Lost Society v BarkingDogs - read all the filings here

On Saturday evening, BD was notified by the Armando Miranda, attorney for Fernando Rosales, owner of Lost Society, that a lawsuit had been filed Friday against BD et al seeking damages for the publication of allegedly defamatory and / or untrue stories and photographs about Lost Society and Rosales since June 2010.

They are seeking the permanent removal of all content posted on this website referencing Fernando Rosales or Lost Society.

In an email to BD sent Saturday evening, the attorney stated...

If you have any questions or wish to resolve this matter by deleteing and removing any and all untrue and/or unverified defamatory statements published by you concerning Mr. Rosales and/or Lost Society, you may contact me at: xxx xxx xxxx.

Armando Miranda

Atorney for Fernando Rosales (sic) (PDF of email)

Miranda email notification of lawsuit against BarkingDogs

Lost Society was also seeking a Temporary Restraining Order on BD et al be restrained from publishing defamatory statements (until a trial is held on the lawsuit) concerning plaintiffs, Fernando Rosales, Lost Society and Initiatve Partners, LLC, at 830am Monday morning in County Court 5, Judge Mark Greenberg presiding.

Petition for Temporary Restraining Order on Barking Dogs

Update 12/14/2010 - Judge Greenberg issued a ruling late Monday afternoon (just posted to County website) in which he denied the plaintiff's application for a temporary restraining order due to the failure of the petitioner to establish entitlement to extraordinary ex parte relief. The TRO, if granted, would have allowed prior restraint on BarkingDogs to publish anything defamatory (in the opinion of Lost Society), an action recognized as unconstitutional.

Judge Greenberg / Refusal to issue TRO on BarkingDogs

Dallas County Court at Law / Case #CC_10_08658_E / Lost Society et al v Barking Dogs et al



Answer from attorneys for Avi S. Adelman to lawsuit in re Lost Society
Response to Request for Disclosures
Adelman First Discovery Requests
Rule 11 Letter Re_ Discovery Deadline (Signed Copy)
Order Setting Injunction Hearing @ April 1, 2011

Defendants Brief in Opposition to Plaintiffs Application for Temporary Injunction

Plaintiffs Brief in Support of Plaintiffs Application for Temporary Injunction

In this filing, we learn some new information about the Plaintiff, Fernando Rosales. This text is quoted exactly as it was typed on the document:

Mr. Fernando Rosales is a thirty years old and a vetern of the military, where he served horably. He is a coollege graduate and is atending a master program in finance/accounting. He is engaged to be married to the daughjter of the former City of dallas, asst firechief. (sic)

The court has notified counsel he will issue a ruling on April 20, 2011, in reply to the motion for a Temporary Injunction. The request (above) for an evidentiary hearing was denied.


Defendants Motion to Strike Plaintiffs Responses

Motion for Summary Judgment

A full list of BarkingDogs articles about Lost Society, Fernando Rosales, or Brightman Nwatu is included below.

Also online: Unfair Park / Dallas Observer: Trying to muzzle a Barking Dog: Avi Adelman sued for defamation over Lost Society postings

Also online: Dallas.org: Indicted bar owner harasses activist

Also online: Reporters Committee for Freedom of the Press: Texas judge tosses request for restraining order on blogger

Also online: Dallas Observer: Harried Dog - Avi Adelman gets sued for libel


Articles about Lost Society, Fernando Rosales, or Brightman Nwatu posted on BarkingDogs.org since June 2010

December 4 - Lost Society - the gift you just can't get rid of

November 4 - BD subpoenaed to give testimony - for Lost Society???

October 30 - Think of those less fortunate - before they get deported

October 21 - One dead, one hurt in Lowest Greenville shooting

September 11 - Lost Society's Rosales back in pokey for skipping a hearing

August 10 - The trials and indictments keep rolling at Lost Society

July 2 - Even the Dallas Sheriff's Department is investigating Lost Society

June 30 - Fresh worms from Lost Society: Sexual assault lawsuit

June 28 - Lost Society scam unraveled by paperwork and stupidity

June 25 - Lost Society owner in custody for false statements

June 23 - Lost Society manager put on ICE after arrest, to be deported

June 10 - Why are Dallas County Sheriff deputies guarding gangsta' clubs????

