Jaime Cortes v. Frias Et Al

8/9/2019 Jaime Cortes v. Frias Et Al

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CAUSE NO. DVl 0-02239-E . .. .' ' 'Wf 4 " .'THE STATE OF TEXAS, EX REL. IN THE DISTRICT ~ m f ~ ' 6. 1),o,c 1/


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election in November 2010 and have any hope of continuing in office beyond January 2011.II.

Defendant can be removed from office pursuant to Section 87.013 of the Texas LocalGovernment Code only for incompetency, official misconduct, or intoxication. The affidavitsattached to the Original Petition show that the affiants have little, if any, personal knowledge of anyconduct ofDefendant which could be the basis for his removal from office. Instead, those affidavitscontain and relate little more than hearsay, unsubstantiated conclusions and opinions, admissions,rumors, assumptions, presumptions, and innuendo; therefore, no reasonable and unbiased person

who did not intend harm to Defendant would have believed either the allegations contained in thoseaffidavits or the allegations contained in the Original Petition. Consequently, the Original Petitionwas not filed in good faith, and neither Plaintiffs nor their attorney made a reasonble inquiry into thefacts and the affidavits attached to the Original Petit ion prior to filing it. Likewise, the allegationscontained in the Original Petition have no good-faith basis in law or in fact, are groundless, and wereclearly made only to harass Defendant.


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roommate Jim Foster as reserve Deputy Constables. After Jim Foster was elected Dallas CountyJudge in November 2006, Judge Foster, County Commissioner Kenneth Mayfield, and anotherDallas County Commiss ioner hired Danny Defenbaugh to investigate Defendant, even though theDallas County District Attorney and other law enforcement agencies have investigated Defendantand declined to request the indictment ofDefendant on any charge. Judge Foster, CommissionerMayfield, and another Dallas County Commissioner hired John Barr to represent Judge Foster andDanny Defenbaugh. Judge Foster and Commissioner Mayfield also voted to approve John Barr'swife as a Dallas CountyMagistrate Judge. Danny Defenbaugh is a tenant of John Barr and regularlyworks as an investigator for John Barr. It is also Defendant's information and belief that theaffidavits attached to the Original Petition were given to Mr. Defenbaugh as part ofhis investigationon behalf of the Dallas County Commissioners Court to further their efforts to smear and harmDefendant and to prevent his re-election.

IV.Based upon the foregoing, Defendant hereby sues Plaintiffs GUADALUPE FRIAS, LOIS


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VI.Defendant further requests that this Court award him a Judgment for reasonable and

necessary attorney's fees, expenses, and Courts costs against Plaintiffs, both through the trial in thiscause and all subsequent appeals, as are equitable and just.

ORIGINAL ANSWERVII.

Defendant enters a general denial and denies each and every, all and singular, the allegationscontained in the pleadings of Plaintiffs and demands strict proof thereof.

VIII.Defendant demands a trial by jury, as Section 87.018 ofthe Local Government Code states

that he may be removed from office only following a trial by jury.IX.

Defendant specifically denies the following allegations in the Original Petition:


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C. That Defendant has engaged in conduct that makes him subject to removal from officetemporarily and/or permanently;D. That Defendant created a quota system by establishing or suggesting a certain number oftraffic tickets be issued by his deputy constables;E. That Defendant violated subsections (a)(2) and/or (b)(l) of Section 72.002 of the TexasTransportation Code and thereby committed misconduct, which is a ground for his removal fromoffice;F. That, during daily briefings or at any other time, Defendant personally and/or through Sgt.

