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Bc et st 7 e ORIGINAL e cause NODL=(2-Gle Ay IN THE District CobRT* JOE BANKSON AND GENA CHARLTON, Plaintifs, ae eur § § § § § JANE DOE, LIBERTY COUNTY § DALLAS COUNTY, TEXAS SHERIFF'S OFFICE, KPRC-TV, § BELO CORP, a § ‘THE NEW YORK TIMES COMPANY, 5 CNN AMERICA, INC,, THOMPSON § REUTERS, and ABC NEWS, INC., § § § § 193"-L, Defendants. JUDICIAL DISTRICT PLAINTIFFS’ ORIGINAL PE ION AND JURY DEMAND ‘TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES Joe Bankson and Gena Charlton, Plaintiffs, and files this Original Petition complaining of Jane Doe, Liberty County Sherift’s Office, KPRC TV, BELO, Corp., the New York Times Company, CNN America, Ine., Thomson Reuters, and ABC News, Inc.(“Defendants”), and would respectfully show the Court as follows: 1.00. DiscovERY ConTROL PLAN Pursuant to Rule 190 of the Texas Rules of Civil Procedure, Plaintiffs request a Level III Discovery Control Plan, 2.00 ParTies 2.01 Plaintiff Joe Bankson resides in Liberty County, Texas. The last four digits of his Social Security number are 9595, 2.02 Plaintiff Gena Chariton resides in Liberty County, Texas. The last four digits of her Social Security number are 6465 and the last four digits of her Texas driver's license number PLAINTIFFS’ ORIGINAL PETITION AND JURY DEMAND Pact | are 0738. 2.03 Defendant Jane Doe is a self-proclaimed psychic going by the pscudo name “Angel.” Defendant Jane Doe's legal name and address are unknown at this time. 2.04 Defendant Liberty County Sheriff's Office is a governmental unit located within Liberty County, and may be served with process by serving County Judge, the Honorable Craig 2.05 Defendant KPRC-TV is a domestic for-profit corporation and may be served with process by serving its registered agent, Jack McGrew, at 2410 Polk Ave., Houston, TX. 2.06 Defendant BELO, CORP. is a foreign corporation doing business in the State of Texas and may be served with process by serving its registered agent, Guy H. Kerr, at 400 South Record St., Dallas, TX_75202. 2.07 Defendant The New York Times Company is a foreign corporation doing business in the State of Texas and may be scrved with process by serving its registered agent, Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company. at 211 E. 7" St., Suite 620, Austin, TX 78701-3218. 2.08 Defendant CNN America, Inc. is a foreign corporation doing business in the State of Texas and may be served with process by serving its registered agent, CT Corporation System, at 350 N. St. Paul St., Suite 2900, Dallas, TX 75201-4234. 2.08 Defendant Thomson Reuters is a foreign corporation doing business in the State of Texas and may be served with process by serving its registered agent, Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company, at 211 £, 7" St. Suite 620, Austin, TX 78701-3218. PLAINTIFFS’ ORIGINAL PETITION AND JURY DEMAND Pace? 2.09 Defendant ABC News, Inc. is a forcign corporation doing business in the State of “Texas and may be served with process by serving its registered agent, Corporation Service Company dfo'a CSC-Lawgers Incorporating Service Company, at 211 E, 7*St, Suite 620, Austin, TX 78701-3218 3.00 VENUE AND JURISDICTION 3.01 This Court has subject matter jurisdiction over the ease because the amount in controversy for the Plaintiffs, exclusive of cost and interest, is within the jurisdictional limits of this Court, 3.02 This Court has jurisdiction over Liberty County Sheriff's Office as this is an action for money damages brought pursuant to 42 U.S.C. § 1983, the Fourth and Fourteenth ‘Amendments to the United States Constitution, and Article | Sec. 9 of the Texas Constitution. Additionally, this Court has jurisdiction over Liberty County Sheriff's Office pursuant to Tex Civ. Prac, & Rem. Code Section 104.002 3.03 Jurisdiction is proper against non-resident Defendants because they did business in the State by, among other acts, contracting by mail or otherwise with a Texas resident, of which either party is to perform the contract in whole or in part in this State, committing a tort in whole or in part in this State, or recruiting a Texas resident, direetly or through an intermediary located in this State, for employment inside or outside of this State. Additionally, the non- the State, resident Defendants have continuous systematic contacts 3.04 Venue is proper in Dallas County, Texas because this is action for libel, slander, or invasion of privacy and Defendant Belo, coma domiciled or had its principal place of business in this county at the time this suit was filed in accordance with Tex. Civ. Prac. & Rem. PLAINTIFFS? ORIGINAL PETITION AND JURY DEMAND Pace 3