NUECES COUNTY, TEXAS, § IN THE COUNTY COURT
Plaintiff s
vs.
FORD MOTOR COMPANY,
CHARLIE THOMAS' COURTESY Q
FORD, INC. F/K/A COURTESY § AT LAW NO. 3
FORD MOTORS, INC., CHARLIE 9
THOMAS' COURTESY FORD, INC. 0
D/B/A PADRE FORD-MAZDA, AND 8
TRADEWINDS FORD SALES, INC. $
F/K/A CROSSTOWN FORD SALES, 8
INC.; BOB LACY FORD, INC. 8 NUECES COUNTY, TEXAS
5
Defendants 8
PLAINTIFF'S ORIGINAL PETITION
Nueces County, Plaintiff, brings this Iawsuit camplaining of Ford Motor Company,
Charlie Thomas' Courtesy Ford, Inc, f/k/a Courtesy Ford Motors, Inc., Charlie Thomas'
Courtesy Ford, Inc. d/b/a Padre Ford-Mazda, Tradewinds Ford Sales, Inc. f/k/a Crosstown
Ford Sales, Inc,, and Bob Lacy Ford, Inc., Defendants, and as grounds allege as follows:
I.
Request for Discovery Control Plan
1.1 Pursuant to Tex. R. Civ. P. 190.1, Plaintiff requests that discovery be
conducted under Level 3, Tex. R. Civ. P. 190.4. Further, Plaintiff moves for an
discovery be conducted in accordance with a discovery control plan tailored to the
circumstances of this specific case, pursuant to Rule 190.4(a).
II.
Parties
2.1 Nueces County, Texas is a governmental entity, specifically a political
subdivision of the State of Texas, which is the owner of approximately 106 Ford Crown
SNIPPETS:
Nueces County, Plaintiff, brings this Iawsuit camplaining of Ford Motor Company,
Charlie Thomas' Courtesy Ford, Inc, f/k/a Courtesy Ford Motors, Inc., Charlie Thomas'
Courtesy Ford, Inc. d/b/a Padre Ford-Mazda, Tradewinds Ford Sales, Inc. f/k/a Crosstown
Ford Sales, Inc,, and Bob Lacy Ford, Inc., Defendants, and as grounds allege as follows:
Pursuant to Tex.
subdivision of the State of Texas, which is the owner of approximately 106 Ford Crown
Victoria Police Interceptor vehicles manufactured and sold during model years 19932001, which
municipalities and other political subdivisions within the state
law enforcement agencies and officers for use as law enforcement vehicles.
Ford Crown Victoria Police Interceptors in question in this suit.
Charlie Thomas' Courtesy Ford, Inc. f/k/a Courtesy Ford Motors, Inc., is here sued under
Defendant may be served by serving its registered agent for service,
disproportionately high rate of rear impact fatalities associated with fuel-fed-fire,
increased fuel system safety to protect against the increased risk.
Company, or the Selling Dealers, send any other information to Nueces County advising
it of the information contained within the Technical Service Bulletin,
will be repaired and defects remedied at the sole cost of the manufacturer.
Notwithstanding the inadequacy of the remedies it recommends,
some being struck at high speeds by large vehicles and others at speeds up to 100 mph.
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