3/30/2021 9:31 AM

Marilyn Burgess - District Clerk Harris County

Envelope No. 51953878
By: Rhonda Momon
Filed: 3/30/2021 9:31 AM

CAUSE NO. ______

DAVID LOPEZ § IN THE DISTRICT COURT

Plaintiff §
§
V. § OF HARRIS COUNTY TEXAS
§
STEVEN F. HOTZE AND LIBERTY §
CENTER FOR GOD AND COUNTRY §
Defendants § _____________ JUDICIAL DISTRICT

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES Plaintiff DAVID LOPEZ, (hereinafter referred to as "Plaintiff" or “Lopez”)

in the above-entitled and numbered cause and files this his Original Petition, complaining of

STEVEN F. HOTZE (“Hotze”) and LIBERTY CENTER FOR GOD AND COUNTRY (“Liberty

Center”) and (hereinafter collectively referred to as "Defendants"), and for cause of action would

respectfully show the following:

I.

DISCOVERY LEVEL

Pursuant to Texas Rules of Civil Procedure 190.1 and 190.4, Discovery will be conducted

pursuant to a level 3 Discovery Control Plan.

II.

PARTIES

Plaintiff is a resident of Houston, Harris County, Texas now and at the time the cause of

action accrued.

Defendant, STEVEN F. HOTZE is an individual who may be served at his office, 20214

Braidwood Drive, Katy TX 77450 or at his residence 5514 Russett Drive, Houston, Texas 77056.
Plaintiff’s Original Petition
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 Defendant, LIBERTY CENTER FOR GOD AND COUNTRY is a purported domestic

nonprofit entity and may be served through its registered agent STEVEN F. HOTZE at its office,

20214 Braidwood Drive, Katy TX 77450.

III.

JURISDICTION AND VENUE

Venue is proper in Harris County, Texas, pursuant to Tex. Civ. Prac. & Rem. Code §15.001,

et. seq., because all or a substantial part of the events or omissions giving rise to the claim that is the

basis of this suit, occurred in Harris County, Texas and Harris County was the Defendants county of

residence at the time the cause of action accrued.

This Court has jurisdiction over the parties and the subject matter of this action because the

Plaintiff seeks damages in an amount within the jurisdictional limits of this Court.

Plaintiff seeks monetary relief over $1,000,000 pursuant to Rule 47, Texas rule of Civil

Procedure, for bodily injury, physical pain, past and future mental anguish, exemplary damages and

attorney fees.

IV.

FACTS

In October 2020, David Lopez was a family man and a productive member of this

community. As part of his work as an air conditioning repairman he drove a box truck containing

his tools and equipment to various Houston-area job sites to support himself and his family. David

Lopez has no significant political ties or affiliations and never has. Instead, he was focused on

taking care of his customers and making a living for his family. Meanwhile, that was not what

Defendants were doing. Unbeknownst to Mr. Lopez, in the days and weeks leading up to the events

Plaintiff’s Original Petition

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of October 19, 2020, Mr. Lopez had been falsely and wrongfully identified and targeted by the

Defendants as a key figure in Defendants’ bizarre and unfounded claims of massive voter fraud and

Defendants’ well-funded efforts to expose baseless, non-existent claims of voter fraud. What

happened next at the hands of Defendants would turn David Lopez’s world upside down, cause him

to fear for his life and has left him mentally and emotionally shaken.

For David Lopez, October 19, 2020 began early as his workdays typically did. By 5:30 am,

he was driving his box truck to get started on his first job of the day. He never made it. Instead,

even before the sun came up, a nightmare began unfolding.

David Lopez was assaulted and falsely imprisoned by Mark Anthony Aguirre, a former

Captain with the Houston Police Department, while working for and under the direct supervision of

Defendants Steven F. Hotze and Liberty Center for God and Country. Aguirre was discharged by

HPD in 2003 in part for his wrongful use of police tactics of which Defendants had actual

knowledge of before hiring Aguirre.

In the predawn darkness of October 19, 2020, Mark Aguirre, while working for and under the

direct supervision of Defendants, Steven F. Hotze and Liberty Center for God and Country, without

warning, intentionally rammed his SUV into the box truck that David Lopez was operating at

approximately 5:30 a.m. Mark Aguirre, driving a black SUV, pulled into David Lopez’s lane and

intentionally struck the back of his vehicle. David Lopez immediately pulled over and walked to the

rear of his box truck to determine the welfare of Mark Aguirre. Mark Aguirre exited the black SUV

and pointed a pistol at David Lopez. David Lopez feared for his life, believing Mark Aguirre was

robbing him. With his loaded gun pointed at Mr. Lopez, Defendant Aguirre began shouting orders.

