Estes VS San Marcos Green Investors (Iconic Village) PDF

9/27/2018 1:39 PM
Velva L. Price
District Clerk
D-1-GN-18-005879 Travis County
NO. __________________ D-1-GN-18-005879
Ruben Tamez
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CHERYL ESTES AND TROY ESTES, § IN THE DISTRICT COURT OF
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INDIVIDUALLY AND ON BEHALF OF §
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THE ESTATE OF DRU ESTES, DECEASED §
§ 345TH
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V. § ________JUDICIAL DISTRICT
§
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SAN MARCOS GREEN INVESTORS, LLC, §
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ELEVATE MULTIFAMILY, LLC, §
DEBORAH JONES, AND §
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THOMAS STEUBING, JR. § TRAVIS COUNTY, TEXAS
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PLAINTIFFS’ ORIGINAL PETITION AND REQUEST FOR DISCLOSURE
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TO THE HONORABLE JUDGE OF SAID COURT:
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NOW COME CHERYL ESTES and TROY ESTES, INDIVIDUALLY and ON BEHALF
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OF THE ESTATE OF DRU ESTES, DECEASED, the Plaintiffs in the above-entitled and
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numbered cause (hereinafter called “Plaintiffs”), complaining of the Defendants SAN MARCOS
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GREEN INVESTORS, LLC, ELEVATE MULTIFAMILY, LLC, DEBORAH JONES, and

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THOMAS STEUBING, JR., the Defendants herein (hereinafter called “Defendants”), and for
cause of action would respectfully show unto the Court as follows:

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I.
DISCOVERY PLAN
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In accordance with Rule 190 of the TEXAS RULES OF CIVIL PROCEDURE, Plaintiffs intend
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to conduct the discovery of this case in accordance with Level 3.

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II.
PARTIES
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Plaintiffs CHERYL ESTES and TROY ESTES reside in San Antonio, Texas. Plaintiffs
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are the parents of DRU ESTES, DECEASED, and are the rightful heir-at-law to their son’s estate
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and therefore a member of the class of persons authorized by Tex. Civ. Prac. & Rem. Code §71.021
to initiate a survival cause of action on behalf of his estate.
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Defendant SAN MARCOS GREEN INVESTORS, LLC is a domestic limited liability
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company. Defendant has its principal place of business at 820 Davis St., Suite 420, Evanston, IL
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60201. Defendant may be served with citation by serving its registered agent, Registered Agent
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Solutions, Inc., 1701 Directors Blvd., Suite 300, Austin, TX 78744. Citation is requested at this
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time.
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Defendant ELEVATE MULTIFAMILY, LLC is a domestic limited liability company.
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Defendant has its principal place of business at 73 W. Monroe, Suite 507, Chicago, IL 60603.
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Defendant may be served with citation by serving its registered agent, Registered Agent Solutions,
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Inc., 1701 Directors Blvd., Suite 300, Austin, TX 78744. Citation is requested at this time.
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Defendant, DEBORAH JONES, is an individual and a resident of the State of Texas.
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Defendant may be served at her place of residence, 3306 Dolphin Dr., Apt. A, Austin, TX 78704
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or wherever she may be found. Citation is requested at this time.

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Defendant, THOMAS STEUBING, JR., is an individual and a resident of the State of

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Texas. Defendant may be served at his place of residence, 481 North Central Ave., New Braunfels,
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TX 78130 or wherever he may be found. Citation is requested at this time.

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III.
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JURISDICTION/VENUE
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The Court has jurisdiction in this case based on appropriate subject matter and based upon
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sufficient amount in controversy.