June 3 - Early morning shooting leaves one dead on Char-Bar parking lot

Google search results - fernando rosales lost society


Fernando Rosales' Dallas County Booking Page

Dallas County Sheriff Department



CAUSE NO. CC-10-08658-E (sic from original text submitted by attorney for Lost Society)

FERNANDO ROSALES AND INITIATIVE PARTNERS, LLC. D/B/A LOST SOCIETY, IN THE DALLAS COUNTY COURT AT LAW #5

Plaintiffs

V.

AVI S. ADELMAN, BARKINGDOG. ORG, AND DALLAS CREATIVE, INC

Defendants.

PLAINTIFF’S AMENDED PETITION, REQUEST FOR EQUITABLE RELIEF, & REQUEST FOR DISCLOSURE

A. Discovery Control Plan

1. Plaintiff intends to conduct discovery under Level 2 of Texas Rule of Civil Procedure 190. 3

B. Parties

2. Plaintiff INITIATIVE PARTNERS, LLC is a Texas Limited Liability Company doing Business as Lost Society in Dallas County.

3. Plaintiff FERNANDO ROSALES is an individual living in Dallas County, Texas.

4. Defendant, AVI S. ADELMAN, is an individual and may be served with process at his residence at 5715 Belmont Drive, Dallas, Texas 75206, Dallas County, Texas.

5. Defendant, www. barkingdog. org is a website owned and operated by Defendant, Avi S, Adelman and may be served with process by serving the owner, Defendant Avi S. Adelman, at his residence at 5715 Belmont Drive, Dallas, Texas 75206, Dallas County, Texas

Defendant, Dallas Creative, Inc is a business owned and operated by the Defendant, Avi S. Adelman and Defendant, Dallas Creative, Inc, is the sponsor of the website, www. barkingdogs. org and may be served with process by serving the owner, Defendant, Avi s. Aderman at his residence at 5715 Belmont Drive, Dallas, Texas 75206, Dallas County, Texas.

C. Venue

6. Venue is mandatory in Dallas County under TCPRC15. 017 because this suit involves defamation and libel and this is he county where Plaintiff, Fernando Rosales and Defendant reside.

D. Jurisdiction

7. This court has jurisdiction of the subject matter and parties in this case.

E. Facts

8. On the below referenced dates, on the his website www. barkingdogs. org in Dallas County, Texas defendant, Avi S. Adelman, published defamatory statements concerning Plaintiffs.

9. On June 3, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, which is owned and maintained by Defendant.

10. The June 3, 2010 post titled, "Early Morning Shooting Leaves One Dead on Char-Bar Parking Lot," states that "[t]wo black males had just left Lost Society Bar" when an argument ensued and one of the males shot and fired four rounds at the other. Defendant has included links to a Dallas Morning News article and a Dallas Observer blog regarding the incident.

11. Defendant's statements about the males just leaving Lost Society bar are false and Defendant knew or should have known there was no basis for this statement. Defendant's own links to news stories regarding the incident make no mention of Lost Society.

12. In the June 3, 2010 post, Defendant made a false statement that the parties involved in the shooting were intoxicated at Lost Society. Defendant has no basis for this false statement and published it to the public as if it were true. Defendant's title of the post even claims that it is the"truth.”

13. On June 6, 2010, Defendant committed libel and published disparaging and defamatory words and pictures that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, which is owned and maintained by Defendant.

14. The June 6, 2010 post titled, "Truth in Advertising Comes to Lowest Greenville," exhibits a picture of Plaintiffs' business billboard sign with the words "LOST SOCIETY" in large letters and "The Ultimate Experience," which is Plaintiffs' slogan. Defendant replaced the picture on Plaintiffs' billboard sign with a picture of a shooting range: target in the shape of a human figure and added the statement "[b]eing murdered on the street after getting intoxicated at our bar, may not be considered an 'ultimate' experience."

