Case 5:22-cv-00323 Document 1-1 Filed 04/01/22 Page 1 of 15
`Case 5:22-cv-00323 Document 1-1 Filed 04/01/22 Page1of15
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`Civil Action No. 5:22-cv-323
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`EXHIBIT 1
`EXHIBIT 1
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`

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`JAMES M. SWEENEY, INDIVIDUALLY,
`AND THE JAMES M. SWEENEY TRUST,
`
`
`
`v.
`
`
`HOY HEALTH LLC AND
`HOY HEALTH CORPORATION,
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`
`
`
`Plaintiffs,
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`Defendants.
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`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`PLAINTIFFS’ ORIGINAL PETITION
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`IN THE DISTRICT COURT OF
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`
`
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`BEXAR COUNTY, TEXAS
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`
`
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`____ JUDICIAL DISTRICT
`
`2 cit cml
`Case 5:22-cv-00323 Document 1-1 Filed 04/01/22 Page 2 of 15
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`FILED
`2/14/2022 3:07 PM
`Mary Angie Garcia
`Bexar County District Clerk
`Accepted By: Krystal Torres
`Bexar County - 225th District Court
`
`
`2022CI02667
`CAUSE NO. ____________
`
`
`
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`Plaintiffs James M. Sweeney, individually (“Mr. Sweeney”) and James M. Sweeney, as
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`Trustee for the James M. Sweeney Trust (“The Sweeney Trust”), file this Original Petition
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`complaining of Hoy Health LLC and Hoy Health Corporation (collectively, “Hoy”).
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`I.
`DISCOVERY CONTROL PLAN
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`Pursuant to the Texas Rules of Civil Procedure 190.4, Plaintiffs intend for
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`1.
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`discovery to be conducted by a Level 3 discovery control plan.
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`II.
`RULE 47 STATEMENTS
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`Pursuant to Texas Rule of Civil Procedure 47(a), a short statement of the causes of
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`2.
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`action sufficient to give fair notice of the claims involved are contained in the various sections set
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`forth below.
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`3.
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`Pursuant to Texas Rule of Civil Procedure 47(c)(4), Plaintiffs seek monetary relief
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`over $1,000,000.
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`4.
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`Pursuant to Texas Rule of Civil Procedure 47(b), the damages sought are within the
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`jurisdictional limits of this Court.
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`III.
`PARTIES
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`Mr. Sweeney is an individual residing in Texas.
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`The Sweeney Trust is a trust created under the laws of California with a principal
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`5.
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`6.
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`place of business in Texas. Mr. Sweeney is the Trustee of the Sweeney Trust with standing to bring
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`claims on its behalf.
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`7.
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`Upon information and belief, Hoy Health LLC is a Delaware limited-liability
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`corporation with a principal place of business at 45 S. Park Place #228, Morristown, New Jersey
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`07960, and offices at 5723 University Heights Blvd., Suite 12, San Antonio, Texas 78249. Hoy
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`Health LLC may be served through its registered agent, The Company Corporation, at 2711
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`Centerville Road, Suite 400, Wilmington, Delaware 19808.
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`8.
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`Upon information and belief, Hoy Health Corporation is a Delaware corporation
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`with a principal place of business at 45 S. Park Place #228, Morristown, New Jersey 07960 and
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`offices at 5723 University Heights Blvd., Suite 12, San Antonio, Texas 78249. Hoy Health
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`Corporation may be served through its registered agent, National Registered Agents, Inc., at 1209
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`Orange Street, Wilmington, Delaware 19801.
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`IV.
`JURISDICTION AND VENUE
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`Plaintiffs seek monetary relief more than the minimum jurisdictional limits of this
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`9.
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`Court.
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`10.
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`Further support for jurisdiction is provided in Article V, Sections I and VIII of the
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`Texas Constitution and Sections 24.007 and 24.008 of the Texas Government Code.
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`11.
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`The basis of the lawsuit involves events occurring in the State of Texas, and at all
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`times relevant, Hoy had systematic and continuous contacts with the State of Texas.