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Defendant DEBORAH JONES was a resident of Austin, Travis County, Texas at the time
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the cause of action accrued and, therefore, venue is proper in Travis County pursuant to the
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provisions of Section 15.002(a)(2) of the Texas Civil Practice and Remedies Code.
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IV.
FACTUAL BACKGROUND
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In the early morning hours of July 20, 2018, a fire broke out at the Iconic Village apartment
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complex located at 222 Ramsay Street in San Marcos, Texas. While the blaze spread though the
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apartment complex filling it with fire and smoke, the fire alarms in the complex failed to activate.
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DRU ESTES, who was 20 years old, resided at the Iconic Village apartment complex. Tragically,
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he and four other people died in the fire, and many others were injured.
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At all times relevant herein, the Iconic Village apartment complex was owned, operated
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and/or managed by Defendants SAN MARCOS GREEN INVESTORS, LLC, and ELEVATE
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MULTIFAMILY, LLC. Defendants DEBORAH JONES and THOMAS STEUBING, JR. were
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the apartment complex managers at the time of the incident.
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V.
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CAUSES OF ACTION
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A. NEGLIGENCE - ALL DEFENDANTS

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Plaintiffs believe and allege that Defendants owned, operated, and/or managed the Iconic
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Village apartment complex where Plaintiff DRU ESTES resided and tragically died. In owning,
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operating, and/or managing the Iconic Village apartment complex, Defendants owed Plaintiff
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DRU ESTES the duty to exercise that ordinary care that would be exercised by a reasonable and
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prudent property owner, manager, and landlord. Defendants committed acts and/or omissions,
which collectively and severally constituted negligence, which were a proximate cause of the
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injury and death of DRU ESTES. Defendants’ acts and/or omissions which constitute negligence
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include but are limited to the following

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1. Failing to provide and maintain a safe premise and living environment for the
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residents of the apartment complex.
2. Failing to adequately inspect and test the fire alarms in the apartments.
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3. Failing to provide a fire sprinkler system.
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4. Failing to provide a fire suppression system.
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5. Failing to provide a fire warning system.
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6. Failing to adequately inspect and test fire prevention or warning systems.
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7. Failing to promulgate and implement adequate safety protocols, policies, and
procedures.
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8. Failing to warn of the dangerous hazards at the apartment complex.
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9. Failing to provide sufficient safety equipment.
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10. Failing to follow applicable local and state rules and regulations in the operation
and maintenance of the apartment complex.
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Plaintiffs would show that each and all of the above and foregoing acts and/or omissions
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on the part of the Defendants herein constitute negligence, and each and all were a direct and
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proximate cause of the injury and death of DRU ESTES and damages suffered by the Plaintiffs
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herein.
B. PREMISES LIABILITY - ALL DEFENDANTS

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Plaintiffs believe and allege that Defendants owned, operated, and/or managed the Iconic
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Village apartment complex where Plaintiff DRU ESTES resided and tragically died. The
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condition of the area where Plaintiff was injured/died posed an unreasonable risk of harm, and
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Defendants had actual knowledge or reasonably should have known of the unreasonably dangerous
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condition.
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Because Plaintiff DRU ESTES was a resident of the Iconic Village apartment complex,
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Defendants had a duty to either warn Plaintiff of the unreasonably dangerous condition or make
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the unreasonably dangerous condition reasonably safe. Defendants failed to warn Plaintiff of this
known unreasonably dangerous condition and failed to make the unreasonably dangerous
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condition reasonably safe. Defendants’ failure was a direct and proximate cause of the injury and
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death of DRU ESTES and damages suffered by the Plaintiffs herein.
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C. GROSS NEGLIGENCE - ALL DEFENDANTS
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Defendants, acting by and through its employees, managers, representatives, and/or agents,
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committed acts and omissions which constituted gross negligence, which proximately caused the
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injury and death of DRU ESTES. Plaintiffs are therefore entitled to recover punitive damages.
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Each of the acts or omissions of the Defendants were more than momentary thoughtlessness,
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inadvertence, or errors of judgment. Such acts or omissions constituted such an entire want of care
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as to establish that the act or omission was a result of actual conscious indifference to the rights,
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safety and welfare of DRU ESTES, and the other residents, and constitutes gross negligence, as
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such terms is defined in Texas. This conduct when viewed objectively from this Defendants’
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standpoint at the time of the conduct, involved an extreme degree of risk, considering the
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probability and magnitude of the potential harm to others, and the Defendants was actually,
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subjectively aware of the risk involved, but nevertheless proceeded with conscious indifference to
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the rights, safety, or welfare of DRU ESTES, and the other residents. Defendants’ acts or
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omissions, collectively and severally, constituted gross negligence that proximately caused the
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injury and death of DRU ESTES. Plaintiffs therefore are entitled to recover judgment against the
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Defendants for exemplary damages for the acts and omissions set forth below:
1. Failing to provide and maintain a safe premise and living environment for the
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residents of the apartment complex.