Fearing that “he is going to shoot me” and that his life was about to end on the side of the road,

Plaintiff’s Original Petition

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David Lopez realized his only hope was to cooperate, so he laid on the ground while Mark Aguirre

held a gun to him and placed his knee on David Lopez’s back. Additional vehicles driven by

Aguirre’s accomplices pulled up to the scene and participated in Aguirre’s assault while Aguirre

held David Lopez at gun point on the ground with his knee on his back. Aguirre ordered an

accomplice to search the box truck while he detained David Lopez. David Lopez overheard the

accomplice report to Aguirre that the box truck was clear. With David Lopez still face down on the

side of the road at gunpoint with Aguirre’s knee in his back at gunpoint, and without permission, one

of Aguirre’s accomplices stole David Lopez’s box truck and drove it from the scene. During the

entire episode David Lopez was laying on the ground with Aguirre’s knee on his back and pistol to

his head. At one point, Aguirre cocked his pistol, one errant move from taking Lopez’s life. David

Lopez feared for his life and believed he was being robbed since his truck was being stolen and

driven away by an accomplice. A Houston Police Officer happened upon the scene and stopped.

The box truck was later located where it had been abandoned a few blocks away in the 1440 block of

Anagnot Street.

Aguirre stated to the HPD officer that he was part of a group of private citizens that call

themselves Liberty Center for God and Country and that they were investigating a voter fraud ballot

harvesting conspiracy that they believed David Lopez was operating out of his home. Aguirre stated

that he and his friends set up a command post at the Springfield Suites Marriott located at 1820

Country Place, Pearland, Brazoria County, Texas. He also stated to HPD officers that he and his

friends had been conducting 24-hour surveillance on Lopez’s home for the past 4 days and that

David Lopez had approximately 750,000 fraudulent mail ballots in his possession and that Lopez

was using Hispanic children to sign the ballots because the children’s fingerprints would not appear

Plaintiff’s Original Petition

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in any database. Aguirre further admitted that he crashed into the Lopez box truck, that he pointed a

firearm at Lopez and held him on the ground at gunpoint. Aguirre refused to provide the names of

his accomplices who were assisting him and conducting the surveillance. Aguirre stated to the

investigating officer that he (investigating officer) could be “a hero or part of the problem.” Aguirre

also stated to the investigating officer “I just hope you’re a patriot” and that he (Aguirre) had already

contacted the Texas Rangers, Ken Paxton and the Regional Director of the Texas Department of

Public Safety for assistance. Lopez then agreed to allow the search of his home where he lives with

his wife and minor daughter.

The group traveled with Aguirre to where Lopez lived in Harris County. Aguirre pointed out

where he would park his car to conduct surveillance. Lopez confirmed that the residence and shed

belonged to him and Lopez allowed HPD to search his vehicle, home and storage shed. Lopez had

no other way to return to freedom except to allow this invasion of his privacy and prove he had done

nothing wrong. HPD searched the mobile home, shed and vehicle and found absolutely no evidence

of voter fraud or ballot harvesting. The HPD officer also found that Lopez’s box truck contained

equipment consistent with his occupation as an air conditioning repair technician. They also found

Lopez’s home to be appropriately furnished as a family home and the home to be filled with ordinary

household items. No evidence of the conspiracy was found.

The senior investigator received a phone call from Lt. Wayne Rubio with the Texas Attorney

General’s office. Lt. Rubio stated that Aguirre contacted him on October 16, 2020 (3 days prior to

the incident), to request that the Attorney General’s office conduct a traffic stop for his investigation.

Lt. Rubio told Aguirre he could not assign a police unit to conduct a traffic stop. Lt. Rubio stated he

received a second call from Aguirre on October 19, 2020 (the date of the incident) and was told that

Plaintiff’s Original Petition

Page 5 of 17
he was in a motor vehicle accident with a voter fraud suspect and that he pulled a gun on the

individual, David Lopez. Lt. Rubio further stated that Aguirre seemed upset that the Department of

Public Safety would not stop and detain an individual based solely on Aguirre’s uncorroborated and

unfounded conspiracy allegations.