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`12.
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`A substantial amount of the conduct described in this lawsuit occurred in Bexar
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`County, Texas.
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`13.
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`Pursuant to Texas Civil Practice and Remedies Code Section 15.002(a)(1), venue
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`is proper in Bexar County because Bexar County is where a substantial part of the events or
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`omissions giving rise to the claims occurred.
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`14.
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`Alternatively, pursuant to Texas Civil Practice and Remedies Code Section
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`15.002(4), venue is proper in Bexar County because it is the county in which Mr. Sweeney resided
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`at the time of the accrual of the causes of action.
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`Background of Mr. Sweeney.
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`V.
`FACTS
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`15. Mr. Sweeney is an iconic and prolific healthcare entrepreneur in advanced home
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`care models and healthcare technologies.
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`16. Mr. Sweeney is responsible for the establishment of the multi-billion-dollar home-
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`infusion therapy industry and was an early pioneer in the remote-monitoring and telehealth sector.
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`17. Mr. Sweeney founded twelve healthcare companies, including (a) Caremark, which
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`was acquired by CVS in 2007 for $24 billion, (b) Coram, which was acquired by CVS in 2013
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`for $2.1 billion, and (c) CardioNet (BioTelemetry), which was sold to Philips in 2021 for $2.8
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`billion.
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`18.
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`In addition, throughout his storied six-decade career, Mr. Sweeney raised $2 billion
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`in financing, including $500 million in venture-capital funds, $700 million in debt and $400
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`million in IPOs.
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`19. Mr. Sweeney has successfully taken four companies public and led a leveraged buy
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`out resulting in a 650% return to investors and 77% internal rate of return in less than four years.
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`20.
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`21.
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`The $2 billion invested resulted in $30 billion exit value.
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`In short, prior to Mr. Sweeney’s association with Hoy, his reputation was not just
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`sterling, but it was one of (if not the single most) impressive reputation in his industry
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`Background of HFH.
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`22.
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`One of Mr. Sweeney’s most recent health-care companies was HomeFront
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`Healthcare (“HFH”), for which he served as Executive Chairman and Founder, as well as a
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`member of HFH’s Board of Directors (“Board Seat”).
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`23.
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`In the short period of time since HFH’s advent early in 2019, Mr. Sweeney raised
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`millions of dollars in financing for HFH, including convertible debt of: (1) $3 million from Bob
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`Castellani through CCH HFH Holdings, LLC (with another $2 million that Mr. Castellani
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`committed by binding contract to HFH in the future), (2) $2.5 million from Roy Block through
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`RWBC Holdings, Inc., (3) $2.5 million from Sudhir Damle through Kivale Partners LLP, and (4)
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`$300,000 from Craig Kruemwiede (collectively, the “Investors” who provided the “Investor
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`Cash”).
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`24.
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`Additionally, The Sweeney Trust invested approximately $800,000 into HFH
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`(“Sweeney Investment”), making The Sweeney Trust the majority common stockholder in HFH
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`and Mr. Sweeney (as the Trustee of The James M. Sweeney Trust) the individual with effective
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`control over HFH (“HFH Company Control”).
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`The Transaction and the Fraud.
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`25.
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`Effective August 18, 2021, Hoy, HFH, Mr. Sweeney, the Investors, and other HFH
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`common stockholders entered a transaction through which The Sweeney Trust abandoned and
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`provided to Hoy the Sweeney Investment, and Mr. Sweeney abandoned and provided to Hoy his
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`HFH Company Control, his control over the Investor Cash, and his Board Seat.
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`26.
