FILED

DALLAS COUNTY
6/12/2015 11:41:37 AM
FELICIA PITRE

4 CT- ATTY

DISTRICT CLER

DC-15-06728

Freeney Anita

CAUSE NO.

IN THE DISTRICT COURT

JOSE BAEZ,
Plaintiff,
v.

J-191ST

JUDICIAL DISTRICT

KRAISH H. KRAISH, individually and

d/b/a FMK LTD,
HANNAH E. KRAISH, individually and
d/b/a HMK LTD,
KHRAISH DEVELOPMENT GROUP,
LLC & HMK LTD.
DALLAS COUNTY, TEXAS
Defendants.
PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY
TO THE HONORABLE JUDGE OF SAID COURT:
COMES Now JOSE BAEZ, hereinafter called Plaintiff; complaining of HMK,
LTD., Khraish Development Group, LLC, Khraish H. Khraish and Hannah E. Khraish,
hereinafter referred to as Defendants, and for cause of action shows the Honorable Court
and Jury as follows:
DISCOVERY CONTROL PLAN
This matter shall be conducted under a Level 3 Discovery Control Plan, pursuant
to Rule 190 of the Texas Rules of Civil Procedure,
I.
PARTIES
Plaintiff is an individual who resides at 316 N. Carroll Ave, Apai hment 203,
Dallas, Dallas County, Texas 75246. The last 3 digits of his social security number are
858.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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Defendant Khraish H. Khraish is an individual who may be served at his office,

1119 Singleton, Dallas, Dallas County Texas or his home address of 5810 Club Oaks
Drive, Dallas, Texas 75248. On August 18, 2011, Defendant Khraish. Khraish filed suit
in Dallas County, Texas (Cause No. 11-10306 in the 134th District Court) representing
that he owned and managed the real property that is the immediate subject of Plaintiff's
illegal lease and subsequent injuries. According to Dallas Central Appraisal District
Records, Defendant Khraish H. Khriaish, individually, owned the subject property in
2010, having acquired it in June of 2000 from Earl B. Dean and having transferred the
deed to HMK Ltd. in April of 2014.
Defendant Hanna E. Kraish is an individual who may be served at his office, 1119
Singleton; Dallas, Dallas County Texas, 75212-5217, or at his residence, 16928 Preston
Bend Dr., Dallas, TXX 75248-1351. On August 18, 2011, Defendant Hanna E. Khraish
filed suit in Dallas County, Texas (Cause No. 11-10306 in the 134th District Court)
representing that he owned and managed the real property that is the immediate subject of
Plaintiff's illegal lease and subsequent injuries.
Defendant HMK, Ltd. is a domestic limited paitilership whose registered agent is
Defendant Khraish H. Khraish and may be served at 1119 Singleton, Dallas, Dallas
County Texas, 75212-5217. Defendant HMK LTD has filed suits in Dallas County
representing to our courts that it owns, operates, and/or manages the real property that is
the immediate subject of Plaintiffs illegal lease and subsequent injuries.
Defendant Khraish Development Group, LLC is a now inactive domestic limited
liability company whose registered agent John H. Carney who may be served at 5005
Greenville, Ave. #200, Dallas, Texas 75206. On August 18, 2011, Defendant Khraish

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Development Group, LLC has filed suit in Dallas County, Texas (Cause No. 11-10306 in
the 134th District Court) representing that it owned and managed the real property that is
the immediate subject of Plaintiff's illegal lease and subsequent injuries.

IL
JURISDICTION AND VENUE

The subject Matter in controversy is within the jurisdictional limits of this court.
Pursuant to TRCP 47(c), the Plaintiff states that she seeks only monetary relief of more
than $100,000.00 but less than $200,000.00, including damages of any kind, penalties,
costs, expenses, pre-judgment interest, and attorney fees.
This court has jurisdiction over the parties because Defendant is a Texas
corporation.
Venue in Dallas County is proper in this cause of action pursuant to all subparts
of TEX. CIV. PRAC. & REM. CODE 15.002.

FACTUAL BACKGROUND

At different times since 2010, each of the named Defendants has represented to a
Dallas County court (and / or Dallas Central Appraisal District) that it or he was entitled
to judicial relief on the grounds that it or he owned, operated, and/or managed hundreds
of properties in the City of Dallas, Dallas County, Texas, including, at all relevant times
pertaining to this action, Dallas City Block 1262, Block 18 and Lot 5 & 6, also known as
917-921 Ann Avenue, Dallas, Texas 75223.