The senior officer reviewed the body worn camera recordings made by the first officer on the

scene and confirmed that Aguirre was detaining Lopez by kneeling on his back with a firearm.

Aguirre further acknowledged that one of his co-conspirators moved Lopez’s box truck to a

parking lot and it was searched without permission from the owner, David Lopez. The senior

investigator confirmed that two rooms at the Spring Hill Suites by Marriott had been rented by

Aguirre from October 17, 2020 through October 21, 2020. It was further confirmed that Aguirre had

received wire transfers of over $250,000 from an account owned and controlled by Liberty Center

for God and Country in the month proceeding the aggravated assault and false imprisonment and

immediately after the incident. Liberty Center for God and Country paid money to Aguirre in three

installments, one in September, and two in October of 2019. Two of the payments were received

prior to the aggravated assault and false imprisonment and the third payment on October 20, 2020,

the day after the aggravated assault and false imprisonment. A clear ratification of Aguirre’s actions.

Aguirre was charged with aggravated assault with a deadly weapon by the Harris County

District Attorney’s Office, a second-degree felony, punishable up to 20 years in prison. He was

released on a $30,000 bond. The Harris County DA is quoted as stating “He crossed the line from

dirty politics to commission of a violent crime and we are lucky no one was killed.” The DA also

stated “His (Aguirre) alleged investigation was backward from the start-first alleging a crime had

occurred and then trying to prove it happened.” Aguirre’s claims of election fraud were found to be

Plaintiff’s Original Petition

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baseless after thorough investigation by Houston Police and by Constable Precinct 1 Alan Rosen, as

part of the Harris County Election Security Task Force.

V.

STEVEN F. HOTZE AND THE LIBERTY CENTER FOR GOD AND COUNTRY

Steven F. Hotze, a local physician with a history of pursuing unfounded voter conspiracy

theories, owns, operates and controls the Liberty Center for God and Country under the pretense of a

charitable, religious and educational purpose. Said entity was established in August of 2020. Since

its inception, Liberty Center for God and Country has been utilized to push unfounded conspiracy

theories in the election arena. Surprisingly, one of its mission statements is, “Civil Law Must be

Derived from God’s Law Found in the 10 Commandments.”

Hotze has confirmed that he and Liberty Center paid Aguirre as a contract investigator to

pursue allegations of election fraud in Harris County and that he provided tips and leads to Aguirre.

He acknowledged that he paid Aguirre, through his group Liberty Center, $266,400 to investigate

alleged voter fraud, $211,000 of this payment was made the day after Aguirre’s assault on Lopez.

Hotze, a local physician who owns and operates Hotze Health & Wellness Center, has a long

history of pursuing and alleging bizarre unfounded voter fraud allegations. Some of his actions

include a handwritten letter to former President Trump in November of 2020 acknowledging that he

“hired 20 private investigators to discover, expose and disrupt the massive vote harvesting election

fraud scheme of the Democrat communists in Harris County, Houston, Texas” and further stated

“The communists Democrats are thieves who had an organized fraud scheme to steal the election

from the American Patriots.”

Plaintiff’s Original Petition

Page 7 of 17
 In addition, Hotze filed numerous unfounded lawsuits challenging measures intended to

expand voting amid the COVID-19 pandemic, including a rejected effort to toss 127,000 legitimate

Harris County votes. Aguirre filed at least one affidavit in Hotze’s lawsuit claiming he had evidence

of election fraud. Aguirre failed to provide such proof.

VI.

RESPONDEAT SUPERIOR AND/OR VICARIOUS LIABILITY

At all times relevant to the incident, all of the acts and omissions complained of herein were

committed by employees, servants, agents, management, or contractors of Defendants who were

acting within the course and scope of their employment or agency and who were acting under the

direction or control of Defendants. Consequently, Defendants are vicariously liable for all of the acts

and/or omissions that were committed by those persons within the course and scope of their

employment, agency and/or direction of Defendants, or committed by Defendants themselves.

At all times relevant to the incident, Mark Aguirre acted within the course and scope of his

employment with one or more of the Defendants named herein; therefore, said Defendants are

vicariously liable for all acts of negligence or intentional conduct committed by Defendant Mark

Aguirre.