Michael Hinojosa or any other person constantly told his deputy constables to ticket cars and/or theirdrivers and to tow cars;G. That Defendant mandated and/or required his deputy constables to ticket drivers and tow carsifthe driver had no proofof insurance, an expired driver's license, or expired registration;H. That Defendant maintained a policy ofrequiring his staffto work at various campaign events,that Defendant circulated a sign-up sheet at daily briefings for his deputy constables and/or staffto


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various neighborhoods, that any deputy constable who did not volunteer would be harassed on thejob, that Defendant and/or any other person acting on his behalf and/or with his knowledgementioned that a deputy constable had not attended an event or threatened to remember who did andwho did not attend an event;K. That Defendant inflicted a pattern of oppression on any employees of Precinct 5 ofDallasCounty, that Defendant authorized or encouraged sign-up sheets in the daily briefing room for deputyconstables to volunteer to work on Defendant's campaign, that Defendant expected his deputycontables to volunteer to work on his campaign, that the job of any employee of Precinct 5 could

have been lost if that employee did not volunteer to work on Defendant's campaign, and thatDefendant ever said or expected 100% participation in weekend neighborhood sweeps or in anycampaign event;L. That Defendant personally and/or through any other person asked deputy constables tovolunteer at the polls and/or to hand out campaign material on election day in November 2008 andthat any employee of Precinct 5 had any reason to believe that his or her job could be lost ifhe or


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officers or deputy constables, that Defendant required only his friends to be assigned to such off-dutywork opportunities, and that Defendant threatened to cancel the account of any officer or deputyconstable;O. That Defendant required the deputy constables who were assigned off-dutywork to kick back$5.00 for being assigned a job, cancelled any account when kick backs were not paid, and/orcondoned such conduct;P. That Defendant insisted that Deputy Nosheska Garcia be given special favors or herpreference ofoff-duty jobs, cancelled any account when DeputyNosheska Garcia was not employed

or given any off-duty job(s), threatened to terminate any person ifDeputy Nosheska Garcia did notreceive her preference of off-duty assigmnents, and/or condoned such conduct;Q. That Defendant questioned Deputy Guadalupe Frias about which supervisors were beingassigned to off-duty work and/or cancelled all off-duty assigmnents;R. That Defendant required supervisors to be paid $25.00 more than the deputy constablesassigned to off-duty work, required that that $25.00 had to be deducted from the money paid to the


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whether he is indicted;V. That Defendant personally and/or through any otherperson required deputy constables or anyother employees of Precinct 5 to sell raffle tickets for Defendant, threatened to harass and/ordiscipline any employee who did not sell such raffle tickets, required any employee to pay for suchraffle tickets ifhe or she did not sell them, and/or condoned such conduct;W. That Defendant required his deputy constables to use only the Dowdy Ferry Towing Serviceto tow all vehicles in Precinct 5, that Defendant received a $25.00 payment for each vehicle whichhis deputy constables requested be towed by or any payment from the DowdyFerry Towing Service,and that Defendant condoned the payment of any money to any person by the Dowdy Ferry TowingService;X. That Defendant violated Section 36.02 ofthe Texas Penal Code or committed the offense ofbribery or corrupt influence;Y. That Defendant has done anything to harm the employees of his office, the taxpayers of


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or will create liability for Dallas County; is wrongful and/or unprotected by any right or entitlement;and has created fear of adverse employment action if Precinct 5 employees complain aboutDefendant or cooperate in Dallas County's ongoing investigation of Defendant;CC. That Plaintiffs, Precinct 5 employees, and/or Dallas County have no adequate remedy at law;that Plaintiffs, Precinct 5 employees, and/or Dallas County have incurred any losses or damages dueto Defendant's conduct; that the financial losses to Dallas County and its taxpayers are likely toexceed Defendant's financial net worth or ability to account for those losses; and that sufficientcompensation will be unavailable ifmoney damages are an adequate remedy in this cause;

DD. That a temporary injunction as requested by Plaintiffs is necessary to preserve the status quoand the property of Plaintiffs, Dallas County, and/or its taxpayers;EE. That Plaintiffs have demonstrated that Defendant is likely to retrieve information from anyof the records of Dallas County or to alter any of that information to the harm of Plaintiffs, DallasCounty, and/or its taxpayers;


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evidence of his wrongdoing;n. That Defendant will conceal or destroy evidence ofhis conduct and has undertaken actionsagainst Precinct 5 employees to create fear ofadverse employment action if any of those employeescomplain about him;KK. That Plaintiffs are entitled to rel ief under Sections 37.003, 37.004(a), and/or 37.009 of theTexas Uniform Delcaratory Judgments Act;LL. Since, the Original Petition is verified by Lois Martin, Defendant denies that, other than theallegations contained in section XI(4) of the Original Petition, she has personal knowledge ofmostof the alleged facts supporting the requested removal ofDefendant from office, despite her swearingto have that personal knowledge under oath;MM. That Plaintiffs are entitled to the relief they seek, since they have not posted "security forcosts" and as the Judge of this Court has not required Plaintiffs to do so, as stated in Section87.016(c) of the Texas Local Government Code;


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hereto. Defendant, accordingly, denies that the last two photocopies attached to the Original Petitionare complete and that they contain campaign material.

x.

