`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 1 of 8 PageID 1Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 1 of 8 PageID 1
`
`
`
`In the United States District Court
`Northern District of Texas
`Amarillo Division
`
`
`Vu Le and Julie Thi Le, Individually, and
`Thuy Van Le, Individually and
`as Representatives of the Estate of
`Camha Thi Vu, Deceased
`
`Vs.
`
`Tyson Foods, Inc.
`
`§
`
`§
`
`§
`§
`§
`§
`§
`§
`
`Action No. _________________
`
`PLAINTIFFS’ ORIGINAL COMPLAINT
`
`Vu Le and Julie Thi Le, Individually, and Thuy Van Le, Individually and as Representatives
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`of the Estate of Camha Thi Vu, Deceased, Plaintiffs, set forth their Complaint for damages against
`
`
`
`
`
`Tyson Foods, Inc., Defendant, and for cause of action would show as follows:
`
`1. Parties
`
`Plaintiff, Thuy Van Le, is a resident and citizen of the State of Texas.
`
`Plaintiff, Vu Le, is a resident and citizen of the State of Texas.
`
`Julie Thi Le, is a resident and citizen of the State of Texas.
`
`1.1
`
`1.2
`
`1.3
`
`1.4
`
`Defendant, Tyson Foods, Inc., (“Tyson”) is a company doing business in the State
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`of Texas and may be served by process by serving its registered agent, CT Corporation System, 1999
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Bryan St., Suite 900, Dallas, Texas 75201-3136. Citation is requested herein. Tyson is a company
`
`
`
`
`
`
`
`2.
`
`2.1
`
`incorporated under the laws of Delaware with a principal place of business in Arkansas.
`
`Jurisdiction and Venue
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Jurisdiction of this Court is invoked pursuant to 28 U.S.C. § 1332. The Plaintiffs and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Defendant are citizens of different states and Plaintiffs seek damages in an amount that exceeds the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 1
`
`
`
`
`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 2 of 8 PageID 2Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 2 of 8 PageID 2
`
`sum or value of $75,000 exclusive of interest and costs.
`
`2.2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Personal jurisdiction and venue are proper because the cause of action accrued and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`the negligent acts occurred within the Northern District of Texas, specifically within its Amarillo
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Division. Furthermore, Tyson has a significant presence within the Northern District of Texas as it
`
`
`
`
`
`
`
`has facilities located in the area.
`
`2.3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiffs are entitled to bring a wrongful death action pursuant to Tex. Civ. Prac. &
`
`
`
`
`
`
`
`
`
`Rem. § 71.004. The family members’ relationships to the decedent are as follows:
`
`Thuy Van Le
`
`Vu Le
`
`Julie Thi Le
`
`Husband of Camha Thi Vu
`
`Child of Camha Thi Vu
`
`Child of Camha Thi Vu
`
`2.4
`
`
`
`
`
`
`
`
`
`Additionally, a survival action is brought herein by Thuy Van Le, in his capacity as
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Representative of the Estate of Camha Thi Vu, Deceased.
`
`3.
`
`Background
`
`
`
`
`
`
`
`3.1
`
`
`
`
`
`
`
`
`
`
`
`Ms. Vu worked as a meat cutter at the Tyson meatpacking plant located at 5000 FM
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1912, Amarillo, Texas 79108. The city of Amarillo issued a stay-at-home order effective April 1,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1
`2
`
`
`
`
`
`
`
`2020. Similarly, Governor Abbott issued a stay-at-home order which took effect on April 2, 2020.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`After working long hours at Tyson, Ms. Vu fell ill and was rushed to the hospital after she started
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`having difficulty breathing. Ms. Vu was admitted on or about April 28, 2020 with COVID-19
`
`symptoms, which later proved to be fatal. Ms. Vu died on May 11, 2020.
`
`3.2
`
`This
`
`
`
`
`
`
`
`
`
`
`
`illness occurred during the COVID-19 pandemic. COVID-19 infected
`
`
`
`
`
`
`
`
`
`1 Amarillo Globe News, https://www.amarillo.com/news/20200330/city-of-amarillo-issues-stay-at-home-order (last
`visited May 21, 2020).
`2 Texas Tribute, https://www.texastribune.org/2020/03/31/greg-abbott-texas-executive-order-closures/ (last visited
`May 21, 2020).
`
`Page 2
`
`
`
`
`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 3 of 8 PageID 3Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 3 of 8 PageID 3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`numerous workers at the Tyson Beef Plant in Amarillo, where Ms. Vu worked. Ms. Vu was
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`required to continue to work during the coronavirus pandemic. Ms. Vu was not provided
`
`
`
`
`
`
`
`
`
`
`
`appropriate personal protective equipment (“PPE”) to protect her from coronavirus.
`
`3.3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiffs would show that nothing that Camha Thi Vu did or failed to do on the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`occasion in question caused or contributed to cause the occurrence. To the contrary, the injuries
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`and death of Ms. Vu were proximately caused by the negligence, both of commission and omission,
`
`of Tyson. Tyson’s negligence caused Ms. Vu to contract COVID-19 and die.