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2. Failing to adequately inspect and test the fire alarms in the apartments.
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3. Failing to provide a fire sprinkler system.

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4. Failing to provide a fire suppression system.
5. Failing to provide a fire warning system.
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6. Failing to adequately inspect and test fire prevention or warning systems.
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7. Failing to promulgate and implement adequate safety protocols, policies, and
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procedures.
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8. Failing to warn of the dangerous hazards at the apartment complex.
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9. Failing to provide sufficient safety equipment.
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10. Failing to follow applicable local and state rules and regulations in the operation
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and maintenance of the apartment complex.
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Plaintiffs would show that each and all of the above and foregoing acts and/or omissions
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on the part of the Defendants herein constitute gross negligence, and each and all were a direct and
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proximate cause of the injury and death of DRU ESTES and the damages suffered by the Plaintiffs
herein. ct
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VI.
RESPONDEAT SUPERIOR
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Plaintiffs would show that the Defendant SAN MARCOS GREEN INVESTORS, LLC,
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acting by and through their employees, managers, representatives, agents, ostensible agents and/or
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agents by estoppel, including but not limited to DEBORAH JONES and THOMAS STEUBING,
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JR., committed certain acts and/or omissions constituting negligence and/or gross negligence as
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set forth above and, therefore, Defendant is liable to Plaintiffs under the doctrine of respondeat
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superior for the acts and/or omissions of its employees, managers, representatives, agents,
ostensible agents and/or agents by estoppel.

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Plaintiffs would show that the Defendant ELEVATE MULTIFAMILY, LLC, acting by
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and through their employees, managers, representatives, agents, ostensible agents and/or agents
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by estoppel, including but not limited to DEBORAH JONES and THOMAS STEUBING, JR.,
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committed certain acts and/or omissions constituting negligence and/or gross negligence as set
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forth above and, therefore, Defendant is liable to Plaintiffs under the doctrine of respondeat
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superior for the acts and/or omissions of its employees, managers, representatives, agents,
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ostensible agents and/or agents by estoppel.
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VII.
JOINT AND SEVERAL RESPONSIBILITY
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The negligence and/or gross negligence of the Defendants, as set forth above, operating
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separately and concurrently, were a proximate cause of the injury and death of DRU ESTES and
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the damages of the Plaintiffs, as more specifically set forth below. Accordingly, said Defendants
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are jointly and severally responsible for the injuries and damages sustained by the Plaintiffs herein.
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VIII.
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DAMAGEStri
As a direct and proximate result of the negligence and/or gross negligence of the
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Defendants herein, the deceased Plaintiff DRU ESTES was caused to suffer conscious physical
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pain and emotional pain, anguish, torment, and suffering prior to the time of his death, for which
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Plaintiffs CHERYL ESTES and TROY ESTES, ON BEHALF OF THE ESTATE OF DRU
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ESTES, DECEASED, seek recovery herein. Further, THE ESTATE OF DRU ESTES,
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DECEASED, has been caused to incur reasonable and necessary funeral and burial expenses, for
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which Plaintiffs CHERYL ESTES and TROY ESTES, ON BEHALF OF THE ESTATE OF DRU
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ESTES, DECEASED, seek recovery herein. Further Plaintiffs CHERYL ESTES and TROY
ESTES, ON BEHALF OF THE ESTATE OF DRU ESTES, DECEASED, also seek compensation
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for any other damages allowable to said Estate pursuant to Tex. Civ. Prac. & Remedies Code Ann.
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§71.021.
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Further, Plaintiffs would show that as a direct and proximate result of the negligence and/or
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gross negligence of the Defendants herein, Plaintiffs CHERYL ESTES and TROY ESTES,
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INDIVIDUALLY, have been caused to suffer the loss of care, maintenance, support, services,
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advice, counsel, and reasonable contributions of a pecuniary value due to the loss of their son,
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DRU ESTES, and in reasonable probability, they will continue to suffer the same in the future for
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which they seek recovery herein. Further, Plaintiffs CHERYL ESTES and TROY ESTES,
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INDIVIDUALLY, have been caused to suffer the loss of the positive benefits flowing from the
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love, comfort, companionship, and society due to the loss of their son, DRU ESTES, and in
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reasonable probability, they will continue to suffer the same in the future for which they seek
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recovery herein. Further, Plaintiffs CHERYL ESTES and TROY ESTES, INDIVIDUALLY, have
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been caused to suffer grief, sorrow, and mental pain and anguish due to the loss of their son, DRU
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ESTES, and in reasonable probability, they will continue to suffer the same in the future for which
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they seek recovery herein. Further, Plaintiffs CHERYL ESTES and TROY ESTES,
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INDIVIDUALLY, seek to recover for any other damages allowed by Tex. Civ. Prac. & Remedies
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Code Ann. §71.001, et seq.