Defendant pleads the following affirmative defenses:A. Plaintiffs are legally and/or Constitutionally estopped from suing Defendant in this causeunless and until they are represented by the Dallas County Attorney;B. Illegality prevents the State of Texas from being the Plaintiff in this cause, as Section87.018(d) of the Local Government Code requires "the state" to be represented by "[t]he countyattorney . . . in a proceeding for the removal of an officer . . . ;" andC. Plaintiffs can recover nothing and can be granted no rel ief in this cause, as Defendant iscloaked with official, sovereign, judicial, and/or legislative immunity, and Plaintiffs have not pleadin the Original Petition a statutory waiver of immunity, plead a jurisdictional basis, and/ordemonstrated that this Court has subject matter jurisdiction over this cause.


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case permits;"B. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegation in section VI(3) of the Original Petition that Defendant hasengaged in conduct which makes him subject to removal from office;C. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegation in the first sentence of section VIl( 1) of the OriginalPetition that Defendant created a quota system by establishing or suggesting a certain number oftickets by issued by his deputy constables;

D. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegation in section VIl(2) of the Original Petition that, by violatingSection 72.002 of the Texas Transportation Code, Defendant committed official misconduct and aground for his removal from office. Plaintiffs should be ordered to state specific facts showing howDefendantviolated subsections (a)(2) and/or (b)(1) ofSection 72.002 oftheTransportation Code and


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insurance, an expired driver's license, or expired registration and to clearly state why James DeCouxfeared retaliation if the car ofthe elderly man who was a double amputee was not towed;G. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support ofthe allegations in section VIII(l) of the Original Petition that Defendantmaintained a policy of requiring his staff to work at various campaign events, that Defendantcirculated a sign-up sheet at daily briefings, and that Defendant would announce at these meetingsthat participation was mandatory. Plaintiffs should also be required to clearly state which deputyconstables handed out campaign material for Defendant while on duty and in uniform at a candidate

meet-and-greet at the Communications Workers' union hall and when that occurred;H. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section VIII(2) of the Original Petition. Plaintiffsshould be required to clearly state who requested volunteers to work at a domestic violence eventin April 2009, why Sgt. Knight's alleged statement "that all team players sign up" should be


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J. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section VIlle4) of the Original Petition. Plaintiffsshould be required to clearly state when Defendant demanded that his deputy constables volunteerfor weekend literature drops in various neighborhoods, why Deputy Willie felt that he would beharassed on the job if he did not volunteer, who mentioned the following day and to whom if adeputy constable did not attend such an event, why Deputy Bostic' s alleged statement that "he wouldremember who did and who did not choose to volunteer" should be attributed to Defendant, whichdeputy constables "volunteered" to weekend literature drops, who that literature benefitted or named,

and why Defendant's statement that those who chose not to volunteer were exercising their ownprerogative should not have been believed;K. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section VIII(5) of the Original Petition. Plaintiffsshould be required to clearly state what pattern ofoppression applied to many employees ofPrecinct


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L. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section VIll(6) of the Original Petition. Plaintiffsshould be required to clearly state who asked deputy contables to volunteer at the polls on electionday in November 2008 and why any such requests should be attributed to Defendant, who "Polk"is, who told Polk to take a vacation day but appear in uniform, who told Polk that the peopledelivering food would give him a box lunch during that day based upon the fact that he was wearinghis uniform, who gave Polk campaign material to hand out that day, who told Polk to hand out thatcampaign material, who that campaign material benefitted or named, and why Polk feared that he

would lose his job ifhe did not volunteer to work that day;M. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section VIll(7) of the Original Petition. Plaintiffsshould be required to clearly state what conduct ofDefendant potentially violates any Texas statute,specifically including, but not limited to, Section 253 .003oftheTexas Ethics Commission, Sections