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`The Sweeney Trust and Mr. Sweeney entered the transaction in reliance on express
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`representations: (a) made by Mario Anglada (acting in capacity of Chief Executive Officer of
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`Hoy) and Rodrigo Rodriguez-Novas (acting in his capacity as Chief Financial Officer of Hoy),
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`(b) made to Mr. Sweeney (acting in his individual capacity and as trustee of The Sweeney Trust),
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`(c) between the period of June 2021 through August 2021 (e.g., on a telephonic meeting of the
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`Board of Directors of HFH on June 22, 2021 during which Mr. Anglada participated), (d) during
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`telephone conferences and at office conferences at 5723 University Heights Blvd., Suite 12, San
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`Antonio, Texas 78249, and (e) comprised of statements that if The Sweeney Trust would abandon
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`and provide to Hoy The Sweeney Investment, and if Mr. Sweeney would abandon and provide to
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`Hoy his HFH Company Control, his control over the Investor Cash, and his Board Seat, then Hoy
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`would have Mr. Sweeney serve as its long-term Chief Strategy Officer at an annual salary of
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`$300,000 and work as an integral part of the Hoy Management Team (collectively,
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`“Misrepresentations”).
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`27.
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`However, these Misrepresentations were false.
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`The Fraud Revealed.
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`28.
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`One month after the transaction through which The Sweeney Trust and Mr.
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`Sweeney abandoned and provided to Hoy The Sweeney Investment, HFH Company Control,
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`control over the Investor Cash, Mr. Sweeney’s Board Seat, Hoy unceremoniously terminated Mr.
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`Sweeney without any notice (“Termination”).
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`29.
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`Due to the Termination: (a) Mr. Sweeney did not serve as Hoy’s long-term Chief
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`Strategy Officer, (b) Mr. Sweeney received only $25,000 in payments from Hoy (before taxes),
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`(c) and Mr. Sweeney did not serve as a part (let alone an integral part) of the Hoy Management
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`Team (and, in fact, Hoy never even identified Mr. Sweeney on Hoy’s website—either as its Chief
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`Strategy Officer or in any other capacity).
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`30.
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`Hoy’s purported reasoning that it provided to Mr. Sweeney for the Termination
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`occurring only weeks after the transaction (through which The Sweeney Trust and Mr. Sweeney
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`abandoned and provided to Hoy The Sweeney Investment, HFH Company Control, control over
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`the Investor Cash, and Mr. Sweeney’s Board Seat) was that Hoy determined—incredibly enough,
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`for the very first time—that Hoy apparently lacked the financial resources to have a position of
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`Chief Strategy Officer after all (“Purported Justification”).
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`31.
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`Given the volume and materiality of the Misrepresentations, however, the
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`Purported Justification was nothing short of a blatant fraud.
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`32.
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`Indeed, Hoy clearly used the Misrepresentations to induce The Sweeney Trust and
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`Mr. Sweeney to abandon and provide to Hoy the Sweeney Investment, HFH Company Control,
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`control over the Investor Cash, and Mr. Sweeney’s Board Seat, when all the time, Hoy knew that
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`it never intended to have Mr. Sweeney serve as its long-term Chief Strategy Officer at an annual
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`salary of $300,000 or work as an integral part of the Hoy Management Team.
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`33.
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`At the very least, and even taking the Purported Justification at face value (which,
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`given Hoy’s due diligence prior to closing the Transaction would be an absurd presumption to
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`take at face value), Hoy would have committed any number of negligent misrepresentations.
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`34.
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`Put simply, based on the Misrepresentations, Hoy swindled The Sweeney Trust and
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`Mr. Sweeney out of the Sweeney Investment, the HFH Company Control, control over the
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`Investor Cash, and Mr. Sweeney’s Board Seat.
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`Case 5:22-cv-00323 Document 1-1 Filed 04/01/22 Page 8 of 15
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`VI.
`CAUSES OF ACTION
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`First Cause of Action – Fraudulent Misrepresentation
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`All the foregoing allegations are incorporated by reference for all purposes.
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`Hoy made material misrepresentations to The Sweeney Trust and Mr. Sweeney,
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`35.
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`36.
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`including the statements that if The Sweeney Trust and Mr. Sweeney (neither of whom were
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`represented by counsel at the time) would abandon and provide Hoy with the Sweeney Investment,
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`HFH Company Control, control over the Investor Cash, and Mr. Sweeney’s Board Seat, then Hoy
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`would have Mr. Sweeney serve as its long-term Chief Strategy Officer at an annual salary of
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`$300,000 and work as an integral part of the Hoy Management Team.
