Case Analysis : ' Geico '

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CAUSE NO. _______________ WARD CLEAVER, JR., individually and derivatively on behalf of Cowtown Carts, Inc., § IN THE DISTRICT COURT § § Plaintiffs, § § § VS. § OF TARRANT COUNTY, TEXAS § JUDY MONDELLO III; § MERCY GENERAL HOSPITAL; § KATIE PERY.; § GEORGE KLOONEY; § GEICO, INC.; AND § WENTWORTH CLUB, INC., § § Defendants. § ________ JUDICIAL DISTRICT PLAINTIFF’S ORIGINAL PETITION TO THE HONORABLE COURT: COMES NOW Plaintiff Ward Cleaver, Jr. individually and derivatively on behalf of Cowtown Carts, Inc. and files this Original Petition against Defendants Judy Mondello III (“Mondello”); Mercy General Hospital (“Mercy”); Katie Pery (“Pery”); George Klooney (“Klooney”); Geico, Inc.…show more content…
2.06 Geico, Inc. is an insurance company doing business in the State of Texas and may be served through its registered agent James G. Brown at 4201 Spring Valley Road, Dallas, Texas 75224. 2.07 Wentworth Club, Inc. is a Texas corporation whose principal place of business is 9800 West 7th Street, Tarrant County, Texas 76110 and may be served with process by serving citation upon Jacob Mathis, its registered agent for service of process at, 2001 Park Hill Drive, Fort Worth, Texas 76110. III. Jurisdiction and Venue 3.01 This Court has jurisdiction over the subject matter of this lawsuit because the amount in controversy complies with the minimum amount necessary to invoke the subject matter jurisdiction of this Court. This Court may exercise personal jurisdiction over each Defendant in that each Defendant either is a Texas corporation that conducts business in Texas, or is an individual resident of the State of Texas. 3.02 Venue is proper in Tarrant County, Texas pursuant to TEX. CIV. PRAC. & REM. CODE § 15.002(a)(1) because all or a substantial part of the events or omissions giving rise to this action occurred in Tarrant County, Texas. Venue is also proper in Tarrant County, Texas pursuant to TEX. CIV. PRAC. & REM. CODE § 15.002(a)(2) because several of the individual Defendants’ residences were in Tarrant County at the time the causes of action accrued. IV. Facts 4.01 On or about January 11, 2017, Cleaver purchased a red, white, and blue

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