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FILED

DALLAS COUNTY
2/3/2015 2:51:27 PM
FELICIA PITRE
DISTRICT CLERK

Hernandez Angelica
DC-15-01325
CAUSE NO. _ _ _ _ __
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Plaiutiff,
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n.
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ARAPAHO ROAD BAPTIST CHURCH, §
GARLAND, TEXAS
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Defendant.
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JANE DOE 103, a pseudouym

IN THE DISTRICT COURT OF

DALLAS COUNTY, TEXAS

JUDICIAL DISTRICT

PLAINTIFF'S ORIGINAL PETITION
AND REOUEST FOR DISCLOSURE

TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Plaintiff, Jane Doe 103, who seeks recovery of damages based on conduct
described as felonies under Chapter 21 and Chapter 33 of the Texas Penal Code. She therefore
exercises her right, pursuant to Section 30.013 of the Texas Civil Practice & Remedies Code as a
victim of sexual assault and sexual abuse, to use a confidential identity. In this petition and all other
further filings in this case, Jane Doe 103 will be used as a pseudonym for the Plaintiff. Doe 103 files
this, her Plaintiff's Original Petition and Request for Disclosure, complaining of Defendant ArapallO
Road Baptist Church, Garland, Texas, and prays for damages as follows:

I
DISCOVERY CONTROL PLAN
1.

As required by TEX. R. CN. P. 190.1, Plaintiff files this lawsuit under a Level 3

Discovery Control Plan (TEX. R. CIV. P. 190.4).

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 1

II
PARTIES

2.

Plaintiff Jane Doe 103 ("Doe 103" or "Doe") resides in Dallas County, Texas. She

was a minor at the time of the sexual abuse and sexual exploitation described herein. Plaintiff s
identity has been or will be made known to Defendant.
3.

Defendant Arapaho Road Baptist Church, Garland, Texas (hereinafter "ARBC"

or "Arapaho"), a corporation organized under the laws of the State of Texas with its principal place
of business in Garland, Texas, was the employer or ostensible employer of Joshua Douglas Earls
(hereinafter "Josh Earls" or "Josh"), and his younger brother, Jordan Keith Earls (hereinafter
"Jordan Earls" or "Jordy"), at the time of the sexual abuse and sexual exploitation of this Plaintiff.
Defendant, Arapaho Road Baptist Church, Garland Texas, in the person of its Registered Agent,
George Butler, may be served at this church at 2256 Arapaho Road, Garland, TX 75044-6054 in
Dallas County, Texas, or wherever he may be found.
III
JURISDICTION AND VENUE

4.

Pursuant to Texas Rules of Civil Procedure 47, relief is sought for damages within

the jurisdictional limits of this court. Plaintiff further pleads that the monetary relief sought by
Plaintiff is more than $1,000,000.00.
5.

Venue is proper in Dallas County, Texas, because it is the county in which all or a

substantial part of the events giving rise to the claims occurred and because Defendant ARBC
maintain its principal offices in Dallas County. See Tex. Prac. & Rem. Code Ann. § 15.002.

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 2

IV

FACTUAL BACKGROUND
6.

Sometime in 2008, Josh Douglas Earls left the Northgate Baptist Church in Florence,

South Carolina, where his father was Lead Pastor, to work at Arapaho Road Baptist Church in
Garland, Texas. At first he interned there, then worked as Co-Youth Minister before being hired as
Youth Minister by ARBC. His younger brother, Jordan Keith Earls, had served as Student Pastor at
his father's church, Northgate Baptist. Jordy also moved to Texas sometime in 2009 andjoined his
brother and ARBC. Both men shared an apartment. Jordy, while not at fust an official employee of
ARBC, helped his brother with music for the church and volunteered with the Youth Group and
Youth Choir. Over the next few years, under the supervision, guidance and control of Josh and
ARBC, Jordy gradually assumed more duties and responsibilities over the youth for the benefit of
Defendant ARBC, including Youth Band Leader.
7.