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`37.
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`The Misrepresentations were false, as Hoy never intended to have Mr. Sweeney
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`serve as its long-term Chief Strategy Officer at an annual salary of $300,000 or work as an integral
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`part of the Hoy Management Team.
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`38.
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`At the time Hoy made the Misrepresentations, Hoy knew the Misrepresentations to
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`be false.
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`39.
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`Hoy made the Misrepresentations with the intent that The Sweeney Trust and Mr.
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`Sweeney rely on them and abandon and provide to Hoy The Sweeney Investment, HFH Company
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`Control, control over the Investor Cash, and Mr. Sweeney’s Board Seat.
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`40.
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`The Sweeney Trust Mr. Sweeney
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`relied
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`to
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`their detriment on
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`the
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`Misrepresentations, and The Sweeney Trust and Mr. Sweeney abandoned and provided to Hoy
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`The Sweeney Investment, HFH Company Control, control over the Investor Cash, and Mr.
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`Sweeney’s Board Seat.
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`41.
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`The Misrepresentations resulted in injuries to The Sweeney Trust, including the
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`loss of the Sweeney Investment, which is approximately $800,000.00 (exclusive of interest or the
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`increased value of the investment over time).
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`42.
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`The Misrepresentations also resulted in injuries to Mr. Sweeney, including loss of
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`the HFH Company Control, control over the Investor Cash, and Mr. Sweeney’s Board Seat.
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`43.
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`Additionally, the Misrepresentations caused Mr. Sweeney to suffer reputational
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`damages, including as follows: (a) prior to the Misrepresentations and Termination, Mr. Sweeney
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`maintained a superlative reputation as a prolific healthcare entrepreneur with abilities to raise
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`investor financing; (b) due to the Misrepresentations and Termination, Mr. Sweeney’s reputation
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`in the industry and among potential investors suffered material damages, which in turn, impeded
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`and continues to impede Mr. Sweeney’s marketability to raise future investor financing and secure
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`similar and/or future employment.
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`44.
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`The reliance damages sought by The Sweeney Trust and Mr. Sweeney do not
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`depend on Mr. Sweeney’s continued employment with Hoy.
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`45.
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`The harm under this cause of action with respect to which The Sweeney Trust and
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`Mr. Sweeney resulted from fraud and/or malice.
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`46.
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`As remedies for fraudulent misrepresentation, The Sweeney Trust and Mr.
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`Sweeney seek, among other things, actual damages, exemplary damages, and rescission of the
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`transaction described in paragraph 25 above. See TEX. CIV. PRAC. & REM. CODE § 41.003; Ginn v.
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`NCI Bldg. Sys., 472 S.W.3d 802, 837 (Tex.App.—Houston [1st Dist.] 2015, no pet. h.)
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`(“Rescission is an equitable remedy that operates to extinguish a contract that is legally valid but
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`must be set aside due to fraud, mistake, or for some other reason to avoid unjust enrichment.”).
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`Second Cause of Action – Negligent Misrepresentation (Pleading in the Alternative)
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`47.
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`48.
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`All the foregoing allegations are incorporated by reference for all purposes.
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`Hoy made the Misrepresentations to The Sweeney Trust and Mr. Sweeney in the
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`course of Hoy’s business or in a transaction in which Hoy had an interest.
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`49.
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`Hoy provided false information to The Sweeney Trust and Mr. Sweeney, including
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`that if The Sweeney Trust and Mr. Sweeney (neither of whom were represented by counsel at the
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`time) would abandon and provide Hoy the Sweeney Investment, HFH Company Control, control
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`over the Investor Cash, and Mr. Sweeney’s Board Seat, then Hoy would have Mr. Sweeney serve
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`as its long-term Chief Strategy Officer at an annual salary of $300,000 and work as an integral part
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`of the Hoy Management Team.
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`50.