15. Defendant has infringes and continues to infringe on Plaintiffs' service mark by creating a confusingly similar sign in Defendant's blog. Defendant received no permission' or license to use Plaintiffs' service mark.

16. Defendant is also violating trademark laws by causing tarnishment and dilution to Plaintiffs' mark by using it in Defendant's blog without permission.

18. Defendant has committed copyright infringement on Plaintiffs': copyright by creating a sign that is substantially similar to Plaintiffs' copyrighted sign design and text. Defendant had no license or permission to use Plaintiffs' copyrighted text or design.

19. On June 10, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, which is owned and maintained by Defendant.

20. The June 10, 2010 post states that "[l]ast week's murder by Char Bar took place after the victim and shooter partied at Lost Society," and calls Lost Society's owner "the scumbar owner.”

21. The June 10, 2010 post also states that Defendant called the Dallas Sheriff’s Office public affairs office and asked them if they "knew the reputation of the club,” implying that Plaintiffs have a bad or negative reputation.

22. The June 10, 2010 post then claims that other Greenville Avenue business owners are trying to "shut down" Lost Society because it is "killing their businesses by scaring people off" and that the club owner is "equally hated for his crap-on-you attitude.”

23. Because of Defendant's June 10, 2010 post, Plaintiffs have suffered damages and a loss of business dealings, as after this posting, the hired security officers that Lost Society regularly hired for added security at the bar, refused to honor their ongoing contract with. Lost Society.

24. On June 23, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiff ROSALES on a public Internet site, www. barkingdogs. org, which is owned and maintained by Defendant.

25 The June 23, 2010 post reads, "Sources tell BD this person is also on the list for a one- way ticket somewhere out of the country.” Defendant implied that Plaintiff ROSALES would be deported, when he knew or should have known the statement was false.

26. On June 25, 2010, Defendant posted a photograph of Plaintiff ROSALES on a public Internet site, www. barkingdogs. org, which is owned and maintained by Defendant.

27. Defendant is infringing on Plaintiff ROSALES' copyright by posting such picture without permission or a proper license.

28. On June 28, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org. which is owned and maintained by Defendant.

29. The June 28, 2010 post reads, "The shooting of a bar patron after he left Lost Society a few weeks ago did not set off the final alarm.”

30. Defendant's statements about the victim of shooting having been a patron of Lost Society bar are false and Defendant knew or should have known there was no basis for this statement.

31. On June 30, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, which is owned and maintained by Defendant.

32. The June 30, 2010 post reads, "Lost Society has been locked down by the landlord for violating their Don't get customers killed clause," which is false and misleading.

33. On July 2, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, owned and maintained by Defendant.

34. The title of the July 2, 2010 post reads, "Even the Dallas Sheriff's Department is Investigating Lost Society," which is untrue and defamatory.

35. Defendant knew or should have known that the headline of the July 2, 2010 post was false, especially since the post itself contained no information regarding an investigation of Lost Society by the Dallas Sheriff’s Department and no such investigation is occurring or has occurred.

36 On September 11, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, owned and maintained by Defendant.

37. The September 11, 2010 post reads, "Lost Society’s Rosales back in pokey for skipping a hearing.”

38. Defendant's statements of “Rosales skipped a hearing before a judge.. Not only did he skip it, but even his attorneys skipped the hearing” and “Rosales and his attorney reportedly told the judge they would try to make it to court in a few days, you know he’s kinda busy renovating the club without any permits” are false and Defendant knew or should have known there was no basis for this statement.

39. On October 21, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, owned and maintained by Defendant.

40. The October 30, 2010 post reads, "One dead, one hurt in Lowest Greenville shooting"

41. Defendant's statements of “This is the second shooting in less than six months on Lowest Greenville. A patron of Lost Society was shot and killed on the Char-Bar parking lot in early June 2010..” are false and Defendant knew or should have known there was no basis for this statement.

