Document text
CAUSE NO.
CHAMPIONS FM I 960 CLUB, INC., §
§
Plaintiff, §
§
v. §
§
NAUTILUS INSURANCE COMP ANY AND§
LEONARD WILLIAMS, §
§
§
Defendants. § 4/17/201910:49 AM
Marilyn Burgess -District Clerk Harris County
Envelope No. 32854800
By: Carolina Salgado
Filed: 4/17/201910:49 AM
IN THE JUDICIAL COURT OF
HARRIS COUNTY, TEXAS
DISTRICT COURT ---
PLAINTIFF'S ORIGINAL PETITION, JURY DEMAND,
AND REQUEST FOR DISCLOSURE
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Champions FM I 960 Club, Inc., ("Plaintiff''), and files Plaintifrs
Original Petition, Jory Demand, and Request for Disclosure, complaining of Nautilus
Insurance Company ("Nautilus") and Leonard Williams ("Williams") (or collectively
"Defendants") and for cause of action, Plaintiff respectfully shows the following:
DISCOVERY CONTROL PLAN
I. Plaintiff intends to conduct discovery under Level 3, Texas Rules of Civil Procedure 190.4
and 169.
PARTIES
2. Plaintiff, Champions FM 1960 Club, Inc., resides in Harris County, Texas.
3. Defendant, Nautilus Insurance Company, is an Arizona insurance company engaged in the
business of insurance in the State of Texas. Plaintiff requests service of citation upon
Nautilus Insurance Company through its registered agent for service: Janet Shemanske,
or her nominee of the Company, 7233 East Butherus Drive, Scottsdale, Arizona
EXHIBIT 2Case 4:19-cv-02023 Document 1-2 Filed on 06/05/19 in TXSD Page 1 of 18
85260. Plaintiff requests service at this time.
4. Defendant Leonard Williams is an individual resident of Houston, Texas. Williams may
be served with citation at the address listed with the Texas Department oflnsurance: 3138
Pleasant Cove Court, Houston, Texas 77059. Plaintiff requests service at this time.
JURISDICTION
5. The Court has jurisdiction over Nautilus because this Defendant engages in the business of
insurance in the State of Texas, and the causes of action arise out of Defendant's business
activities in the state, including those in Harris County, Texas, with reference to this
specific case.
6. The Court has jurisdiction over Williams because this Defendant engages in the business
of adjusting insurance claims in the State of Texas, and the causes of action arise out of
Defendant's business activities in the state, including those in Harris 'county, Texas, with
reference to this specific case.
VENUE
7. Ven tie is proper in Harris County, Texas because the insured property is located in Harris
County, Texas, and all or a substantial part of the events giving rise to this lawsuit occurred
in Harris County, Texas. TEX. CIV. PRAC. & REM. CODE§ 15.032.
FACTS
8. Plaintiff asserts claims for breach of contract, violations of sections 541 and 542 of the
Texas Insurance Code, and violations of the Texas DTPA.
9. Plaintiff owns a Nautilus Insurance Company commercial insurance policy, number
NN840807 ("the Policy"). At all relevant times, Plaintiff owned the insured premises
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located at 14340 West Sylvanfield Drive Houston, Texas 77014 ("the Property").
I 0. Nautilus or its agent sold the Policy, insuring the Property, to Plaintiff. Nautilus or its
agent represented to Plaintiff that the Policy included windstorm and hail coverage for
damage to Plaintiffs Property. Nautilus has refused the full extent of that coverage
currently owed to Plaintiff.
11. On or about January 11, 20 I 8, the Property sustained extensive damage resulting from a
severe storm that passed through the Houston/ Harris County, Texas area.
I 2. In the aftermath of the windstorm and hail, Plaintiff submitted a claim to Nautilus against
the Policy for damage to the Property. Nautilus assigned claim number I 0098579 to
Plaintiffs claim.
13. Plaintiff asked Nautilus to cover the cost of damage to the Property pursuant to the Policy.
14. Nautilus hired or assigned Vericlaim, Inc., who assigned its agent, Williams to inspect and
adjust the claim. Williams conducted an inspection on or about July 24, 2018. Williams'
findings were that the claim was not covered due to wear and tear. Plaintiff was left without
adequate funds to make repairs on the entirety of their claim.
15. Nautilus, through its agent, Williams, conducted a substandard and improper inspection of
the Property, which grossly undervalued the cost of repairs in its estimate and yielded an
unrealistic amount to underpay coverage.
