Doc 1 Baez v Khraish Original Petition

7/24/2019 Doc 1 Baez v Khraish Original Petition

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CAUSE NO.

IN THE DISTRICT COURT

OSE BAEZ,

Plaintiff,

v.

KRAISH H. KRAISH, individually and

d/b/a FMK LTD,

HANNAH E. KRAISH, individually and

d/b/a HMK LTD,

KHRAISH DEVELOPMENT GROUP,

LLC HMK LTD.

JUDICIAL DISTRICT

DALLAS COUNTY, TEXAS

Defendants.

PLAINTIFF'S ORIGINAL PETITION REQUEST FOR DISCOVERY

TO THE HONORABLE JUDGE OF SAID COURT:

COMES Now JOSE BAEZ, hereinafter called Plaintiff; complaining of HMK,

LTD., Khraish Development Group, LLC, Khraish H. Khraish and Hannah E. Khraish,

hereinafter referred to as Defendants, and for cause of action shows the H onorable Court

and Jury as follows:

DISCOVERY CONTROL PLAN

T his matter shall be conducted under a L evel 3 Discovery Control Plan, pursuant

to Rule 190 of the Texas Rules of Civil Procedure,

I.

PARTIES

Plaintiff is an individual who resides at 316 N . Carroll Ave, A pai

ment 203,

Dallas, Dallas County, Texas 75246. The last 3 digits of his social security number are

858.

PLAINTIFF'S ORIGINAL PETITION REQU EST FOR DISCOVERY

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DISTRI

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DALLA

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Defendant Khraish H. Khraish is an individual who may be served at his office,

1119 Singleton, Dallas, Dallas County Texas or his home address of 5810 Club Oaks

Drive, Dallas, Texas 75248. On August 18, 2011, Defendant Khraish. Khraish filed suit

in Dallas County, Texas (Cause No. 1 1-10306 in the 134 t District Court) representing

that he owned and managed the real property that is the immediate subject of Plaintiff's

illegal lease and subsequent injuries. According to Dallas Central Appraisal District

Records, Defendant Khraish H. Khriaish, individually, owned the subject property in

2010, having acquired it in June of 2000 from Earl B. Dean and having transferred the

deed to HMK Ltd. in April of 2014.

Defendant Hanna E. K raish is an individual who may be served at his office, 1119

Singleton; Dallas, Dallas County Texas, 75212-5217, or at his residence, 16928 Preston

Bend Dr., Dallas, TXX 75248-1351. On August 18, 2011, Defendant Hanna E. Khraish

filed suit in Dallas County, Texas (Cause No. 11-10306 in the 134t District Court)

representing that he owned and managed the real property that is the immediate subject of

Plaintiff's illegal lease and subsequent injuries.

Defendant HMK, Ltd. is a domestic limited paitilership whose registered agent is

Defendant Khraish H. Khraish and m ay be served at 11 19 Singleton, Dallas, Dallas

County Texas, 75212-5217. Defendant HM K LT D has filed suits in Dallas County

representing to our courts that it owns, operates, and/or manages the real property that is

the immediate subject of Plaintiffs illegal lease and subsequent injuries.

Defendant Khraish Development G roup, LLC is a now inactive domestic limited

liability company w hose registered agent John H. Carney w ho may be served at 5005

Greenville, Ave. 200, Dallas, Texas 75206. On August 18, 2011, Defendant Khraish


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Development Group, LLC has filed suit in Dallas County, Texas (Cause No. 11-10306 in

the 134t District Court) representing that it owned and managed the real property that is

the immediate subject of Plaintiff's illegal lease and subsequent injuries.

L

JURISDICTION AND VENUE

The subject Matter in controversy is within the jurisdictional limits of this court.

Pursuant to TRCP 47(c), the Plaintiff states that she seeks only monetary relief of more

than 100,000.00 but less than 200,000.00, including damages of any kind, penalties,

costs, expenses, pre-judgment interest, and attorney fees.

This court has jurisdiction over the parties because Defendant is a Texas

corporation.

Venue in Dallas County is proper in this cause of action pursuant to all subparts

of TEX. CIV. PRAC . REM . COD E 15.002.

FACTUAL BACKGROUND

At different times since 2010, each of the named Defendants has represented to a

Dallas County court (and / or Dallas Central Appraisal District) that it or he was entitled

to judicial relief on the grounds that it or he owned, operated, and/or managed hundreds

of properties in the City of Dallas, Dallas County, Texas, including, at all relevant times

pertaining to this action, Dallas City Block 1262, Block 18 and Lot 5 & 6, also known as

917-921 Ann Avenue, Dallas, Texas 75223.

PLAINTIFF'S ORIGINAL PETITION REQUES T FOR DISCOVERY

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For example, on August 21, 2014, Defendant HM K LT D filed suit in Dallas

County Cause No. DC-14-09120 in the 298

t District Court) representing that it owns,

operates, and/or manages the real property that is the immediate subject of Plaintiff's

illegal lease and subsequent injuries. Yet in that same cause of action, both Defendants

Khraish H. Khriash and Hanna E. Khraish allege that they are owners (plural) of the

subject property.

As previously noted, according to Dallas Central Appraisal District Records,

Defendant Khraish H . Kh riaish, individually, owned the subject property in 2010 and in

2012 as well as all times relevant to this peition, having acquired it in June of 2000 from

Earl B. Dean and having transferred the deed to HM K L td. on April 25, 2014.

How ever, in a February 16, 2015 pleading filed by Defendant Khraish H. K hraish

in Cause No. CC -14-02577-D, Dallas County Court at Law No. 4, Defendant Khraish H.

Khraish offered an affidavit stating that he sold the subject property to HMK, Ltd. on

January 1, 2010.

Defendant Hanna E. Khraish annually files suit against Dallas Central Appraisal

District alleging that he, in his individual capacity some times in along with Defendant

HM K, Ltd., sometimes with Defenant Khraish Development Group, LLC, always w ith

Defendant Khraish H. Khraish).

Defendants either variously or collectively -- were responsible for the operation,

management, and maintenance of the subject property which is one over 400 residential

rental properties owned by Defendants in Dallas County according to it's own pleadings

in Dallas County District Court Cause No. DC-14-09120 in the 298

t District Court).'

in 2010, Defendants filed suit against DCAD in Cause No. 1040914 in the 95

t

District Court, Dallas

County alleging that they owned m ore than 400 properties in Dallas County, Including the subject property

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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At all times relevant to this pleading, Plaintiff was a tenant of D efendants

pursuant to a lease entered into on or about August 25, 2010.

