Fourth Amendment To Plaintiffs Petition Essay

1029 words - 5 pages

CAUSE NO. CV41C0220396
-------------------------------------------x §
JENNIFER MCFALL, Plaintiff(s) §
VS. §
Defendant(s) §
-------------------------------------------x § HARRIS COUNTY, TEXAS


The PLAINTIFF, Jennifer McFall, moves the court to amend her Original Petition in accordance to the Texas Rules of Civil Procedure - RULE 63. Amendments and Responsive Pleadings.

The Plaintiff demands to incorporate Defendant, SKYE BANEGAS into the civil ...view middle of the document...

3) The Plaintiff’s vehicle was sold by the Defendant(s), to be found in contempt of court, after both Defendants were being given strict instructions by the Honorable Judge Goodwin - not to sell, move, or alter the vehicle in any way shape or form, due to being involved in a civil suit.
4) On April 20, 2015 the Plaintiff received a Certified Title History from the Texas Department of Motor Vehicles for the following Vehicle:
VIN# 1YVHP80C855M04160

5) The Defendant(s) committed Civil Theft by Conversion, utilizing a Government Agency - Texas Department of Motor Vehicles, and transferred title into the name: MATTHEW NICOLAS MACIAS, on March 10, 2015, while the Plaintiff/Owner was pending a civil suit in Precinct 4 Place 1 court.
6) The vehicle value in the Kelley Blue Book, retrieved May 9, 2016, is a value worth $4,252.00.

a) EXHIBIT “B” - Loss Wages
1) The Plaintiff acquires a weekly salary of $1,192.31 ($238.46 Daily), and lost a total of Nine (9) days of work, for case settings in the Honorable Judge Goodwin’s Chambers, Precinct 4 Place 1, False Imprisonment at the Harris County Jail, criminal case settings in Harris County Court at Law No. 3, and bail bond settings following thereafter for the following dates:
a) March 03, 2015,
b) April 15, 2015,
c) April 22, 2015,
d) May 04, 2015,
e) May 5, 2015,
f) July 16, 2015
g) July 30, 2015
h) August 03, 2015
i) September 4, 2015
2) The Plaintiff suffered an immense hardship in the form of compensatory damages for lost wages in the amount of $2,146.14.
a) EXHIBIT “C” – Court Costs
1) The Plaintiff paid court costs for an Abstract Judgement in the amount of $5.00 and Writ of attachment in the amount of $130.00, requesting further compensatory damages for court costs in the amount of $135.00.

b) EXHIBIT “D” – Rental Car Costs
1) The Plaintiff exhausted the resource of paying for a rental car during the length of the case from December 18, 2014 until May 05, 2015, in the amount of $1,812.29.

c) EXHIBIT “E” – Mailing Costs
1) The Plaintiff accrued Mailing expense in the amount of $207.03.

d) EXHIBIT “F” – False...

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