SALUM RESTAURANT LTD d/b/a
`SALUM RESTAURANT,
`
` Plaintiff,
`
` v.
`
`THE TRAVELERS INDEMNITY
`COMPANY,
`
` Defendant
`
`
`
`
`Civil Action No. 3:20-cv-01034
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`COMPLAINT AND JURY
`DEMAND
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`Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 1 of 16 PageID 1Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 1 of 16 PageID 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
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`
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`PLAINTIFF’S ORIGINAL COMPLAINT
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`INTRODUCTION
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`I.
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`1.
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`Plaintiff, Salum Restaurant Ltd. d/b/a Salum Restaurant (“Salum”), files this
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`complaint against Defendant, The Travelers Indemnity Company (“Travelers”), for its denial of
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`benefits for the business interruption sustained by Salum as a result of the “Stay Home Stay Safe”
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`orders issued by Dallas County and the City of Dallas. These orders prohibited all dine-in services
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`at restaurants in the County and within the City’s limits, and Salum’s business is offering dine-in
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`fine dining experiences and catering services for formal events. Despite the extensive interruption
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`of Salum’s business, Travelers summarily denied its claim while the “Stay Home Stay Safe” order
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`was still in place.
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`II.
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`PARTIES
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`2.
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`Plaintiff, Salum Restaurant Ltd. d/b/a Salum Restaurant (“Salum”), is a limited
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`partnership organized under the laws of Texas with its principal place of business at 4152 Cole
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`Avenue, Texas 75204, Dallas County, Texas. Plaintiff Salum is authorized to do business in the
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`State of Texas.
`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`PAGE 1 OF 16
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`3.
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`Defendant, The Travelers Indemnity Company, is a corporation organized under
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`the laws of Connecticut, with its principal place of business at One Tower Square, Hartford,
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`Connecticut 06183. Citation may be served through its registered agent for service of process at
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`Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company, 211 East 7th
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`Street, Suite 620, Austin, Texas 78701-3218, Travis County, Texas.
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`4.
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`At all times herein, Defendant acted by and through its duly authorized agents and
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`servants, each acting within the course and scope of his or her employment.
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`III.
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`JURISDICTION AND VENUE
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`5.
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`Venue is proper in the Northern District of Texas pursuant 28 U.S.C.A. § 1391
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`because a substantial part of the events or omissions giving rise to the claim occurred in the
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`Northern District of Texas and the insured premises that is the subject of the action is situated in
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`the Northern District of Texas.
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`6.
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`This Court has jurisdiction pursuant to 28 U.S.C. § 1332(a) because the amount in
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`controversy is greater than $75,000 and plaintiff and defendant are citizens of different states.
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`7.
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`This Court has specific jurisdiction over Defendant as its activities were directed
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`toward Texas and injuries complained of resulted from their activities in Texas. Defendant has a
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`substantial connection with Texas and the requisite minimum contacts with Texas necessary to
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`constitutionally permit the Court to exercise jurisdiction.
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`IV.
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`FACTUAL ALLEGATIONS
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`A. Plaintiff Salum Obtains Insurance Coverage for Its Business from Defendant
`Travelers.
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`8.
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`Plaintiff Salum provides fine dining services in Dallas, Texas. It is owned by Chef
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`
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`Abraham Salum. The restaurant specializes in fine cuisine and wine. It offers an exclusive dining
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`experience in the restaurant setting. It is located in the center of Dallas County.
`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`PAGE 2 OF 16
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`9.
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`Travelers issued commercial policy number 680-7G01605A-20-42 to Salum for the
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`policy period of January 14, 2020 to January 14, 2021, including Business Income (Extra Expense)
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`Coverage Form (the “Policy”) for the property located at 4152 Cole Avenue #103, Dallas, Texas
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`75204; 1135 S. Lamar St., Dallas, Texas 75215; 7750 North Macarthur Blvd. Suite 120-352,
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`Irving, Texas 75063; 2001 Ross Avenue Suite 325, Dallas, Texas 75201 (“Insured Premises”).
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`This policy is attached hereto as Exhibit A. Salum has performed all of its obligations under the
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`Policy, including faithfully paying policy premiums.
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`
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`B. The Coronavirus 2019 Global Pandemic Causes Damage, Including in Dallas County.
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`10.
