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- 1 - IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________ )) ) Petitioner/Plaintiff, ))) NO. Vs. ))) Individually, and )) Defendant ) COMPLAINT COMES NOW Plaintiff ________________ by and through counsel, and files this Complaint against Defendant, ________________, individually and against ________________, and, in support hereof, states as follows: PARTIES 1. Plaintiff ________________ is an adult resident citizen of ________________ County, ________________. 2. Defendant ________________ is an adult resident citizen of ________________ County, ________________ who may be served with service of process by this Court at the following address: RELEVANT FACTS 3. Some time prior to ______________, 20____, Defendant ________________ began doing business as ________________ and engaged in the lawn maintenance business for commercial and residential clients. 4. During the same approximate time frame, Plaintiff ________________ was engaged in the operation of a lawn maintenance and landscaping business commonly known as ________________.
. . 5. Plaintiff's company was incorporated in the state of Texas in the month of 20, 2004 and operated out of a commercial office. 6. Approximately one year later, on or about 19, 2003, defendant and his company began doing business as. He and his company, were engaged in the lawn maintenance services and landscaping services provided by plaintiff. 7. Approximately one year later on or about 19, 2003, plaintiff's company was involved in an incident which resulted in plaintiff sustaining injuries. 8. In connection with the aforementioned incident, plaintiff sued defendant for an amount in the amount of approximately 11,500 in damages to plaintiff. 9. The following is a copy of the original complaint and a copy of the original complaints served as evidence at the hearing. 10. According to the original complaints, and in support, plaintiff does not have any attorney. 11. No service of process was made on defendant, and therefore the service of process is void and of no effect. 12. According to the original complaint, and in support, plaintiff's business did not have a sign on the rear of the business and was not regularly inspected, and the business had only one sign, was not always maintained properly, and was in disrepair at the time of the present incident. 13. According to the original complaints, and in support, plaintiff's conduct involved willful, wanton and malicious conduct and, therefore, the allegations here in relief which are brought against plaintiff as such, must be stricken. 14. According to the original complaints, and in support, plaintiff does not have any form of insurance. 15. According to the original complaints, and in support, plaintiff did not have any business license and was not a licensed salesman of lawn services or landscaping services, and defendant had no business license either. The complaints and the evidence here in relief, show that the two business are connected in ways described therein. In this manner, the present matter is for trial and judgment can be rendered, and this court now grants defendant's motion for summary judgment as to plaintiff's complaints. Case no. 6-03-00233-cr-wkbg detailed statement of claim 1. Plaintiff is an adult resident citizen of county, 2. Defendant is an adult resident citizen of county who is and may be served with service of process by this action, at the applicable address of the individual at identified above, 3. Defendant's attorney is named as the defendant's representative. 4. The