Both Jordy Earls and Josh Earls quickly ingratiated themselves with the parents of

the youth group kids and began "grooming" Doe 103 and other minor girls who participated in
Youth Group and Youth Choir. Doe 103 was only an 8th grader when she fust met the Earls
brothers. Her parents, serving as Sunday school teachers, were long-time members of ARBC. It
should have been obvious to Defendant ARBC that the Earls brothers were paying special, particular
attention to some young girls in the church. The grooming by these men included giving the girls
gifts and cards, hosting swimming parties at their apartment, where the Earls brothers shared a unit,
and giving the girls rides to and from Youth Group meetings and school. The continual grooming
and eventual sexual misconduct also included inappropriate full-body hugs, ticlding of knees and
upper thighs, telling the girls how pretty they were, and using sexually suggestive and lewd language
in conversation and written communication (text messages and newsletters) with them.
PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 3

8.

In perfonning his duties as Youth Pastor, Josh Earls frequently joined minor girls

for lunch at tlleir respective schools and held overnight events for the children, including lock-ins
and Bible retreats. Well versed in social media, Josh used it as a way to "connect" with the
youngsters. By the fall of Doe 103 's 9th grade year, Josh also began conducting weekly Bible study
at Doe 103' s parents' home. He and Jordy would sometinles spend the night there after a yOUtll party.
Soon, Jordy offered to give Doe private guitar lessons at her house.
9.

The sexual grooming by bOtll men continued into Doe 103' s 9th and 10th grade years.

During Doe's 10th and 11 th grade years, Josh began conducting what he told the girls were exclusive
"book club" meetings at the apartment he shared with Jordy.
10.

Beginning in 2009, Doe 103's mother and father had complained to ARBC's

leadership about what they viewed as Josh's inappropriate conduct, especially with young girls,
including giving them rides (unaccompanied by another adult) and placing childish, profane and
perverted messages in church bulletins and on social media. The leadership at ARBC told them they
would "talk" to Josh about their concerns, but there is no evidence they did.
11.

Both men continued grooming Doe 103 and other girls, but J ordy' s sexual advances

toward Doe soon escalated. He began giving her romantic compliments, sending her sexually
suggestive texts and the like, and even telling the impressionable girl they "were dating." The first
incident of sexual abuse and assault occurred after Sunday school in the youth building on the church
premises.
12.

The sexual assaults, abuse and exploitation continued weekly, sometimes more than

once a week during the 10th and 11 tll grade. The sex acts included, but were not limited to,
violations of the law under Texas Penal Code Chapter 21, § 21.02, § 21.11, § 22.011, § 22.01 and

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 4

Chapter 33, § 33.021. These acts were the child's introduction to sex. Then, abruptly, in 2013, both
Josh Earls and Jordan Earls left Arapaho Road, telling the children they had been "called" to other
assignments in South Carolina.
13.

However, the truth was that in early 2013, the family of one of the otller girls from

tlle Youth Group at ARBC notified law enforcement that Josh Earls had sexually molested their
minor daughter in 2012 at a pool party. After a police investigation, Josh Earls was extradited back
to Dallas and arrested on Federal charges of making pornographic images and videos involving
multiple underage girls from ARBC. At tlle same time, local police were also investigating J ordy
Earls. As part of tlleir investigation, law enforcement contacted Doe and her parents. Consequently,
J ordy was also extradited from South Carolina and retunled to Dallas where he soon faced sinlliar
Federal charges of child pornography and also state charges specifically for the sexual abuse of Doe
103 but of other girls as well.
14.

Both Josh and Jordy Earls subsequently pleaded guilty to federal charges of making

child pornography. They had successfully solicited several girls to send them nude pictures.
Emboldened, they sent nude pictures of tllemselves to the girls in violation of state and federal laws.
Josh pleaded guilty. In February 2014, he was sentenced to 12 years in Federal Prison and lifetime
registration as a sexual offender. As Judge Lynn noted in sentencing him, Josh Earls had been
caught with hundreds of "vile images of children subjected to bondage and torture." Like his brother,
Jordy also pleaded guilty to child pornography, but, as of the date of the filing of this lawsuit, his
sentencing is still pending in the u.S. District Court for the Northern District of Texas.