If Defendant Mark Aguirre is found to have acted outside the scope of his employment with

Defendants at the time of the incident, Plaintiff, David Lopez, asserts that:

“. . . a master is under a duty to exercise reasonable care so as to control his servant

while acting outside the scope of his employment as to prevent him from
intentionally harming others or from so conducting himself as to create an
unreasonable risk of bodily harm to them. If the servant is upon the premises in
possession of the master or upon which the servant is privileged to enter only as his
servant, or is using a chattel of the master, and the master knows or has reason to
know that he has the ability to control the servant and knows or should know the
Plaintiff’s Original Petition
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 necessity and opportunity for exercising such control, and fails to do so, the master is
liable for the acts of the servant.” RESTATEMENT (SECOND) OF TORTS § 317.

Mark Aguirre committed acts material to the incident while he was acting within his

“apparent authority” to accomplish the wrongful acts, and as such, was acting within the “apparent

scope” of his employment with Defendants, Steven F. Hotze and/or Liberty Center for God and

Country; therefore, Defendants Steven F. Hotze and/or Liberty Center for God and Country and/or

all Defendants doing business as Liberty Center for God and Country, are liable for the acts of Mark

Aguirre.

Mark Aguirre committed acts material to the incident while he was acting within his

“apparent authority” to accomplish the wrongful acts, and as such, was acting within the “apparent

scope” of his employment with Defendant Liberty Center for God and Country.

If the Defendants allege they had no duty regarding one or more of the acts or omissions

complained of herein, Plaintiff, in accordance with RESTATEMENT (SECOND) OF TORTS § 219(d)(2),

asserts that:

“Under the aided-in-agency theory, an employer may be held liable for the
intentional torts of an employee acting outside the scope of his or her employment if
the employee ‘was aided in accomplishing the tort by the existence of the agency
relation.’”

Defendants are also jointly liable under the theory of ratification. The elements of

ratification are the adoption or confirmation by a person, with knowledge of all material facts, of a

prior act which did not then legally bind that person and which that person had the right to repudiate.

Defendants failed to repudiate the actions of Mark Aguirre and in fact clearly ratified the actions

and conduct of Aguirre by compensating him the day after the incident in the amount of $211,000.

The Plaintiff, David Lopez was injured because of a tort committed by Mark Aguirre. Mark

Plaintiff’s Original Petition

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Aguirre was the apparent or ostensible agent and/or employee of Steven F. Hotze and/or Liberty

Center for God and Country. The tort was committed while Mark Aguirre was an employee,

apparent or ostensible agent, while acting within the scope of his employment and agency and within

his general authority and in furtherance of the Defendants business and for the accomplishment of

the object for which he was retained.

VII.

RATIFICATION

Defendants Steven F. Hotze and/or Liberty Center for God and Country approved the acts

and/or conduct of Mark Aguirre after acquiring full knowledge and/or conduct and the Defendants

approval was given with the intention of giving validity to the agent or non-agents act or conduct.

The agent or non-agent, Mark Aguirre committed the act or conduct (assault and false imprisonment)

on behalf of the Defendants. Said actions resulted in bodily injury, physical pain and mental anguish

to Lopez. Ratification from the Defendants to Mark Aguirre was accomplished by a

payment/compensation the day following the egregious acts.

VIII.

FALSE IMPRISONMENT

The Defendants by and through their apparent or ostensible agent Aguirre intentionally and

willfully detained the Plaintiff, such detention was without the Plaintiff’s consent and such reckless

detention was without legal authority or justification.

More specifically, Aguirre rammed the rear of Lopez’s truck in a successful attempt to get

him to stop. Once stopped he assaulted Lopez by kneeling on his back and threatened him with a

loaded pistol, all of which placed Lopez in fear of his life, intentionally detaining him, without

Plaintiff’s Original Petition

Page 10 of 17
Lopez consent and without any legal or moral authority or justification. Said actions resulted in

bodily injury, physical pain and mental anguish to Lopez.

IX.

ASSAULT

The Defendants by and through their agent acted intentionally, knowingly and/or recklessly.

The agent, Mark Aguirre, made contact with David Lopez and the contact by the apparent or

ostensible agent caused injury to Plaintiff.

In addition, the Defendants apparent or ostensible agent acted intentionally or knowingly,

and their agent threatened the Plaintiff with imminent bodily injury and the threat caused injury to

the Plaintiff.