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`The Coronavirus disease was first detected toward the end of 2019, emerging in
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`Wuhan, China. The World Health Organization proposed the nomenclature COVID-19, standing
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`for coronavirus disease 2019.1
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`11.
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`On January 30, 2020, the World Health Organization declared the virus a public
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`health emergency of international concern. In February 2020, coronavirus deaths began to be
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`reported outside of China. Throughout February 2020, Coronavirus infections were reported in a
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`growing number of locations around the world, including in the Philippines, Japan, Europe, South
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`Korea, Iran, Latin America, Sub-Saharan Africa, and the United States.
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`12.
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`On March 11, 2020, the World Health Organization characterized the Coronavirus
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`(COVID-19) as a pandemic. On March 13, 2020, a national emergency was declared in the United
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`States of America. On March 15, 2020, the United States Centers for Disease Control and
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`https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance/naming-the-
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`1
`Cf.
`coronavirus-disease-(covid-2019)-and-the-virus-that-causes-it. As used in this Petition, the term “Coronavirus” refers
`to the virus termed as Coronavirus disease 2019 (COVID-19), including without limitation the severe acute respiratory
`syndrome coronavirus 2 (SARS-CoV-2), and the term is used broadly, and references the global pandemic associated
`with the virus first detected in December 2019 in Wuhan, China.
`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`PAGE 3 OF 16
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`Prevention advised no gatherings of 50 or more people in the United States. The next day, the
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`President advised citizens to avoid groups of more than 10.
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`13.
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`The Coronavirus has caused tens of thousands of deaths throughout the United
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`States, with the death toll increasing every day, and the numbers of reported cases growing
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`exponentially. The economy has been devastated by business interruptions in Dallas County, the
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`State of Texas, the United States, and worldwide.
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`14.
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`Coronavirus cases in Texas spiked in March 2020, and a growing number of
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`municipalities issued quarantine directives. The numbers of reported Coronavirus cases have
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`spread throughout Texas Counties, curtailing business, social, and economic activities throughout
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`the State. Correspondingly, the entire nation experienced spikes in infections and deaths, with a
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`growing number of citizens subjected to quarantine orders and business shutdowns.
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`15.
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`The scientific community recognizes the Coronavirus as a cause of real physical
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`loss and damage.
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`16.
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`The Coronavirus is physically impacting public and private property, and physical
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`spaces in communities around the world.
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`17.
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`The global pandemic is exacerbated by the fact that the potentially deadly virus
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`physically infects and stays on the surface of objects or materials for weeks. The duration of the
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`virus’ lethal staying power, and the conditions upon which the virus can continue to propagate and
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`infect people, are known facts under continued scrutiny by the scientific community. The virus
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`can physically infect and stay on surfaces for weeks, up to twenty-eight days under some estimates.
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`Moreover, because of the ongoing Coronavirus pandemic, which is raging in Dallas County, a
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`significant component of the public health crisis is the risk of continued contamination of the
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`surface of objects and materials which could propagate infections. Therefore, the Coronavirus has
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`caused damage, including damage to property, as a result of the staying power of the virus and the
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`communicability of disease from exposure to the surface of objects and materials.
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`18.
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`For example, China, Italy, France, and Spain have implemented the cleaning and
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`fumigating of public areas prior to allowing them to re-open publicly due to the intrusion of
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`microbials.
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`19.
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`The physical contamination of surfaces with communicable Coronavirus is a well-
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`recognized cause of physical damage and a reason that civil authorities have issued quarantine
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`orders.
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`C. The Civil Authorities Closed Plaintiff’s Business, Causing a Cessation of Business
`Activity.
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`20.
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`On March 19, 2020, Texas Governor Greg Abbott issued Executive Order No. GA-
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`
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`08 relating to COVID-19 preparedness and mitigation, which prohibited certain business activities
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`in order to contain the Coronavirus.
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`21.
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`Also on March 19, 2020, John W. Hellerstedt, M.D., the Commissioner of the
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`Texas Department of State Health Services, in accordance with Section 81.082(d) of the Texas
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`Health and Safety Code, declared a state of public health disaster for the entire State of Texas for
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`the first time since 1901.
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`22.