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For example, on August 21, 2014, Defendant HMK LTD filed suit in Dallas
County (Cause No. DC-14-09120 in the 298th District Court) representing that it owns,
operates, and/or manages the real property that is the immediate subject of Plaintiff's
illegal lease and subsequent injuries. Yet in that same cause of action, both Defendants
Khraish H. Khriash and Hanna E. Khraish allege that they are "owners" (plural) of the
subject property.
As previously noted, according to Dallas Central Appraisal District Records,
Defendant Khraish H. Khriaish, individually, owned the subject property in 2010 and in
2012 as well as all times relevant to this peition, having acquired it in June of 2000 from
Earl B. Dean and having transferred the deed to HMK Ltd. on April 25, 2014.
However, in a February 16, 2015 pleading filed by Defendant Khraish H. Khraish
in Cause No. CC-14-02577-D, Dallas County Court at Law No. 4, Defendant Khraish H.
Khraish offered an affidavit stating that he sold the subject property to HMK, Ltd. on
January 1, 2010.
Defendant Hanna E. Khraish annually files suit against Dallas Central Appraisal
District alleging that he, in his individual capacity (sometimes in along with Defendant
HMK, Ltd., sometimes with Defenant Khraish Development Group, LLC, always with
Defendant Khraish H. Khraish).
Defendants either variously or collectively -- were responsible for the operation,
management, and maintenance of the subject property which is one over 400 residential
rental properties owned by Defendants in Dallas County according to it's own pleadings
in Dallas County District Court (Cause No. DC-14-09120 in the 298th District Court).'

in 2010, Defendants filed suit against DCAD in Cause No. 1040914 in the 95th District Court, Dallas
County alleging that they owned more than 400 properties in Dallas County, Including the subject property
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At all times relevant to this pleading, Plaintiff was a tenant of Defendants

pursuant to a lease entered into on or about August 25, 2010.2 The terms of the lease
were in violation of TEX. PROP. CODE 96.006(e)3 in that it imposed duties on Plaintiff to
make any and all repairs to the property and no obligation on the landlord to do so. The
terms of the lease also violated TEX. PROP. CODE 96.056(g).4
Defendants presented to Plaintiff that a payment of security deposit would waive
the first months rent. The security deposit was instead applied to Defendant's own
expenses. The deposit was never returned to Plaintiff,nor accounted for by Defendant.
On or about June 17, 2012, at such time that Plaintiff was a tenant in Defendants'
property in Apartment 202, 917 Ann Street, Dallas, Texas 75223, Plaintiff was awakened
by pain in the second toe of his left foot. Plaintiff saw a rat run off after biting his toe.
The rat then ran to the kitchen cabinet and left from whence he came through a sizable
hole in the wall. Plaintiff notified Defendant of the infestation on multiple occasions
prior to this incident, when Defendant responded that since the rat was inside the
apartment and not in a common area, it was "not [defendant's] problem."
The apartment had been infested with rats and other vermin for some time. Its
exterior structures were decaying, the structure was not water-tight I weather-tight. The

2 According to DCAD records, the owner of the subject property on that date was Defendant Khraish H.
Khraish and he continued to be the owner until April 25, 2014. However Defendant Khraish H. Khraish has
also recently made an affidavit stating that he sold the property to Defendant HMK, Ltd. on January 1,
2010.
"A landlord and tenant may agree for the tenant to repair or remedy, at the tenant's expense, any condition
covered by Subchapter B if all of the following conditions are met: (1)at the beginning of the lease term the
landlord owns only one rental dwelling." This defendant landlord owns more than one rental dwelling and
in fact owns dozens of rental properties. The lease violates other subsections of this statue as well,
including, without limitation, TEx. PROP. CODE 92.006(e)(2).
4 "A lease must contain language in underlined or bold print that informs the tenant of the remedies
available under this section and Section 92.0561." The lease between Plaintiff and Defendant contains no
such language.