16. Nautilus and Williams have ultimately refused full coverage which includes, but is not
limited to, replacement of the roof and additional interior damage. The third-party inspector
hired to review the damage to the Property found damage to the main building modified
bitumen roof. In addition, the third-party inspector found damage to roof drain cover, cap
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flashings, flashing, gravity roof ventilator, and furnace vent that were completely absent
from Williams's estimate. The storms extensive and obvious windstorm and hail damage
including, but not limited to, the roofs, vents, flashings, and sheetrock damages. The storm
compromised the integrity of the roof allowing water to enter the ceiling tiles.
17. The damage to Plaintiff's Property is currently estimated at $128,443.68.
18. Williams had a vested interest in undervaluing the claims assigned to him by Williams in
order to maintain his employment. The disparity in the number of damaged items in his
report (I) compared to that of tlie third-party inspector's (80) as well as the difference in
valuation is evidence of on the part of Williams.
19. Furthermore, Williams was aware of Plaintiff's $7,620.00 wind/hail policy deductible prior
to inspecting the Property. Williams had advanced knowledge of the damages he needed
to document in order to be able to deny the claim.
20. Williams misrepresented the actual amount of damage Plaintiffs Property sustained in
addition to how much it would cost to repair the damage. Williams made these
misrepresentations as a licensed Texas adjuster with the hope that Plaintiff would rely on
his expertise and accept the bad faith estimate as a true representation of the damages.
21. After reviewing Plaintiffs Policy, Williams misrepresented that the damage was caused
by non-covered perils. Williams used his expertise to fabricate plausible explanations for
why visible damage to Plaintiffs Property would not be covered under the policy.
22. As stated above, Nautilus and Williams improperly and unreasonably adjusted Plaintiffs
claim. Without limitation, Nautilus and Williams misrepresented the cause of, scope of,
and cost to repair damages to Plaintiffs Property, as well as the amount of insurance
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coverage for Plaintiffs claim or loss under the Policy.
23. Nautilus and Williams made these and other false representations to Plaintiff, either
knowingly or recklessly, as a positive assertion, without knowledge of the truth. Nautilus
and Williams made these false representations with the intent that Plaintiff act in
accordance with the misrepresentations regarding the grossly deficient damage and repair
estimates prepared by Williams.
24. Plaintiff relied on Nautilus and Williams' misrepresentations, including but not limited to
those regarding coverage, the cause of, scope of, and cost to repair the damage to Plaintiffs
Property. Plaintiffs damages are the result of Plaintiffs reliance on these
misrepresentations.
25. Upon receipt of the inspection and estimate reports from Williams, Nautilus failed to assess
the claim thoroughly. Based upon Williams grossly unreasonable, intentional, and reckless
failure to investigate the claim properly prior to underpaying coverage, Nautilus failed to
provide coverage due under the Policy, and Plaintiff suffered damages.
26. Because Nautilus and Williams failed to provide coverage for Plaintiffs insurance claim,
Plaintiff has been unable to complete any substantive repairs to the Property. This has
caused additional damage to Plaintiffs Property.
27. Furthermore, Nautilus and Williams failed to perform their contractual duties to Plaintiff
under the terms of the Policy. Specifically, Williams performed an unreasonable and
substandard inspection that allowed Nautilus to refuse to pay full proceeds due under the
Policy, although due demand was made for an amount sufficient to cover the damaged
Property, and all conditions precedent to recover upon the Policy were carried out by
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Plaintiff.
28. Nautilus and Williams' misrepresentations, unreasonable delays, and continued denials
constitute a breach of the statutory obligations under Chapters 54 l and 542 of the Texas
Insurance Code. Thus, the breach of the statutory duties constitutes the foundation of a
breach of the insurance contract between Defendant and Plaintiff.
29. Nautilus and Williams' conduct constitute a violation of the Texas Insurance Code, Unfair
Settlement Practices. TEX. INS. CODE §541.060(a) (!). Nautilus and Williams have
failed to settle Plaintiff's claim in a fair manner, although they were aware of their liability
to Plaintiff under the Policy. Specifically, Nautilus and Williams have failed to, in an
honest and fair manner, balance their own interests in maximizing gains and limiting
disbursements, with the interests of Plaintiff by failing to timely pay Plaintiff coverage due
under the Policy.
30. Nautilus and Williams's conduct constitute a violation of the Texas Insurance Code, Unfair
Settlement Practices. TEX. INS. CODE §54 I .060(a) (2) (A). Nautilus and Williams failed
to provide Plaintiff a reasonable explanation for underpayment of the claim.