The terms of the lease

were in violation of TEX. PR OP. C ODE 96.006(e)

3 in that it impo sed duties on P laintiff to

make any and all repairs to the property and no obligation on the landlord to do so. The

terms of the lease also violated TEX. PROP. CODE 96.056(g).4

Defendants presented to Plaintiff that a payment of security deposit would waive

the first months rent. The security deposit was instead applied to Defendant's own

expenses. The deposit was never returned to Plaintiff,nor accounted for by Defendant.

On or about June 17, 2012, at such time that Plaintiff was a tenant in Defendants'

property in A partment 202, 917 Ann Street, Dallas, Texas 75223, Plaintiff was aw akened

by pain in the secon d toe of his left foot. Plaintiff saw a rat run off after biting his toe.

The rat then ran to the kitchen cabinet and left from whence he came through a sizable

hole in the wall. Plaintiff notified Defendant of the infestation on multiple occasions

prior to this incident, when Defendant responded that since the rat was inside the

apartment and not in a common area, it was not [defendant's] problem.

The apartment had been infested with rats and other vermin for some time. Its

exterior structures were decaying, the structure was not water-tight I weather-tight. The

2 According to DCAD records, the owner of the subject property on that date was Defendant Khraish H.

Khraish and he continued to be the owner until April 25, 2014. However D efendant Khraish H. Khraish has

also recently made an affidavit stating that he sold the property to Defendant H MK , Ltd. on January 1,

2010.

A landlord and tenant may agree for the tenant to repair or remedy, at the tenant's expense, any condition

covered by Subchapter B if all of the following conditions are met: (1)at the b eginning of the lease term the

landlord owns only one rental dwelling. This defendant landlord owns more than one rental dwelling and

in fact owns d ozens of rental properties. The lease violates other subsections of this statue as well,

including, without limitation, TEx. PR OP. CO DE 92.006(e)(2).

4

A lease must contain language in und erlined or bold print that informs the tenant of the remedies

available under this section and Section 92.0561. The lease between Plaintiff and Defendant contains no

such language.


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floors, walls, ceilings were in decay, riddled with holes, cracks and loose materials. It

was desperately in need of serious repairs, which Defendant failed to provide.

Bars over

the windows for security of tenants were broken and not fixed, and the parking lots were

on uneven, unsafe surfaces that were not constructed of any type of gravel road. All of

Defendants' properties regularly receive violations regarding code violations like trash

problems, abandoned vehicles, and untamed w eeds; and responding to citizen com plaints

about trash odors, lawn maintenance, anim al feces, and parking problems in the

neighborhood, and D efendants consistently require that such violations are the

responsibility of its tenants.

Defendants own hundreds of properties, and on occasions prior to and unrelated

to this incident, employed Plaintiff for maintenance on. Defendants' properties. Such

properties were each in violation of many if not m ost obligations imposed by Texas

statutes, common law, and local ordinances. Defendants' misrepresented their obligations

to prior tenants in the same one-page lease form as that signed by Plaintiff, The Lease

by fraudulently assigning Defendants', and other tenants' statutory duty to keep the

dwelling safe and habitable to Plaintiff. Defendants misrepresented the condition of its

in-fact deplorable condition that greatly endangered the health and safety of all

Defendants' tenants.

Iv

COMMON LAW FRAUD

Defendants are guilty of fraud w ith respect to the occurrence in question in that

they made a 1) material representation 2) that was false, 3) that was known to be false

s

In the aftermath of this event, the premises made the basis of this cause of action. was inspected by the.

City of Dallas and found to be in violation of 18 sections of the Dallas City Code, including m any which

materially affect the ph ysical health or safety of the ordinary tenant.


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when made, or made recklessly without knowledge of truth, (4) that was intended to be

acted on, (5) that was relied on, and (6) that caused injury to Plaintiff.

Italian Cowboy

Partners Ltd. v. Prudential Ins Co. of Am.

341 S.W.3d 323 (Tex. 2011) ;

Aquaplex Inc.

v. Rancho la Valencia Inc.

297 S.W.3d 768, 774 (Tex. 2009)(per curiam);

De Santis v.

Wackenhut Corp.

793 S.W.2d 670, 688 (Tex. 1990).

Defendants made a material representation in the lease that Plaintiff was solely

responsible for fumigating for...rodents. Such representation was material because it

attempted to illegally shift a non-delegable duty from Defendants to Plaintiff

Defendants, as landlords / lessors of dozens of properties made this representation with

reckless disregard for the truth, at best, but more likely knew it was illegal and false when

made. They intended for Plaintiff to rely on it (i.e. don't bother us about the rat problem

on the premises, that's your problem per the lease ); Plaintiff relied on this

misrepresentation to his detriment by not demanding that Defendants carry out their legal

duty to fumigate for rats and this reliance ultimately cost Plaintiff serious injury.

VI.

S T A T U T O RY F RA U D

V I OLAT I ON OF TEX . B us. C OM . C OD E

pu

Defendant defrauded Plaintiff by inducing him to sign the lease on the reliance

that the deposit provided to Defendant would be treated as a deposit as defined under the

TEX. PROP. CO DE 92.

See

TEX. Bus. & COM. CODE 27.01. Prior to signing a lease,

Defendant presented to Plaintiff that a payment of security deposit would waive the first

months rent. The security deposit was instead applied to Defendant's own expenses and

never returned to Plaintiff, nor accounted for.

PLAINTIFF 'S ORIGINAL PETITION REQUEST FOR DISCOVERY

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VI.

CONSTRUCTIVE FRAUD

Constructive fraud involves the breach of a legal or equitable duty that the law

declares to be fraudulent, irrespective of moral guilt, because of its tendency to deceive

others, to violate confidence, o r to injure public interests. Archer v. G riffith

390 S.W.2d

735, 740 (Tex. 1964). As a general rule, the following elements must appear to constitute

actionable fraud based o n misrepresentation: (1) a m aterial representation

was made; (2)

the representation was false; {3) when the representation was made, the speaker knew it

was false or m ade it recklessly without any know ledge of the truth and as a positive

assertion; (4) the speaker made the representation with the intent that the other party

should act up on it; (5) the party acted in reliance on the represen tation; and (6) the party

thereby suffered injury.

