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FiteD FILED DIST DISTRICT CLERK OF JEFFERSON CO TEXAS 4/19/2018 11:26 AM JAMIE SMITH N DISTRICT CLERK Cause No. Serine CAROL GAUTHIER 8 IN THE DISTRICT COURT OF Plaintiff § § vs. OUNT 8 JEFFERSON COUNTY, TEXAS § THE CITY OF PORT ARTHUR, § SCOTT GASPARD and MICKEY § STERLING 8 Defendants § JUDICIAL DISTRICT IGINAL FEI PLAINTIEE’S ORIGINAL PETITION To THE HONORABLE CourT AND JURY: in Comes now, CAROL GAUTHIER, Plaintiff, complaining of THE CITY OF PORT ! ARTHUR, SCOTT GASPARD and MICKEY STERLING, Defendants, and for cause of action herein would show as follows: 1, DISCOVERY CONTROL PLAN Tex. R. Civ. P, 190 requites that this, like every case, be governed by a Discovery Control Plan. Plaintiffs would respectfully submit that this lawsuit be classified as a Level 3 as set forth in Tex. R. Civ. P. 190.4. 2. PARTIES ‘Your Plaintiff, CAROL GAUTHIER, is a resident citizen of Jefierson County, Texas. Defendant, THE CITY OF PORT ARTHUR, is a municipality in Jefferson County, Texas. Said Defendant may be served by serving its Secretary, Sherri Bellard, P.O. Box 1089, Port Arthur, Texas 77641 by certified mail, return receipt requested. i ssa oh /os of JeDefendant, SCOTT GASPARD, is a resident citizen of Jefferson County, Texas and may ' 'be served with process herein at his residence address, 719 6" Street, Nederland, Jefferson County, ‘Texas 77627-2623 by certified mail, return receipt requested. Defendant, MICKEY STERLING, isa resident citizen of Jasper County, Texas and may ‘be served with process herein at his residence address, 291 CR $26, Buna, Jasper County, Texas 77612 by certified mail, return receipt requested. UE: 3. JURISDICTION AND VENUE This Court has jurisdiction over the person, parties and subject matter herein. Venue is proper as one of more Defendants reside in Jefferson County, Texas and the events substant ing the causes of action herein occurred in Jefferson County, Texas, As required, Plaintiff airOversy 1s affitmatively states that the amount in controversy is substantially in excess of One Million Dollars ($1,000,000). mel ss Sacre’ eqenReater 2 Texas is a fair notice pleading state and requires nothing more or less. Plaintiffs would initially assert that the facts underlying plaintif’s causes of action herein are well-known to defendants and, in large part, have been reduced to writing within certain defendants’ own files, records and investigation. Such being the case, plaintiffs offer the following outline: f Goubior <

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