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`In March and April 2020, the Dallas County Commissioners Court issued disaster
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`declarations and executive orders, commanding that individuals SHELTER IN PLACE, as a result
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`of the Coronavirus. Dallas County officials first issued a disaster declaration related to the COVID-
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`19 pandemic on March 12, 2020. On March 22, 2020, Dallas County Judge Clay Jenkins issued a
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`“Stay Home Stay Safe” shelter-in-place order that went into effect at 11:59 pm on March 23, 2020.
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`23.
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`This order closed all dine-in service in Dallas County restaurants and all events
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`were catering services might be used. Specifically, as to restaurants, the order provided:
`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`Restaurants with or without drive-in or drive-through services and microbreweries,
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`micro-distilleries, or wineries may only provide take out, delivery, or drive-through
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`services as allowed by law.
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`The March 22, 2020 “Stay Home Stay Safe” order is attached as Exhibit B.
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`24.
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`Public events where catering services might be used were also prohibited:
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`All public or private gatherings of any number of people occurring outside a single
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`household or living unit are prohibited, except as otherwise provided herein.
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`Id.
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`25.
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`On March 24, 2020, the City of Dallas adopted Dallas County’s “Stay Home Stay
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`Safe” order.
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`26.
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`On April 3, 2020, the County Commissioners issued a renewal of a disaster
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`declaration through May 20, 2020. The most recent shelter-in-place order has been extended
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`through May 15, 2020. It continues the same restrictions on restaurant services.
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`27.
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`Thus, by executive order of Dallas County, all individuals were ordered to
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`SHELTER IN PLACE at their current place of residence. By executive order of Dallas County,
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`all restaurants in Dallas County, which includes the insured premises, were required to stop all
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`dine-in services and catering services.
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`28. While the executive order permits take-out and delivery service of food from
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`restaurants, Salum does not have a drive-through and has never had a take-out or delivery service
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`clientele, so that the executive order effectively resulted in a suspension of business at Salum.
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`29.
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`A cause of civil authorities’ closure of businesses, including Plaintiff’s, is the
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`contamination of property outside of the insured premises with the Coronavirus.
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`PAGE 6 OF 16
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`D. The Policy Covers Plaintiff’s Damage and Losses Sustained and Costs and Expenses
`Incurred.
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`30.
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`The damage and loss sustained by Salum as a result of the Coronavirus are covered
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`
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`by the policy (Exhibit A) issued by Defendant to Plaintiff, and no exclusions or defenses alleviate
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`Defendant’s obligation to Plaintiff under the policy.
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`31.
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`Contamination, and potential contamination, of the insured premises by the
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`Coronavirus constitutes a direct physical loss needing remediation to clean the surfaces of, and the
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`surfaces of objects at, the establishment.
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`32.
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`The policy promises to “pay for direct physical loss of or damage to Covered
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`Property at the premises.” Exhibit A, MPT1020205, Page 1 of 39 ¶A.
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`33.
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`Salum has sustained direct physical loss and/or damage to property arising from
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`and/or related to the Coronavirus, Coronavirus contamination, the threat of Coronavirus
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`contamination, and/or the Civil Authority response related to the Coronavirus.
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`34.
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`The policy promises to “pay for the actual loss of Business Income . . . sustain[ed]
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`due to the necessary ‘suspension’ of your ‘operations[.]’” Exhibit A, MPT1020205, Page 2 of 39
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`¶A(3)(a)(2).
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`35.
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`The policy promises to pay for additional coverages, including Civil Authority
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`coverage for business income and extra expenses. Exhibit A, MP1020205, Page 15 of 39 ¶A(7)(g).
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`36.
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`The Policy promises that it provides the “DELUXE PLAN” for businessowners’
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`coverage. Exhibit A, MPT1300205, Page 1 of 1.
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`37.
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`The Policy promises that changes in form language will benefit the insured.
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`Specifically, Travelers promises that:
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`Your new Travelers CGL policy will contain coverage terms and conditions
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`substantially similar to those in your expiring Travelers CGL policy. Also, in order
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`PLAINTIFF’S ORIGINAL COMPLAINT
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`to make this transition to our new proprietary policy forms as easy as possible for
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`you, we will adjust any claims for CGL coverage under your new policy based upon
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`the terms and conditions of either your expiring policy or your new policy,
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`whichever are broader. Likewise, if your expiring policy includes LL coverage
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`and you are renewing that coverage with us, we will adjust any claims for LL
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`coverage under your new policy based upon the terms and conditions of either your
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`expiring policy or your new policy, whichever are broader.