42. On October 30, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, owned and maintained by Defendant.

43. The October 30, 2010 post reads, "Think of those less fortunate - before they get deported"

44. Defendant's statements of “There's no word on when his former partner and BFF, Fernando Rosales, will be back in detention, but the wheels of justice they do grind slowly. We are patient.” are false and Defendant knew or should have known there was no basis for this statement.

45. On December 4, 2010, Defendant committed libel and published disparaging and defamatory words that were untrue about Plaintiffs on a public Internet site, www. barkingdogs. org, owned and maintained by Defendant.

46. The December 4, 2010 post reads, "Lost Society - the gift you just can't get rid of"

47. Defendant's statements of “For example, hosting Sunday afternoon block parties starting at 2pm, even though the lease said they could not open for business until 5pm. And the good news for Lowest Greenville's other scumbars- Lost Society is going to be providing lots of story ideas and leadership for at least four more years, if not longer.. If Rosales is trying to pump up sales by offering lunch, he better have a killer menu and chef in the kitchen (pardon the pun). In fact, it would help if he had a kitchen that could pass a health inspection after years of sitting idle since Suede installed it. Their liquor sales ain't doing too hot either, according to the Texas Comptroller and AlcoholSales. com. In the months after the patron was killed at Char Bar, sales are down nearly 30% compared to the same months last year. There's still plenty of time for Lost Society and its scummy owner to provide stories to BD and the local media, as well as keep the attention of the TABC.” are false and Defendant knew or should have known there was no basis for this statement.

F. Grounds for TRO

48. Plaintiff will suffer immediate and irreparable injury, loss, or damage, if Defendants' conduct described above is not enjoined for these reasons: Plaintiffs does not have an adequate remedy at law because Defendant will not be able to satisfy the judgment that will probably be rendered in Plaintiffs's favor in this suit; Defendant lacks nonexempt property with which to satisfy the judgment; Defendant has demonstrated unwillingness to pay Plaintiffs's claim; and this conduct of Defendant will result in Defendant's not having assets subject to execution". Plaintiffs has exercised due diligence in prosecuting this claim. The injury to Plaintiffs if Defendants continue the conduct described above would outweigh any injury the restraining order and injunction might cause Defendants, and issuance of the restraining order and injunction would not disserve the public interest. Plaintiffs is willing to post a bond to secure TRO.

G. Request for Temporary Restraining Order, Temporary Injunction and Injunction

49. Petitioner requests the Court to dispense with the issuance of a bond, and Petitioner requests that Respondent be temporarily restrained immediately, without hearing, and after notice and hearing be temporarily enjoined, pending the further order of this Court, from: the below listed requests. Petitioner requests the Court, after notice and hearing, to dispense with the issuance of a bond, to make temporary orders and issue any appropriate temporary injunctions for the preservation of the property and protection of the parties as deemed necessary and equitable. Petitioner requests that the Court enjoin Respondent and order the following:

50. The Defendants, Avi S. Adelman and Barkingdogs. org be should be restrained from publishing false defamatory statements concerning Plaintiffs, Fernando Rosales, Lost Society and Initiatve Partners,LLC;

The Court should order that the Defendants, Avi S. Adelman, Dallas Creative, Inc. , and Barkingdogs. org be ordered to delete and remove all defamatory statements concerning plaintiffs, Fernado Rosales, Lost Society and Initiatve Partners,LLC that were published by the defendants on the internet, including, the website www. barkingdogs. org

51. The Court should order the parties to mediate this matter.

H. Count 1 - Defamation

52. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety here

53. Defendant published statements by written communication in his blog asserting them as facts;

54. The statements involved a private matter.

55. The statements referred to plaintiff by name.

56. The statements were defamatory.

57. The statements were false.

58. Defendant is strictly liable to plaintiff for the defamation.

59. Defendant’s false statements caused injury to plaintiff, which resulted in the damages.

60. Plaintiff seeks unliquidated damages within the jurisdictional limits of this court.

61. Exemplary damages. Plaintiff’s injury resulted from defendant’s malice, which entitles plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41. 003(a).