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 5

V
SEXUAL ASSAULT AND SEXUAL ABUSE OF DOE 103
15.

As more fully describe below, Plaintiff Jane Doe 103 alleges that she suffered sexual

abuse and exploitation as a child by Jordan Earls while he was a member of the staff of Defendant
Arapaho Road Baptist Church and within the supervision, employment and control of the same
Defendant. Further, Jane Doe 103 alleges that Joshua Earls, who was his brother's supervisor and
an employee, agent or dual agent of ARBC, was negligent in the hiring, selection, retention and
supervision of Jordy when he knew or should have known that he was, like himself, a sexual deviant
and predator of young girls.
16.

Doe 103 was raised in a devout Baptist family. She was taught to hold the leadership

of the Baptist Church in great trust, confidence, reverence and respect. She and her entire family
were active members of ARBC. She and her siblings were active members of the Youth Group and
Youth Choir. By the time Doe 103 entered the 10th grade, Jordy Earls and his brother had been
actively involved in the Youth Group for approximately two years and both men had for years
actively groomed several teenage girls, including Doe. Their improper activities were no secret to
the leadership. Indeed, as early as 2009, Doe's own mother had reported to Associate/Executive
Pastor George Butler that Josh and J ordy Earls's conduct with girls was inappropriate, in particular
the brotllers' picking up their daughter without their consent and taking her, along with oilier girls,
to swim parties at their apartment.
17.

Subsequent to this time, Jordy Earls began to concentrate his attention on Doe 103.

He had become the church's Band Leader under the immediate supervision and control of his
brother, Josh. J ordy began "sexting" Doe and spending considerable time with her in connection with
church activities. Indeed, most of the sexual abuse and exploitation took place in various rooms at
PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 6

the church or the youth building. The sexual abuse included forced masturbation, digital penetration
of Doe and forced oral sex by her. Jordan Earls's sexual abuse of Doe 103 continued during 10th
grade and through the fall of her 11th grade year in 2012113. In 2012, Doe's mother again
complained to the ARBC leadership, Lead Pastor and Member of the Board of Elders (Board of
Directors) Dr. David Rogers, about a lewd cartoon Josh had sent to the children. Again, nothing was
done. Doe's parents were simply told that Josh had already resigned but would stay until July of that
year to train his replacement. Each time, ARBC' s leadership reassured Doe's parents that they could
trust them and that the Earls brothers would be talked to. Unbeknownst to her parents, however, Doe,
as well as other girls in the Youth Group, continued to be sexually abused by the Earls brothers.
18.

Doe 103 alleges that Jordan Earls, while working at Arapaho Road, had, like his

brother the Youth Pastor, a psychosexual disorder characterized by an abnonnal, impulsive sexual
attraction to young girls. Doe 103 further alleges that Defendant Arapaho Road knew or should have
known ofJordan Earls's sexual misconduct prior to the abuse complained of herein. This Defendant
also knew or should have known that Jordan Earls's psychosexual disorder rendered him unfit for
a position of trust and confidence as Youth Band Leader and Worship Leader at Arapaho Road since
the position allowed him unsupervised access to minors. Thus, Doe 103 relies on Jordan Earls's
mental condition as part of her claims. See Texas Rules ofEvidence 509(e) (4) and 51 O(d) (5).

VI
CAUSES OF ACTION AGAINST DEFENDANT ARBC
A.

Negligence
19.

Defendant ARBC negligently retained Jordan Earls and/or allowed him to assume

positions of trust, confidence and autllority under tlle supervision of his brother, Josh Earls, thus
placing him in direct contact with minor girls. As Youth Pastor, Josh's job was to recruit teenagers
PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 7

to join ARBC, to be accessible to them 24 hours a day, 7 days a week, to counsel the youth regarding
emotional relationship and attitudinal issues in the context of the teachings of ARBC. J ordy was the
Youth Worship Leader and Band Leader. Both men were supposed to be a role models of Christian
virtue. Defendant ARBC knew or should have known that the Earls brothers were decidedly sexually
dangerous and unsuited for such assignments. Defendant ARBC thus recklessly entrusted and
exposed minors, including Doe 103, to the Earls brothers' care, counsel, and predation.
20.