Italian Cowboy P artners Ltd. v. Prudential Ins. Co. of Am.

341

S.W.3d 323, 54 Tex. Sup. C t. J. 822, 830 (Tex. 2011) ;

Aquaplex Inc. v. Rancho la

Valencia Inc. 297 S.W.3d 768, 774 (Tex. 2009) (per curiam);

De Santis v Wackenhut

Corp.

793 S.W .2d 670, 688 (Tex. 1990) ;

Stone v. Law yers Title Ins. Corp.

554 S.W.2d

183, 185 (Tex. 1977) .

A lease must contain language in underlined or bold print that informs the tenant

of the remedies available under TEx. PROP. CODE

92.056 and TEx. PROP. CODE

92.0561.

The lease between Plaintiff and D efendant contains no such language. D efendant violated

TE X. PR OP . CO DE 92.006(e) in that it attempted to impose a duty to provide any and

all repairs to the premises from the Defen dant landlord to the P laintiff tenant at the

tenant s expense, which may be done only under certain circumstances which were not

PLAINTIFF'S ORIGINAL PETITION REQU EST FOR 'DISCOVERY

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present. Defendant also violated TEX_ PROP. CODE 92.109 when it failed to return or

account for Plaintiff s security deposit.

Fraudulent misrepresentation of Defendant s obligations under the pest control

statute were the direct and proximate cause of Plaintiff s injuries. The Texas Structural

Pest Control Act governs who may apply pesticides to apartment buildings. The act

establishes two types of pesticide applicators: certified commercial applicators and

certified noncommercial applicators. An apartment building owner may obtain pest

control services from either a business with a structural pest control business license or

require an employee who is a licensed certified noncommercial applicator to perform the

services. Although the amendment uses the word may, a broad reading of the bill

suggests the correct wording to be must. An uncertified owner is prohibited from

applying pesticides to an apartment building containing two or more dwelling units.

ee

TEX. OCC. COD E 1951.

Since Defendant attempted to delegate this duty to Plaintiff, in direct violation of

State law, and causing Plaintiff injury, Defendant is liable to Plaintiff for constructive

fraud.

VII.

BREA C H OF C ON TRA C T

VIOLATION O F TEX. PROP. CODE

The lease between Plaintiff and Defendant violated TEx. PROP. CODE 92.006(e)

in that it attempted to impose a duty to provide any and all repairs to the premises from

the Defendant landlord to the Plaintiff tenant at the tenant s expense, which may be done

only under certain circumstances, which were not present here.


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Specifically, shifting the burden to make repairs contractually from landlord to

tenant at tenant's expense can only be done by landlords who own only one rental

dwelling.

Moreover, doing so may only be done if, at the beginning of the lease term, the

dwelling is free from any condition which would materially affect the physical health or

safety of an ordinary tenant. That was certainly not the case here. This was a knowing

violation of TEX. PR OP. CO DE 92.006(e).

Finally, [a] landlord's duties and the tenant's remedies under Subchapter B,

which covers conditions materially affecting the physical health or safety of the ordinary

tenant, may not be waived except as provided in Subsections (d), (e), and (f) of this

section.

VIII.

JUDICIAL REMEDY

TEx.

PROP. ODE 96.006 e)

The remedies for a knowing violation of TEX. PROP. CODE 92.006 are statutorily

prescribed. A landlord who knowingly violates TEX. PROP. CODE 92.006 by contracting

orally or in writing with a tenant to waive the landlord's duty to repair shall be liable to

the tenant for (1) actual damages, (2) a civil penalty of one month's rent plus $ 2,000, and

{3) reasonable attorney's fees.

IX.

PLAINTIFF 'S ACTUAL DAM AGES

To date, Plaintiff Jose Baez has incurred the following reasonable and necessary

expenses, for which additional amount he sues herein:

JOSE BAEZ'S PAST MEDICAL EXPENSES:

PLAINTIFF'S ORIGINA L PETITION REQUEST FOR DISCOVERY

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Parkland Emeregency Room will supplement

Baylor University Medical Center

29,465.39

Dallas Emergency Physicians

1,080.00

National Primary Care, P.A.

2,160.00

TOTAL

32,705.39

Plaintiff has also suffered physical pain, physical impairment, physical

disfigurement and loss of earning capacity in the past and will, in all likelihood, continue

to suffer physical pain, physical impairment, physical disfigurement and loss of earning

capacity in the future.

X.

EXEMPLARY DAMAGES

Plaintiff is entitled to exemplary damages pursuant to TEX . CIV. PRAC . REM .

CODE 41.003(a)(1), (2), and (3).

Exemplary damages are not limited pursuant to TEx. Cw. PRAC . REM . CODE

41.008(a) or (b) because Defendant's fraud is an exception to such limitations. TEX.

CIV. PRAC. REM. CODE 41.008(c)(11).

XI.

ADDITIONAL REMEDIES

Plaintiff herein seeks all remedies available to him pursuant to TEX. PROP. CODE

92.0563 including, without limitation, costs of court and attorneys fees, as well as pre

and post-judgment interest pursuant to TEx. FIN. CODE 304.


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PLAINTIFF S REQUEST FOR DISCOVERY

A. Request for Disclosure

Defendant is hereby requested to disclose, within fifty (50) days of service of

this petition and incorporated request, the information or material described in

Rule 194.2(a)-(i) of the Texas Rules of Civil Procedure, to the undersigned

counsel of record for Plaintiff.

B. Interrogatories

Defendant is hereby requested to answer, within fifty (50) days of service this

petition and incorporated request, the interrogatories attached hereto as

Exhibit A, separately, fully, in writing, and under oath, pursuant to Rule 197

of the Texas Rules of Civil Procedure, to the undersigned counsel of record

for Plaintiff.

C.

Request for Production

Defendant is hereby requested to produce, within fifty (50) days of service of

this petition and incorporated request the documents and tangible items in the

list attached hereto as Exhibit B, pursuant to Rule 196 of the Texas Rules of

Civil Procedure, to the undersigned counsel of record for Plaintiff.

