galbraith v h2h academy - final

REQUESTS FOR DISCLOSURES AND JURY DEMAND !

!

CAUSE NO. _____________________

PLAINTIFF'S ORIGINAL PETITION,

REQUESTS FOR DISCLOSURES AND JURY DEMAND

TO THE HONORABLE JUDGE OF SAID COURT: KRISTI AND BRAD GALBRAITH, Individually and as Next Friends of

a minor, Original Petition, complaining of HEART 2

HEART MONTESSORI ACADEMY, LTD d/b/a Heart2Heart Montessori Academy,

RH2H MANAGEMENT LLC, ASHLEA J. PENA, and PAMELA D. DECKER and for

cause of action would respectfully show the Court the following:

I . DISCOVERY PLAN AND REQUESTS FOR DISCLOSURES

1.01. Plaintiffs intend that discovery in this lawsuit be conducted in accordance with

TEXAS RULES OF CIVIL PROCEDURE 190.3, Level 3, as the facts and circumstances giving rise to

claims make it appropriate that discovery be conducted in accordance with a specific

discovery control plan tailored to this lawsuit. Plaintiffs will cooperate with the Defendants in

KRISTI AND BRAD GALBRAITH, Individually and as Next Friends of

a minor, Plaintiffs,

§ § § § § §

IN THE DISTRICT COURT

V. § §

_____ JUDICIAL DISTRICT

S HEART 2 HEART

MONTESSORI ACADEMY, LTD d/b/a Heart2Heart Montessori Academy, RH2H MANAGEMENT LLC, ASHLEA J. PENA, AND PAMELA D. DECKER

§ § § § § § § §

Defendants. § PARKER COUNTY, TEXAS


trying to agree to the provisions of a reasonable discovery control plan or, failing agreement,

Plaintiffs may file a motion with the Court seeking an order for such a plan.

1.02. Plaintiffs hereby request that Defendants disclose the materials and information

required to be disclosed under TEXAS RULES OF CIVIL PROCEDURE 194.2(a) through (f), by

serving Plaintiffs counsel with responses to these requests for disclosures within the time limits

provided for responses to such requests under TEXAS RULES OF CIVIL PROCEDURE 194.1.

I I . PARTIES

2.01. Plaintiffs Kristi and Brad Galbraith, Individually and as Next Friend of

are residents of Parker County, Texas and are the natural parents of a

minor. The , and the

last three digits of her Social Security Number are 985

Texas , and the last three digits of his Social Security Number

are 901.

2.02. Defendant Ruyle Heart 2 Heart Montessori Academy, Ltd. d/b/a Heart2Heart

Montessori Academy is a Texas Limited Liability Partnership and may be served with a copy of

this petition and citation on its registered agent, Ashlea J. Pena at either her place of employment

at 201 Canyon Court, Willow Park, TX 76087 or her residence at 108 El Colina Road,

Weatherford, TX 76085.

2.03 intention to sue the day care facility which operates now

and at which time operated on June 17, 2014 at 201 Canyon Court, Willow Park, TX, and is now

known and/or then known in the community as Heart2Heart Montessori Academy. Plaintiffs

reserves the right to amend and supplement this petition by naming the correct legal entity(ies).


2.04 Defendant RH2H Management, LLC is a Texas Limited Liability Company and,

based upon information and belief, is the general partner of Defendant Ruyle Heart 2 Heart

Montessori Academy, Ltd. RH2H Management, LLC may be served with a copy of this petition

and citation on its registered agent, Ashlea J. Pena at either her place of employment at 201

Canyon Court, Willow Park, TX 76087 or her residence at 108 El Colina Road, Weatherford, TX

76085.

2.05 Defendant Ashlea J. Pena is a Texas resident and is one of the owners of the Heart

2 Heart Montessori Academy, general partners of Defendant Ruyle Heart 2 Heart Montessori

Academy, Ltd., and/or one of the managing members of Defendant RH2H Management, LLC.

Based upon information and belief, at all material times, Ms. Pena

Ms. Pena may be served with a copy

of this petition and citation at either her place of employment at 201 Canyon Court, Willow Park,

TX 76087 or her residence at 108 El Colina Road, Weatherford, TX 76085.

2.06 Defendant Pamela D. Decker is a Texas resident and is/was one of the owners of

the Heart 2 Heart Montessori Academy, general partners of Defendant Ruyle Heart 2 Heart

Montessori Academy, Ltd., and/or one of the managing members of Defendant RH2H

Management, LLC. Ms. Decker may be served with a copy of this petition and citation at her

residence at 319 Clear Lake Lane, Weatherford, TX 76087.