Defendant ARBC failed to provide reasonable monitoring and supervision of Jordan

Earls. Defendant ARBC retained overall responsibility for all aspects of religious life at the church,
including the following duties: (a) to have inquired and investigated before granting permission to
Jordan Earls to work as a Youth Leader within the church environment; (b) to have supervised,
evaluated, monitored, inspected and overseen all activities of Jordan Earls while at the church or
activities involving youth groups supported by the church; (c) to have investigated, monitored and
supervised Jordan Earls when he was Band Leader and Youth Worship Leader for the church; (d)
to have removed Jordan Earls's access to any and all youth groups upon early notice that Jordan
Earls was decidedly unsuited for the position to which he was assigned; (e) to have actually
conducted an investigation of the allegations and complaints against Jordan Earls; (f) to have
informed concerned parents of their findings; and (g) to have ensured that Jordan Earls was not
allowed to work at another church with the same opportunities to abuse girls. Defendant ARBC was
negligent in relation to each of these duties. Had the ARBC and its leadership not been negligent,
Jordan Earls would never have had the opportunity, means and power to sexually molest Doe 103
and other girls.

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 8

21.

Defendant ARBC failed to perform adequate background checks on persons hired or

in positions of authority over youth.
22.

Defendant ARBC failed to train, supervise, manage or monitor persons such as the

Earls brothers who would be in direct contact with youth.
23.

Defendant ARBC and its leadership failed to implement reasonable policies and

procedures to detect and prevent the sexual abuse of children by persons who had authority over
children such as Jordan Earls and his brother. ARBC failed to formulate, adopt, and enforce adequate
rules, policies and procedures with respect to the supervision of persons who would be in contact
or interact with teenagers.
24.

Defendant ARBC failed to warn Plaintiff, her family or any of the other church

families about Defendant Jordan Earls's dangerous sexual propensities despite their lmowledge and
notice of these dangerous proclivities. Indeed, several times over the years Doe's parents had voiced
concerns about the Earls brothers. They were told to trust them (ARBC's leadership) to address her
concerns. Their suspicions were thus silenced, but the Earls brothers were, in fact, allowed to
continue to molest children.
25.

Prior to Jordan Earls's sexual abuse of Doe 103, Defendant ARBC and its leadership

failed to investigate reports regarding Jordan Earls's and his brother's misconduct or to act on
knowledge that they were unsuitable for a position affording unfettered access to girls and to respond
responsibly by removing them from positions affording contact with such potential victims. But for
his position with ARBC, Jordan Earls would have been unable to victimize Doe. ARBC is therefore
liable for Jordan Earls's conduct because it promoted him as a qualified, trained and supervised
youth leader.

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B.

Breach of Fiduciary Duty
26.

Plaintiff's parents entrusted their teenage daughter to the care of ARBC and its

leadership. There could be no higher relationship of trust and confidence than when parents entrust
their child or children to another, particularly when the entrusted person or entity elicits such trust
by claiming high moral and ethical standards. Defendant ARBC' s fiduciary duty or special duty is
based upon a moral, social and personal relationship of trust and confidence, which Defendant
unconscionably breached. Defendant ARBC had a duty of loyalty and good faith as well as a duty
to act with integrity of the strongest kind, all of which it failed to do. Defendant ARBC's breach of
tins duty to Doe 103 and her parents resulted in substantial and life-changing injuries and damages
to Doe. Such injuries and damages were a forseeable result of the breach of tlris fiduciary duty.
Further, such conduct was grossly negligent.

C.

Vicarious Liability/Respondeat Superior/Agency
27.

The sexual abuse and sexual exploitation in tins case arose from Jordan Earls's

exercise of authority and power and access to victims and their families made possible by Defendant
ARBC and its staff through positions Jordy was given, such as volunteer, Band Leader and cosponsor of youth activities, including Youth Worslnp Leader. Jordy Earls was therefore an agent or
ostensible agent of ARBC. Plaintiff thus pleads vicarious liability under the doctrine of Respondeat
Superior and/or agency in that Defendant ARBC and its leadership knew or should have known of
his misconduct and the dangerous propensities of Defendant Jordan Earls and Ins brother and,
further, that Jordan Earls's injurious sexual actions were foreseeable.

