. Greyhound violated that highest degree of care in the following particulars:
a. Failing to act as a very cautious or prudent company would under the same or similar
circumstances;
b. Failing to exercise a high degree of care to avoid a foreseeable risk of injury to Hunter;
c. Failing to exercise a high degree of care in the hiring of Coley to drive passengers;
d. Failing to exercise a high degree of care in the supervising, retaining, monitoring, or
training of Coley as an employee to drive passengers;
e. Failing to exercise a high degree of care in selecting Coley as a driver as Coley was
incompetent or unfit to be a driver for hire;
f. Failing to exercise a high degree of care in exercising whatever control Greyhound
retained over Coley;
g. Failing to exercise a high degree of care in dispatching Coley to Hunters bus as a driver
to provide transportation;
h. Failing to exercise a high degree of care in adopting, implementing, and enforcing safety
policies;
i. Failing to exercise a high degree of care in adopting, implementing, and enforcing safe
dispatch/driver scheduling policies and procedures;
j. Failing to exercise a high degree of care in adopting, implementing, and enforcing safety
policies to prevent drivers providing transportation while fatigued;
k. Through its employed driver transporting Hunter, failing to assure passengers were
accounted for at all stops;

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 7 of 13
 l. Through its employed driver transporting Hunter, failing to remain stopped for the
stated length of time;
m. Through its employed driver transporting Hunter, failing to maintain a safe and proper
lookout;
n. Through its employed driver transporting Hunter, failing to maintain a safe speed;
o. Through its employed driver transporting Hunter, failing to allow all passengers to
board safely before putting the vehicle in motion;
p. Through its employed driver transporting Hunter, failing to comply with all federal laws
and regulations for passenger motor carriers and drivers;
q. Through its employed driver transporting Hunter, failing to comply with all traffic laws;
and
r. Through its employed driver transporting Hunter, operating the bus in an unsafe
manner.
35. The above acts or omissions by Greyhound were a producing and/or proximate cause of
Hunters death and the resulting damages Plaintiffs seek in this suit. Plaintiffs pray that, following a
verdict, all such damages asserted below be awarded against Greyhound.
B. Count Two: Negligence of Greyhound Lines, Inc.
36. Plaintiffs incorporate the above paragraphs by reference.
37. At all relevant times, Greyhound committed the following acts and/or omissions which
constitute negligence and were a proximate cause of Hunters injuries and the damages Plaintiffs seek
to recover. Defendant Greyhound was negligent, as that term is defined by law and its conduct was,
singularly and severally, a proximate cause of the collision and Hunters injuries and damages.
Defendant Greyhound acted or failed to act by and through its owner, agents, officers, employees,
principals, and vice-principals. Driver Arthur Coley was acting within the course and scope of his
employment, statutory employment, agency, and authority with Greyhound at all times relevant.
38. At all relevant times, Defendant Greyhound had a duty to act as a reasonably prudent passenger
motor carrier company in like or similar circumstances, including in providing safe transportation
policies, practices, and services to customers riding Greyhound buses. It breached that duty through
its acts and omissions, including but not limited to:
a. Failing to act as a reasonably prudent company would under the same or similar
circumstances;
b. Failing to exercise reasonable care to avoid a foreseeable risk of injury to Hunter;
c. Failing to exercise reasonable care in the hiring of Coley to drive passengers;

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 8 of 13
 d. Failing to exercise reasonable care in the supervising, retaining, monitoring, or training
of Coley as an employee to drive passengers;
e. Failing to exercise reasonable care in selecting Coley as a driver as Coley was
incompetent or unfit to be a driver for hire;
f. Failing to exercise reasonable care in exercising whatever control Greyhound retained
over Coley;
g. Failing to exercise reasonable care in dispatching Coley to Hunters bus as a driver to
provide transportation;
h. Failing to exercise reasonable care in adopting, implementing, and enforcing safety
policies;
i. Failing to exercise reasonable care in adopting, implementing, and enforcing safe
dispatch/driver scheduling policies and procedures;
j. Failing to exercise reasonable care in adopting, implementing, and enforcing safety
policies to prevent drivers providing transportation while fatigued;
k. Through its employed driver transporting Hunter, failing to assure passengers were
accounted for at all stops;
l. Through its employed driver transporting Hunter, failing to remain stopped for the
stated length of time;
m. Through its employed driver transporting Hunter, failing to maintain a safe and proper
lookout;
n. Through its employed driver transporting Hunter, failing to maintain a safe speed;
o. Through its employed driver transporting Hunter, failing to allow all passengers to
board safely before putting the vehicle in motion;
p. Through its employed driver transporting Hunter, failing to comply with all federal laws
and regulations for passenger motor carriers and drivers;
q. Through its employed driver transporting Hunter, failing to comply with all traffic laws;
and
r. Through its employed driver transporting Hunter, operating the bus in an unsafe
manner.
39. The above acts or omissions by Greyhound were a producing and/or proximate cause of
Hunters death and the resulting damages Plaintiffs seek in this suit. Plaintiffs pray that, following a
verdict, all such damages asserted below be awarded against Greyhound.