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`Exhibit A, PNU3020419, Page 1 of 2 (emphasis in original).
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`38.
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`39.
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`Salum has sustained a suspension of dine-in services as a result of the Coronavirus.
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`Salum has sustained loss of income and incurred expenses as a result of civil
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`authorities prohibiting access to the insured premises.
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`40.
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`The commercial, business, and property losses and damages, business interruption,
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`income losses sustained, and costs and expenses incurred, as a result of the Coronavirus and the
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`civil authority response to the Coronavirus, are covered by the policy. Defendants owe Plaintiff
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`compensation for Salum’s damages, losses, costs, and expenses arising from and related to the
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`Coronavirus, Coronavirus contamination, the threat of Coronavirus contamination, and/or the
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`Civil Authority response related to the Coronavirus.
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`E. Defendants Denied Plaintiff’s Claim.
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`41.
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`In compliance with the prerequisites for coverage, including the notice
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`prerequisites, Salum submitted a claim for coverage for the damage and losses sustained and costs
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`and expenses incurred as a result of the Coronavirus, as more fully discussed herein, fulfilling all
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`notice provisions in the policy.
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`42.
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`The claim Plaintiff submitted to Defendant under the policy was summarily denied
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`without any meaningful investigation.
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`43.
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`The letter from Defendant, dated March 30, 2020, offered the following reasons for
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`denying the claim:
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`a. Plaintiff had not suffered a cessation of business because, although all dine-in
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`service was ordered suspended, it was still legally permissible for customers to
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`approach the premises to pick up take-out orders;
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`b. Plaintiff had reported no physical damage to the insured premises;
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`c. A civil authority had not prohibited access to the premises due to loss or damage
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`to property other than the insured premises;
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`d. The policy does not cover loss or damages caused by “delay, loss of use, or loss
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`of market” or “contamination by other than ‘pollutants’”;
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`e. The policy does not cover loss or damages caused by “acts or decisions,
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`including the failure to act or decide, of any person, group, organization or
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`governmental body”; and
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`f. The policy does not cover loss or damages caused by “any virus, bacterium or
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`other microorganism.”
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`See Letter from Travelers, dated March 30, 2020, attached as Exhibit C. Travelers summarized the
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`reasons for the denial this way:
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`To the extent that you seek coverage for Business Income losses that are caused by
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`or resulting from “loss of use or loss of market”, “contamination by other
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`‘pollutants’”, and/or “[a]cts or decisions, including the failure to act or decide, of
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`any person, group, organization or governmental body”, there is no coverage for
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`your loss. Additionally, because the policy excludes loss or damage caused by or
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`resulting from any virus, which includes the COVID-19 virus, your business
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`income loss is not covered.
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`Id.
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`44.
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`Each and every reason Travelers’ letter proffers for denying coverage is inaccurate,
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`and each basis is denied by Plaintiff.
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`45.
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`One reason why Travelers’ denial letter is inaccurate is because, inter alia, the letter
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`quotes language not in the policy.
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`46.
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`Page three quotes language allegedly appearing in an endorsement titled “exclusion
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`of loss due to virus or bacteria.” See Exhibit C, p. 3. Even were this language in the Policy, it
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`would not foreclose coverage because inter alia the loss is caused by Civil Authority closure.
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`Independently, the language quoted in Travelers’ denial letter does not apply because it is not in
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`the Policy. Contrast Exhibit C, p. 3 with Exhibit A (quoted language beginning with “A. the
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`exclusion . . . or disease” is not there). There is a reference to IL T3 82 05 13, but the form and the
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`language quoted in Travelers’ denial letter is not in the Policy.2
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`V.
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`CAUSES OF ACTION
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`COUNT ONE
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`Breach of Contract
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`47.
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`Plaintiff restates and incorporates all the paragraphs above into this claim for relief
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`as if fully set forth herein.
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`2 The Policy skips from PR T4 97 03 15 to PN T0 22 12 15. See Exhibit A.
`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`48.
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`Plaintiff entered into a contract with Travelers for insurance coverage, including
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`coverage for Business Income, Extra Expense and Civil Authority.
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`49.