D. Request for Admissions

Defendant is hereby requested to admit or deny, in writing, within (50) days

of service of this petition and incorporated request, the propositions of fact

and/or law attached hereto as Exhibit C, pursuant to Rule 198 of the Texas

Rules of Civil Procedure, to the undersigned counsel of record for Plaintiff

PLAINTIFF S ORIGINAL PETITION

REQUEST FOR DISCOVERY

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PRAYER

WHEREFORE, PREMISES CONSIDERED, Plaintiff, respectfully prays that

the Defendant be cited to appear and answer herein, and that upon a final hearing of the

cause, judgment be entered for the Plaintiff against Defendant for damages in an amount

within the jurisdictional limits of the Court; together with pre-judgment interest from the

date of injury through the date of judgment) at the maximum rate allowed by law; post-

judgment interest at the legal rate, costs of court; and such other and further relief to

which the Plaintiff may be entitled at law or in equity.

Respectfully submitted,

R OLLE, B R EELAND, R YAN, LANDAU,

W INGLER A ND INDMA N. P.C .

By:

Michael Hindm

State Bar No. 24 i 4 026

2030 Main Street, Suite 2

Dallas, Texas 75201

Phone No. 214) 742-8897

Fax No.

214) 637-6872

[email protected]

[email protected]

ATTORNEY FOR PLAINTIFF

PLAINTIFF 'S ORIGINAL PETITION REQU EST FOR DISCOV ERY

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EXHIBIT A

PLAINTIFF'S REQUEST FOR INTERROGATORIES

TO DEFENDANT

DEFINITIONS ND INSTRUCTIONS

1

As used herein, the terms you and your

shall

refer the Defendants

HMK Ltd., Khraish Development Group LLC, Hanna E. Khraish and Khraish H.

Khraish named herein, Defendants' attorneys, agents, and all other natural persons or

business or legal entities acting or purporting to act for or on behalf of Defendants,

whether authorized to do so or not

2.

As used herein, the term incident or date of incident refers to the

events described as occurring on June 17, 2012 in Part III of Plaintiff s

.Original Petition.

3.

As used herein, the term documents shall mean all writings of every

kind, source and authorship, both originals and all non-identical copies thereof, in your

possession, custody, or control, or known by you to exist, irrespective of whether the

writing is one intended for or transm itted internally by you, or intended for or transmitted

to any other person o r entity, including without limitation any governm ent agency,

department, administrative, or private entity or person. The term shall include

handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall

include comm unications in words, symbols, pictures, sound recordings, films, tapes, and

information stored in, or accessible through, computer or other information storage or

retrieval systems, together with the cod es and/or programm ing instructions and other

materials necessary to understand and use such systems. For purposes of illustration and

not limitation, the term shall include: affidavits; agendas; agreem ents; analyses;

announcem ents; bills, statements, and other records of obligations and expenditures;

books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other

records of paym ents; charts or draw ings; check registers; checkbooks; circulars; collateral

files and contents; contracts; corporate bylaw s; corporate charters; correspondence; credit

files and contents; deeds of trust; deposit slips; diaries; drafts; files; guaranty agreements;

instructions; invoices; ledgers, journals, balance sheets, profit and loss statements, and

other sources of financial data; letters; logs, notes, or mem oranda of telephonic or face-

to-face conversations; manuals; memoranda of all kinds, to and from any persons,

agencies, or entities; minutes; m inute books; notes; notices; parts lists; papers; press

releases; printed m atter (including books, articles, speeches, and n ewspaper clippings);

purchase orders; records; records of adm inistrative, technical, and financial actions taken

or recomm ended; reports; safety deposit boxes and contents and records of entry;

schedules; security agreements; specifications; statements of bank accounts; statements;

interviews; stock transfer ledgers; technical and engineering reports, evaluations, advice,

recomm endations, comm entaries, conclusions, studies, test plans, manuals, procedures,

data, reports, results, and conclusions; summ aries, notes, and other records and

recordings of any conferences, meetings, visits, statements, interviews or telephone

conversations; telegrams; teletypes and o ther comm unications sent or received;

PLAINTIFF 'S ORIGINAL PETITION & REQ UEST FOR DISCOVER Y

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transcripts of testimony;. UC C instrumen ts; work papers; and all other w ritings, the

contents of which relate to, discuss, consider, or otherwise refer to the subject matter of

the particular discovery requested.

4.

In accordance with Tex. R. Civ. P. Rule 192.7, a docume nt is deemed to

be in your possession, custody or control if you either have ph ysical possession of the

item or have a right to possession of the item that is equal or superior to the person who

has physical control of the item.

5. Person : The term person shall include individuals, associations,

partnerships, corporations, and any other type of entity or institution whether formed for

business purposes or any other purposes.

6.

Identify or Identification :

(a)

. When used in reference to a person, identify or identification

means to state hiS or her full name, present or last known residence address,

present or last known business address and telephone number.

(b) When used in reference to a public or private corporation,

governm ental entity, partnership or association, identify or identification

means to state its full name, present or last known bu siness address or operating

address, the name of its Chief Executive Officer and telephone number.

(c)

Whe n used in reference to a docume nt, identify or

identification shall include statement of the following:

(i) the title, heading, or caption, if any, of such document;

(ii)

the identifying number(s), letter(s), or combination thereof,

if any; and the significance or meaning of such number(s), letter(s), or

combination thereof, if necessary to an understanding of the docum ent and

evaluation of a ny claim of protection from discovery;

(iii) the date appearing on such docum ent; if no date appears

thereon, the answer shall so state and shall give the date or approximate

date on which such docum ent was prepared;

(iv)

the number of pages and the general nature or description

of such docum ent (i.e., whether it is a letter, mem orandum, m inutes of a

meeting, etc.), with sufficient particularity so as to enable such document

to be precisely identified;

(v)

the name and capacity of the person who signed such

document; if it was not signed, the answer shall so state and shall give the

name o f the person or persons who prepared it;

PLAIN TIFF'S ORIGINA L PETITION & REQUEST FOR D ISCOVERY

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(vi) the name and capacity of the person to whom such

document was addressed and the name and capacity of such person, other

than such addressee, to whom such document, or a copy thereof, was sent;

and

(vii) the physical location of the document and the name of its

custodian or custodians.

7.

Settlement : as used herein, means:

a) n oral or written, disclosed or undisclosed agreement, bargain,

contract, settlement, partial settlement, limited settlement, arrangem ent, deal,

understanding, loan arrangement, credit arrangement, contingent settlement,

limitation on the amount of liability or judgment, or a promise by or between

plaintiff and any defendant or between any defendant herein whereby plaintiff or

defendant have in any way released, compromised, in whole or in part, directly or

indirectly, or agreed to do so in the future, any of the matters in controversy in

this lawsuit wh ether before, after or during trial or before or after any jury v erdict

is returned herein or a judgment is entered or rendered herein.