31. Additionally, after Nautilus received statutory demand on or about January I 6, 2019,
Nautilus has not communicated that any future settlements or payments would be
forthcoming to pay for the entire loss covered under the Policy, nor did it provide any
explanation for failing to settle Plaintiff's claim properly.
32. Nautilus and Williams's conduct constitute a violation of the Texas Insurance Code, Unfair
Settlement Practices. TEX. INS. CODE §54 l .060(a) (4). Williams pe1formed a biased and
intentionally substandard inspection designed to allow Nautilus to refuse to provide full
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coverage to Plaintiff under the Policy.
33. Specifically, Nautilus and Williams performed an outcome-oriented investigation of
Plaintiff's claims, which resulted in a biased, unfair, and inequitable evaluation of
Plaintiff's losses on the Property.
34. Nautilus's conduct constitutes a violation of the Texas Insurance Code, Prompt Payment
of Claims. TEX. INS. CODE §542.055. Due to a subpar inspection, Nautilus failed to
reasonably accept or deny Plaintiff's full and entire claim within the statutorily mandated
time after receiving all necessary information.
35. Nautilus's conduct constitutes a violation of the Texas Insurance Code, Prompt Payment
of Claims. TEX. INS. CODE §542.056. Due to Williams intentional undervaluation of
Plaintiff's claims, Nautilus failed to meet its obligations under the Texas Insurance Code
regarding timely payment of the claim. Specifically, Williams's understatement of the
damage to the Property caused Nautilus to delay full payment of Plaintiff's claim longer
than allowed, and Plaintiff has not received rightful payment for Plaintiff's claim.
36. Nautilus and Williams's wrongful acts and omissions have forced Plaintiff to retain the
professional services of the attorneys and law firm representing him with respect to these
causes of action.
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CAUSES OF ACTION AGAINST DEFENDANTNAUTILUS INSURANCE
COMPANY
3 7. All paragraphs from the fact section of this petition are hereby incorporated into this
section.
BREACH OF CONTRACT
38. Nautilus is liable to Plaintiff for intentional violations of the Texas Insurance Code, and
intentional breach of the common-law duty of good faith and fair dealing. It follows, then,
that the breach of the statutory duties constitutes the foundation of an intentional breach of
the insurance contract between Nautilus and Plaintiff.
39. Nautilus's failure and/or refusal to pay adequate coverage as obligated under the terms of
the Policy, and under the laws· of the State of Texas, constitutes a breach of the insurance
contract with Plaintiff.
NONCOMPLIANCE WITH THE TEXAS INSURANCE CODE:
UNFAIR SETTLEMENT PRACTICES
40. Nautilus's conduct constitutes multiple violations of the Texas Insurance Code, Unfair
Settlement Practices. TEX. INS. CODE §541.060(a). All violations under this article are
actionable by TEX. INS. CODE §541.151.
41. Nautilus's unfair settlement practice of misrepresenting to Plaintiff material facts relating
to coverage constitutes an unfair method of competition and a deceptive act or practice in
the business of insurance. TEX. INS. CODE §541.060(a)(l).
42. Nautilus's unfair settlement practice of failing to attempt in good faith to make a prompt,
fair, and equitable settlement of the claim, even though liability under the Policy was
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reasonably clear, constitutes an unfair method of competition and a deceptive act or
practice in the business of insurance. TEX. INS. CODE §541.060(a)(2)(A).
43. Nautilus's unfair settlement practice of failing to provide Plaintiff a prompt and reasonable
explanation of the basis in the Policy, in relation to the facts or applicable law, for partial
denial of the claim, constitutes an unfair method of competition and a deceptive act or
practice in the business of insurance. TEX. INS. CODE §54 l.060(a)(3).
44. Nautilus's unfair settlement practice of failing within a reasonable time to affirm or deny
coverage of the claim to Plaintiff constitutes an unfair method of competition and a
deceptive act or practice in the business of insurance. TEX. INS. CODE §541.060(a)(4).
45. Nautilus's unfair settlement practice ofrefusing to pay Plaintiff's claim without conducting
a reasonable investigation constitutes an unfair method of competition and a deceptive act
or practice in the business of insurance. TEX. INS. CODE §54 l .060(a)(7).