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 9 of 13
C. Count Three: Gross Negligence of Greyhound.
40. Plaintiffs incorporate the above paragraphs by reference.
41. The conduct of Greyhound and its employee set forth above was substantially more than
ordinary carelessness or inadvertence. Rather, the conduct rises to the level of gross negligence and
malice, as those terms are defined by law. The failure to stop and/or turning to avoid running over
Hunter Brown was such an entire want of care as to indicate that the acts or omissions in question were
the result of conscious indifference to the rights, welfare or safety of Hunter Brown. Moreover, those
acts and omissions of Defendant involved an extreme degree of risk, considering the probability and
magnitude of the potential harm to Hunter Brown when Defendant had actual, subjective awareness
of the risk involved, such that the conduct amounts to conscious indifference to the rights, safety
and/or welfare of Hunter Brown.
42. Defendant Greyhound acted recklessly in its employment and supervision of Arthur Coley who
was unfit for the job, and Greyhounds continued employment of Coley was ratification of his conduct.
As such Greyhound is liable for exemplary damages attributable to the conduct of Coley.
43. For this gross negligence, Plaintiffs specifically plead for the recovery of exemplary damages in
an amount to be determined by the jury sufficient to deter future conduct.
VI.
A GENCY

44. At all relevant times, Arthur Coley was acting in the course and scope of his employment with
Greyhound Lines, Inc. and in furtherance of his employers business. At all relevant times Arthur Coley
was a statutory employee of Greyhound acting in the course and scope of the same. Therefore,
Greyhound is responsible for the actions of Coley under the doctrine of respondeat superior.
VII.
D AMAGES

A. Survival Damages of the Estate of Hunter Brown

45. Pursuant to TEXAS CIVIL PRACTICE & REMEDIES CODE 71.021, the Estate of Hunter Brown
is entitled to and seeks damages to Hunter Brown for the following elements from the time of the
incident complained of until the time of his death:
a. Physical pain and mental anguish;
b. Medical Expenses; and
c. Funeral expenses.
46. As a result of the foregoing, Hunter Brown incurred injury and damages in an amount in excess
of the minimum jurisdictional limits of this court, and Plaintiffs plead for such damages as authorized

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 10 of 13
in this case. Plaintiffs further request that this case be tried to a jury and that the Estate of Hunter
Brown be awarded fair and reasonable damages as determined by the jury.
B. Wrongful Death Damages of Paula Becker and Barron Brown
47. Pursuant to TEXAS CIVIL PRACTICE & REMEDIES CODE 71.021, Paula Becker and Barron
Brown are wrongful death beneficiaries as the surviving parents of Hunter Brown and in that capacity
seek damages including, but not limited to the following:
a. Mental anguish sustained in the past;
b. Mental anguish that will be sustained in the future;
c. Loss of the care, maintenance, support, services, advice, counsel and reasonable
contributions of a pecuniary value, excluding loss of inheritance, in the past;
d. Loss of the care, maintenance, support, services, advice, counsel and reasonable
contributions of a pecuniary value, excluding loss of inheritance, that will be sustained
in the future;
e. Loss of companionship and society sustained in the past; and
f. Loss of companionship and society that will be sustained in the future.
48. All of the above have resulted in damages which are within the jurisdictional limits of this Court,
for which Plaintiffs now plead against Defendant.
VIII.
E XEMPLARY D AMAGES