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`Hoy provided this false information to The Sweeney Trust and Mr. Sweeney,
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`including for the guidance of others, namely The Sweeney Trust and Mr. Sweeney.
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`51.
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`Hoy failed
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`to exercise reasonable care or competence
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`in obtaining or
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`communicating information, including whether Hoy maintained or lacked the financial resources
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`to maintain the position of Chief Strategy Officer, and by extension, whether Hoy maintained or
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`lacked the financial resources to have Mr. Sweeney serve as Hoy’s long-term Chief Strategy
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`Officer at an annual salary of $300,000 and work as an integral part of the Hoy Management Team.
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`52.
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`The Sweeney Trust and Mr. Sweeney justifiably relied to their detriment on the
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`Misrepresentations and abandoned and provided to Hoy The Sweeney Investment, HFH Company
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`Control, control over the Investor Cash, and Mr. Sweeney’s Board Seat.
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`53.
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`The Misrepresentations resulted in injuries to The Sweeney Trust, including the
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`loss of the Sweeney Investment, which is approximately $800,000.00 (exclusive of interest or the
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`increased value of the investment over time).
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`54.
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`The Misrepresentations also resulted in injuries to Mr. Sweeney, including loss of
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`the HFH Company Control, control over the Investor Cash, and Mr. Sweeney’s Board Seat.
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`55.
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`Additionally, the Misrepresentations caused Mr. Sweeney to suffer reputational
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`damages, including as follows: (a) prior to the Misrepresentations and Termination, Mr. Sweeney
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`maintained a superlative reputation as a prolific healthcare entrepreneur with abilities to raise
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`investor financing; (b) due to the Misrepresentations and Termination, Mr. Sweeney’s reputation
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`in the industry and among potential investors suffered material damages, which in turn, impeded
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`and continues to impede Mr. Sweeney’s marketability to raise future investor financing and secure
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`similar and/or future employment.
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`56.
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`The reliance damages sought by The Sweeney Trust and Mr. Sweeney do not
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`depend on Mr. Sweeney’s continued employment with Hoy.
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`57.
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`The harm under this cause of action with respect to which The Sweeney Trust and
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`Mr. Sweeney resulted from gross negligence and/or malice.
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`58.
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`As remedies for fraudulent misrepresentation, The Sweeney Trust and Mr.
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`Sweeney seek, among other things, actual damages, exemplary damages, and rescission of the
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`transaction described in paragraph 25 above. See TEX. CIV. PRAC. & REM. CODE § 41.003; Ginn v.
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`NCI Bldg. Sys., 472 S.W.3d 802, 837 (Tex.App.—Houston [1st Dist.] 2015, no pet. h.)
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`(“Rescission is an equitable remedy that operates to extinguish a contract that is legally valid but
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`must be set aside due to fraud, mistake, or for some other reason to avoid unjust enrichment.”).
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`Third Cause of Action – Unjust Enrichment (Pleading in the Alternative)
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`59.
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`60.
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`All the foregoing allegations are incorporated by reference for all purposes.
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`Hoy wrongly secured or received the Sweeney Investment, HFH Company Control,
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`control over the Investor Cash, and Mr. Sweeney’s Board Seat.
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`61.
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`Hoy is unjustly enriched because it obtained the Sweeney Investment, HFH
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`Company Control, control over the Investor Cash, and Mr. Sweeney’s Board Seat by fraud and the
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`taking of undue advantage.
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`62.
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`The fraud and taking of undue advantage included Hoy making material and
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`knowingly false Misrepresentations to The Sweeney Trust and Mr. Sweeney that if The Sweeney
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`Trust and Mr. Sweeney (neither of whom were represented by counsel at the time) would abandon
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`and provide Hoy with the Sweeney Investment, HFH Company Control, control over the Investor
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`Cash, and Mr. Sweeney’s Board Seat, then Hoy would have Mr. Sweeney serve as its long-term
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`Chief Strategy Officer at an annual salary of $300,000 and work as an integral part of the Hoy
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`Management Team.
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`63.
