Page 2Bob Deuell is the current incumbent State Senator for Senate District 2 and may beserved at 6403 Creekside Drive, Greenville, Hunt County, Texas 75402. Bob Deuell wasdefeated in the recent Republican Primary Run-off Election on May 27, 2014.
III.JURISDICTIONANDVENUE
This Court has personal jurisdiction over the Defendant because he resides in Texas, andbecause a substantial part of the events giving rise to this cause of action occurred in Texas.The matters in controversy fall within this Court’s general jurisdiction, and the amount incontroversy exceeds this Court’s minimum jurisdictional limits.Venue is proper in Harris County, Texas, whereupon information and belief, all or asubstantial part of the causes of action set forth herein arose.
IV.FACTUALBACKGROUND
Texas Right to Life is a Texas not-for-profit corporation that is primarily engaged inpromoting the common good and general welfare of the people of Texas by advancing the causeof life. Texas Right to Life achieves this purpose by informing the public on the myriad lifeissues and influencing legislation relevant to advancement of the pro-life cause.During the March 4, 2014 Republican Party Primary, Defendant was a candidate for re-election to the office of State Senator for Senate District 2.
Defendant faced two challengers inthe March Republican Primary wherein he received 48.49% of the vote forcing a run-off electionwith Bob Hall who received 38.81% of the vote in the March Republican Primary.
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Senate District 2 is composed of Delta, Hopkins, Hunt, Rockwall, Kaufman, Fannin, Rains, and Van Zandtcounties, and parts of Dallas County.