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Plaintiffs believe they have been injured and damaged in a sum within the jurisdictional
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limits of this Court.

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IX.
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REQUEST FOR DISCLOSURE

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Under the Texas Rule of Civil Procedure 194, Defendants SAN MARCOS GREEN
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INVESTORS, LLC, ELEVATE MULTIFAMILY, LLC, DEBORAH JONES, and THOMAS

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STEUBING, JR., are requested to disclose within fifty (50) days of service of this request, the
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information or material described in Texas Rule of Civil Procedure 194.2(a) through (l).
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X.
PRAYER
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WHEREFORE, Plaintiffs pray for and demand a jury trial, and pray that the Defendants
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be cited to appear and answer herein, and that the Plaintiffs have and recover judgment of and
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from the Defendants, jointly and severally, for:
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a. Damages as set forth above;
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b. Prejudgment and post-judgment interest to the maximum extent allowed by
law;
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Attorney’s fees and expenses as allowed by law;
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c.
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d. Costs of court;
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e. Punitive/Exemplary Damages; and,
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f. Such other and further general and special, legal and equitable relief to
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which the Plaintiffs may be entitled.
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Respectfully submitted,
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LYONS & LYONS, P.C.

126 Villita St.
San Antonio, TX 78205
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Telephone: (210) 225-5251

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Telefax: (210) 225-6545

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By: /s/ Clem Lyons

Clem Lyons
Clem@lyonsandlyons.com
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State Bar No. 12742000