NONCOMPLIANCE WITH THE TEXAS INSURANCE CODE:
THE PROMPT PAYMENT OF CLAIMS
46. Nautilus's conduct constitutes multiple violations of the Texas Insurance Code, Prompt
Payment of Claims. All violations made .under this article are actionable by TEX. INS.
CODE §542.060.
47. Nautilus's failure to notify Plaintiff in writing of its acceptance or rejection of the full claim
within the applicable time constraints constitutes a non-prompt payment in violation of
TEX. INS. CODE §542.056.
48. Nautilus's delay in paying Plaintiff's claim following receipt of all items, statements, and
forms reasonably requested and required, for longer than the amount of time provided,
constitutes a non-prompt payment of the claim. TEX. INS. CODE §542.058.
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BREACH OF THE DUTY OF GOOD FAITH AND FAIR DEALING
49. Nautilus's conduct constitutes a breach of the common-law duty of good faith and fair
dealing owed to an insured in insurance contracts.
50. Nautilus's failure to adequately and reasonably investigate and evaluate Plaintiffs claim,
although, at that time, Nautilus knew or should have known by the exercise of reasonable
diligence that liability was reasonably clear, constitutes a breach of the duty of good faith
and fair dealing.
DTPA VIOLATIONS
51. Nautilus's conduct constitutes multiple violations of the Texas Deceptive Trade Practices
Act ("DTPA"), TEX. BUS. & COM. CODE 17.41-63. Plaintiff is a consumer of goods
and services provided by Nautilus pursuant to the DTPA. Plaintiff has met all conditions
precedent to bringing this cause of action against Nautilus. Specifically, Nautilus's
violations of the DTP A include, without limitation, the following matters
A. By its acts, omissions, failures, and conduct, Nautilus has violated sections
l 7.46(b)(2), (5), (7), (9), (12), (20) and (24) of the DTPA. Nautilus's violations
include without limitation, (I) unreasonable delays in the investigation, adjustment,
and resolution of Plaintiffs claim, (2) failure to give Plaintiff the benefit of the
doubt, and (3) failure to pay for the proper repair of Plaintiffs property when
liability has become reasonably clear, which gives Plaintiff the right to recover
under section l 7.46(b )(2).
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B. Nautilus represented to Plaintiff that the Policy and Nautilus's adjusting and
investigative services had characteristics or benefits that they did not possess,
which gives Plaintiff the right to recover under section l 7.46(b )( 5) of the DTP A.
C. Nautilus also represented to Plaintiff that the Policy and Nautilus's adjusting
services were of a particular standard, quality, or grade when they were of another,
in violation of section 17.46(b)(7) of the DTPA.
D. Furthermore, Nautilus advertised the Policy and adjusting services with the intent
not to sell them as advertised, in violation of section 17.46(b)(9) of the DTPA.
E. Nautilus breached an express warranty that the damages caused by wind and hail
would be covered under the Policy. This breach entitles Plaintiff to recover under
sections 17.46(b)(l2) and (20) and 17.50(a)(2) of the DTPA.
F. Nautilus's actions are unconscionable in that Nautilus took advantage of Plaintiffs
lack of knowledge, ability, and experience to a grossly unfair degree. Nautilus's
unconscionable conduct gives Plaintiff a right to relief under section 17 .50( a)(3) of
the DTP A; and
G. Nautilus's conduct, acts, omissions, and failures, as described in this petition, are
unfair practices in the business of insurance in violation of section 17.50(a)( 4) of
the DTPA.
52. Each of the above-described acts, omissions, and failures of Nautilus is a producing cause
of Plaintiff's damages. All of the above-described acts, omissions, and failures were
committed "knowingly" and "intentionally," as defined by the Texas Deceptive Trade
Practices Act.
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CAUSES OF ACTION AGAINST DEFENDANT LEONARD WILLIAMS
NONCOMPLIANCE WITH THE TEXAS INSURANCE CODE:
UNFAIR SETTLEMENT PRACTICES
53. All allegations above are incorporated herein.
54. Williams conduct constitutes multiple violations of the Texas Insurance Code, Unfair
Claim Settlement Practices Act. TEX. INS. CODE §541.060(a).
55. Williams is individually liable for his unfair and deceptive acts, irrespective of the fact that
he was acting on behalf of Nautilus, because William is a "person," as defined by TEX.
INS. CODE §541.002(2).
56. Williams knowingly underestimated the amount of damage to the Property. As such,
Williams failed to adopt and implement reasonable standards for the investigation of the
claim arising under the Policy. TEX. INS. CODE §542.003(3).