`
`3.4
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Upon information and belief, at least 4,500 Tyson employees have contracted
`
`
`
`
`
`3
`
`
`
`
`
`
`
`
`
`
`
`COVID-19, and at least 18 have died. A grossly disproportionate number of Tyson employees
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`have contracted COVID-19, and have died, when compared to the population as a whole. Tyson
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`does not provide workers compensation insurance to its employees, nor does it provide them with
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`any sick paid leave. Rather, Tyson institutes a rigged “injury settlement” program under which the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`deck is stacked against its employees. The thousands of Tyson employees who have been injured on
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`the job over the years know this rigged program as “WISP,” which stands for “Workplace Injury
`
`
`
`
`
`Settlement Program.”
`
`3.5
`
`
`
`
`
`Tyson was grossly negligent and acted with malice, as that term is understood under
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Texas law, and such conduct was a proximate cause of the injuries and death of Ms. Vu. Tyson’s
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`malicious and grossly negligent conduct justifies the imposition of punitive and exemplary damages
`
`both as punishment of Tyson and its callous disregard for the safety of individuals such as Ms.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Camha Thi Vu. Plaintiffs therefore ask for punitive and exemplary damages in addition to actual
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`damages.
`
`3 Business Insider,
`https://www.businessinsider.com/tyson-4500-covid-19-cases-as-meat-industry-blames-workers-2020-5 (last visited May
`14, 2020).
`
`Page 3
`
`
`
`
`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 4 of 8 PageID 4Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 4 of 8 PageID 4
`
`3.6
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff, Thuy Van Le has also suffered pecuniary loss from the death of his wife,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Camha Thi Vu. Decedent provided her husband with care, attention, and counsel. In all reasonable
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`probability, decedent would have continued to provide for her husband until death. Thuy Van Le
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`seeks to recover a sum of money that would fairly and reasonably compensate him for the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`termination of the husband-wife relationship, including the loss of the love, companionship and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`society that he would have received from his wife had she lived. Plaintiff, Thuy Van Le also seeks
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`compensation for the mental anguish, emotional pain, torment and suffering that he has suffered,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`and in reasonable probability will continue to suffer in connection with the wrongful death of
`
`Camha Thi Vu.
`
`3.7
`
`Vu Le and Julie Thi Le have suffered pecuniary loss from the death of their mother,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`including losses of care, maintenance, support, services, advice, counsel, and contributions of a
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`pecuniary value that they would, in reasonable probability, have received from their mother during
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`her lifetime had he lived. They have suffered additional losses by virtue of the destruction of the
`
`
`
`
`
`
`
`
`
`parent-child relationship,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`including the right to love, affection, solace, comfort, companionship,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`society, emotional support, and happiness. They have suffered mental anguish, grief, and sorrow as
`
`
`
`
`
`
`
`a result of the death of their mother, and are likely to continue to suffer for a long time in the future.
`
`
`
`
`
`
`
`
`
`
`
`
`
`Additionally, a survival action is brought herein by Thuy Van Le, in his capacity as
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3.8
`
`and suffering.
`
`3.9
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Representative of the Estate of Camha Thi Vu, Deceased, including claims for medical bills and pain
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Thuy Van Le, Vu Le and Julie Thi Le were present when Ms. Vu suffered from
`
`
`
`
`
`
`
`
`
`
`
`
`
`COVID-19 symptoms and death and they were in shock as a result of direct emotional impact from
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`perceiving the death of Ms. Vu as it happened. Accordingly, Plaintiffs are entitled to recover
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 4
`
`
`
`
`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 5 of 8 PageID 5Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 5 of 8 PageID 5
`
`mental-anguish damages as a bystander to the death of Ms. Camha Thi Vu.
`
`3.10
`
`Tyson was not a subscriber to a policy of workers compensation insurance, and thus
`
`Plaintiff brings this suit for damages under the provisions of Section 406.033 of the Texas Labor
`
`Code for personal injuries while in the course and scope of her employment with Defendant.
`
`3.11 Tyson, as a non-subscriber under the Texas Workers' Compensation Act, and
`
`pursuant to Section 406.033 of the Texas Labor Code, has lost its common law defenses of:
`
`a.
`
`b.
`
`c.
`
`contributory negligence of Plaintiff;
`
`that the death was caused by the negligence of a fellow employee; and/or
`
`that the Plaintiff assumed the risk of the illness incident to her employment.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3.12 Furthermore, Tyson was the owner of the premises where the incident occurred or
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`otherwise was in control of the premises located at 5000 FM 1912. Ms. Vu was its invitee at the
`
`
`
`
`
`
`
`
`
`time the illness occurred. The plaintiff went on defendant’s premises for the mutual benefit of
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`herself and the defendant, upon the invitation of employment at the premises in question.
`
`4.
`
`Employer Negligence
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`4.1
`
`
`
`
`
`
`
`
`
`On the occasion in question, Tyson owed Ms. Vu a duty of care commensurate with
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`its relationship to her as her employer. As her employer, Tyson owed Ms. Vu a duty to use ordinary
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`care in providing a safe workplace, hiring competent co-employees, providing needed safety
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`equipment or assistance, warning Ms. Vu of the hazards of her employment, and providing training
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`and supervision.