(b)

any resolution of the differences between the plaintiff and

defendant by loan to the plaintiff or any other device which is repayable in whole

or in part out of any judgment the plaintiff may recover against defendant.

(c)

The term settlement shall also include MaryCarter

Agreements as that term is used under Texas Law.

8.

nless a specific date or dates is set forth in any spec ific question herein,

you are directed that each question shall be answered for the period of time up to and

including the present date.

9.

s used herein, the term lease or rental contract refers to the

document described in Part III of Plaintiff's Original Petition ( At all times relevant to

this pleading, Plaintiff was a tenant of Defendant pursuant to a lease entered into on or

about August 25, 2010 ).

10.

s used herein, the tern premises or premises made the basis of this

suit refers to , Dallas City Block 1262, Block 18 and Lot 5 & 6, also known as 917-921

Ann A venue, Dallas, Texas 75223.

PLAINTIFF 'S O RIGINAL PETITION & REQ UEST FOR DISCOVE RY

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INTERROGATORIES

1. If the responding defendant ever purchased the premises, please provide the following

information:

a:

the date on which the property was purchased by the defendant;

b. identify the seller from whom the defendant purchased the property;

c.

the purchase price of the property;

d. identify the source of financing for the purchase of the property, including

any federally assisted financing, or financing which involved federally

assisted insurance; including, but not limited to, FHA, VA or other federal

insurance;

e.

identify all parties or entities which were co-purchasers, with the,

defendant of the property;

f.

if the defendant no longer owns the property, state the date on which the

defendant ceased to be the owner of the property and describe the

circumstances under which the defendant ceased being the owner of the

property (e.g., sale, foreclosure, etc.).

ANSWER:

2. If the responding defendant acquired the premises in any manner other than by

purchase, please provide the following information:

a. the manner in which the defendant acquired an ownership interest in the

property;

b. the nature of the defendant s ownership interest in the property;

c. the dates on which the defendant s ownership interests commenced and

terminated;

d.

identify any party or entity that is or was a co-owner, with the defendant,

of the property, and the dates when that party or entity is or was a co-owner

with the defendant;

e.

the consideration given in exchange for such acquisition; and

f.

if the defendant no longer owns the property, state the date on which the

defendant ceased to be the owner of the property and describe the

circumstances under which each defendant ceased being the owner of the

property (e.g., sale, foreclosure, etc.).

ANSWER:

3. From the date the defendant executed an agreement to purchase the property through

the date the plaintiff vacated the premises, please identify whether the property

was inspected or appraised, including identifying whether any such inspections or

appraisals were conducted by the defendant or by anyone acting on the


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defendant's behalf? For the purpose of this interrogatory, inspected or appraised

shall be limited to inspections or appraisals which include condition of the

premises or general inspections so as to encompass the health and safety of the

tenants, but shall not include inspections or ap praisals of parts or the property or

equipment on the property which would not include the health and safety of the

tenants.

ANSWER:

4. If the answer to the p revious interrogatory is in the affirmative, please provide the

following information:

a.

identify the persons or entities who made such inspections;

b.

state the date or dates on which the property was inspected or appraised,

and identify each person who was present during each such inspection or

appraisal;

c.

state all reasons each such inspection or appraisal was performed;

d.

identify e ch written report or document which w s issued s result of

each such inspection or appraisal;

e. identify any instructions given by the defendant to the inspectors or

appraisers, and the date the instructions were given; and

E identify any instructions given by the insp ectors or appraisers to the

defendant, and the date the instructions were given.

ANSWER:

5. Through the date the plaintiff vacated the property, describe any and all construction,

repairs, rehabilitation, remodeling, or other improvements made to the property

by you o r on your behalf or on b ehalf of the defendant, and provide for each such

instance:

a.

the nature of the constructions, repair, rehabilitation, remodeling, or o ther

improvement (the activity );

b.

the approximate start and completion dates of each such activity;

c.

the name of the person or entity who completed each such activity;

d. the cost of each such activity;

e.

identify all contracts entered into for such activity; and

f.

identify any local, state, federal governm ent or other financial assistance

provided to assist in the completion of any such activity.

ANSWER:

6.

f the tenancy of the plaintiff was su bject to an oral or written lease; please

PLA INTIFF'S O RIGINAL PETITION & REQUEST FOR D ISCO VERY

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identify whether it was an oral or written lease, and describe each term of the

lease, including any m odifications or proposed m odifications..

ANSWER:

7.

lease identify all owners of the premises during the residency or tenancy of

the plaintiff, provide the dates each person owned the premises, and identify the

nature of each person's ownership interest..

ANSWER:

8. t any time during the defendant's ownership of the prem ises up until the date

the plaintiff vacated, did the defendant possess or obtain a certificate of apartment

occupancy from the municipality in which the property is situated? If so, please provide

the following information:

a.

the date on which each such certificate was obtained;

b. the name of the person and department w ho issued each such certificate;

c.

identify each such certificate or in the alternative provide a copy of each such

certificate.

ANSWER:

9.

dentify each owner of the prem ises from January 1, 2000 through the current date

and the means by which ownership was transferred.

ANSWER:

10.

dentify each and every partner of HMK, Ltd. since it s initial date of inception

through the present date, the dates from which the p artnership interest was acquired

through the date it wa s relinquished, sold or transferred and the buyer of the interest when

it was relinquished, sold or transferred.

ANSWER:

11.

dentify each and every employee of HM K Ltd. from January 1, 2010 through the

present date by name, address and telephone number. For each such employee,

please provide a job description as well as dates of employm ent.

PLAINTIFF'S ORIGINAL PETITION REQ UEST FOR DISCOVE RY

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ANSWER:

12. p to the date the plaintiff vacated the premises, did you ever inspect or have the

premises inspected for any structural or habitable conditions for financing

purposes or any other reason prior to or during the residency or tenancy of the

plaintiff, and, if so, please state when the inspection occurred, the identity of the

inspector, the purpose of the inspection and the conclusion or results.

ANSWER:

13.

oes the responding defendant employ or otherwise retain persons e.g., as

consultants) who manage and/or maintain the property owned by the defendant,

and if so, please identify, up to the date the plaintiff vacated:

a.

the names of the persons or entities in charge of managing each such

property and the dates they managed the property. Describe their

management responsibilities; and

b.

the names of the persons or entities in charge of maintaining each such

property and the dates they maintained the property. Describe their

maintenance responsibilities.