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floors, walls, ceilings were in decay, riddled with holes, cracks and loose materials. It
was desperately in need of serious repairs, which Defendant failed to provide.5 Bars over
the windows for security of tenants were broken and not fixed, and the parking lots were
on uneven, unsafe surfaces that were not constructed of any type of gravel road. All of
Defendants' properties regularly receive violations regarding code violations like trash
problems, abandoned vehicles, and untamed weeds; and responding to citizen complaints
about trash odors, lawn maintenance, animal feces, and parking problems in the
neighborhood, and Defendants consistently require that such violations are the
responsibility of its tenants.
Defendants own hundreds of properties, and on occasions prior to and unrelated
to this incident, employed Plaintiff for maintenance on. Defendants' properties. Such
properties were each in violation of many if not most obligations imposed by Texas
statutes, common law, and local ordinances. Defendants' misrepresented their obligations
to prior tenants in the same one-page lease form as that signed by Plaintiff, "The Lease"
by fraudulently assigning Defendants', and other tenants' statutory duty to keep the
dwelling safe and habitable to Plaintiff. Defendants misrepresented the condition of its
in-fact deplorable condition that greatly endangered the health and safety of all
Defendants' tenants.
Iv.
COMMON LAW FRAUD

Defendants are guilty of fraud with respect to the occurrence in question in that
they made a (1) material representation (2) that was false, (3) that was known to be false
s In the aftermath of this event, the premises made the basis of this cause of action. was inspected by the.

City of Dallas and found to be in violation of 18 sections of the Dallas City Code, including many which
materially affect the physical health or safety of the ordinary tenant.
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when made, or made recklessly without knowledge of truth, (4) that was intended to be
acted on, (5) that was relied on, and (6) that caused injury to Plaintiff. Italian Cowboy
Partners, Ltd. v. Prudential Ins, Co. of Am., 341 S.W.3d 323 (Tex. 2011) ; Aquaplex, Inc.
v. Rancho la Valencia, Inc., 297 S.W.3d 768, 774 (Tex. 2009)(per curiam); De Santis v.
Wackenhut Corp., 793 S.W.2d 670, 688 (Tex. 1990).
Defendants made a material representation in the lease that Plaintiff was solely
responsible for "fumigating for...rodents." Such representation was material because it
attempted to illegally shift a non-delegable duty from Defendants to Plaintiff
Defendants, as landlords / lessors of dozens of properties made this representation with
reckless disregard for the truth, at best, but more likely knew it was illegal and false when
made. They intended for Plaintiff to rely on it (i.e. "don't bother us about the rat problem
on the premises, that's your problem per the lease"); Plaintiff relied on this
misrepresentation to his detriment by not demanding that Defendants carry out their legal
duty to fumigate for rats and this reliance ultimately cost Plaintiff serious injury.
VI.
STATUTORY FRAUD
VIOLATION OF TEX. Bus. & COM. CODE pun
Defendant defrauded Plaintiff by inducing him to sign the lease on the reliance
that the deposit provided to Defendant would be treated as a deposit as defined under the
TEX. PROP. CODE 92. See TEX. Bus. & COM. CODE 27.01. Prior to signing a lease,
Defendant presented to Plaintiff that a payment of security deposit would waive the first
months rent. The security deposit was instead applied to Defendant's own expenses and
never returned to Plaintiff, nor accounted for.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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VI.
CONSTRUCTIVE FRAUD

Constructive fraud involves the breach of a legal or equitable duty that the law
declares to be fraudulent, irrespective of moral guilt, because of its tendency to deceive
others, to violate confidence, or to injure public interests. Archer v. Griffith, 390 S.W.2d
735, 740 (Tex. 1964). As a general rule, the following elements must appear to constitute
actionable fraud based on misrepresentation: (1) a material representation ;was made; (2)
the representation was false; {3) when the representation was made, the speaker knew it
was false or made it recklessly without any knowledge of the truth and as a positive
assertion; (4) the speaker made the representation with the intent that the other party
should act upon it; (5) the party acted in reliance on the representation; and (6) the party
thereby suffered injury. Italian Cowboy Partners, Ltd. v. Prudential Ins. Co. of Am., 341
S.W.3d 323, 54 Tex. Sup. Ct. J. 822, 830 (Tex. 2011) ; Aquaplex, Inc. v. Rancho la
Valencia, Inc., 297 S.W.3d 768, 774 (Tex. 2009) (per curiam); De Santis v. Wackenhut
Corp., 793 S.W.2d 670, 688 (Tex. 1990) ; Stone v. Lawyers Title Ins. Corp., 554 S.W.2d
183, 185 (Tex. 1977) .
A lease must contain language in underlined or bold print that informs the tenant
of the remedies available under TEx. PROP. CODE 92.056 and TEx. PROP. CODE 92.0561.
The lease between Plaintiff and Defendant contains no such language. Defendant violated
TEX. PROP. CODE 92.006(e) in that it attempted to impose a duty to provide any and
all repairs to the premises from the Defendant landlord to the Plaintiff tenant at the
tenant's expense, which may be done only under certain circumstances which were not