2.07 Hereinafter, Defendants, Heart2Heart

Montessori Academy

I I I . JURISDICTION AND VENUE

3.01. The District Courts of Parker County, Texas have jurisdiction over this action

because Plaintiffs are bringing causes of action within the subject matter jurisdiction of district


damages sought to be recovered herein are in an amount in excess of the

minimum amount in controversy for jurisdiction in district courts.

3.02. Venue is proper in Parker County, Texas, pursuant to TEX. CIV. PRAC. & REM

CODE §15.002, because (a) a substantial part of the events and omissions giving rise to Plaintiffs

claims occurred in Parker County, Texas; and (b) the Heart2Heart Montessori Defendants

principal place of business and/or residence is located in Parker County, Texas.

3.03 As required by Rule 47(b) of the TEXAS RULES OF CIVIL PROCEDURE, Plaintiffs

counsel states that the damages sought are within the jurisdiction limits of this Court. As required

by Rule 47(c) of the TEXAS RULES OF CIVIL PROCEDURE, Plaintiffs counsel states that Plaintiffs

seek monetary relief in an amount in excess of $200,000 but not more than $1,000,000. The

amount of monetary relief actually awarded, however, will ultimately be decided by a jury.

Plaintiffs also seek pre-judgment and post-judgment interest at the highest legal rate.!

IV. SUMMARY OF FACTS

A. Accountability and Responsibility

4.01 This case is about accountability and responsibility. Each and every day, millions

of parents entrust our most precious and prized possessions our children - in the hands of day

care centers and their owners and staff. While our children are left in these in centers and

schools, the ultimate responsibility for their care and welfare lies with those who choose to take

care of and watch our children. These day care centers must ensure that our children are safe and

enforce a code of conduct that is beyond reproach.

4.02 Parents depend on day care centers, their owners and staff for honesty and

transparency. After all, their business is tied to the health and welfare of the children they serve.


Taking care of children, at times, is difficult and challenging. Accountability is not. Day care

centers can either do the right thing or not. It is that simple when it comes to taking care of our

children. Ethical failures and a course of unconscionable conduct in a day care center leads to

child abuse and neglect.

B. Reports of Abuse

4.03 regularly attended daycare at the

Heart2Heart Montessori Academy located at 201 Canyon Court, Willow Park, TX 76087 while

his parents, Kristi and Brad Galbraith, worked and/or tended to personal medical conditions

requiring cancer treatment including radiation, rehabilitation, and recovery.

4.04 On Tuesday, June 17, 2014, at approximately 4:15 pm, while in route to pick up

at school, Kristi Galbraith received an unexpected phone call from one of

Heart2Heart Montessori Academy Def

Tidwell advising her that her son (and another little boy) had been forcefully secured to his

napping mat by duct tape over his blanket by one of the fac

that she did not understand why the teachers also seemed to be the roughest on their child. Ms.

Tidwell corroborated her story by texting to the Galbraiths three photographs she snapped while

the child was lying down.

4.05 Upon becoming informed of the abusive actions, Kristi Galbraith immediately

called her husband to report what happened, rushed home to pick him up, and then drove to the

school to pick up their child and personally address this situation with Ms. Decker.

4.06 While driving to Heart2Heart, Kristi and Brad Galbraith had another discussion

with Ms. Tidwell. She again reiterated what she saw and also told the Galbraiths that she


confronted Ms. Decker about her inappropriate actions and Ms. Decker responded with words to

Do not say anything about this. I know this illegal but felt it was necessary. Ms.

Tidwell also told the Galbraiths that Ms. Decker had done this to at least one other girl in the

past.

4.07 Shockingly, during this phone call with the Galbraiths, Ms. Tidwell further

advised the Galbraiths that this was not the only abusive behavior she witnessed during her short

time at Heart2Herat. She also advised the Galbraiths that Heart2Heart withheld water from the

children, limiting them to two water breaks per day, so the staff did not need to change as many

diapers. This employee also reported that there was at least one instance of one child being

locked up in a room alone (without supervision) for an extended period of time causing the child

to miss lunch. Ms. Tidwell advised the Galbraiths that, in addition to reaching out to them, she

quit her job and notified and reported this incident to child care protective services in

Weatherford.