On October 29, 2020, Mark Aguirre intentionally, knowingly and/or recklessly caused

physical contact with Plaintiff, David Lopez, in that he knew or should have reasonably known that

his physical contact with him would be regarded by him as offensive:

Said assault and false imprisonment by Defendant Mark Aguirre resulted in bodily injury,

physical pain and mental anguish sustained by David Lopez, for which he sues.

X.

CIVIL CONSPIRACY

Defendants jointly and severally conspired to accomplish an unlawful purpose. Specifically,

the ramming of Lopez vehicle, unlawful stop of Lopez vehicle, unlawful search of Lopez’s vehicle,

unlawful surveillance of Lopez and his home and family, unlawful false imprisonment and assault of

Lopez. In addition, Defendants each conspired to conceal the assault on David Lopez, taking steps to

falsify, conceal, and destroy evidence by stealing his truck and moving it to another location and

Plaintiff’s Original Petition

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refusing to name the accomplices Defendants were members of a civil conspiracy for which David

Lopez sues.

Defendant Steven F. Hotze and Liberty Center and his agent, Mark Aguirre conspired to

accomplish an unlawful purpose or a lawful purpose by unlawful means. Steven F. Hotze and Mark

Aguirre had a meeting of the minds on the object or course of action to be taken and Mark Aguirre

committed an unlawful overt act to further the object or course of action and as a result the Plaintiff

suffered bodily injury, physical pain and mental anguish as a proximate result of the wrongful act or

acts.

XI.

THEFT LIABILITY ACT

Defendants are also liable for civil theft. The Texas Civil Practices and Remedies Code

§§134.001-134.005 governs civil liability for theft. Pursuant to the statute, the Defendants are liable

under Texas Penal Code §31.03 and §31.04. Defendants’ actions (unlawfully commandeering his

truck and unlawfully searching it) amount to a theft of real or personal property and/or a theft of

service and thus are actionable under the auspices of The Theft Liability Act. Defendants’ theft

caused Plaintiffs’ damages for which Plaintiff now seeks recovery.

XII.

AIDING AND ABETTING

Steven F. Hotze and Liberty Center aided and abetted the conduct and the tort committed by

Mark Aguirre. Defendant Steven F. Hotze and Liberty Center had knowledge that the primary

actor’s conduct/Mark Aguirre constituted a tort and Hotze had the intent to assist the primary actor,

Aguirre, in committing the tort and gave the primary actor assistance or encouragement to commit

Plaintiff’s Original Petition

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the tort, which was a substantial factor in causing the tort, bodily injury, physical pain, mental

anguish and such assistance or encouragement was a substantial factor in causing the tort.

XIII.

ACTUAL AUTHORITY

Defendant Steven F. Hotze and Liberty Center intentionally conferred authority on the agent,

Mark Aguirre and intentionally allowed the agent, Mark Aguirre, to believe he had authority or

through the lack of due care, allowed the agent to believe he had authority. The agent, Mark

Aguirre, was acting within the scope of his agency when he committed the torts of assault and false

imprisonment causing bodily injury, mental anguish and physical pain.

XIV.

APPARENT AUTHORITY

Defendants, Steven F. Hotze and Liberty Center affirmatively held the agent or non-agent as

having authority to act on his behalf and knowingly permitting the agent, Mark Aguirre, or non-

agent, to hold himself out as having authority or acting with such a lack of ordinary care as to clothe

the agent or non-agent with indicia of authority. Defendants’ conduct caused the agent to commit

the torts of false imprisonment and assault causing physical pain, bodily injury and mental anguish.

XV.

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

Defendants’ acts or omissions complained of herein jointly and severally were intentional

and reckless, their conduct was extreme and outrageous in character and so extreme in degree as to

go beyond all possible bounds of decency as to be regarded as atrocious and utterly intolerable in a

civilized community. Defendants are further responsible for the intentional acts of Aguirre as further

Plaintiff’s Original Petition

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described herein. Consequently, Plaintiffs assert that in committing the acts or omissions

complained of herein, Defendants are guilty of intentional infliction of emotional distress upon

David Lopez, for which he sues.