57. Furthermore, Williams did not attempt in good faith to affect a fair, prompt, and equitable
settlement of the claim. TEX. INS. CODE §542.003(4).
58. Williams's unfair settlement practice of failing to provide Plaintiff a prompt and reasonable
explanation of the basis in the Policy, in relation to the facts or applicable law, for partial
denial of the claim, also constitutes an unfair method of competition and an unfair and
deceptive act or practice. TEX. INS. CODE §541.060(a)(3).
59. Williams's unfair settlement practice of failing to attempt in good faith to make a prompt,
fair, and equitable settlement of the claim, even though liability under the Policy was
reasonably clear, constitutes an unfair method of competition and a deceptive act or
practice in the business of insurance. TEX. INS. CODE §54 l .060(a)(2)(A).
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DTPA VIOLATIONS
60. All allegations above are incorporated herein.
61. Williams's conduct constitutes multiple violations of the Texas Deceptive Trade Practices
Act ("DTPA"), TEX. BUS. & COM. CODE 17.41-63. Plaintiff is a consumer of goods
and services provided by pursuant to the DTPA. Plaintiff has met all conditions precedent
to bringing this cause of action against Williams. Specifically, Williams' violations of the
DTPA include the following matters:
A. By this Defendant's acts, omissions, failures, and conduct, Williams has violated
sections l 7.46(b)(2), (5), and (7) of the DTPA. Williams' violations include, (I)
failure to give Plaintiff the benefit of the doubt, and (2) failure to write up an
estimate reflecting the proper repair of Plaintiff's Property when liability has
become reasonably clear, which gives Plaintiff the right to recover under section
17.46(b)(2).
B. Williams represented to Plaintiff that the Policy and his adjusting and investigative
services had characteristics or benefits they did not possess, which gives Plaintiff
the right to recover under section 17.46(b)(5) of the DTPA.
C. Williams represented to Plaintiff that the Policy and his adjusting services were of
a particular standard, quality, or grade when they were of another, in violation of
section l 7.46(b )(7) of the DTP A.
D. Williams' actions are unconscionable in that Williams took advantage of Plaintiff's
lack of knowledge, ability, and experience to a grossly unfair degree. Williams's
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unconscionable conduct gives Plaintiff a right to relief under section l 7.50(a)(3) of
the DTPA; and
E. Williams' s conduct, acts, omissions, and failures, as described in this petition, are
unfair practices in the business of insurance in violation of section 17.SO(a)( 4) of
theDTPA.
62. Each of Williams's above-described acts, omissions, and failures is a producing cause of
Plaintiffs damages. All acts, omissions, and failures were committed "knowingly" and
"intentionally" by, as defined by the Texas Deceptive Trade Practices Act. TEX. BUS. &
COM. CODE 17.45.
KNOWLEDGE
63. Defendants made each of the acts described above, together and singularly, "knowingly,"
as defined in the Texas Insurance Code, and each was a producing cause of Plaintiffs
damages described herein.
W AIYER AND ESTOPPEL
64. Defendants waived and are estopped from asserting any coverage defenses, conditions,
exclusions, or exceptions to coverage not contained in any reservation of rights letter to
Plaintiff.
DAMAGES
65. The damages caused to the Property have not been properly addressed or repaired since the
claim was made, causing further damage to the Property, and undue hardship and burden
to Plaintiff. These damages are a direct result of [!efendants' mishandling of Plaintiffs
claims in violation of the laws set forth above.
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66. Plaintiff currently estimates that actual damages to the Property under the Policy are
$128,443.68.
67. Plaintiff would show that all of the aforementioned acts, taken together or singularly,
constitute the producing causes of the damages sustained. The above described acts,
omissions, failures, and conduct of Defendants have caused Plaintiffs damages, which
include, without limitation, the cost to properly repair Plaintiffs Property and any
investigative and engineering fees incurred.
68. For breach ofcontract, Plaintiff is entitled to regain the benefit of his bargain, which is the
amount of his claims, consequential damages, together with attorney's fees.
69. For noncompliance with the DTPA and Texas Insurance Code, Unfair Settlement Practices,
Plaintiff is entitled to actual damages, which include the loss of benefits owed pursuant to
the Policy, mental anguish, court costs, and attorney's fees. For knowing and intentional
conduct of the acts described above, Plaintiff asks for three (3) times his actual damages.
TEX. INS. CODE §541.152 and TEX. BUS. & COM. CODE 17.50(b) (1).