C. The Galbraiths Meeting with Pam Decker

4.08 When the Galbraiths arrived at the school, they requested to speak with Ms.

Decker. Kristi Galbraith then proceeded with and his after school care teacher,

Ms. Bennett, to Ms. Bennett

whether she was aware that her son had been duct-taped to his mat and Ms. Bennett did not

respond.

4.09 Meanwhile, after what appeared to be a considerable amount of time, Ms. Decker

finally appeared in the lobby to greet the Galbraiths, walking in nonchalantly, with no-sense of

urgency or purpose, uncharacteristically holding one of her grandchildren. When confronted

with the accusation of their child being duct taped to his nap mat, Ms. Decker although not


admitting or denying the accusations had no meaningful response and appeared to shrug off the

accusation as implausible. It was only after the Galbraiths advised her that they had copies

photographs of their son duct taped to the nap mat that Ms. Decker became visibly shaken; not

distraught with what she had done but rather distressed that she had been caught. Stuttering and

mumbling, Ms. Decker repeatedly apologized to the Galbraiths saying that she should not have

done this.

4.10 hone, and

unbeknownst to Ms. Galbraith, Ms. Decker sent an email to Kristi Galbraith stating1:

We would appreciate you ordering a weighted blanket2 for [ to use here at school. Nap time continues to be a real challenge and the weighted blankets seem to be very beneficial. The best price we have found is on the internet at Sensory Goods. We would like to have this by the first of July.

D. and Confirmation of the Truth of their Story

4.11 Appropriately concerned and upset about what had transpired at Heart2Heart, the

Galbraiths pulled their son from Heart2Heart Montessori Academy and rightfully notified other

parents y had email

addresses) via email on Tuesday evening, June 17, 2014, about their conversations with Ms.

Tidwell concerning her report to CPS about the abusive incidents occurring at Heart2Heart

including the duct taping of their own child to his nap mat.

4.12

parents of other children at the school were outraged and several parents contacted Ms. Tidwell

directly. One parent reported to the email list that Ms. Tidwell

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!1 Ms. Galbraith saw this email only after she returned home from picking up at school and when she had finally had a chance to sit down to read emails. !2 ! Weighted blankets are often used as a therapeutic modality to calm autistic children and/or to provide self-regulation in children in a variety of stressful situations. !


Tidwell and got

some disturbing info. My husband and I will be at their doorsteps tomorrow to pull our

4.13 The Galbraiths conversations continued the following day, Wednesday, June 18,

2014, with appropriate officials including the Willow Park police department and the Texas

. In addition, the

Galbraiths answered many phone calls and sent additional emails updating the email list of their

contacts with the appropriate officials and additional facts learned from other parents.

E.

4.14 Also, on Wednesday, June 18, 2014, only after Ms. Decker had been advised that

photographic evidence existed of her actions, and one day following her atrocious actions, Ms.

Decker called another parent, Lorrie Almquist, wanting to update her on what was occurring at

the school. However, prior to the time that this Ms. Almquist received the phone call, she also

received an email on Tuesday, June 17 from Ms. Decker advising that she needed to order her

son a weighted blanket since nap time seems to still be a real challenge and another email

advising that Ms. Tidwell was making false accusations against the school and was no longer an

employee.

4.15 During this phone call, Ms. Decker asked Ms. Almquist whether she had talked to

stated that

she had no idea about what Ms. Decker was talking. Ms. Decker advised Ms. Almquist that Ms.

Tidwell was pregnant and hormonal and saying crazy things about the school and then told Ms.

Almquist that as she (Ms. Decker) was walking through the classroom, she noticed that Ms.

son and another little boy were not lying down and napping and that she got


frustrated. Ms. Decker then told Ms. Almquist that she

o duct tape her son and the other little boy

to their nap mats. Ms. Decker apologized to Ms. Almquist and advised her that other parents

Ms.

4.16 Following this conversation, Ms. Almquist also called Ms. Tidwell who

confirmed wha

F. and Incomplete Admission

4.17 Later that evening, on Wednesday evening, June 18, 2014, Ashlea Pena, another

Heart2Heart owner (who happens to be ), provided an email update to

some of the parents whose children were still enrolled in the school, advising them that they

the investigation is complete and we

their efforts to

given the benefit of the doubt as one family can clearly cause such doubt in our loyal family of

clients. We apologize for all of the distress this is causing you, especially creating mistrust in

een extremely

exaggerated by a very upset parent that did not allow [emphasis

added].