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Sean Lyons
Sean@lyonsandlyons.com
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LoAn K. Vo
LoAnVo@lyonsandlyons.com
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ATTORNEYS FOR PLAINTIFFS
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CIVIL CASE INFORMATION SHEET
CAUSE NUMBER (FOR CLERK USE ONLY): _______________________________ COURT (FOR CLERK USE ONLY): ______________________
STYLED ___________________________________________________________________________________________________
Cheryl Estes and Troy Estes, Individually and On Behalf of the Estate of Dru Estes, Dec'd v. San Marcos Green Investors, LLc, et al.
(e.g., John Smith v. All American Insurance Co; In re Mary Ann Jones; In the Matter of the Estate of George Jackson)
A civil case information sheet must be completed and submitted when an original petition or application is filed to initiate a new civil, family law, probate, or mental
health case or when a post-judgment petition for modification or motion for enforcement is filed in a family law case. The information should be the best available at
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the time of filing.
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1. Contact information for person completing case information sheet: Names of parties in case: Person or entity completing sheet is:
Attorney for Plaintiff/Petitioner
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Name: Email: Plaintiff(s)/Petitioner(s): Pro Se Plaintiff/Petitioner
Title IV-D Agency
LoAn Vo
_____________________________ LoAnVo@lyonsandlyons.com
____________________________ Cheryl Estes
_________________________________ Other: _________________________
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Address: Telephone: Troy Estes
_________________________________
Additional Parties in Child Support Case:
126 Villita St.
_____________________________ (210) 225-5251
____________________________
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Defendant(s)/Respondent(s): Custodial Parent:
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City/State/Zip: Fax: _________________________________
San Marcos Green Investors, LLC
_________________________________
San Antonio, TX 78205 (210) 225-6545
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_____________________________ ____________________________ Non-Custodial Parent:
Elevate Multifamily, LLC
_________________________________ _________________________________
Signature: State Bar No:
(See additional page)
_________________________________ Presumed Father:
24013692
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_____________________________ ____________________________ _________________________________
[Attach additional page as necessary to list all parties]
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2. Indicate case type, or identify the most important issue in the case (select only 1):
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Civil Family Law
Post-judgment Actions
Contract Injury or Damage Real Property Marriage Relationship (non-Title IV-D)
Debt/Contract Assault/Battery Eminent Domain/ Annulment Enforcement
Consumer/DTPA
Debt/Contract
Construction
Defamation
Condemnation
Partition
ct Declare Marriage Void
Divorce
Modification—Custody
Modification—Other
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Fraud/Misrepresentation Malpractice Quiet Title With Children Title IV-D
Other Debt/Contract: Accounting Trespass to Try Title No Children Enforcement/Modification
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____________________ Legal Other Property: Paternity
Foreclosure Medical ____________________ Reciprocals (UIFSA)
Home Equity—Expedited Other Professional
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Support Order
Other Foreclosure Liability:
Franchise _______________ Related to Criminal
Insurance Motor Vehicle Accident Matters Other Family Law Parent-Child Relationship
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Landlord/Tenant Premises Expunction Enforce Foreign Adoption/Adoption with

Non-Competition Product Liability Judgment Nisi Judgment Termination
Partnership Asbestos/Silica Non-Disclosure Habeas Corpus Child Protection
Other Contract: Other Product Liability Seizure/Forfeiture Name Change Child Support
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______________________ List Product: Writ of Habeas Corpus— Protective Order Custody or Visitation
_________________ Pre-indictment Removal of Disabilities Gestational Parenting
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Other Injury or Damage: Other: _______________ of Minority Grandparent Access

_________________ Other: Parentage/Paternity
__________________ Termination of Parental
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Employment Other Civil  Rights

Other Parent-Child:
Discrimination Administrative Appeal Lawyer Discipline _____________________
Retaliation Antitrust/Unfair Perpetuate Testimony
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Termination Competition Securities/Stock

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Workers’ Compensation Code Violations Tortious Interference

Other Employment: Foreign Judgment Other: _______________
______________________ Intellectual Property
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Tax Probate & Mental Health

Tax Appraisal Probate/Wills/Intestate Administration Guardianship—Adult
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Tax Delinquency Dependent Administration Guardianship—Minor

Other Tax Independent Administration Mental Health
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Other Estate Proceedings  Other: ____________________

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3. Indicate procedure or remedy, if applicable (may select more than 1):

Appeal from Municipal or Justice Court Declaratory Judgment Prejudgment Remedy
Arbitration-related Garnishment Protective Order
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Attachment Interpleader Receiver

