PLAINTIFF’S ORIGINAL PETITION– Page 3 of 13
Defendant Legends Hospitality LLC is a stadium management company that, inpart, manages merchandising and other operations at Cowboys Stadium in Arlington, Texas.Legends may be served through its registered agent for service of process, Corporation ServiceCompany d/b/a CSC – Lawyers Incorporating Service Company, 1021 Main Street, Suite 1150,Houston, Texas 77002.8.
Defendant Success Dynamics, Inc. d/b/a All Pro Classics is a business organizedunder the laws of the State of Arkansas with its principal place of business at 3634 CentralAvenue, Suite E, Hot Springs, Arkansas 71913. Pursuant to Texas Civil Practices and RemediesCode § 17.044(b), the Texas Secretary of State is the agent for service on nonresident DefendantAll Pro because: (1) nonresident Defendant All Pro has engaged in business in Texas;(2) nonresident Defendant All Pro does not maintain a regular place of business in Texas;(3) nonresident Defendant All Pro does not have a designated agent for service of process; and(4) this lawsuit arises out of the nonresident Defendant All Pro’s business in Texas. Therefore,Defendant All Pro may be served with process by transmitting process to the Texas Secretary of State in accordance with the requirements of Texas Civil Practices and Remedies Code§ 17.044(b), to the Citations Unit, Secretary of State, P.O. Box 12079, Austin, Texas 78711-2079, directed to its agent for service of process in Arkansas – Success Dynamics, Inc. d/b/a AllPro Classics, Attention: Terry D. Toler, 104 Legacy Lane, Hot Springs, Arkansas 71901.
V. JURISDICTION AND VENUE
The amount in controversy exceeds the minimum jurisdictional limits of thisCourt. This Court has personal jurisdiction over Defendants as they have continuous andsystematic contacts with Texas and/or conduct business in Texas. Additionally, this Court has