4.18 Without ever referencing any specific incident, Ms. Pena admits that the

ave the best interest of the child or


is DEVASTATED by a very foolish decision she made. Please be assured that the child involved

was in no way harmed or caus

4.19 In this same email, Ms. Pena continues her desperate attempt to distance

email, Ms. Pena intentionally misled her parent body that Ms. Decker had actually duct taped

only one child when, in fact, two children had been duct taped to their nap mats on Tuesday,

June 17, and that another parent had reported the similar behavior on a prior occasion.

4.20

ter

from Heart2Heart Montessor

The letter also threatened the

And, following this cease and desist letter, the Heart2Heart Montessori Academy Defendants

threatened to obtain a temporary injunction against the Galbraiths. At that time, Heart2Heart was

more concerned about protecting their reputation and reducing any negative fallout from the

truthful statements that had been disseminated to other concerned parents than actually

addressing the agg

4.21

school convened a parent meeting on Thursday evening, June 19. At that meeting, Ashlea Pena

greeted the parents and told them that

and that the school is currently under investigation by Childcare Licensing. Ms. Pena admitted


Further, Ms. Pena wanted these

parents to hear from Ms. Decker about

4.22

Ms. Decker continued to explain

and playing with some items from

the diaper table and that all of the other children were asleep. She explained that all of the other

teachers were across the room with the other children. Ms. Decker saw that was

id she spoke with him on several occasions and asked him to please

-i

with him for 5 or 6 minutes and continued to ask him to lie down and to rest but that after the

fifth time of asking him to rest, he would not go down and looked

going to happen. So, I made a very foolish decision. I went into the kitchen and got some duct

tape

lay down on his stomach and that she pulled the blanket over him so that he was

covered and that she put the strip across the blanket.

4.23

cried. He never complained. He was not in any anguis n any way,

emotionally, physically, at all although Ms. Decker readily admitted that her decision to duct


4.24 Ms. Decker unequivocally stated that after went to sleep, she

anything else [emphasis added]. However, the pictures show a completely different story. The

duct tape was tightly wrapped and tucked around the nap mat causing to be

illegally restrained to his mat.

4.25 Ms. Decker explained that she did the same thing to another little boy in another

classroom and reasoned that since duct-taping seemed to work, she would see if

it would help with this one as well.

4.26 Ms. Decker told her parent audience - this incident and


not disclose the time she made her phone call to Ms. Pena or tha -

4.27 Based upon information and belief, it was only after the Heart2Heart Montessori

Academy Defendants were told about copies of the picture of bound to his nap

-

Department of Family and Protective Services Child Licensing Division. If, in fact, anyone at

Heart2Heart Montessori Academy was remotely remorseful for their actions, they would have

-

their crimes.

4.28 After Ms. Decker spoke, a woman, who introduced herself as a friend of the day

sure

4.29 During the question and answer session, one parent asked if this type of incident

Ms. Pena failed to disclose that another

parent previously made these same accusations.

G. All the Signs Point to Abuse

4.30 Based upon information and belief, Heart2Heart Montessori Academy Defendants

also punished and other children at the school by purposefully withholding

water and other forms of liquids in an effort to reduce the number of diaper changes throughout

the day and by further punishing children by slapping them on the head during diaper changes if

t school.


4.31 Day care center abuse is extremely difficult to identify because children often lack

the necessary vocabulary and understanding to articulate problems or concerns. Although a

number of Heart2Heart parents, including the Galbraiths, had a gut intuition that something was

exactly what the

problems were. Unfortunately, it now seems as if their worst fears have been confirmed.

4.32 In the G the

Galbraiths, without elaborating any specific facts, shared that they had some suspicions for the

e other events and behavior issues with but

could never put their finger on the problem.

4.33 Later that evening, another parent emailed his observations to the email group that

chool. It is not unusual for her to finish

4.34 Lorrie Almquist reported that she had noticed behavioral changes in her child

several weeks prior to the duct taping incident. Specifically, Ms. Almquist disclosed that her son

was not happy going to school and would be uncharacteristically upset when being dropped off

routines recently changed, she is now convinced that her son had been

previously abused and duct taped during naps. Ms. Almquist also believes that the allegations

lked to

today has had the same exact complaint about their children being extremely thirsty when they

4.35 Ms. Almquist also has concerns about the manner in which her son was being


the class room, since he had an accident. She discussed this with Ms. Decker, who responded,

later found

4.36 Another parent reported to the email

specifically about M

changed from light hearted to

that children would be smacked on the head while their diapers were changed at the school. This

4.37

and that on his last day at Heart2Heart on June 6, when he was picked up at noonish, he had not

had a bowel movement and had urination accidents all weekend. This parent reported that her

child finally pooped on Sunday and attributed these incidents to lack of water at the school.