Bill of Review License Sequestration
Certiorari Mandamus Temporary Restraining Order/Injunction
Class Action Post-judgment Turnover
4. Indicate damages sought (do not select if it is a family law case):
Less than $100,000, including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney fees
Less than $100,000 and non-monetary relief
Over $100, 000 but not more than $200,000
Over $200,000 but not more than $1,000,000
Over $1,000,000
NO. __________________
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CHERYL ESTES AND TROY ESTES, § IN THE DISTRICT COURT OF
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INDIVIDUALLY AND ON BEHALF §
OF THE ESTATE OF DRU ESTES, §
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DECEASED §
§ ________JUDICIAL DISTRICT
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V. §
§
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SAN MARCOS GREEN INVESTORS, §
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LLC, ELEVATE MULTIFAMILY, §
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LLC, DEBORAH JONES, AND § TRAVIS COUNTY, TEXAS
THOMAS STEUBING, JR.
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CIVIL CASE INFORMATION SHEET (CONTINUE)
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Defendant(s)/Respondent(s):
Deborah Jones ct
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Thomas Steubing, Jr.
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SERVICE REQUEST FORM
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VELVA L. PRICE
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District Clerk, Travis County
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Civil Division (512) 854-9457
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REQUESTED BY:
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ATTORNEY/FILER: LoAn Vo SUBMITTED BY: LoAn Vo
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PHONE #: (210) 225-5251 TITLE: Attorney
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EMAIL: LoAnVo@lyonsandlyons.com SIGNATURE:
ISSUE PROCESS FOR:
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CAUSE #: CASE STYLE: Cheryl Estes and Troy Estes, et al v. San Marcos Green Investors, LLC, et al
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QUICK CITATION REQUEST: (FOR SERVICE OF CITATION ON ALL DEFENDANTS BY PERSONAL
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ISSUE CITATION TO ALL DEFENDANTS LISTED IN THE ORIGINAL PETITION AT THE ADDRESS SPECIFIED IN THE PETITION AND FORWARD THE CITATION(S) TO THE FOLLOWING:
☐TRAVIS CO. CONSTABLE (specify): ☐CERTIFIED MAIL BY CLERK ☐ATTORNEY/REQUESTER

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☐PRIVATE PROCESS AGENCY (specify): ☐I HAVE INCLUDED ATTACHMENTS TO THIS REQUEST (e.g. DISCOVERY) TO INCLUDE
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DETAILED SERVICE REQUEST: (ON PARTICULAR PARTIES, BY VARIOUS DELIVERY METHODS, OR FOR NON-CITATION
PROCESS)
DESRIPTION OF INSTRUMENT(S) TO BE SERVED:
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☐I HAVE INCLUDED ATTACHMENTS TO THIS REQUEST (e.g. discovery) TO INCLUDE IN THE CITATION
TYPE OF PROCESS TO ☐CITATION ☐CERTIFIED NOTICE ☐PROTECTIVE ORDER* ☐TRO*^ ☐INJUNCTION*^ ☐SEQUESTRATION*^
ISSUE: ☐ATTACHMENT* ☐EXECUTION* ☐ABSTRACT* ☐SUPERSEDEAS^ ☐SCIRE FACIAS* ☐OTHER^
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*SPECIFY TITLE AND DATE OF UNDERLYING ORDER IN CASE RECORD: ^ATTACH A COPY OF BOND AND/OR OTHER SUPPORTING
DOCUMENT
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SERVICE TO BE ISSUED:
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PARTY NAME: EMAIL PROCESS TO: SERVE VIA:

☐TRAVIS CO. CONSTABLE ☐PERSONAL SERVICE
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PARTY TYPE: ☐ATTORNEY/REQUESTOR ☐CERTIFIED MAIL (BY CONSTABLE)

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☐PRIVATE PROCESS AGENCY: ☐CERTIFIED MAIL (BY CLERK)

