`
`FILED
`5/16/2022 11:49 AM
`FELICIA PITRE
`DISTRICT CLERK
`DALLAS CO., TEXAS
`SADAF RAJPUT DEPUTY
`
`THE STATE OF TEXAS:
`COUNTY OF DALLAS:
`
`CAUSE NO.: DC-22-03950
`COURT: 134' DISTRICT COURT
`
`Style: ROBERT CLAY SHIELDS
`VS
`3M COMPANY,et al
`
`Came to Hand: APRIL 28, 2022 @ 9:00 AM
`
`Date and Time APRIL 28, 2022
`Delivered:
`12:58 PM
`5444 WESTHEIMER ROAD,SUITE 1000, HOUSTON, TEXAS 77056
`
`Document(s)
`Delivered:
`
`1--PLAINTIFF’S PETITION AND JURY DEMAND ON:
`DISCLOSURESON:
`FOSTER WHEELER ENERGY CORPORATION-— BY SERVING
`ITS REGISTERED AGENT UNITED AGENT GROUP,INC.—
`MARIA NEWMAN ACCEPTED
`
`Before me the undersigned authority, on this day personally appeared CAROL AGNEW,known to meto bethe
`person whose nameis subscribed hereto and underoath stated:
`
`“My name is CAROL AGNEW.I personally delivered the document(s) to REGISTERED AGENT-
`UNITED AGENT GROUP INC.- MARIA NEWMAN ACCEPTED FOR FOSTER WHEELER ENERGY
`CORPORATION.I am overthe age of twenty-one years and of sound mind.
`I am nota party to or interested
`in the outcomeofthis cause, and I am authorizedto servecitations, petitions and civil process for the courts of
`Texas. | have personal knowledge of every statement herein made, and I am fully competent to testify as to
`matters stated herein.
`
`Every statementin this affidavit is true and correct”.
`Signed this 2% day of APRIL 2022.
`
`CO01MAD nox
`CAROL AGNEW es
`
`Authorized Process Server
`EXPIRES 8/31/23
`
`SUBSCRIBED AND SWORN TO BEFORE MEonthis BS day ofAPRIL 2022.
`
`a
`
`Notary Public, State of Texas
`
`il,—ROBERT DAVID BAKER
`20
`F904 Notary Public, State of Texas
`35:oy
`»FN“25 Comm. Expires 01-14-2023
`oes
`mw Notary ID 1006431
`
`>
`
`
`
`FORM NO. 353-3—CITATION
`THE STATE OF TEXAS
`
`To:
`
`FOSTER WHEELER ENERGY CORPORATION
`BY SERVING ITS REGISTERED AGENT UNITED AGENT GROUP,INC
`5444 WESTHEIMER#1000
`HOUSTON,TX 77056
`
`GREETINGS:
`You have been sued. You may employ an attorney. If you or your attorney donotfile a written answer with the clerk who issued
`this citation by 10 o'clock a.m, of the Mondaynext following the expiration of twenty days after you were servedthiscitation and
`petition, a default judgment may be taken against you. In additionto filing a written answer with the clerk, you may be required to
`makeinitial disclosures to the other parties of this suit. These disclosures generally must be made nolater than 30 daysafter you file
`your answer with the clerk. Find out more at TexasLawHelp.org. Your answer should be addressedto the clerk of the 134th District
`Court at 600 CommerceStreet, Dallas, Texas 75202.
`
`Said Plaintiffbeing ROBERT CLAY SHIELDS
`
`ESERVE
`CITATION
`
`
`
`No.: DC-22-03980
`
`
`ROBERT CLAY SHIELD
`YS.
`
`3M COMPANY, et al
`
`
`ISSUED
`on this the 22nd day of April, 2022
`
`FELICIA PITRE
`Clerk District Courts,
`Dallas County, Texas
`
`Filed in said Court 12th day of April, 2022 against
`3M COMPANY; 4520 CORPORATION,INC.; ABLE SUPPLY CO.; AMETEK, INC. ; ASHLAND, LLC; BW/IP
`INTERNATIONAL, INC. ; CHAMPION OIL COMPANY; CHAMPLAIN CABLE CORPORATION; CRANECO.;
`ELLIOTT COMPANY F/K/A AND D/B/A ELLIOTT TURBOMACHINERY COMPANY; EXXON MOBIL
`CORPORATION; FLOWSERVE CORPORATION; FLOWSERVE US, INC.; FMC CORPORATION ; FOSTER
`WHEELER ENERGY CORPORATION; GENERAL ELECTRIC COMPANY; THE GOODYEAR TIRE & RUBBER
`
`COMPANY; GOULDS PUMPS, INCORPORATED; HERCULESLLC ; INTERNATIONAL PAPER COMPANY;ITT By:GAYLANE,Deputy
`CORPORATION; JOHN CRANE,INC.; LAMONS GASKET COMPANY; METROPOLITANLIFE INSURANCE
`COMPANY; RILEY POWER, INC.; SHELL OIL COMPANY; STERLING FLUID SYSTEMS (USA), LLC ; THE
`Attornev for Plaintiff
`WILLIAM POWELL COMPANY; UNION CARBIDE CORPORATION; VELAN VALVE CORPORATION; VALERO
`yt
`REFINING - TEXAS, LP; VIACOMCBSINC. ; WARREN PUMPS,LLC;
`DARREN MCDOWELL
`
`dsuitb bered 80, th f which d d foll 9489 BLAIR ROAD
`
`
`
`
`
`
`
`ForSuit, said
`suit
`being numbered DC-22-03980, the nature of which
`demand
`is as follows:
`Suit on OTHER (CIVIL)etc. as shown on said petition, a copy of which accompanies
`DALLAS TX 75231
`this citation. If this citation is not served, it shall be returned unexecuted.