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Guadalupe Frias to employ Defendant's friends when assigning officers and/or deputy constablesto such work, and when Defendant threatened to cancel the account of any officer or deputyconstable and for what reason(s);O. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section IX(2) of the Original Petition. Plaintiffs shouldbe required to clearly state who required deputy constables who were assigned off-duty work to kickback a $5.00 charge for being assigned such a job and when that occurred, why that should beattributed to Defendant, who instructed or said that DeputyN osheska Garcia was assigned to all suchjobs which she wanted and when that occurred, why that instruction or statement should be attributedto Defendant, who cancelled any account at the end of August and in which year that occurred, towhom Deputy Frias was expected to pay the required kick backs, why Deputy Frias did not wish toemployDeputy Nosheska Garcia, who threatenedDeputyFrias with termination ifDeputyNosheskaGarcia did not receive her preference of off-duty work assignments, when that occurred, and why


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assigmnents to 2 officers is related in Defendant in any way;Q. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support ofthe allegations in section IX(4) ofthe Original Petition. Plaintiffs shouldbe required to clearly state who decided that supervisors were to be paid $25.00 more than the deputyconstables assigned to off-duty work and when that occurred, who decided that that $25.00 had tobe deducted from the money paid to the deputy constables if the client refused to pay that extra$25.00 and when that occurred, and why any of this should be attributed to Defendant;R. For the same reasons, Defendant requests that this COUli Order Plaintiffs to clearly statespecific facts in support of the allegations in section IX(5) of the Original Petition. Plaintiffs shouldbe required to clearly state what conduct ofDefendant violated Section 36.06 and/or Section 39.03of the Texas Penal Code and/or constitutes obstruction, retaliation, and/or official oppression;S. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section X(l) of the Original Petition. Plaintiffs shouldbe required to clearly state which deputy constables were told by Defendant that, if they talked to the


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U. For the same reasons,Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section X(3) ofthe Original Petition. Plaintiffs shouldbe required to clearly state on which social media site the February 3,2010 staff meeting was madepublic and provide details regarding how that social media site can be accessed, so the recording ofthat meeting can be viewed and/or listened to;V. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section X(4) ofthe Original Petition. Plaintiffs shouldbe required to clearly state which deputy constables were told by Defendant that, ifhe was indicted,

he would obtain a bond, would then deal with the deputies while he was still in office, and that hehad seen some affidavits from deputy constables, and when that occurred;W. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section X(5) of the Original Petition. Plaintiffs shouldbe required to clearly state what conduct of Defendant violated Sections 36.05, 36.06, and/or 39.03


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pay for the tickets he was given since he did not sell them, and why that should be attributed toDefendant;Y. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section XI(2) of the Original Petition. Plaintiffs shouldbe required to clearly state how and/or why Chief Ken Hines' alleged statements to Deputy JamesDeCoux should be attributed to Defendant and when the things alleged in that section occurred;Z. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support of the allegations in section XI(3) of the Original Petition. Plaintiffs should

be required to clearly state how and/or why Chief Ken Hines' alleged conduct and statement toDeputy DeCoux should be attributed to Defendant, when that occurred, and why Defendant wouldnot like Deputy DeCoux giving his check and a raffle ticket back to Chief Hines;AA. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support ofthe allegations in section XI(4) of the Original Petition. Plaintiffs should


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constituted making or accepting contributions in violation of Chapter 253 of the Texas EthicsCommission, abuse ofhis official capacity or ofthe official capacity ofany deputy constable, officialoppression, or a violation of any Standards of Conduct and/or state agency ethics policy;Cc. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support ofthe allegations in sectionXII(l) of the Original Petition. Plaintiffs shouldbe required to clearly state how Defendant required his deputy constables to use only the DowdyFerry towing service to tow all vehicles in Precinct 5, when Defendant stated that requirement andto whom, how Sgt. Howard Watson's alleged statements to Deputy Willie should be attributed toDefendant, why what Sgt. Howard Watson allegedly told Deputy Willie should be believed, andwhen and where each ofthese alleged statements by Sgt. Howard Watson to Deputy Willie occurred;DD. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support ofthe allegations in section XII(2) ofthe Original Petition. Plaintiffs shouldbe required to clearly state what conduct of Defendant violated Section 36.02 of the Texas Penal