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`As remedies for unjust enrichment, The Sweeney Trust and Mr. Sweeney seek,
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`among other things, quasi-contract or restitution, by returning to The Sweeney Trust and Mr.
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`Sweeney the Sweeney Investment, HFH Company Control, control over the Investor Cash, and
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`Mr. Sweeney’s Board Seat. Further, The Sweeney Trust and Mr. Sweeney seek rescission of the
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`transaction described in paragraph 25 above. See Ginn v. NCI Bldg. Sys., 472 S.W.3d 802, 837
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`(Tex.App.—Houston [1st Dist.] 2015, no pet. h.) (“Rescission is an equitable remedy that operates
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`to extinguish a contract that is legally valid but must be set aside due to fraud, mistake, or for some
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`other reason to avoid unjust enrichment.”).
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`IX.
`PRAYER
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`Plaintiffs respectfully pray that the Court enter judgment in their favor and against
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`64.
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`Defendants on each of Plaintiffs’ claims, as set forth above.
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`65.
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`Plaintiffs further respectfully pray that after a trial on the merits, the Court shall
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`grant Plaintiffs their actual damages, exemplary damages, rescission, quasi contract/restitution,
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`Case 5:22-cv-00323 Document 1-1 Filed 04/01/22 Page 13 of 15
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`costs of court, pre-judgment interest, post-judgment interest, and all other and further relief, at law
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`or in equity, to which Plaintiffs may be justly entitled.
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`Respectfully submitted,
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`/s/ Lawrence Morales II_________
`LAWRENCE MORALES II
`State Bar No. 24051077
`ALLISON S. HARTRY
`State Bar No. 24083149
`THE MORALES FIRM, P.C.
`6243 IH-10 West, Suite 132
`San Antonio, Texas 78201
`Telephone No. (210) 225-0811
`Facsimile No. (210) 225-0821
`lawrence@themoralesfirm.com
`ahartry@themoralesfirm.com
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`ATTORNEYS FOR PLAINTIFFS JAMES M.
`SWEENEY, INDIVIDUALLY THE JAMES M.
`SWEENEY TRUST
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`PLAINTIFFS’ ORIGINAL PETITION
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`

`Name:
`Lawrence Morales II
`_____________________________
`
`Email:
`lawrence@themoralesfirm.com
`____________________________
`
`Address:
`6243 W. Interstate 10, #132
`_____________________________
`
`Telephone:
`210-225-0811
`____________________________
`
`City/State/Zip:
`San Antonio, TX 78201
`_____________________________
`
`Fax:
`210-225-0821
`____________________________
`
`
`
`Signature:
`
`
`
`__________________________________________________
`
`State Bar No:
`
`24051077
`____________________________
`
`Plaintiff(s)/Petitioner(s):
`James M. Sweeney and The James
`_________________________________
`M. Sweeney Trust
`_________________________________
`
`Defendant(s)/Respondent(s):
`Hoy Health, LLC and
`_________________________________
`Hoy Health Corporation
`_________________________________
`
`_________________________________
`
`2. Indicate case type, or identify the most important issue in the case (select only 1):te case t pe or identif th
`
`
`
`[Attach additional page as necessary to list all parties]
`
`Civil
`
`Person or entity completing sheet is:
`Attorney for Plaintiff/Petitioner
`Pro Se Plaintiff/Petitioner
`Title IV-D Agency
`Other: _________________________
`
`Additional Parties in Child Support Case:
`
`Custodial Parent:
`_________________________________
`
`Non-Custodial Parent:
`_________________________________
`
`Presumed Father:
`_________________________________
`
`CIVIL CASE INFORMATION SHEET
`Case 5:22-cv-00323 Document 1-1 Filed 04/01/22 Page 14 of 15
`CAUSE NUMBER (FOR CLERK USE ONLY): _______________________________ COURT (FOR CLERK USE ONLY): ______________________
`
`STYLED ___________________________________________________________________________________________________
`James M. Sweeney and The James M. Sweeney Trust v. Hoy Health, LLC and Hoy Health Corporation
`(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
`the time of filing.