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present. Defendant also violated TEX_ PROP. CODE 92.109 when it failed to return or
account for Plaintiff's security deposit.
Fraudulent misrepresentation of Defendant's obligations under the pest control
statute were the direct and proximate cause of Plaintiff's injuries. The Texas Structural
Pest Control Act governs who may apply pesticides to apartment buildings. The act
establishes two types of pesticide applicators: certified commercial applicators and
certified noncommercial applicators. An apartment building owner may obtain pest
control services from either a business with a structural pest control business license or
require an employee who is a licensed certified noncommercial applicator to perform the
services. Although the amendment uses the word may, a broad reading of the bill
suggests the correct wording to be must. An uncertified owner is prohibited from
applying pesticides to an apartment building containing two or more dwelling units. See
TEX. OCC. CODE 1951.
Since Defendant attempted to delegate this duty to Plaintiff, in direct violation of
State law, and causing Plaintiff injury, Defendant is liable to Plaintiff for constructive
fraud.
VII.
BREACH OF CONTRACT
VIOLATION OF TEX. PROP. CODE
The lease between Plaintiff and Defendant violated TEx. PROP. CODE 92.006(e)
in that it attempted to impose a duty to provide any and all repairs to the premises from
the Defendant landlord to the Plaintiff tenant at the tenant's expense, which may be done
only under certain circumstances, which were not present here.

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Specifically, shifting the burden to make repairs contractually from landlord to

tenant at tenant's expense can only be done by landlords who own only one rental
dwelling.
Moreover, doing so may only be done if, at the beginning of the lease term, the
dwelling is free from any condition which would materially affect the physical health or
safety of an ordinary tenant. That was certainly not the case here. This was a knowing
violation of TEX. PROP. CODE 92.006(e).
Finally, "[a] landlord's duties and the tenant's remedies under Subchapter B,
which covers conditions materially affecting the physical health or safety of the ordinary
tenant, may not be waived except as provided in Subsections (d), (e), and (f) of this
section."
VIII.
JUDICIAL REMEDY

TEx. PROP. ODE 96.006(e)

The remedies for a knowing violation of TEX. PROP. CODE 92.006 are statutorily
prescribed. A landlord who knowingly violates TEX. PROP. CODE 92.006 by contracting
orally or in writing with a tenant to waive the landlord's duty to repair shall be liable to
the tenant for (1) actual damages, (2) a civil penalty of one month's rent plus $ 2,000, and
{3) reasonable attorney's fees.
IX.

PLAINTIFF'S ACTUAL DAMAGES

To date, Plaintiff Jose Baez has incurred the following reasonable and necessary
expenses, for which additional amount he sues herein:
JOSE BAEZ'S PAST MEDICAL EXPENSES:
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Parkland Emeregency Room

will supplement

Baylor University Medical Center

$29,465.39

Dallas Emergency Physicians

$ 1,080.00

National Primary Care, P.A.

$ 2,160.00

TOTAL

$32,705.39

Plaintiff has also suffered physical pain, physical impairment, physical

disfigurement and loss of earning capacity in the past and will, in all likelihood, continue
to suffer physical pain, physical impairment, physical disfigurement and loss of earning
capacity in the future.

X.
EXEMPLARY DAMAGES

Plaintiff is entitled to exemplary damages pursuant to TEX. CIV. PRAC. & REM.
CODE 41.003(a)(1), (2), and (3).
Exemplary damages are not limited pursuant to TEx. Cw. PRAC. & REM. CODE
41.008(a) or (b) because Defendant's fraud is an exception to such limitations. TEX.
CIV. PRAC. & REM. CODE 41.008(c)(11).
XI.
ADDITIONAL REMEDIES

Plaintiff herein seeks all remedies available to him pursuant to TEX. PROP. CODE
92.0563 including, without limitation, costs of court and attorneys fees, as well as pre
and post-judgment interest pursuant to TEx. FIN. CODE 304.

