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TARPLEY Are 864. the Last Three Digits of the Social

TARPLEY Are 864. the Last Three Digits of the Social

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Published by: matsby on Dec 12, 2009
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12/11/2009

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 PETITIONER’S ORIGINAL PETITION FOR WRIT OF MANDAMUS, TEMPORARYRESTRAINING ORDER, INJUNCTION, AND DECLARATORY JUDGMENT
TARPLEY are 864. The last three digits of the social security number for SHIRLEY DEMUSTARPLEY are 320.C. Respondent CARROLLTON-FARMERS BRANCH INDEPENDENT SCHOOLDISTRICT BOARD OF TRUSTEES (hereafter referred as “C-FB ISD Board of Trustees”), may be served with process by serving on LYNN CHAFFIN, an Individual who is a resident of Texas, in her capacity as President of the C-FB ISD Board of Trustees, and may be served with process at the following address: Dallas City Hall, 1500 Marilla Street, Dallas, TX 75201.Service of said Respondent as described above can be effected by personal delivery.D. Respondent, C-FB ISD Board of Trustees, may be served with process by servingon NANCY CLINE, an Individual who is a resident of Texas, in her capacity as Vice Presidentof the C-FB ISD Board of Trustees, and may be served with process at the following address:16801 Westgrove Drive, Addison, TX 75001. Service of said Respondent as described abovecan be effected by personal delivery.E. Respondent, C-FB ISD Board of Trustees, may be served with process by servingon FRANK SHOR, an Individual who is a resident of Texas, in his capacity as Secretary of C-FB ISD Board of Trustees, and may be served with process at the following address: 1620 EBeltline Rd, Carrollton, TX 75006. Service of said Respondent as described above can beeffected by personal delivery.F. Respondent, C-FB ISD Board of Trustees, may be served with process by servingon NANCY WATTEN, an Individual who is a resident of Texas, in her capacity as AssistantSecretary of C-FB ISD Board of Trustees, and may be served with process at the following
 
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 PETITIONER’S ORIGINAL PETITION FOR WRIT OF MANDAMUS, TEMPORARYRESTRAINING ORDER, INJUNCTION, AND DECLARATORY JUDGMENT
address: 2744 Bay Meadow Ct., Farmers Branch, TX 75234. Service of said Respondent asdescribed above can be effected by personal delivery.G. Respondent, C-FB ISD on behalf of C-FB ISD Board of Trustees, may be servedwith process by serving on BOBBY BURNS, an Individual who is a resident of Texas, in hiscapacity as Superintendent of C-FB ISD, and may be served with process at the followingaddress: 1445 N. Perry Road, Carrollton, TX 75006. Service of said Respondent as describedabove can be effected by personal delivery.
III. JURISDICTION AND VENUE
 A. The subject matter in controversy is within the jurisdictional limits of this court.B. This court has jurisdiction over the parties because Respondents are Texasresidents.C. Venue in DALLAS County is proper in this cause under Section 15.002(a)(3) of the Texas Civil Practice and Remedies Code because this county is the county of the principaloffice of C-FB ISD Board of Trustees, Respondent herein. Furthermore, because venue is proper with respect to Respondent C-FB ISD Board of Trustees, venue for this action with respect to allRespondents is proper under 15.005 of the Texas Civil Practice and Remedies Code.D. Section 551.142 of the Open Meetings Act confers jurisdiction on this, theDistrict Court, over actions seeking mandamus or injunction to stop, prevent, or reverseviolations or threatened violations under the Texas Open Meetings Act (referred to as “TOMA”or “the Act”)—thereby waiving sovereign immunity to this type of lawsuit and its request for attorney fees. Tex. Gov’t Code Ann. (Vernon 2004).

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