Yet another parent stated that she had similar incidents with her child not having a bowel

movement for 2 to 3 days and needing to offer her child water constantly. This parent was

furious as to how much pain her child experienced as a result of her child being denied water.

4.38 Still another parent stated that she had to begin picking her child up early in May

home with ant bites all over


4.39 Within a week of pulling their children from Heart2Heart, parents started to

settled into his happy, easy going, polite self again. He would have SUCH bad

2H, it

H. Effects of the Abuse

4.40 As a result of these incidences, often times acted erratically at

home. For several weeks up to a month or more prior to learning of this incident, on occasion,

completely out of his character and normal behavior patterns, became very

upset and suddenly stopped wanting to go into his classroom when he was dropped off at school.

In addition, Kristi and Brad further noted that would scream as if he was in pain

when his diaper was being changed, taking multiple people, at times, to calm him down in order

to change his diaper. would also -

purposefully striking his head with his own fists. Moreover, would cry

inc

Kristi Galbraith noticed that a large drink as soon as he was

picked up from school.

V. CAUSES OF ACTION AGAINST DEFENDANTS

A. Negligence

5.01 Paragraphs 1.01 through 4.40 are incorporated herein as if fully alleged.


5.02 Plaintiffs Kristi and Brad Galbraith, Individually and as Next Friend of

a minor, will show that the Heart2Heart Montessori Academy Defendants were

negligent in failing to properly carry out their responsibilities to thereby,

proximately causing injuries. Specifically, the acts and/or omissions of

negligence are as follows:

a) Heart2Heart Montessori Academy Defendants did not provide care to according to the acceptable standard of care for a child

care facility in the State of Texas. The failure to meet the proper standard of care resulted in injury and pain and suffering of

b) Heart2Heart Montessori Academy Defendants failed to use ordinary care, that is, failed to do that which a child care facility of ordinary prudence would have done under the same or similar circumstances with respect to

care; and

c) Heart2Heart Montessori Academy Defendants failed to properly supervise its employees with regard to the treatment and discipline of the children entrusted to the care of Heart2Heart Montessori Academy Defendants resulting in injury and pain and suffering of

5.03 The above-referenced conduct of Defendants was a direct and proximate cause of

injuries.

B. Gross Neglect/Gross Negligence

5.04 Paragraphs 1.01 through 5.03 are incorporated herein as if fully alleged.

5.05 Plaintiffs will further show that the negligent acts and/or omissions of the

Defendants as set out above constitutes such an entire want of care as to indicate that the acts

and/or omissions in question were the result of conscious indifference to the rights, welfare or

safety of and/or constituted gross neglect and/or gross negligence, which was

the proximate cause of injuries.


C. Negligence Per Se

5.06 Paragraphs 1 through 5.05 are incorporated herein as if fully alleged.

5.07 Plaintiffs will show that Defendants were negligent per se in that they committed

unexcused violations of minimum standards which were designed to prevent injury to a class of

persons to which bel negligent acts per se

include, but are not limited to the following:

a) Failure on the part of Defendants Pena and Decker to ensure that the daily operation of Heart2Heart Montessori Academy Defendants was administered in compliance with the Texas Minimum Standards for Licensed Child-Care Centers, as required by 40 T.A.C. Part 19, Chapter 746.1003(1);

b) Failure on the part of Heart2Heart Montessori Academy Defendants child-care

employees to demonstrate competency, good judgment, and self-control in the presence of children and when performing assigned responsibilities, as required by 40 T.A.C., Part 19, Chapter 746.1201(1);

c) Abusing and other children in violation of 40 T.A.C., Part 19,

Chapter 746.1201(4); d) Failing to provide basic care for and other toddlers including

routines such as diapering, feeding, and sleeping as required by 40 T.A.C., Part 19, Chapter 746.2501(1).