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`Plaintiff suffered property damage and loss of business income and extra expenses
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`covered by the Policy.
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`50.
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`Travelers breached its contract with Plaintiff by denying coverage and denying
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`Plaintiff’s claim.
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`51.
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`Plaintiff has been damaged by the breach, at a minimum, in the amount of the
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`unpaid insurance proceeds.
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`52.
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`All conditions precedents that are material to coverage for Plaintiff’s claim have
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`been performed.
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`COUNT TWO
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`Violation of the Texas Insurance Code §541.060
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`53.
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`Plaintiff restates and incorporates all the paragraphs above into this claim for relief
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`as if fully set forth herein.
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`54.
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`Travelers misrepresented a material fact and policy provision relating to the
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`coverage at issue in violation of Tex. Ins. Code §541.060(a)(1). Namely, despite its knowledge
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`that the Salum’s property was contaminated by the virus and Salum sustained business income
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`loss as a result, Travelers stated that there was no covered loss to the Insured Premises.
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`55.
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`Travelers failed at all material times to effectuate a prompt, fair and equitable
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`settlement of Plaintiff’s claim, after its lability had become reasonably clear, in violation of Tex.
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`Ins. Code § 541.060(a)(2)(4). Travelers’ liability became reasonably clear when it had notice of
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`the widespread contamination of property by the coronavirus and issuance of executive orders
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`prohibiting certain business activities. Instead of promptly investigating and paying Salum’s
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`claim, Travelers summarily denied the claim.
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`56.
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`Travelers violated Tex. Ins. Code §541.060(a)(7) by refusing to pay Salum’s claim
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`without conducting a reasonable investigation or any analysis with respect to the claim. Travelers
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`has conducted no investigation as to Salum’s business income loss before it denied the claim.
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`57.
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`58.
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`Travelers’ violations were done knowingly.
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`Plaintiff is entitled to actual damages as well as any and all consequential damages,
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`statutory penalties, and punitive damages as provided by law.
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`COUNT THREE
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`Breach of the Duty of Good Faith and Fair Dealing
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`59.
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`Plaintiff restates and incorporates all the paragraphs above into this claim for relief
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`as if fully set forth herein.
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`60.
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`Travelers owes Plaintiff a duty of good faith and fair dealing in connection with the
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`investigation and resolution of claims under the Policy.
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`61.
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`Such duty obligated Travelers to not deny liability to Plaintiff when its liability
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`under the policy was reasonably clear.
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`62.
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`Travelers’ liability was reasonably clear when it had notice of the widespread
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`contamination of property by the coronavirus and issuance of executive orders prohibiting certain
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`business activities.
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`63.
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`Travelers violated and continues to violate its duty of good faith and fair dealing by
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`denying liability to Plaintiff under the Policy and continuing to refuse to pay Plaintiff the sums
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`due and owing to Plaintiff under the policy.
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`64.
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`Travelers’ acts and omissions constituting a breach of the duty of good faith and
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`fair dealing were and continue to be committed with actual awareness that they are wrongful and
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`that they are inflicting harm on Plaintiff. Travelers’ violation of the duty of good faith and fair
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`dealing is grossly negligent, malicious, and/or fraudulent. Travelers’ violation of the duty of good
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`faith and fair dealing, therefore, warrants and authorizes the imposition of punitive or exemplary
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`damages.
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`65.
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`Plaintiff has suffered and will continue to suffer actual damages as a result of
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`Travelers’ breach of the duty of good faith and fair dealing.
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`COUNT FOUR
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`Declaratory Judgment Action
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`66.
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`Plaintiff restates and incorporates all the paragraphs above into this claim for relief
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`as if fully set forth herein.
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`67.
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`Pursuant to Texas Civil Practice and Remedies Code Sections 37.001, et seq., the
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`Court may declare rights, status, and legal relations whether or not further relief is or could be
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`claimed, and before or after breach of contract.
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`68.
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`Plaintiff Salum seeks a judgment declaring that the Policy provides coverage to
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`Salum for: (1) the damage to the Insured Premises by the Coronavirus; (2) business income loss
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`and extra expenses resulting from the interruption of Salum’s operation due to the damage to the
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`Insured Premises by the Coronavirus; and (3) the business income loss and extra expenses Salum
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`sustained as result of Salum’s inability to access and use the Insured Premises due to executive
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`orders and other actions taken by civil authorities.