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should be required to clearly state what justifies waiver of a bond for any person appointed astemporary Constable ofPrecinct 5 ofDallas County, especially since Section 87.017 (b) requires theexecution of such a bond with at least 2 good and sufficient sureties in an amount and on conditionsfixed by the Judge ofthis Court;GG. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support ofthe allegations in section XV( 1)oftheOriginal Petition. Plaintiffs shouldbe required to clearly state what conduct of Defendant has resulted and will continue to result inirreparable harm to Precinct 5 employees, the property and rights ofDallas County, and the taxpayers

ofDallas County and/orhas created liability and for whom, is wrongful and unprotected by any rightor entitlement, and has created fear of adverse employment action if employees of Precinct 5complain about him or cooperate in Dallas County's ongoing investigation of Defendant;HH. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in supportofthe allegations in section XV(2) ofthe Original Petition. Plaintiffs should


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preserve the status quo and the property of Plaintiffs, Dallas County, and its taxpayers;JJ. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in support ofthe allegations in section XVII ofthe Original Petition. Plaintiffs shouldbe required to clearly state how and why it is essential that this Court immediately restrainDefendant, as they request, without prior notice to Defendant; how Defendant has undertaken acourse of conduct to squelch the reporting or discovery of evidence of his wrongdoing; and howDefendant is likely to conceal or destroy evidence ande/or has previously done so; andKK. For the same reasons, Defendant requests that this Court Order Plaintiffs to clearly statespecific facts in supportof the allegations in section XVIII ofthe Original Petition. Plaintiffs shouldbe required to clearly state why Plaintiffs are entitled to relief under Sections 37.003, 37.004(a),and/or 37.009 of the Texas Uniform Delcaratory Judgments Act; why Plaintiffs need a declarationof their right to be free from intimidation, harassment, and retaliation by Defendant and to be freefrom supervision by Defendant; why this justifies or entitles Plaintiffs to injunctive relief; and whyPlaintiffs are entitled to recover any attorney's fees and/or an award of costs.


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MOTION FOR SANCTIONSXIII.

Defendant denies that Plaintiffs and their attorney read the Original Petition in this causeprior to filing it. Likewise, Defendant denies that Plaintiffs and their attorney read the affidavitsattached to the Original Petit ion prior to filing that Original Petition because, based upon the hearsay,unsubstantiated conclusions, and admissions contained in those affidavits, no reasonable andunbiased person could or would have verified the Original Petition and/or would have believed thatthe allegations contained in that Original Petition could have been made in good faith, with a basisin law or in fact, and not for the purpose of harassing Defendant.

XIV.Consequently, Defendant alleges that the Original Petition is groundless and that Plaintiffs

and their attorney filed the Original Petition in bad faith and for the purpose of harassment ofDefendant. Because Plaintiffs and their attorneys should have known statements in the Original


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Defendant additionally prays that this Court, after hearing, grant his Plea to the Jurisdiction anddismiss this cause. In addition, Defendant prays that this Court, after service ofnotice on PlaintiffsGUADALUPE FRIAS, LOIS MARTIN, and LESLIE WILLIE a/kla LES WILLIE and their attorneyF. Benjamin Rick, III and after hearing, find good cause for the imposition of sanctions on bothPlaintiffs and their attorney as authorized by Rules 13 and 215-b2 of the Texas Rules of CivilProcedure because Plaintiffs and their attorney signed and/or filed the Original Petition in bad faithand for the purpose of harassment, knew or should have known that statements in the OriginalPetition are groundless and false and that Plaintiffs and their attomey should be held guilty of

contempt for filing the Original Petition. Defendant further prays that Plaintiffs GUADALUPEFRIAS, LOIS MARTIN, and LESLIE WILLIE a/k/a LES WILLIE be cited to appear and answerDefendant's Counter-Claim and that, after final hearing, this Court enter a Declaratory Judgment inthis cause that Plaintiffs are not entitled to the relief which they seek in this cause for failing tocomply with all statutory requirements and all conditions precedent and award him a Final Judgment


