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Plantiff Petition

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Submitted By dgaygage
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CAUSE NO.2010-37898

JJ LOWELL ORLOFF § IN THE DISTRICT COURT OF
Plaintiff § § vs. § HARRIS COUNTY, TEXAS § §
HOME DEPOT USA, INC. § §
Defendant § 80 JUDICIAL DISTRICT

PLAINTIFF’S ORIGINAL PETITION FOR NEGLIGENCE AND PERSONAL INJURY

COMES NOW, JJ LOWELL ORLOFF hereinafter called PLANTIFF, JJ LOWELL ORLOFF complaining of HOME DEPOT USA, INC., hereinafter referred to as DEFENDANT, and for care of action would respectfully show the court and jury as follows:

I. Discovery Control Plan A. Plaintiff intend to conduct discovery under Level 2 of Texas Rule of Civil Procedure 190.3 and affirmatively pleads that and seeks monetary relief of it seeks monetary relief aggregating more than $50,000 but less than $100,000 excluding costs, pre-judgment interest and attorneys fees. II Parties A. Plaintiff, JJ Lowell Orloff is a resident of Harris County, Texas and is authorized to file suit in this county. B. Defendant, HOME DEPOT USA, INC. is a corporation incorporated under the laws of the State of Texas and can be served through its registered agent for service of process, Janice Jones at 501 Jones Street, Houston, Texas 77065. III. Venue 1. Is proper in Harris County pursuant to section 15.02 of the Texas Civil Practice and Remedies Code in that all or a substantial part of the events giving rise to the Plaintiff claim occurred in Harris County. IV Facts
1. On or about September 15, 2010, the National Weather Service placed Harris County Texas under a Hurricane Watch, the Service predicted that Hurricane Crazy Horse, a class five hurricane, was anticipated to make landfall in Galveston County Texas. Plaintiff JJ Lowell Orloff was at Defendant place of business, located at 2277 South Loop West, Houston, Texas 77054, to use the premises for a specific purpose. At said time and place

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