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 10

D.

Misrepresentation

28.

During the existence of the fiduciary relationship pleaded herein, Defendant ARBC

and its leadership actively and constructively stated andlor represented numerous falsehoods,
including representing that Defendant Jordan Earls was to be trusted by both parents and children
as a man of good moral character, a man who could be entrusted by ARBC leadership with the care,
counseling, teaching, and instruction of children. These representations, among others outlined in
this pleading, were false and misleading and were known to be false and misleading at the time they
were made, or were made with a reckless disregard as to whether they were true or false or of
potential consequence to members of the congregation. These falsehoods and non-disclosures were
material facts made with the intent to deceive and to induce reliance.
29.

Doe 103 asserts that Defendant ARBC is liable for acts and/or omissions pursuant

to the Restatement (Second) of Torts, Section 302B, under the legal doctrine ofnegligent assumption
of risk of intentional or criminal conduct.
An act or an omission may be negligent if the actor realizes or should realize that it involves
an unreasonable risk of harm to another through the conduct of the other or a third person
which is intended to cause harm, even though such conduct is criminal.

Restatement (Second) of Torts, Section 302B.
30.

Doe 103 asserts that Defendant ARBC is liable for acts andlor omissions pursuant

to the Restatement (Second) of Torts, Section 311, under the legal doctrine of negligent
misrepresentation involving risk of physical harm.
(1)

One who negligently gives false information to another is subject to liability
for physical harm caused by action taken by the other in reasonable reliance
upon such information, where such harm results
(a)

to the other, or

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 11

(b)

(2)

to such third persons as the actor should expect to be put in
peril by the action taken.

Such negligence may consist of failure to exercise reasonable care
(a)

in ascertaining the accuracy of the information, or

(b)

in the manner in which it is communicated.

Restatement (Second) of Torts, Section 311.

E.

Premises Liabilitv
31.

Defendant ARBC is liable to Doe 103 for premises liability. Doe 103 was an invitee

by the ARBC to its property, namely the Arapaho Road Baptist Church, in Garland, Texas.
Defendant ARBC owed a duty of care to those who may be harmed by criminal acts on its premises
where it conducted its business when the risk of criminal conduct is so great that it is both
unreasonable and foreseeable. Defendant was aware of or should have been aware of criminal acts
of sexual assault by the Earls brothers and in particular by Jordan Earls, on its property. ARBC thus
breached its duty of care to Doe 103 when it allowed Jordan Earls to remain on its property, thus
harming Doe 103.

F.

Gross Negligence
32.

Sexual abuse of a child is utterly reprehensible and cannot be tolerated in a civilized

society, particularly by one of the institutions that is granted exceptions and exemptions that even
its own members may not enjoy individually. Defendant ARBC and its leadership, at the time and
on the occasions in question, acted with heedless and reckless disregard for the safety of Jane Doe
103 and other girls, which disregard was the result of conscious indifference to the rights, welfare,
and safety of Plaintiff Doe 103 in violation of the laws of the State of Texas.

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 12

33.

Further, Tex. Civ. Prac. & Rem. Code §41.005(a) does not apply to bar punitive

damages in this matter because the Defendant was criminally complicit. Tex. Civ. Prac. & Rem.
Code §41.005(b)(2) provides an exception when a defendant is criminally responsible as a party to
the criminal act. Under Chapter 7 of the Texas Penal Code, specifically §7.02(a), a person is
criminally responsible for an offense committed by the conduct of another if:
(I)

acting with intent to promote or assist the commission of the offense, he
solicits, encourages, directs, aids, or attempts to aid the other person to
commit the offense;
or

(2)

having a legal duty to prevent commission of the offense and acting with
intent to promote or assist its commission, he fails to make a reasonable
effort to prevent commission of the offense.

34.