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further relief, both at law and in equity, to which he may show himselfjustly entitled.Respectfully submitted,T AW OFFICES OF DOMINGO A. GARCIA. P.C.- ,

I 'BDomingo A. GarciState Bar No. 0763 50Paul D. Rich, OfCounselState Bar No. 16842500

600 Bank ofAmerica Tower - Oak Cliff400 S. Zang Blvd.Dallas, Texas 75208Telephone:(214) 941-8300Facsimile:(214) 943-7536ATTORNEYS FOR DEFENDANT

VERIFICATIONSTATE OF TEXAS ]


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witr ~ " mv hand and official seal.

/1--Notary Public in and for the State of TexasMy Commission Expires: December 9, 2010 Print Notary's Name: Mark W. Nelson

CERTIFICATE OF SERVICEA true and correct photocopy of this document was served upon all counsel of record in this

cause on March 24, 2010 in accordance with TEX. R. CIV. P. 8,21, and 21a.~ - - - - - - .,'''''

/I

- - ' - - -Domingo A. Garcia


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CONSTABLE JAIME CORTES: A life long resident of Precinct 5 Began his career in law enforcement as a reserve

deputy constable with Dallas County Precinct 6 in1997.

He quickly became a permanent employee that sameyear with Dallas County Constable's Office Precinct7 as a deputy constab le.

After the merger of precincts 7 & 8 and under the leadership of Constable Derick Evans, he served as one of theSergeants in charge of overseeing the Traffic Divisionfor Dallas County Constable's Office Precinct l.Serving as a Sergeant of Precinct 1, Constable JaimeCortes not only assisted in providing leadership to thetraffic division of precinct 1, he also aided in the fieldtraining of the Civil Division and was a community service liaison. A Certified basic police instructor A Certified field training officer Firearms Instructor Spanish Instructor Specialized Gang Recognition Training, H o s t a g ~ ; N e g o t i a t i o n s ~ First R e s p o I t d ~ r T r a i n i n g

' ] t h e t W Q o d ~ i l 1 ~ ~ o f f i ~ t : r ~ " i a s i , g ; h e ( I t 9 , p i l o t

Constable Senice fees:~ , . . .Citations, Subpoenas, Summons, ProtectiveOrders, Notices, Citations by Publication& Evictions $60JHlWrits of Garnishment, Attachment&: Sequestration 511O.UOFor additional Fees of Service COil tart the office,Cash, Cashiers Checks or Money Orders AcceptedMade Payable to Dallas County.l i ee Seh!.!!:ule for Jr 5-2 Court:\'11 rt t of Execu lion IDa lias County) S l15.t{j'\Vrit of possession, including Sen ice Ie,,: for on!,\ ,lPeIJefendalll (Dallas CO) Plus S3600 pel depUl) a Jt(:i 3hours (The additional fee will be charged 0111;. if morethan three hours are spent, ) Ballas Co. only$135.00Smull Claims Filing (including Service feefur only one Defendant) Dallas Co. only S72JWJustice Su its tiled (including service feefor only one Defendant) Dallas Co. only S97JJOEvictions (FE& D)for one residence of service 592.00for each additional address of service SMI.OOFiling Suit VI hen defendant (s) are OU T OF STATE (1\'OUT OF C O U r ~ T Y onlySmall Claims $12.00Justice S32,O\:)Subpoena-For each Witness Sen ed inDalias County $ H ) . 1 ~ i J Subpoena DUCl lS TecumWitness fees (3 ten dollar bill) plus $11.00The production ofdocument (s) lee (3 one dollar bill)to attach to each subpoena requested."CiTtitled" CopiesFirst page $2.00l.nch additional p,ige $.15Hot Checks-are lilted VI ith the Do'\s OfficeAt No ChargeCashlMoney Order/Cashier's Checks accepted and .

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Jaime Cortes v. Frias Et Al