`
`4.2 Ms. Vu died as a proximate result of of Tyson’s negligence and gross negligence
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`because Tyson and/or its employees negligently:
`
`a. failed to provide a safe workplace;
`
`Page 5
`
`
`
`
`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 6 of 8 PageID 6Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 6 of 8 PageID 6
`
`b. failed to protect employees against coronavirus;
`
`c. failed to hire competent co-employees;
`
`d. failed to supervise its employees;
`
`e. failed to properly train employees on safety protocols; and
`
`f. failed to properly supervise employees on a regular basis and under pandemic
`
`conditions.
`
`4.3
`
`Tyson’s breach of its duty to use ordinary care constituted negligence and was a
`
`proximate cause of Ms. Vu’s injuries and death.
`
`Premises Liability
`
`5.
`
`5.1
`
`
`
`
`
`
`
`
`
`Additionally, as the premises owner, Tyson owed Ms. Vu (its invitee) the duty to
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`exercise ordinary care to keep the premises in a reasonably safe condition, inspect the premises to
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`discover latent defects, and make safe any defects or give an adequate warning.
`
`5.2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Tyson’s conduct, and that of its agents, servants, and employees, acting within the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`scope of their employment, constituted a breach of the duty of ordinary care owed by Tyson to Ms.
`
`
`
`
`
`Vu.
`
`5.3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Tyson knew or should have known that the condition on its premises created an
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`unreasonable risk of harm to invitees because Tyson knew of the rampant spread of COVID-19
`
`
`
`throughout its facility.
`
`5.4
`
`
`
`
`
`
`
`
`
`
`
`
`
`Tyson failed to exercise ordinary care to reduce or eliminate this risk by exposing
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`employees to coronavirus and failing to maintain its premises in a reasonably safe condition, by
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`failing to institute proper safety precaution to protect employees from the spread of COVID-19.
`
`5.5
`
`Each of these acts and omissions, whether taken singularly or in any combination,
`
`Page 6
`
`
`
`
`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 7 of 8 PageID 7Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 7 of 8 PageID 7
`
`was a proximate cause of the occurrence described above and of the plaintiff’s injuries and damages
`
`described below.
`
`6.
`
`Punitive/Exemplary Damages
`
`
`
`
`
`
`
`
`
`
`
`6.1 Ms. Vu adopts and incorporates by reference the preceding Paragraphs 1 through 5.5
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`as if fully stated within this section.
`
`6.2
`
`Tyson was grossly negligent, as that term is understood under Texas law, and such
`
`conduct was a proximate cause of Ms. Vu’s injuries and death. Tyson’s grossly negligent conduct
`
`justifies the imposition of punitive and exemplary damages both as punishment of Tyson and its
`
`callous disregard for the safety of individuals such as Ms. Vu, and to deter Tyosn’s ongoing actions
`
`as well as other companies from engaging in similar conduct.
`
`6.3
`
`Plaintiff therefore asks for punitive and exemplary damages in addition to all actual
`
`Pre- and Post-Judgment Interest
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiffs would additionally show that they are entitled to recovery of pre- and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`damages.
`
`7.
`
`7.1
`
`
`
`post-judgment interest in accordance with law and equity as part of their damages herein, and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiffs here and now sue for recovery of pre- and post-judgment interest as provided by law and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`equity, under the applicable provisions of the laws of the State of Texas.
`
` Jury Demand
`
`Plaintiffs hereby request a trial by jury.
`
`Conclusion and Prayer
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiffs request that Defendants be cited to appear and answer, and that on final
`
`
`
`
`
`8.
`
`8.1
`
`9.
`
`9.1
`
`trial Plaintiffs have: (1) judgment against Defendants, for actual, compensatory and exemplary
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 7
`
`
`
`
`
`Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 8 of 8 PageID 8Case 2:20-cv-00131-Z Document 1 Filed 05/21/20 Page 8 of 8 PageID 8
`
`
`
`
`
`
`
`
`
`
`
`damages in accordance with the evidence; (2) pre-judgment and post-judgment interest as provided
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`by law; (3) costs of court; (4) attorney's fees; and (5) such other and further relief, general and
`
`
`
`
`
`
`
`
`
`
`
`
`
`special, to which Plaintiffs may show themselves justly entitled at law and in equity.
`
`Respectfully submitted,
`
`VB Attorneys
`
`/s/ Vuk S. Vujasinovic
`Vuk S. Vujasinovic
`SBN: 00794800
`Vuk@vbattorneys.com
`Job Tennant
`SBN: 24106501
`Job@vbattorneys.com
`6363 Woodway, Suite 400
`Houston, Texas 77056
`713.224.7800
`713.224.7801 Fax
`Admin E-copy to Liza@vbattorneys.com
`Attorneys for Plaintiffs, Vu Le and Julie Thi Le,
`Individually, and Thuy Van Le, Individually and as
`Rep. of the Estate of Camha Thi Vu, Deceased,
`
`Page 8
`
`