ANSWER:

14.

f any portion of the answer to the previous interrogatory is in the negative,

please describe the manner in which the responding defendant carried out the

management and/or maintenance of each such property, identifying:

a.

the names of the persons or entities in charge of managing each such

property, the dates they managed the property and their management

responsibilities; and

b.

the names of the persons or entities in charge of maintaining each such

property, the dates they maintained the property and their maintenance

responsibilities.

ANSWER:

15.

f the responding defendant was involved in the management of the property,

please provide the following information:


Pg. 20


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a.

the date on which the defendant first was involved in the managem ent of

the property;

b.

the name of all owners on w hose behalf the defendant acted as a property

manager for the property;

c.

he name of the person or entity by which the defendant was em ployed

while serving as the property manage r for the property; and

d.

the date on which the defendant first had contact with the plaintiff

concerning the property.

ANSWER:

16.

ow many mortgages has HMK Mortgage, LLC issued since it s inception in

2012? For each such mortgage, please identify the mortgagor by name, last known

address and last known phone number as w ell as the physical address of the property

subject to the mortgage and the am ount of the mortgage.

ANSWER:

17. How many mortgages has HMK Mortgage, LLC sold on the secondary market,

including, specifically and without limitation, any sold to Fannie Mae or Freddie

Mac? For each such mortgage, please identify the mortgagor by name, last

known ad dress and last known phone num ber, the purchaser of the m ortgage, as

well as the physical address of the property subject to the mortgage and the

amount of the sale mortgage.

ANSWER:

18. For each tenant that has vacated a rental unit since January 1, 2010, please state:

a. he am ount of the original security deposit paid by tenant;

b.

the amo unt of the original security deposit returned to tenant on m ove-out and;

c.

a full and final accounting of all security deposits or portions thereof that were

not returned to the tenant.

ANSWER:

19. State the name and street address of the bank where the security deposit of

Defendant s current tenants are presently on deposit, the name of the account, and the

account number at said bank.

ANSWER:

PLAINTIFF'S. ORIGINAL PETITION REQUE ST FOR DISCOVERY

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20.

dentify by name, last known address and last known telephone number, each and

every tenant of yours with whom you have entered into an agreement to reduce

rent in exchange for labor since January 1, 2010.

ANSWER:

21. For each person identified in the answer to interrogatory number 20, state the total

hours of maintenance work completed, the amount paid, or, in the alternative, the final

amount by which that tenant s rent was reduced for such services.

ANSWER:

22. State the total hours of labor completed by Plaintiff, including a complete accounting

of the amount you paid Plaintiff or, in the latemative, the final amount by which his rent

was reduced for such services.

ANSWER:

23. For each complaint as to any condition of any residential rental property since

January 1, 2010, please state:

a. whether the notice was received orally or in writing;

b.

where and to whom the notice was given; and

c.

what steps were taken to repair or remedy such conditions.

ANSWER:

24. For each residential rental property you have owned or acquired since January 1,

2010, please state the procedure by which you re-keyed and installed statutorily

compliant security devices.

ANSWER:

25. For each residential property you have acquired since January 1, 2010, please state

the procedure by which you ensure the residence does not endanger the health, safety, or

welfare of tenants on delivery to tenant.

ANSWER:


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26.

Did you, o r any a gent or representative receive any oral or written notices or requests

from Plaintiff alleging defects or violations of the Dallas City Code or items Plaintiff

requested to be repaired or remedied by Defendant? For each occurrence, provide the

date and time of each such notice/request/demand, a summ ary of each verbal demand, a

copy of each w ritten demand, and the name of the person receiving such notice on behalf

of Defendant.

ANSWER:

27.

W as Defendant aw are of the fact that the Plaintiff had complained to De fendant or

Defendant s representatives about the need for repairs to the apartment or the building of

which it is a part and/or to the City of Dallas?

ANSWER:

28.

If Defendant was aware of Plaintiff s complaint(s) to the City of Dallas, when did

Defendant first have such knowledge and how did such fact(s) come to the knowledge of

Defendant?

ANSWER:

29.

Is the Ann Street building now, or ha s it ever been, the subject matter of

administrative proceedings initiated by or under the auspices of the City of Dallas

Building Department or any o ther agency of the City of D allas alleging building code

violations?

ANSWER:

30.Are any of Defendant s properties now, or have they ever been, the subject matter of

administrative proceedings initiated by or under the auspices of the City of Dallas

Building Department or any o ther agency of the City of D allas alleging building code

violations?

ANSWER:

31.

State the names and positions of each person who made or participated in the

decision to terminate Plaintiff s tenancy.

PLAINTIFF'S ORIGINAL PETITION REQ UEST FOR DISCOVERY

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ANSWER:

32.

State the reason for the decision to terminate Plaintiff s tenancy.

ANSWER:

33.

If you claim that any conditions of disrepair were caused by Plaintiff, describe the

factual basis for this allegation with respect to each condition, including tile date the

condition w as caused, how Plaintiff caused the condition, and the information on w hich

you rely to form such conclusion.

ANSWER:

34. Please describe in detail facts concerning the existence of any rats in the Ann Street

building, including but not limited to your efforts to determine the prevalence of pests,

efforts to fumigate or remedy such prevalence, and any com plaints from other tenants on

your Ann Street property regarding the existence of pests of any kind.

35. Please describe in detail any and all repairs or maintenance performed to the Aim

Street building since your asserted acquisition, including any and all visits you made to

the property.

36. For each actual or alleged condition of disrepair, including those asserted by the city

of Dallas, state

a.

whether you agree that said condition of disrepair exists or has existed on the property

during the period of your ownership

b. the date and manner in which you first became aware of each condition, and

c.

the specific steps, if any, you have taken to address eac h such condition, including the

date and substance thereof, cost, and persons involved.

37. Identify and describe in detail any and all civil or criminal proceedings against you,

as w ell any proceedings regarding criminal activity that occurred on properties you own

or have acquired since January 1, 2000.

PLAINTIFF 'S OR IGINAL PETITION REQ UEST FOR DISCOV ERY

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VERIFIC TION

ST TE OF TEX S

COUNTY OF D LL S

BEFORE ME the undersigned authority personally appeared

who stated upon oath that the statements made in the

foregoing instrument are within his personal knowledge and are true and correct.