`1. Contact information for person completing case information sheet:
`
`Names of parties in case:
`
`Contract
`Debt/Contract
`Consumer/DTPA
`Debt/Contract
`Fraud/Misrepresentation
`Other Debt/Contract:
`____________________
`Foreclosure
`Home Equity—Expedited
`Other Foreclosure
`Franchise
`Insurance
`Landlord/Tenant
`Non-Competition
`Partnership
`Other Contract:
` ______________________
`
`Injury or Damage
`Assault/Battery
`Construction
`Defamation
`Malpractice
`Accounting
`Legal
`Medical
`Other Professional
` Liability:
` _______________
`Motor Vehicle Accident
`Premises
`Product Liability
`Asbestos/Silica
`Other Product Liability
`List Product:
`_________________
`Other Injury or Damage:
` _________________
`
`Real Property
`Eminent Domain/
` Condemnation
`Partition
`Quiet Title
`Trespass to Try Title
`Other Property:
` ____________________
`
`Related to Criminal
`Matters
`Expunction
`Judgment Nisi
`Non-Disclosure
`Seizure/Forfeiture
`Writ of Habeas Corpus—
` Pre-indictment
`Other: _______________
`
`Employment
`Discrimination
`Retaliation
`Termination
`Workers’ Compensation
`Other Employment:
` ______________________
`
`Administrative Appeal
`Antitrust/Unfair
` Competition
`Code Violations
`Foreign Judgment
`Intellectual Property
`
`Other Civil
`
`Lawyer Discipline
`Perpetuate Testimony
`Securities/Stock
`Tortious Interference
`Other: _______________
`
`Marriage Relationship
`Annulment
`Declare Marriage Void
`Divorce
`With Children
`No Children
`
`Family Law
`Post-judgment Actions
`(non-Title IV-D)
`Enforcement
`Modification—Custody
`Modification—Other
`Title IV-D
`Enforcement/Modification
`Paternity
`Reciprocals (UIFSA)
`Support Order
`
`Other Family Law
`Enforce Foreign
` Judgment
`Habeas Corpus
`Name Change
`Protective Order
`Removal of Disabilities
` of Minority
`Other:
` __________________
`
`Parent-Child Relationship
`Adoption/Adoption with
`Termination
`Child Protection
`Child Support
`Custody or Visitation
`Gestational Parenting
`Grandparent Access
`Parentage/Paternity
`Termination of Parental
` Rights
`Other Parent-Child:
` _____________________
`
`Tax
`Tax Appraisal
`Tax Delinquency
`Other Tax
`
`Probate/Wills/Intestate Administration
`Dependent Administration
`Independent Administration
`Other Estate Proceedings
`
`Probate & Mental Health
`Guardianship—Adult
`Guardianship—Minor
`Mental Health
`Other: ____________________
`
`3. Indicate procedure or remedy, if applicable (may select more than 1):
`Appeal from Municipal or Justice Court
`Declaratory Judgment
`Arbitration-related
`Garnishment
`Attachment
`Interpleader
`Bill of Review
`License
`Certiorari
`Mandamus
`Class Action
`Post-judgment
`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
`
`Prejudgment Remedy
`Protective Order
`Receiver
`Sequestration
`Temporary Restraining Order/Injunction
`Turnover
`
`

`

`Case 5:22-cv-00323 Document 1-1 Filed 04/01/22 Page 15 of 15
`
`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 persons listed below. The rules governing
`certificates of service have not changed. Filers must still provide a
`certificate of service that complies with all applicable rules.
`Lawrence Morales on behalf of Lawrence Morales II
`Bar No. 24051077
`lawrence@themoralesfirm.com
`Envelope ID: 61726707
`Status as of 2/15/2022 8:12 AM CST
`
`Case Contacts
`
`Name
`Lawrence Morales II
`
`BarNumber Email
`lawrence@themoralesfirm.com
`
`TimestampSubmitted
`2/14/2022 3:07:24 PM
`
`Status
`SENT
`
`