The Defendants acted intentionally or recklessly and as a result the Plaintiff, David Lopez,

suffered emotional distress that was severe, and the Defendants conduct by and through its apparent

or ostensible agent was extreme and outrageous. The Defendants and the agents conduct

proximately caused the Plaintiff’s emotional distress and no alternative causes of action will provide

a remedy for the severe emotional distress caused by Defendants and their agent’s conducts.

XVI.

PROXIMATE CAUSE

Each and every, all and singular of the foregoing acts and omissions, on the part of

Defendants, taken separately and/or collectively, constitute a direct and proximate cause of the

bodily injuries, physical pain and mental anguish and damages set forth below.

XVII.

EXEMPLARY DAMAGES

Defendants had a specific intent to cause, and did cause, substantial injury or harm to the

Plaintiff.

Defendants and Mark Aguirre's acts or omissions described above, when viewed from the

standpoint of Mark Aguirre at the time of the act or omission, involved an extreme degree of risk,

considering the probability and magnitude of the potential harm to Plaintiff. Defendants and Mark

Aguirre had actual, subjective awareness of the risk involved in the above-described acts or

omissions, but nevertheless proceeded with conscious indifference to the rights, safety, or welfare of

Plaintiff’s Original Petition

Page 14 of 17
Plaintiff.

Defendants had a specific intent to cause substantial injury or harm to the Plaintiff.

Defendants and Mark Aguirre, acts or omissions when viewed from the standpoint of Mark

Aguirre at the time of the act or omission, involved an extreme degree of risk, considering the

probability and magnitude of the potential harm to Plaintiff and others. Mark Aguirre had actual,

subjective awareness of the risk involved in the above-described acts or omissions, but nevertheless

proceeded with conscious indifference to the rights, safety, or welfare of Plaintiff and others.

Based on the facts stated herein, Plaintiff requests exemplary damages be awarded to

Plaintiff from Defendants.

XVIII.

PRE-JUDGMENT AND POST-JUDGMENT INTEREST

David Lopez seeks recovery of pre-judgment and post-judgment interest as permitted by law.

XIX.

RESERVATION OF RIGHTS

David Lopez reserves the right to prove the amount of damages at trial and to amend his

Petition to add additional claims upon further discovery and as his investigation and formal

discovery continues.

XX.

DEMAND FOR JURY

Plaintiff demands a jury trial of his peers.

XXI.

NOTICE OF INITIAL DISCLOSURES

Plaintiff’s Original Petition

Page 15 of 17
 Plaintiff hereby states that pursuant to the Texas Rules of Civil Procedure, Defendants must

disclose, the information and documents listed in Rule 194.2 (b) (1) – (12) must be produced to the

office of Plaintiff’s attorney no later than thirty (30) days after the first answer or general appearance

is filed. Pursuant to Texas Rule of Civil Procedure 99(c) you are advised.

XXII.

DAMAGES/REMEDIES

As a direct, proximate, and foreseeable result of Defendants’ conduct, Plaintiff suffered

injuries and damages, including, but not limited to the following:

1) physical pain;

2) past and future mental anguish;

3) statutory damages;

4) exemplary damages;

5) attorneys fees both as required to respond to the events Defendants set in motion and as

prevailing party in this case; and

6) appropriate injunctive relief to restrain defendants from further vigilantism and unlawful

conduct toward Lopez and others.

XXIII.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendants be cited to

appear and answer herein, and that upon final hearing Plaintiff have judgment against Defendants,

jointly and severely, for their compensatory damages, together with pre-judgment and post-judgment

interest as provided by law, exemplary damages, costs of court, attorneys fees and for other and
Plaintiff’s Original Petition
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further relief, at law and in equity to which Plaintiff may show himself justly entitled to receive.

Respectfully Submitted,

BRAZIL & DUNN LLP

/s/ K. Scott Brazil

K. Scott Brazil - 02934050
13231 Champion Forest Dr., Suite 406
Houston, Texas 77069
Telephone (281) 580-6310
Facsimile (281) 580-6362
[email protected]

LAW OFFICE OF DICKY GRIGG, P.C.

/s/ Dicky Grigg

Dicky Grigg – 08487500
4407 Bee Caves Rd., Suite 111 Bldg 1
West Lake Hills, Texas 78746-6498
Telephone (512) 474-6061
Facsimile (512) 582-8260
[email protected]

ATTORNEYS FOR PLAINTIFF

Plaintiff’s Original Petition

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