49. The negligent acts and/or omissions of Defendant, as set out above, constitute an entire want
of care so as to indicate that the acts and/or omissions in question were the result of conscious
indifference to the rights, welfare, and safety of Plaintiffs, such that they constitute gross negligence, as
that term is defined by TEXAS CIVIL PRACTICE AND REMEDIES CODE 41.001(11) , so as to give rise
to an award of exemplary damages.
50. Plaintiffs would show that the negligent acts and/or omissions of Defendant, which when
viewed objectively from the standpoint of Defendant at the time of the occurrence, involved an extreme
degree of risk, considering the probability and magnitude of the potential harm to others; of which
Defendant had actual, subjective awareness of the risks involved, but nevertheless proceeded with
conscious indifference to the rights, welfare and safety of others. Plaintiffs would show that the
negligent acts and/or omissions of the Defendant, as set out above, constitute gross negligence, as that
term is defined by law, so as to give rise to an award of exemplary damages against Defendant.
Considering the nature of the wrong, the character of the conduct involved, the degree of culpability
of the Defendant, the situation and sensibilities of the Defendant, and the extent to which Defendants

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 11 of 13
conduct offends a public sense of justice and propriety, Plaintiffs hereby plead for exemplary damages.
Additionally, by reason of such conduct, Plaintiffs are entitled to and therefore assert a claim for
punitive and exemplary damages in an amount sufficient to punish and deter Defendant, and others like
it, from such conduct in the future. The Court should assess exemplary damages against Defendant in
an amount that will punish Defendant and deter others from engaging in similar conduct.
IX.
P RE -J UDGMENT AND P OST J UDGMENT I NTEREST

51. Plaintiffs request pre-judgment and post-judgment interest in accordance with the maximum
legal interest rates allowable as interpreted under the laws of the State of Texas.
X.
R EQUEST FOR A J URY T RIAL

52. Plaintiffs demand a jury trial on all issues so triable and contemporaneously with the filing of
this Petition submit the applicable fee.
XI.
R EQUEST FOR D ISCLOSURE

53. Pursuant to TEXAS RULE OF CIVIL PROCEDURE 194, Defendant is requested to disclose the
information and material described in Rule 194.2. The written responses to the above requests for
disclosure should conform to Rule 194.3 and the materials, documents, and/or copies of the same
should be produced in compliance with Rule 194.4. The written responses, materials and/or documents
are to be delivered to ALDOUS \ WALKER LLP, 2311 Cedar Springs Road, Suite 200, Dallas, Texas 75201,
as required following receipt of this request.
XII.
P RAYER

54. Plaintiffs pray that Defendant be cited to appear and answer herein, and that upon final
determination of these causes of action, Plaintiffs receive a judgment against Defendant awarding the
Plaintiffs relief as follows:
a. Actual, compensatory, consequential, exemplary, and punitive damages, in an amount
in excess of the minimal limits of the Court;
b. Costs of Court;
c. Prejudgment interest at the highest rate allowed by law from the earliest time allowed
by law;
d. Interest on judgment at the highest legal rate from the date of judgment until collected;
and

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 12 of 13
 e. All such other and further relief at law and in equity to which the Plaintiffs may show
themselves to be justly entitled.

Respectfully submitted,

/s/ Charla G. Aldous

Jane Paulson
CHARLA G. ALDOUS
Oregon Bar No: 911804
State Bar. No. 20545235
Pro hac vice application forthcoming
caldous@aldouslaw.com
jane@paulsoncoletti.com
BRENT R. WALKER
State Bar No. 24047053
PAULSON COLETTI
bwalker@aldouslaw.com
TRIAL ATTORNEYS P.C.
HEATHER L. LONG
1022 NW Marshall #450
State Bar No. 24055865
Portland, OR 97209
hlong@aldouslaw.com
Phone: (503) 226-6361
Fax: (503)
ALDOUS\WALKER LLP
2311 Cedar Springs Rd., Suite 200
Dallas, TX 75201
Phone: (214) 526-5595
Fax: (214) 526-5525

ATTORNEYS FOR PLAINTIFFS

PLAINTIFFS ORIGINAL PETITION, REQUEST FOR DISCLOSURE AND JURY DEMAND Page 13 of 13