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`69.
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`Plaintiff also seeks a declaratory judgment that it has fulfilled any and all
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`preconditions, notices, and duties owed to Defendant under the Policy.
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`PAGE 13 OF 16
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`

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`Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 14 of 16 PageID 14Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 14 of 16 PageID 14
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`COUNT FIVE
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`Costs Under Civil Practice and Remedies Code Section Chapters 37 and 38
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`
`70.
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`Plaintiff restates and incorporates all the paragraphs above into this claim for relief
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`as if fully set forth herein.
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`71.
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`Plaintiff is entitled to recover costs and reasonable and necessary attorney fees that
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`are equitable and just under Texas Civil Practice and Remedies Code Section 37.009, because this
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`is a suit for declaratory relief. Plaintiff is also entitled to recover its costs and reasonable attorney’s
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`fees under Texas Civil Practice and Remedies Code Section 38.001 and all applicable provisions
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`of the Texas Insurance Code.
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`VI.
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`CONDITIONS PRECEDENT
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`72.
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`All conditions precedent to Plaintiff’s claim for relief have been performed or have
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`occurred.
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`VII.
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`REQUESTED RELIEF
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`73.
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`For these reasons Plaintiff Salum Restaurant Ltd., asks that the Court render
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`judgment: (1) declaring that the policy issued by Defendant provides coverage for Plaintiff’s
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`property loss as a result of coronavirus pandemic, and the business income loss and extra expenses
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`Plaintiff sustained due to the property loss and the actions taken by civil authorities as requested
`
`herein, and (2) awarding Plaintiff the following damages:
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`a. Actual damages for the full amount of property loss, business income loss and
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`extra expenses sustained by Salum as a result of the Coronavirus and actions
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`taken by civil authorities;
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`b. Actual damages of all amounts owed under the contract;
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`c. Treble damages under Texas law;
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`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`PAGE 14 OF 16
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`Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 15 of 16 PageID 15Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 15 of 16 PageID 15
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`d. Attorneys’ fees and costs pursuant to Texas Civil Practice and Remedies Code
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`Sections 37.009 and 38.001, Texas Insurance Code Section 542.60, and Texas
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`Insurance Code Chapter 542A;
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`e. Penalties as provided by Sections 542.058(a) and 542.060(a) of the Texas
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`Insurance Code;
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`f. Actual damages caused by the Defendants wrongful conducts, including but not
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`limited to the benefits wrongfully withheld and attorneys’ fees and court costs.
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`g. Exemplary damages; and
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`h. Pre- and post-judgment interest to the extent permitted by law.
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`April 24, 2020
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`JURY TRIAL DEMANDED
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`Respectfully submitted,
`
`
`/s/ Matthew McCarley
`MATTHEW MCCARLEY
`Texas State Bar No. 24041426
`mmccarley@fnlawfirm.com
`N. MAJED NACHAWATI
`Texas State Bar No. 24038319
`mn@fnlawfirm.com
`S. ANN SAUCER
`Texas State Bar No. 00797885
`asaucer@fnlawfirm.com
`MISTY A. FARRIS
`Texas State Bar No. 00796532
`mfarris@fnlawfirm.com
`FEARS NACHAWATI, PLLC
`5473 Blair Rd.
`Dallas, Texas 75231
`Telephone: (214) 890-0711
`Facsimile: (214) 890-0712
`
`NEJAT AHMED
`Texas State Bar No. 24034304
` nejat@lalawtx.com
`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
`
`PAGE 15 OF 16
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`Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 16 of 16 PageID 16Case 3:20-cv-01034-L Document 1 Filed 04/24/20 Page 16 of 16 PageID 16
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`JENNIFER B. LeMASTER
` State Bar No. 24041063
` jennifer@lalawtx.com
` LEMASTER & AHMED PLLC
` 555 Republic Drive, Suite 200
` Plano, Texas 75074
` Telephone: 972.484.0410
` Facsimile: 972.484.0413
`
`
`ATTORNEYS FOR SALUM RESTAURANT LTD.
`
`
`
`
`
`______________________________________________________________________________
`PLAINTIFF’S ORIGINAL COMPLAINT
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`PAGE 16 OF 16
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`
`