e) Failure to use discipline with and other children that is (1)

individualized and consistent for each child; (2) appropriate to understanding; and (3) directed toward teaching the child acceptable behavior and self-control as required by 40 T.A.C., Part 19, Chapter 746.2801;

f) Failure to use discipline and guidance with and other children

that is positive and encourages self-esteem, self-control, and self-direction as required by 40 T.A.C., Part 19, Chapter 746.2803;

g) Exercising punishment on and other toddlers that is harsh, cruel,

or unusual treatment including (1) corporal punishment or threats of corporal punishment and (2) punishment associated with food, naps, or toilet train as prohibited by 40 T.A.C., Part 19, Chapter 746.2805(1) and (2); and


h) Forcing and other children to sleep by restraining their heads or

bodies as prohibited by 40 T.A.C., Part 19, Chapter 746.2905.


the damages and injuries sustained by

D. Breach of Contract


5.10 Defendant made contractual representations as to the quality of care and services

provided by Defendant including quality of care, child care, the timing and appropriateness of

treatment, the quality and nature of the staff available to take care of children including

and a number of other representations, incidental or related to such services which

were not carried out.

5.11 The above-referenced conduct of Defendant was a direct and proximate cause of


E. Res Ipsa Loquitur


5.13 Under the doctrine of Res Ipsa Loquitur, the Heart2Heart Montessori Academy

Defendants are directly responsible for injuries and damages. The

Heart2Heart Montessori Academy Defendants were in complete physical control and had total

responsibility for care and custody at the time the incident occurred. Because

was completely under the care, custody and control of the Heart2Heart

Montessori Academy Defendants, the character of this occurrence is such that it would ordinarily

not have happened in the absence of negligence of the employees, agents and servants of the

Heart2Heart Montessori Academy Defendants.


F. Fraud/Negligent Misrepresentation


5.15 The Heart2Heart Montessori Academy Defendants made material representations

as to the quality of care and services provided by Defendants including quality of care, child care

techniques, the timing and appropriateness of care, the quality and nature of the staff available to

take care of children including and a number of other representations,

incidental or related to such services which were not carried out. These representations were

made to induce Kristi and Brad Galbraith to utilize Heart2Heart Montessori Academy

Defendants for the paid care of their child, These representations were not

accurate.



G. Violation of Penal Code


5.18 Defendants violated the Texas Penal Code, Section 22.04 because Defendants

intentionally, knowingly, recklessly or with criminal negligence by act or omission caused

and other children, under the age of 15 years, serious bodily injury.



VI. RESPONDEAT SUPERIOR


6.02 At all times material hereto, the employees of the Heart2Heart Montessori

Academy Defendants were employees, agents or servants of Heart2Heart Montessori Academy


Defendants and were in the course and scope of their employment and in furtherance of their

employer's businesses. Therefore, the Heart2Heart Montessori Academy Defendants are directly

responsible for the actions of the employees, servants or agents working at Heart2Heart

Montessori Academy under the doctrine of respondeat superior.

VII . DAMAGES FOR PLAINTIFFS


7.02 As a result of the foregoing, Plaintiffs have incurred injury and damage in an

amount which is, as of yet, undetermined, and avers that said damages are in excess of minimum

jurisdictional limits of this court. Plaintiffs further state that upon trial Plaintiffs should be

awarded fair and reasonable damages, including but not limited to their pain and suffering and

mental anguish, as determined by the jury.

VII I . ATTORNEYS FEES


8.02 Plainti fees pursuant to section 38.001 of the Texas

Civil Practice and Remedies Code.

IX. JURY DEMAND

9.01 Plaintiffs request a trial by jury and herewith tender the required jury fee.

CONCLUSION AND PRAYER

Wherefore, premises considered, Plaintiffs pray that Defendants be cited to appear and

answer herein and, upon final hearing, that Plaintiffs recover a judgment against the Defendants,

jointly and severally, for all of their damages, including actual, consequential and exemplary

damages, pre and post j court


costs and other recoverable costs included herein, and for such other relief, at law or in equity, to

which Plaintiffs may be justly entitled

Respectfully submitted,

RASANSKY LAW FIRM

By: /s/ Jeffrey Rasansky Jeffrey H. Rasansky State Bar No. 16551150 [email protected] Sadie Horner State Bar N. 24083201 [email protected] 2525 McKinnon Street Suite 625 Dallas, Texas 75201 (214) 651-6100 (214) 651-6150 Fax ATTORNEYS FOR PLAINTIFFS

!

!

galbraith v h2h academy - final

Documents

canyon court

defendant ashlea

plaintiffs original

willow park

plaintiffs kristi

jury demand page

texas resident

plaintiffs counsel