Tex. Pen. Code Ann. §7.02(a)(2). The provisions of this statute are met because

Defendant assisted and aided J ordy Earls in the commission of the sexual assaults on Plaintiff by
allowing him access to Plaintiff.
35.

Further, provisions of Tex. Pen. Code Ann. §7.02(a)(3) are met because Defendant

had a duty to prevent the sexual assault of Plaintiff. Defendant knew or should have known of
J ordy' s sexual misconduct but, despite that knowledge, did not timely withhold him remove him,
nor report him to police but repeatedly placed him in environments where he could prey upon
young girls like Plaintiff.
36.

Additionally, Tex. Pen Code Ann. §§7.21-7.23 encompasses the criminal

responsibility of corporations or associations and provide that a corporation or association is
criminally responsible for the conduct of its agent if it was authorized, performed or recklessly
tolerated by a high managerial agent. The Defendant not only tolerated it, they aided and abetted the

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 13

Earls brothers in acquiring more victims. Plaintiff would show tbat Defendant recJdessly tolerated
and allowed the conduct of tbese predators and are tberefore subject to punitive damages in this
matter.

G.

Intentional Infliction of Emotional Distress
37.

Plaintiff alleges tbat tbe actions of Defendant ARBC and its leadership have inflicted

emotional distress upon Plaintiff.
38.

As a direct and proximate result oftbe acts or omissions of ARBC set forth above,

it is foreseeable to a person of ordinary prudence tbat a trusting, impressionable child of tbe church
would be exposed to an unreasonable danger and actually be harmed and tbat tbe acts or omissions
of Defendant ARBC had proximately caused injury to Doe 103.

VII
DAMAGES

39.

As a result of tbe acts and omissions described herein, Plaintiff Doe 103 has suffered

severe mental anguish in tbe past and present and in all reasonable probability will sustain severe
mental anguish in the future.
40.

As a result oftbe conduct and incidents described herein, Plaintiff, Doe 103, has

incurred medical and/or counseling expenses in tbe past and in all reasonable probability will incur
medical and/or counseling expenses in tbe future.
41.

Plaintiff Doe 103 has experienced physical pain and suffering and bodily injury in tbe

42.

Plaintiff Doe 103 pleads physical impairment damages.

past.

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43.

Plaintiff Doe 103 in all reasonable probability will suffer loss of earning capacity in

the future.
44.

Plaintiff Doe 103 seeks exemplary damages based on Defendant's gross negligence.

45.

As a result of the above, Plaintiff Doe 103 seeks damages within the jurisdictional

limits of the Court.
VIII
REOUEST FOR DISCLOSURE
Under Texas Rule of Civil Procedure 194, Plaintiff Jane Doe 103 requests that Defendant
disclose, within 50 days of the service of this request, the information or material described in Rule
194.2 (a) - (I).
IX
PRAYER

WHEREFORE, PREMISES CONSIDERED, Plaintiff Jane Doe 103 respectfully requests
that Defendant ArapallO Road Baptist Church, Garland, Texas, be cited to appear and answer, and
on final trial, that Plaintiff have judgment for:
a.

Actual damages;

b.

Punitive damages;

c.

Prejudgment and post judgment interest in accordance with §304.1 04, et seq., Texas
Finance Code and any other applicable law;

d.

Costs of suit;

e.

Monetary relief of more than $1,000,000.00;

f.

Any further relief, either in law or equity, to which Plaintiff is justly entitled.

PLAINTIFF'S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE - PAGE 15

X

DEMAND FOR JURy TRIAL
Plaintiff demands that a jury of her peers be empaneled to hear and decide the issues
presented in this case.

RESPECTFULLY SUBMITTED,

lsi Tahira Khan Merritt
Tahira Khan Merritt
State Bar No. 11375550
Tahira Khan Merritt, PLLC
8499 Greenville Ave., Suite 206
Dallas, Texas 75231-2424
(214) 503-7300 Telephone
(214) 503-7301 Facsimile
tallira@tkmlawfirm.com

ATTORNEY FOR PLAINTIFF
JANE DOE 103

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