SUBSCRIBED ND SWORN TO BEFORE ME

on

y

Notary Public State of Texas


Pg. 25


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EXHIBIT B

PLAINTIFF'S FIRST REQUEST FOR PRODUCTIONS

DEFINITIONS AND INSTRUCTIONS

1

As used herein, the terms you and your shall mean the Defendant

named herein, and all attorneys, agents, and other natural persons or business or legal

entities acting or purporting to act for or on behalf of Defendant, whether authorized to

do so or not.

2. As used herein, the term incident ' or date of incident refers to the

events described as occurring on June 17, 2012 in Part III of Plaintiff's Original Petition.

3.

As used herein, the term documents shall mean all writings of every

kind, source and authorship, both originals and all non-identical copies thereof, in your

possession, custody, or control, or known by you to exist, irrespective of whether the

writing is one intended for or transm itted internally by you, or intended for or transmitted

to any other person o r entity, including without limitation any gov ernment agency,

department, adm inistrative, or private entity or person. The term shall include

handwritten, typewritten, printed, photocopied, photographic, or recorded m atter. It shall

include comm unications in words, symbols, pictures, sound recordings, films, tapes, and

information stored in, or accessible through, computer or other information storage or

retrieval systems, together with the code s and/or programm ing instructions and other

materials necessary to understand and use such system s. For purposes of illustration and

not limitation, the term shall include: affidavits; agendas; agreem ents; analyses;

announcem ents; bills, statements, and other records of obligations and ex penditures;

books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other

records of paym ents; charts or drawings; c heck registers; checkbooks; circulars; collateral

files and contents; contracts; corporate bylaws; co rporate charters; correspondence; credit

files and contents; deeds of trust; deposit slips; diaries or drafts; files; guaranty

agreements; instructions; invoices; ledgers, journals, balance sheets, profit and loss

statements, and other sources of financial data; letters; logs, notes, or mem oranda of

telephonic or face-to-face conversations; manuals; m emoranda of all kinds, to and from

any persons, agenc ies, or entities; minutes; minute book s; notes; notices; parts lists;

papers; press releases; printed m atter (including books, articles, speeches, and newspaper

clippings); purchase orders; records; records of administrative, technical, and financial

actions taken or recomm ended; reports; safety deposit boxes and contents and records of

entry; schedules; security agreements; specifications; statements of bank accounts;

statements or interviews; stock transfer ledgers; technical and engineering reports,

evaluations, advice, recomm endations, comm entaries, conclusions, studies, test plans,

manuals, procedures, data, reports, results, and conclusions; summ aries, notes, and other

records and recordings of any conferences, m eetings, visits, statements, interviews or

telephone conversations; telegrams; teletypes and other com munications sent or received;

transcripts of testimony; UC C instruments; w ork papers; and all other writings, the

PLAINTIFF'S OR IGINAL PETITION & R EQUES T FOR DISCOV ER Y

Pg. 26


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contents of which relate to, discuss, consider, or otherwise refer to the subject matter of

the particular discovery requested.

4.

In accordance with Tex. R. Civ. P. Rule 192.7, a document is deemed to

be in your possession, custody or control if you either have physical possession of the

item or have a right to possession of the item that is equal or superior to the person who

has physical control of the item.

5.

Person or persons means any natural persons, firms, partnerships,

associations, joint ventures, corporations and any other four of business organization or

arrangement, as well as governmental or quasi-governmental agencies. If other than a

natural person, include all natural persons associated with such entity..

6.

Any and all data or information which is in electronic or magnetic form

should be produced in a reasonable mariner.

7.

As used herein, the term lease or rental contract refers to the




8.

As used herein, the term premises or premises made the basis of this


Ann Avenue, Dallas, Texas 75223.

USE OF DEFINITIONS

The use of any particular gender in the plural or singular number of the words

defined under paragraph 1 , Definitions is intended to include the appropriate gender

or number as the text of any particular request for production of documents may require.

TIME PERIOD

Unless specifically stated in a request for production of documents, all

information herein requested is for the entire time period from June 17, 2000, through the

date of production of documents requested herein.


Pg. 27


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DOCUMENTS TO BE PRODUCED

1 All documents w hich mem orialize any agreements you made w ith Plaintiff related

to his tenancy at the prem ises, such as leases, rental contracts, rent payments,

receipts, and notices to Plaintiff from you in your capacity as landlord / lessor.

2. All photographs taken of the prem ises, the scene of the incident or the

surrounding area of the scene of the incident in the possession, constructive

possession, custody or control of Defendants, Defendants attorney or anyone

acting on Defendants behalf

3. All photographs taken of Plaintiff or the premises which m ay be in-the possession,

constructive possession, custody or control Defendants, Defendants attorney or

anyone acting on Defendants behalf.

4. All pictures, motion pictures, movies, films, or photographic m aterial of any kind

taken of Plaintiff or the premises w hich are in the po ssession, constructive


acting on Defendants behalf.

5.

All pictures, motion pictures, movies, films, or photographic m aterial of any kind

concerning the premises or the events and happenings m ade the basis of the

lawsuit taken before, during or after the incident in question which are in the

possession, constructive possession, custody or control of Defendants,

Defendants attorney or anyone acting on Defendants behalf.

6.

All w ritten statements m ade by the Plaintiff in the possession, constructive


acting on Defendants behalf.

7.

All oral statements made by Plaintiff which were either recorded or taped on an

electronic device or recorder w hich are in the possession, constructive possession,

custody or control of Defendants, Defendants attorney or anyone acting on

Defendants behalf.

8.

A copy of all documents filed with any state, county, city, federal or governmental

agency, institution or departm ent containing information about P laintiff or the

premises which are in the possession, constructive possession, custody or control of

Defendants, Defendants attorney or anyone acting on Defendants behalf.

PLAINTIFF 'S ORIGINAL PETITION REQ UEST FOR DISCOVER Y

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9

Any and all copies of investigation documentation, reports and/or memoranda

made by or submitted to Defendant, as a result of the incident which has been

made the basis of Plaintiffs lawsuit

10

Any and all written communications, including but not limited to letters and/or

memorandum s, between agents, employees and/or representatives of Defendant

that Defendant prepared as a result of the incident made the basis of Plaintiffs

lawsuit

11

All corporate records for HM K, Ltd.

12

All records reflecting your purchase and ownership of the promises.

13 All documents reflecting Code violations of any premises you have owned since

August 25, 2000.