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PLAINTIFF'S REQUEST FOR DISCOVERY

A. Request for Disclosure
Defendant is hereby requested to disclose, within fifty (50) days of service of
this petition and incorporated request, the information or material described in
Rule 194.2(a)-(i) of the Texas Rules of Civil Procedure, to the undersigned
counsel of record for Plaintiff.
B. Interrogatories
Defendant is hereby requested to answer, within fifty (50) days of service this
petition and incorporated request, the interrogatories attached hereto as
"Exhibit A," separately, fully, in writing, and under oath, pursuant to Rule 197
of the Texas Rules of Civil Procedure, to the undersigned counsel of record
for Plaintiff.
C. Request for Production
Defendant is hereby requested to produce, within fifty (50) days of service of
this petition and incorporated request the documents and tangible items in the
list attached hereto as "Exhibit B," pursuant to Rule 196 of the Texas Rules of
Civil Procedure, to the undersigned counsel of record for Plaintiff.
D. Request for Admissions
Defendant is hereby requested to admit or deny, in writing, within (50) days
of service of this petition and incorporated request, the propositions of fact
and/or law attached hereto as "Exhibit C," pursuant to Rule 198 of the Texas
Rules of Civil Procedure, to the undersigned counsel of record for Plaintiff

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PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiff, respectfully prays that
the Defendant be cited to appear and answer herein, and that upon a final hearing of the
cause, judgment be entered for the Plaintiff against Defendant for damages in an amount
within the jurisdictional limits of the Court; together with pre-judgment interest (from the
date of injury through the date of judgment) at the maximum rate allowed by law; postjudgment interest at the legal rate, costs of court; and such other and further relief to
which the Plaintiff may be entitled at law or in equity.
Respectfully submitted,
ROLLE, BREELAND, RYAN, LANDAU,
WINGLER AND INDMAN. P.C.

By:
Michael Hindm
State Bar No. 24 i 4 026
2030 Main Street, Suite 2
Dallas, Texas 75201
Phone No.(214) 742-8897
(214) 637-6872
Fax No.
mjhindman@sbeglobal.net
kaseyk@rbrl.com
ATTORNEY FOR PLAINTIFF

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"EXHIBIT A"
PLAINTIFF'S REQUEST FOR INTERROGATORIES
TO DEFENDANT
DEFINITIONS AND INSTRUCTIONS
1.
As used herein, the terms "you" and "your" shall refer the Defendants
HMK Ltd., Khraish Development Group LLC, Hanna E. Khraish and Khraish H.
Khraish named herein, Defendants' attorneys, agents, and all other natural persons or
business or legal entities acting or purporting to act for or on behalf of Defendants,
whether authorized to do so or not.
2.
As used herein, the term "incident" or "date of incident" refers to the
events described as occurring on June 17, 2012 in Part III of Plaintiff s.Original Petition.
3.
As used herein, the term "documents" shall mean all writings of every
kind, source and authorship, both originals and all non-identical copies thereof, in your
possession, custody, or control, or known by you to exist, irrespective of whether the
writing is one intended for or transmitted internally by you, or intended for or transmitted
to any other person or entity, including without limitation any government agency,
department, administrative, or private entity or person. The term shall include
handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall
include communications in words, symbols, pictures, sound recordings, films, tapes, and
information stored in, or accessible through, computer or other information storage or
retrieval systems, together with the codes and/or programming instructions and other
materials necessary to understand and use such systems. For purposes of illustration and
not limitation, the term shall include: affidavits; agendas; agreements; analyses;
announcements; bills, statements, and other records of obligations and expenditures;
books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other
records of payments; charts or drawings; check registers; checkbooks; circulars; collateral
files and contents; contracts; corporate bylaws; corporate charters; correspondence; credit
files and contents; deeds of trust; deposit slips; diaries; drafts; files; guaranty agreements;
instructions; invoices; ledgers, journals, balance sheets, profit and loss statements, and
other sources of financial data; letters; logs, notes, or memoranda of telephonic or faceto-face conversations; manuals; memoranda of all kinds, to and from any persons,
agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press
releases; printed matter (including books, articles, speeches, and newspaper clippings);
purchase orders; records; records of administrative, technical, and financial actions taken
or recommended; reports; safety deposit boxes and contents and records of entry;
schedules; security agreements; specifications; statements of bank accounts; statements;
interviews; stock transfer ledgers; technical and engineering reports, evaluations, advice,
recommendations, commentaries, conclusions, studies, test plans, manuals, procedures,
data, reports, results, and conclusions; summaries, notes, and other records and
recordings of any conferences, meetings, visits, statements, interviews or telephone
conversations; telegrams; teletypes and other communications sent or received;
PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY
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transcripts of testimony;. UCC instruments; work papers; and all other writings, the
contents of which relate to, discuss, consider, or otherwise refer to the subject matter of
the particular discovery requested.
4.
In accordance with Tex. R. Civ. P. Rule 192.7, a document is deemed to
be in your possession, custody or control if you either have physical possession of the
item or have a right to possession of the item that is equal or superior to the person who
has physical control of the item.
5.
"Person": The term "person" shall include individuals, associations,
partnerships, corporations, and any other type of entity or institution whether formed for
business purposes or any other purposes.
6.