`214-890-0711
`dmcdowell@fnlawfirm.com
`A
`Oeee.
`NOT PAID.
`.
`
`WITNESS: FELICIA PITRE,Clerk ofthe District Courts of Dallas, County Texas.
`Given under myhand andthe Seal ofsaid Court atoffice onthis the 22nd day ofApril, 2022
`ATTEST: FELICIA PITRE,
`
`Clerk of the District Courts of Dallas County, Texas
`
`By
`GAY LANE
`
`, Deputy
`
`
`
`
`
`OFFICER'S RETURN
`
`Cause No. DC-22-03980
`
`Court No.: 134th District Court
`
`Style: ROBERT CLAY SHIELDS
`vs.
`
`3M COMPANY,et al
`
`Came to hand on the
`az
`day of APRIL
`, 20_Ge2
`
`at Glico.CO
`oclokA ™M.
`Executed at S4YY y WESTHEIMER,SvITE [608HouS7ONTEAS within the County of"Jima 1s_ 1705¢
`1A:58
`o'clock
`f_
`.M.onthe
`ay
`dayof GPRIL
`,20 Zed
`,
`by
`delivering
`the
`to
`within
`named
`
`
`
`FOSTER WOH CORPORATIONBYSERVINGwv REGISTERED NT UniTed Aeent Grove
`
`
`NG -
`ELIMAN AiCCerTeD
`
`each, in person, a true copy of this Citation together with the accompanying copy ofthis pleading, having first endorsed on same date of
`delivery. The distance actually traveled by mein serving such process was
`miles and my fees are as follows:
`To certify which
`witness my hand.
`
`ForservingCitation
`Formileage
`ForNotary
`
`$
`$
`$
`
`CSOLS Ex ¥/5/31/o=<
`of aanSs
`County,
`ALA)
`Sexe&
`By
`
`Signed and sworn to by the said_Cy ro [
`20_2>
`
`(Mustbe verified if served outside the State of Texas.)
`day of Aor (
`hey,ntad—
`before methis 43
`_, to certify which witness my hand andsealofoffice.
`VAa
`
`;
`
`Notary Public Aare 9
`
`County 74X as
`
`ySo
`
`ROBERT DAVID BAKER
`SNFl,
`S3/NOKs*
`==
`KEeeNotary Public, State of Texas
`, e Comm. Expires 01-14-2023
`H BOERS
`Notary ID 1006431
`
`==4‘
`
`iw
`
`
`
` @is CORPORATE CREATIONS®
`
`
`@)
`art
`of the Comput
`Fe
`ro
`
`Authorization of Authority
`
`I, Trent Bavaro, Chief Operating Officer of Corporate Creations NetworkInc.
`and United Agent GroupInc., do hereby authorize Regus, andallofits staff, including
`but not limited to Maria Newmanand Harold Schultz, to accept and forwardall
`documents,including any andall court documents servedordelivered by the court,
`private server, sheriff, courier, or otherwise on behalf of each business and each
`business entity represented by Corporate Creations NetworkInc. and United Agent
`GroupInc.
`
`This authorization includessigning on behalf of Corporate Creations NetworkInc.or
`United Agent GroupInc. to accept all mail and documents,including court
`documentsserved ordelivered by the court, private server, sheriff, courier, or
`otherwise to 5444 Westheimer #1000, Houston, TX 77056.
`
`This affidavit is valid until the next issued affidavit or until December 31, 2022,
`whichever comes sooner.
`
`Dated: September 2, 2021
`
`HEREBY SEEN AND AGREED:
`
`Ze”Bo>
`
`Trent Bavaro
`Chief Operating Officer
`Corporate Creations NetworkInc.
`United Agent GroupInc.
`
`STATE OF FLORIDA
`COUNTY OF PALM BEACH
`
`The foregoing instrument was acknowledgedbefore methis 29d day of September
`2021 by the above namedsignatory, whois personally knownto me or who
`produced a driverslicense or passport as identification and who did take an oath.
`
`SS
`
`
` tig.
`JON-MICHAEL SANCHEZ
`‘te; Commission # GG 175368
`
`s/ Expires January 15, 2022
`“Bonded Thru Troy Fain inswrence 600-285-7019
`
`
`
`
`
`
`Signature of Notary Public
`
`Stamp of Notary Public
`
`
`
`Automated Certificate of eService
`This automated certificate of service was created by the efiling system.
`The filer served this document via email generated by the efiling system
`on the date and to the personslisted below. The rules governing
`certificates of service have not changed. Filers muststill provide a
`certificate of service that complies with all applicable rules.
`
`Envelope ID: 64526445
`Status as of 5/17/2022 10:13 AM CST
`
`Associated Case Party: UNION CARBIDE CORPORATION
`
`Misti Mosteller pO mmosteller@dehay.com|5/16/2022 11:49:29 AM|SENT
`
`Associated Case Party: ROBERTCLAYSHIELDS
`
`
`5/16/2022 11:49:29 AM|SENT
`
`DARREN MC DOWELL po dmcdowell@fnlawfirm.com|5/16/2022 11:49:29 AM|SENT
`DARREN MCDOWELL P| dmcdowell@fnlawfirm.com|5/16/2022 11:49:29 AM|SENT
`Chelsea Britton po cbritton@fnlawfirm.com
`
`