70. For noncompliance with Texas Insurance Code, Prompt Payment of Claims, Plaintiff is
entitled to the amount of his claims, plus an eighteen percent (I 0%) per annum penalty on
those claims, as damages, as well as pre-judgment interest and reasonable attorney's fees.
TEX. INS. CODE §542.060.
71. For breach of the common law duty of good faith and fair dealing, Plaintiff is entitled to
compensatory damages, including all forms of loss resulting from Defendants' breach of
duty, such as additional costs, economic hardship, losses due to the nonpayment of the
amount owed, exemplary damages, and damages for emotional distress.
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72. Defendants' breach. of the common law duty of good faith and fair dealing was committed
intentionally, with a conscious indifference to Plaintiffs rights and welfare, and with
"malice," as that term is defined in Chapter 41 of the Texas Civil Practices and Remedies
Code. These violations are the type of conduct which the State of Texas protects its citizens
against by the imposition of exemplary damages. Therefore, Plaintiff seeks the recovery
of exemplary damages in an amount determined by the finder of fact sufficient to punish
Defendants for their wrongful conduct, and to set an example to deter Defendants and
others from committing similar acts in the future.
73. For the prosecution and collection of this claim, Plaintiff has been compelled to engage the
services of the attorneys subscribed to this pleading. Therefore, under Chapter 38 of the
Texas Civil Practices and Remedies Code, sections 541 and 542 of the Texas Insurance
Code, and section 17.50 of the DTPA, Plaintiff is entitled to recover a sum for the
reasonable and necessary services of Plaintiffs attorneys in the preparation and trial of this
action, including any appeals to the Court of Appeals and/or the Supreme Court of Texas.
74. As required by Rule 47(b) of the Texas Rules of Civil Procedure, Plaintiffs counsel states
that the damages sought are in an amount within the jurisdictional limits of this Court. As
required by Rule 47(c)(4) of the Texas Rules of Civil Procedure, Plaintiffs counsel states
that Plaintiff seeks only monetary relief of no less than $200,000 and no more than
$1,000,000.00, including damages of any kind, penalties, costs, expenses, pre-judgment
interest, and attorney fees. A jury will ultimately determine the monetary relief actually
awarded, however. Plaintiff also seeks pre-judgment and post-judgment interest at the
highest legal rate.
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. .
REQUESTS FOR DISCLOSURE
75. Under Texas Rules of Civil Procedure 190 and 194, Plaintiff requests that Defendants
disclose, within fifty (50) days from the date this request is served, the information or material
described in Rules 190.2(b)(6) and 194.2.
JURY DEMAND
76. Plaintiff hereby requests a jury trial for all causes of action alleged herein, tried before a
jury consisting of citizens residing in Harris County, Texas. Plaintiff hereby tenders the
appropriate jury fee.
PRAYER
Plaintiff prays that Defendants, Nautilus Insurance Company and Leonard Williams, be
cited and served to appear, and that upon trial hereof, Plaintiff, Champions FM 1960 Club, Inc.,
has and recovers from Defendants, Nautilus Insurance Company and Leonard Williams, such sums
as would reasonably and justly compensate Plaintiff in accordance with the rules of law and
procedure, as to actual, consequential, and treble damages under the Texas Insurance Code and
Texas Deceptive Trade Practices Act, and all punitive, additional, and exemplary damages, as may
be found. In addition, Plaintiff requests the award of attorney's fees for the trial and any appeal
of this case, for all costs of Court expended on Plaintiff's behalf, for pre-judgment and post
judgment interest as allowed by law; and for any other and further relief, at law or in equity, to
which Plaintiff, Champions FM 1960 Club, Inc., may show Plaintiff is justly entitled.
17 Respectfully submitted,
CHAD T. WILSON LAW FIRM PLLC
By: Isl Patrick C. McGinnis Case 4:19-cv-02023 Document 1-2 Filed on 06/05/19 in TXSD Page 17 of 18
. .
18 Chad T. Wilson
Bar No. 24079587
Patrick C. McGinnis
Bar No. 13631900
455 E Medical Center Blvd, Ste 555
Webster, Texas 77598
Telephone: (832) 415-1432
Facsimile: (281) 940-2137
eService to:
[email protected]
[email protected]
[email protected]
ATTORNEYS FOR PLAINTIFF Case 4:19-cv-02023 Document 1-2 Filed on 06/05/19 in TXSD Page 18 of 18