14

Any and all receipts, invoices, contracts, and agreements for work performed in or

on the premises from January 1, 2005 through the present date.

15

All documents mem orializing comm unication between you and Rep. Eric Johnson

from January 1, 2010 through the present date.

16

All documents dem onstrating any contracts or agreements you have m ade with

any person or entity to provide extermination and / or fumigation services at any

property own ed by you since January 1, 2010.

17

All documents dem onstrating any contracts or agreements you have m ade with

any person or entity to provide repair services at any property owned by you since

January 1, 2010.

18 All documents dem onstrating any contracts or agreements you have m ade with

any person or entity to provide services at any property owned by you since

January 1, 2010.

19

All documents reflecting any commu nication between yo u and Dallas Central

Appraisal District regarding the premises at any time since June 1, 2000.

PLAINTIFF 'S ORIGINAL PETITION REQU EST FOR DISCOV ERY

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EXHIBIT C

PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS

DEFINITIONS AND INSTRUCTIONS

1 As used herein, the terms you and your shall refer to Defend ants,

Defendants' attorneys, agents, and all other natural persons or business or legal entities

acting or purporting to act for or on behalf of Defendants, whether authorized to do so or

not.

2.

Person : The term person shall include individuals, associations,

partnerships, corporations, and any other type of entity or institution whether formed for

business purposes or any other purposes.

3.

As used herein, the term incident or date of incident refers to the

events described as occurring on June 17, 2012 in Part III of Plaintiff's Original Petition.

4.

Unless a sp ecific date or dates is set forth in any specific question herein,

you are directed that each question shall be answered for the period of time from August

25, 2000 up to and including the present date.

5.

As used herein, the term lease or rental contract refers to the




6.

As used herein, the term premises or premises made the basis of this


Ann Avenue, Dallas, Texas 75223.

PLAINTIFF'S OR IGINAL PETITION & REQUEST FOR DISCOVERY

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REQUESTS FOR ADMISSION

Adm it on the date that on August 25, 2010 you owned more than one hundred

rental properties.

ADMIT OR DENY:

2.

Adm it that the lease did not comply with the Texas Property Code.

ADMIT OR DENY:

3.

Adm it that you had aw areness of your duties as a landlord / lessor under Texas

Property Code section 96 on August 25, 2010.

ADMIT OR DENY:

4.

Adm it that you had aw areness of your duties as a landlord / lessor under Texas

Property Code section 92 on A ugust 25, 2010.

ADMIT OR DENY:

5. Adm it that you charged Plaintiff a 200.00 deposit at the time he began his

tenancy of the premises in September 2010.

ADMIT OR DENY:

6.

Adm it that on August 25, 2010, you were aw are that under the Texas Property

Code you w ere not allowed to shift the responsibility for extermination of the

premises to Plaintiff.

ADMIT OR DENY:

7.

Adm it that in the lease you misrepresented to Plaintiff that you had no

responsibility to provide extermination of the premises and that it was his

responsibility.

ADMIT OR DENY:

8. Whe n Khraish H. K hraish has represented in court pleadings filed in Dallas

County e.g. Cause No. DC-14-09120 in the 298

t1 District Court) over the past


Pg. 31


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four years that h e, individually, is entitled to judicial relief as a result of a dispute

against Dallas Central Appraisal District with respect to the premises, he was

misrepresenting facts and making false allegations to a court of law.

ADMIT OR DENY:

9. When Hannah K hraish has represented in court pleadings filed in Dallas County

over the past four years (e.g. Cause No. D C-14-09120 in the 298

t District Court)

that he, individually, is entitled to judicial relief as a result of a dispute against

Dallas Central Appraisal District with respect to the premises, he was

misrepresenting facts and making false allegations to a court of law.

ADMIT OR DENY:

10.

Admit that in the past six years you have knowingly allow drug dealers to operate

out of a premises you own located at 4422 Canal Street, Dallas, Texas.

ADMIT OR DENY:

11.

Adm it that you filed a fraudulent affidavit in Cause No. CC-14-02577-D when

you represented that Khraish H. K hraish was not the owner of the premises on

the date of the incident m ade the basis of this suit.

ADMIT OR DENY:

12.

Admit that you have represented to the Dallas Central Appraisal District that

Khraish H. K hraish, individually, was the ow ner of the premises from June

2000 through April 25 2014.

ADMIT OR DENY:

13.

On August 25, 2010, y ou knew that it was illegal under the Texas Property Code

for you to attempt to place a burden on Plaintiff to provide for extermination

and / or fumigation for pests and rodents.

ADMIT OR DENY:

PLAINTIFF 'S ORIGINAL, PETITION REQU EST FOR DISCOVERY

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14.

Adm it that the language in the lease that illegally attempts to shift the burden to

tenants such as Plaintiff to fumigate...for rodents is fraudulent.

ADMIT OR DENY:

15.

Adm it that the language in the lease that illegally attempts to shift the burden to

tenants such as Plaintiff to fumigate...for rodents is to discourage tenants

such as Plaintiff from m aking any com plaints to you about rodents on the

premises.

ADMIT OR DENY:

16.Adm it that, upon receiving complaints from tenants of vermin, insects, rodents, or

other pests, you have not fumigated or taken remedial steps, on the grounds

that such actions are the responsibility of tenants pursuant to your lease

agreements.

ADMIT OR DENY:

17.

Adm it that you did not install and re-key statutorily compliant security devices in

- your residential rental units.

ADMIT OR DENY:

18. Adm it that you induced Plaintiff to enter into a lease agreement based on an

advertised $200 FIRST MONTH MOVE-IN SPECIAL

ADMIT OR DENY:

19.

Adm it that you actually required Plaintiff to pay a security deposit when he

entered into the lease agreement.

ADMIT OR DENY:

20.

Admit that you did not return Plaintiff's security deposit or an accounting for

the related expenses after he vacated the unit.

ADMIT OR DENY:

PLAINTIFF'S ORIGINAL PETITION REQU EST FOR DISC OVERY

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21. Admit that you habitually do not return tenants security deposits, or provide

an accounting for them.

ADMIT OR DENY:

22.

Admit that when Plaintiff presented himself at your office to complain of a toe

amputation because of your unsanitary premises, you told him that rats inside his

apaitment are not your problem.

ADMIT OR DENY:

ADMIT OR DENY:

Documents

Doc 1 Baez v Khraish Original Petition