起訴的形式和具體文件要求 VIA REGISTERED INTERNATIONAL MAIL May 18, 2005 Deguang Zhang, Esq. Zhang, Wang & Lee, L.L.P. 666 East Chang’an Blvd. Beijing 100001, China Re: Texas Instrumental, Inc. v. China Huaguang Hitech Co. Dear Mr. Zhang: Pursuant to your request, enclosed are copies of the Complaint, Demand for Jury Trial with Exhibits, and Plaintiff’s First Request for Production of Documents, all of which were personally served on your client’s representative in Texas on March 2, 2005. It has been over six weeks since your client was served with these pleadings and the responses are now overdue. Please let me know at your earliest convenience when you will be providing the responses. Sincerely, Baker & Associates, P.C. ____________________ Susan Miller, Esq. Enclosure IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NORTHERN TEXAS ___________________________________ * Texas Instrumental, Inc. * 111 Nowhere Lane S.W. * Civil Action No. 00001 College Point, TX 11111 * Plaintiff * vi. * * China Huaguang Hitech Co. * 111 Happy Road *
__ * COMPLAINT FOR BREACH OF CONTRACT COMES NOW the Plaintiff, Texas Instrumental, Inc., by and through counsel, Baker & Associates, P.C., and does hereby state the following as and for its complaint: I. JURISDICTION Jurisdiction of this Court is founded on Diversity of Citizenship and Amount in Controversy under U.S.C. Title 28 Sections 1331 and 1332. Plaintiff is a corporation incorporated under the laws of the State of Delaware and defendant is a corporation incorporated under the laws of the People’s Republic of China. The matter in controversy exceeds the sum of Sixty Five Thousand dollars (USD $65,000.00), exclusive of interest and costs. II. PARTIES A. Plaintiff Texas Instrumental, Inc. is a Delaware corporation with its offices located at 111 Nowhere Lane S.W., College Point, TX 11111. B. Defendant China Huaguang Hitech Co. is a People’s Republic of China corporation with its headquarters located at 111 Happy Road, Nowhere City, China 222222. III.ALLEGATIONS 1. On or about September 21, 2004, Plaintiff entered into an agreement in writing with Defendant whereby Defendant contracted to purchase five (5) sets of automatic chip processing machines. A copy of said agreement is attached hereto, marked “Exhibit A,” and made a part of this complaint. 2. All terms and conditions of the agreement have been performed by Plaintiff or have occurred. 3. All goods and services contracted for by Defendant have been rendered by Plaintiff. 4. Defendant has failed and neglected to pay the sum of USD $170,540.00 (One Hundred and Seventy Thousand, Five Hundred and Forty U.S. Dollars) or any part thereof, although payment has been duly demanded by plaintiff.
WHEREOF, Plaintiff Texas Instrumental, Inc., prays this court assume jurisdiction in this matter and grant to Plaintiff judgment in the amount of USD $170,540.00, plus accrued interest in the amount of USD $4,321.00 as provided by the terms of the agreement, and for such other relief as the court may deem appropriate. RESPECTFULLY SUBMITTED, Baker & Associates, P.C. 123 West Putnam Parkway, Suite 1103 Austin, Texas 80012 ________________________________ By: Susan Miller, Texas Bar No.: 1234
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