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Galbraith v H2H Academy - Final

Galbraith v H2H Academy - Final

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Published by CBS11
Copy of the lawsuit filed by a couple accusing a daycare and its teachers of abuse.
Copy of the lawsuit filed by a couple accusing a daycare and its teachers of abuse.

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Published by: CBS11 on Aug 26, 2014
Copyright:Traditional Copyright: All rights reserved

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08/28/2014

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  
REQUESTS FOR DISCLOSURES AND JURY DEMAND Page 1
CAUSE NO. _____________________ PLAINTIFF'S ORIGINAL PETITION, REQUESTS FOR DISCLOSURES AND JURY DEMAND
TO THE HONORABLE JUDGE OF SAID COURT:
KRISTI AND BRAD GALBRAITH, Individually and as Next Friends of a minor
,
 
Original Petition, complaining of 
 

HEART 2 HEART MONTESSORI ACADEMY, LTD d/b/a Heart2Heart Montessori Academy, RH2H MANAGEMENT LLC, ASHLEA J. PENA, and PAMELA D. DECKER
and for cause of action would respectfully show the Court the following:
 I. DISCOVERY PLAN AND REQUESTS FOR DISCLOSURES
1.01. Plaintiffs intend that discovery in this lawsuit be conducted in accordance with T
EXAS
ULES OF
C
IVIL
P
ROCEDURE
 190.3, Level 3, as the facts and circumstances giving rise to

 claims make it appropriate that discovery be conducted in accordance with a specific discovery control plan tailored to this lawsuit. Plaintiffs will cooperate with the Defendants in
KRISTI AND BRAD GALBRAITH, Individually and as Next Friends of a minor, Plaintiffs, § § § § § § IN THE DISTRICT COURT V. § § _____ JUDICIAL DISTRICT

S HEART 2 HEART MONTESSORI ACADEMY, LTD d/b/a Heart2Heart Montessori Academy, RH2H MANAGEMENT LLC, ASHLEA J. PENA, AND PAMELA D. DECKER § § § § § § § § Defendants. § PARKER COUNTY, TEXAS
 
  
REQUESTS FOR DISCLOSURES AND JURY DEMAND Page 2
trying to agree to the provisions of a reasonable discovery control plan or, failing agreement, Plaintiffs may file a motion with the Court seeking an order for such a plan. 1.02. Plaintiffs hereby request that Defendants disclose the materials and information required to be disclosed under T
EXAS
ULES OF
C
IVIL
P
ROCEDURE
 194.2(a) through (f), by serving Plaintiffs
 counsel with responses to these requests for disclosures within the time limits  provided for responses to such requests under T
EXAS
ULES OF
C
IVIL
P
ROCEDURE
 194.1.
II. PARTIES
2.01. Plaintiffs Kristi and Brad Galbraith, Individually and as Next Friend of are residents of Parker County, Texas and are the natural parents of a minor. The
      
 
    
, and the last three digits of her Social Security Number are 985
      
Texas
    
, and the last three digits of his Social Security Number are 901. 2.02. Defendant Ruyle

 Heart 2 Heart Montessori Academy, Ltd. d/b/a Heart2Heart Montessori Academy is a Texas Limited Liability Partnership and may be served with a copy of this petition and citation on its registered agent, Ashlea J. Pena at either her place of employment at 201 Canyon Court, Willow Park, TX 76087 or her residence at 108 El Colina Road, Weatherford, TX 76085. 2.03
  
intention to sue the

day care facility which operates now and at which time operated on June 17, 2014 at 201 Canyon Court, Willow Park, TX, and is now known and/or then known in the community as Heart2Heart Montessori Academy. Plaintiffs reserves the right to amend and supplement this petition by naming the correct legal entity(ies).
 
  
REQUESTS FOR DISCLOSURES AND JURY DEMAND Page 3
2.04 Defendant RH2H Management, LLC is a Texas Limited Liability Company and,  based upon information and belief, is the general partner of Defendant Ruyle

 Heart 2 Heart Montessori Academy, Ltd. RH2H Management, LLC may be served with a copy of this petition and citation on its registered agent, Ashlea J. Pena at either her place of employment at 201 Canyon Court, Willow Park, TX 76087 or her residence at 108 El Colina Road, Weatherford, TX 76085. 2.05 Defendant Ashlea J. Pena is a Texas resident and is one of the owners of the Heart 2 Heart Montessori Academy, general partners of Defendant Ruyle

 Heart 2 Heart Montessori Academy, Ltd., and/or one of the managing members of Defendant RH2H Management, LLC. Based upon information and belief, at all material times, Ms. Pena
         
Ms. Pena may be served with a copy of this petition and citation at either her place of employment at 201 Canyon Court, Willow Park, TX 76087 or her residence at 108 El Colina Road, Weatherford, TX 76085. 2.06 Defendant Pamela D. Decker is a Texas resident and is/was one of the owners of the Heart 2 Heart Montessori Academy, general partners of Defendant Ruyle

 Heart 2 Heart Montessori Academy, Ltd., and/or one of the managing members of Defendant RH2H Management, LLC. Ms. Decker may be served with a copy of this petition and citation at her residence at 319 Clear Lake Lane, Weatherford, TX 76087. 2.07 Hereinafter, Defendants,
       
Heart2Heart Montessori Academy

 
III. JURISDICTION AND VENUE
3.01. The District Courts of Parker County, Texas have jurisdiction over this action  because Plaintiffs are bringing causes of action within the subject matter jurisdiction of district

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