I. Count 1 - Defamation

62. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

63. Defendant published a statements by written communication asserting as facts.

64. The statement involved a public matter.

65. The statement referred to plaintiff by name.

66. The unambiguous statements were defamatory

67. The statement were false

68. Defendant was negligent in determining whether the statement was true.

69. Defendant’s false statement caused injury to plaintiff, which resulted in the damages.

70. Plaintiff seeks unliquidated damages within the jurisdictional limits of this court.

71. Exemplary damages. Plaintiff’s injury resulted from defendant’s malice and knowledge of the statement’s falsity or reckless disregard for the truth, which entitles plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41. 003(a).

72. Exemplary damages. Plaintiff’s injury resulted from defendant’s malice, which entitles plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41. 003(a). Alternatively, Plaintiff’s injury resulted from defendant’s malice and knowledge of the statement’s falsity and/or reckless disregard for the truth, which entitles plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41. 003(a).

J. Count 2 - Libel Per Se

73. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

74. Defendant’s written statements described in Count 1 was libel per se as defined by Texas Civil Practice & Remedies Code section 73. 001. Defendant’s statement

(A) injured plaintiff’s reputation and exposed plaintiff to public hatred, contempt, ridicule, or financial injury.

(B) impeached plaintiff’s honesty, integrity, virtue, or reputation.

(C) described plaintiff’s natural defects and exposed plaintiff to public hatred, ridicule, or financial injury.

75. The defamatory statement requires no proof of its injurious character because it was obviously hurtful to plaintiff.

K. Count 3 - Defamation Per Se

76. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

77. Defendant’s written statements described in Count 1 was defamatory per se under the common law. Defendant’s statement

(A) injured plaintiff in plaintiff’s profession and/or occupation.

(B) falsely charged plaintiff with a crime punishable by imprisonment.

78. The defamatory statement requires no proof of its injurious character because it was obviously hurtful to plaintiff.

L. Count 4 - Intentional Infliction of Emotional Distress

79. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

80. In the alternative to all other counts, defendant intentionally caused plaintiff emotional distress.

81. Defendant’s conduct set forth herein and described above was intentional or reckless.

82. Defendant’s conduct was extreme and outrageous without verification and disregarding the truth

83. Defendant’s conduct proximately caused severe emotional distress to plaintiff.

84. Plaintiff’s severe emotional distress cannot be remedied by any other cause of action.

85. Defendant’s wrongful conduct caused damages:

86. Plaintiff seeks unliquidated damages within the jurisdictional limits of this court.

87. Exemplary damages. Plaintiff’s injury resulted from defendant’s malice, which entitles plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41. 003(a).

M. Count 5 - Business Disparagement

88. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

89. Defendants published written disparaging words about plaintiff’s Lost Society

90. The words were false.

91. Defendant published the words with malice or actual malice

92. Defendant published the words without privilege.

93. Defendant’s false statement caused injury to plaintiff, which resulted in the special damages.

94. Plaintiff seeks unliquidated damages within the jurisdictional limits of this court.

N. Count 1 - Tortious Interference with Prospective Relations

95. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

96. Plaintiff was prepared to enter into a contract with another party to prospective contract

97. Plaintiff had an ongoing business relationship with said party.

98. Defendant knew of plaintiff’s prospective contract or business relationship and intentionally interfered with it.

99. Defendant’s actions were independently tortious or unlawful, regardless of the effect those actions had on plaintiff’s prospective contract or business relationship with the other party to prospective contract and/or ongoing relationship.

100. Plaintiff suffered actual damage or loss because defendant’s interference prevented plaintiff from entering into the prospective contract and/or continuing plaintiff’s business relationship the other party to the prospective contract or ongoing relationship

101. Defendant’s interference proximately caused injury to plaintiff, which resulted in damages.

101. Plaintiff seeks unliquidated damages within the jurisdictional limits of this court.

103. Exemplary damages. Plaintiff’s injury resulted from defendant’s malice or actual fraud, which entitles plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41. 003(a).

