DARLENE BARRON vs. STEINBOK HOSPITALITY INC

COMES NOW, L.G., a minor (hereinafter referred to as "Plaintiff"), by and through L.G.'s Next Friend, Darlene Barron, and by and through undersigned coun- sel, and respectfully files this Original Petition against Steinbok Hospitality, Inc. d/b/a Holiday Inn Express (hereinafter referred to as "Steinbok" or "Defendant").

In support hereof, Plaintiff would state and show unto this Honorable Court the following:

Plaintiff intends to conduct discovery under Level 3 pursuant to Rule 190.4 1. of the Texas Rules of Civil Procedure.

2. Plaintiff L.G., a minor appears in this action by and through L.G.'s Next Friend, Darlene Barron, who is L.G.'s mother. L.G. is an individual who resides in and is a citizen of the State of Texas.

3. Defendant Steinbok Hospitality, Inc. ("Steinbok"), is a corporation doing business in Texas. Service of process upon this Defendant may be had by serving its registered agent for service, Natasha Kassam, - 4142 , or wherever Defendant may be found.

4. Plaintiff prefers to have the jury determine the fair amount of compensation for Plaintiff's damages. It is too early in the case to be assessing the full nature and scope of Plaintiff's damages, and Plaintiff places the decision regarding the amount of compensation to be awarded in the jury's hands.

5. Rule 47 of the Texas Rules of Civil Procedure, however, requires Plaintiff to provide a statement regarding the amount of monetary relief sought. Accordingly, Plaintiff states that monetary relief of over $250,000 but not more than $1,000,000, in an amount to be determined by the jury, is being sought.

6. Pursuant to the Texas Rules of Civil Procedure and/or any applicable Texas statute, Plaintiff hereby gives notice that Defendant is being sued in all of its business

or common names regardless of whether such businesses are partnerships, unincor- porated associations, individuals, entities, limited liability companies, or private cor- porations. Furthermore, in the event that any parties are misnamed or not included herein, it is Plaintiff's contention that such was a "misnomer" and/or parties are/were "alter egos" of parties named herein.

7. On or about July 23, 2023 , L.G., a minor, was on Defendant's premises, and Plaintiff was injured while on Defendant's premises.

8. More specifically, Plaintiff was at one of Defendant's properties, Holiday Inn Express.

9. Plaintiff was at the Holiday Inn Express when a sign fell on him.

10. At all times mentioned herein, Defendant was in control of, the possessor of, maintained, leased, and/or owned the premises on which Plaintiff's injuries occurred.

11. Defendant had a duty to use ordinary care to ensure that the premises did not present a danger to Plaintiff. This duty included, but is not limited to, the duty to inspect and make safe any dangerous condition and/or the duty to warn and/or to cure.

12. Plaintiff was an invitee at the time the injury occurred.

13. Plaintiff suffered injuries as a result of this incident.