IN THE COUNTY COURT AT LAW NUMBER TWO

EL PASO COUNTY, TEXAS

DONALD L. THOMPSON,
Plaintiff, Pro-Se                                                                                                

                   vs.                                                                                                 Cause No. 94-12,817

ALLSTATE INSURANCE COMPANY
and ROBERT WILSON,
Defendants

PLAINTIFF'S MOTION TO TRANSFER VENUE TO POTTER COUNTY

 

TO: THE HONORABLE JUDGE OF SAID COURT

     COMES NOW, Donald L. Thompson, Plaintiff herein, and pursuant to Rule 86 of the Texas Rules of Civil Procedure, files this motion to move this Court, and will respectfully show the following:

I.

     This action was originally brought in both the jurisdiction and venue of this Court due the fact that Defendant ALLSTATE has a representative agent in El Paso County.

II.

     Because this original action involves a breach of contract on the part of Defendant ALLSTATE, and that said breach is over Plaintiff's loss of property in Potter County, Plaintiff believes that said action is not within the venue of this Court. More specifically, the county where this action is currently pending is not the proper county under the Texas Property Code. Mandatory venue of this instant action is prescribed in Potter County. Suits involving land must be tried in the county where the land is situated. Plaintiff further requests that due to the dollar amounts of this suit as claimed in Plaintiffs Original Complaint, this action should be transferred to a Potter County District Court for proper adjudication.

PRAYER FOR RELIEF

WHEREFORE, premises considered, respectfully moves this Honorable Court to transfer venue to a Potter County District Court, in that the property sued over herein, is located in Potter County. Or in the alternative, this Court set a time certain for hearing, and order Defendant to come forth and show cause why venue should not be transferred.

                                                                          Respectably submitted,

                                                                        Donald L. Thompson

CERTIFICATE OF SERVICE

     The undersigned certifies, that a true and correct copy of this motion and orders was served on Mayfield and Perrenot, P.C. Attorneys for Defendant at 300 E. Main, Fifth Floor, El Paso, Texas 79901-1369, by post paid United States Mail on this the ______ day of April, 1996.

Donald L. Thompson

 

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