☐USE ADDRESS IN ORIGINAL PETITION ☐SECRETARY OF STATE Process Agency Name: ☐CITATION BY POSTING*
☐OTHER ADDRESS: ☐CITATION BY PUBLICATION*
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*THIS TYPE OF SERVICE MAY REQUIRE A COURT ORDER. ENTER DATE OF SERVICE ORDER IN CASE RECORD:
ADDITIONAL INSTRUCTIONS FOR CLERK OR FOR OFFICER SERVING PROCESS:
FOR ADDITIONAL PARTIES TO BE SERVED, USE e-FILED PROCESS ISSUANCE REQUEST FORM ADDENDUM
AMALIA
Velva L.RODRIGUEZ-MENDOZA
Price
DistrictCOUNY
TRAVIS Clerk, Travis County
DISTRICT CLERK SERVICE REQUEST FORM
Civil DIVISION
CIVIL Division (512) 854-9457
(512) 854-9457
Cause #: Case Style:

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☐OTHER ADDRESS:
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☐CITATION BY PUBLICATION*
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*This Type of Service may require a court order. Enter date of service order in case record:

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9/27/2018 1:39 PM

GREEN INVESTORS, LLC, ELEVATE MULTIFAMILY, LLC, DEBORAH JONES, and

cause of action would respectfully show unto the Court as follows:

to conduct the discovery of this case in accordance with Level 3.

to initiate a survival cause of action on behalf of his estate.

or wherever she may be found. Citation is requested at this time.

Defendant, THOMAS STEUBING, JR., is an individual and a resident of the State of

TX 78130 or wherever he may be found. Citation is requested at this time.

sufficient amount in controversy.

A. NEGLIGENCE - ALL DEFENDANTS

include but are limited to the following

residents of the apartment complex.

B. PREMISES LIABILITY - ALL DEFENDANTS

residents of the apartment complex.

3. Failing to provide a fire sprinkler system.

4. Failing to provide a fire suppression system.

5. Failing to provide a fire warning system.

ostensible agents and/or agents by estoppel.

Code Ann. §71.001, et seq.

limits of this Court.

REQUEST FOR DISCLOSURE

INVESTORS, LLC, ELEVATE MULTIFAMILY, LLC, DEBORAH JONES, and THOMAS

LYONS & LYONS, P.C.

Telephone: (210) 225-5251

Telefax: (210) 225-6545

By: /s/ Clem Lyons

State Bar No. 12742000

State Bar No. 00792280

State Bar No. 24013692

Landlord/Tenant Premises Expunction Enforce Foreign Adoption/Adoption with

Other Injury or Damage: Other: _______________ of Minority Grandparent Access

Employment Other Civil  Rights

Termination Competition Securities/Stock

Workers’ Compensation Code Violations Tortious Interference

Tax Probate & Mental Health

Tax Delinquency Dependent Administration Guardianship—Minor

Other Estate Proceedings  Other: ____________________

3. Indicate procedure or remedy, if applicable (may select more than 1):

Attachment Interpleader Receiver

ISSUE PROCESS FOR:

☐TRAVIS CO. CONSTABLE (specify): ☐CERTIFIED MAIL BY CLERK ☐ATTORNEY/REQUESTER

PARTY NAME: EMAIL PROCESS TO: SERVE VIA:

PARTY TYPE: ☐ATTORNEY/REQUESTOR ☐CERTIFIED MAIL (BY CONSTABLE)

☐PRIVATE PROCESS AGENCY: ☐CERTIFIED MAIL (BY CLERK)

PARTY NAME: EMAIL PROCESS TO: SERVE VIA:

PARTY TYPE: ☐ATTORNEY/REQUESTOR ☐CERTIFIED MAIL (BY CONSTABLE)

☐TRAVIS CO. CONSTABLE ☐PERSONAL SERVICE

☐PRIVATE PROCESS AGENCY: ☐CERTIFIED MAIL (BY CLERK)

Cause #: Case Style:

PARTY NAME: EMAIL PROCESS TO: SERVE VIA:

☐PRIVATE PROCESS AGENCY: ☐CERTIFIED MAIL (BY CLERK)

PARTY NAME: EMAIL PROCESS TO: SERVE VIA:

PARTY TYPE: ☐ATTORNEY/REQUESTOR ☐CERTIFIED MAIL (BY CONSTABLE)

☐OTHER ADDRESS: ☐CITATION BY PUBLICATION*

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