O. Count 2 - Tortious Interference with Existing Contract

104. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

105. In the alternative or in addition to other counts, defendant interfered with plaintiff’s contract with his landlord, Wonderful Seven A.

106. Plaintiff had a valid contract with his landlord, Wonderful Seven-A.

107. Defendant knew or had reason to know of plaintiff’s contract with his landlord and plaintiff’s interest in the contract.

108. Defendant willfully and intentionally interfered with plaintiff’s contract with his landlord.

109. Defendant’s interference proximately caused injury to plaintiff, which resulted in the actual damage or loss.

110. Plaintiff seeks unliquidated damages within the jurisdictional limits of this court.

111. Exemplary damages. Plaintiff’s injury resulted from defendant’s malice or actual fraud, which entitles plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41. 003(a).

P. Application for Temporary Restraining Order

112. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

113. Plaintiff’s application for a temporary restraining order is authorized by Tex. Civ. Prac. & Rem. Code §65. 011(1).

114. Plaintiff asks the court to The Defendants, Avi S. Adelman and Barkingdogs. org be should be restrained from publishing false defamatory statements concerning Plaintiffs, Fernando Rosales, Lost Society and Initiatve Partners,LLC.

115. It is probable that plaintiff will recover from defendant after a trial on the merits because Plaintiff is able to prove the elements of the counts alleged herein

116. If plaintiff’s application is not granted, harm is imminent because defendant will continue to publish false unverified defamatory statements against plaintiff’s causing damages and irreparable harm.

117. The harm that will result if the temporary restraining order is not issued is irreparable because the damage and injury will continue to plaintiff’s reputation, loss of goodwill and economic business loss.

118. Plaintiff has no adequate remedy at law because certain damages are incalculable and defendant is insolvent.

119. Plaintiff is willing to post bond.

Q. Ex Parte Relief

120. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

121. There is not enough time to serve notice on defendant and to hold a hearing on this application. Defendant will continue to publish defamatory staements about Plaintiffs.

R. Request for Temporary Injunction

122. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

123. Plaintiff asks the court to set his application for temporary injunction for a hearing and, after the hearing, issue a temporary injunction against defendant.

124. Plaintiff has joined all indispensable parties under Texas Rule of Civil Procedure 39.

S. Request for Permanent Injunction

125. Plaintiff’s incorporate the above-referenced paragraphs as if recited in their entirety herein

126. Plaintiff asks the court to set his request for a permanent injunction for a full trial on the merits and, after the trial, issue a permanent injunction against defendant.

T. Jury Demand

127. Plaintiff demands a jury trial and tenders the appropriate fee with this petition.

U. Request for Disclosure

128. Under Texas Rule of Civil Procedure 194, plaintiff requests that defendant disclose, within 50 days of the service of this request, the information or material described in Rule 194.2.

V. Prayer

129. For these reasons, plaintiff asks that the court issue citation for defendant to appear and answer, and that plaintiff be awarded a judgment against defendant for the following:

a. Actual damages.

b. Physical pain and suffering in the past;

c. Physical pain and suffering in the future;

d. Lost profits past and future;

e. Loss of Goodwill;

f. Damages to Business’s credit reputaion;

g. Mental anguish in the past; and

h. Mental anguish in the future.

i. TRO and Permenant Injunction

j. Exemplary damages.

k. Prejudgment and postjudgment interest.

l. Attorney fees.

m. All other relief to which plaintiff is entitled.

n. Court costs

Respectfully submitted,

Armando Miranda

Texas Bar No. 14199599

923 W/. Jefferson.

Dallas, Tx. 75208

Tel. (214) 943 4888

Fax. (214) 943 2544

Attorney for Plaintiffs

By Avi S. Adelman under Neighborhoods , Legal issues