"Identify" or "Identification":

(a) . When used in reference to a person, "identify" or "identification"

means to state hiS or her full name, present or last known residence address,
present or last known business address and telephone number.
(b)
When used in reference to a public or private corporation,
governmental entity, partnership or association, "identify" or "identification"
means to state its full name, present or last known business address or operating
address, the name of its Chief Executive Officer and telephone number.
When used in reference to a document, "identify" or
(c)
"identification" shall include statement of the following:
(i)

the title, heading, or caption, if any, of such document;

the identifying number(s), letter(s), or combination thereof,

(ii)
if any; and the significance or meaning of such number(s), letter(s), or
combination thereof, if necessary to an understanding of the document and
evaluation of any claim of protection from discovery;
(iii) the date appearing on such document; if no date appears
thereon, the answer shall so state and shall give the date or approximate
date on which such document was prepared;
(iv) the number of pages and the general nature or description
of such document (i.e., whether it is a letter, memorandum, minutes of a
meeting, etc.), with sufficient particularity so as to enable such document
to be precisely identified;
the name and capacity of the person who signed such
(v)
document; if it was not signed, the answer shall so state and shall give the
name of the person or persons who prepared it;
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(vi) the name and capacity of the person to whom such

document was addressed and the name and capacity of such person, other
than such addressee, to whom such document, or a copy thereof, was sent;
and
(vii) the physical location of the document and the name of its
custodian or custodians.
7.

"Settlement": as used herein, means:

o
(a)
an oral or written, disclosed or undisclosed agreement, bargain,
contract, settlement, partial settlement, limited settlement, arrangement, deal,
understanding, loan arrangement, credit arrangement, contingent settlement,
limitation on the amount of liability or judgment, or a promise by or between
plaintiff and any defendant or between any defendant herein whereby plaintiff or
defendant have in any way released, compromised, in whole or in part, directly or
indirectly, or agreed to do so in the future, any of the matters in controversy in
this lawsuit whether before, after or during trial or before or after any jury verdict
is returned herein or a judgment is entered or rendered herein.
any resolution of the differences between the plaintiff and
(b)
defendant by loan to the plaintiff or any other device which is repayable in whole
or in part out of any judgment the plaintiff may recover against defendant.
The term "settlement" shall also include "MaryCarter
(c)
Agreements" as that term is used under Texas Law.
Unless a specific date or dates is set forth in any specific question herein,
8.
you are directed that each question shall be answered for the period of time up to and
including the present date.
As used herein, the term "lease" or "rental contract" refers to the
9.
document described in Part III of Plaintiff's Original Petition ("At all times relevant to
this pleading, Plaintiff was a tenant of Defendant pursuant to a lease entered into on or
about August 25, 2010").
10.
As used herein, the tern "premises" or "premises made the basis of this
suit" refers to , Dallas City Block 1262, Block 18 and Lot 5 & 6, also known as 917-921
Ann Avenue, Dallas, Texas 75223.

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INTERROGATORIES
1. If the responding defendant ever purchased the premises, please provide the following
information:
a:- the date on which the property was purchased by the defendant;
b. identify the seller from whom the defendant purchased the property;
c. the purchase price of the property;
d. identify the source of financing for the purchase of the property, including
any federally assisted financing, or financing which involved federally
assisted insurance; including, but not limited to, FHA, VA or other federal
insurance;
e. identify all parties or entities which were co-purchasers, with the,
defendant of the property;
f. if the defendant no longer owns the property, state the date on which the
defendant ceased to be the owner of the property and describe the
circumstances under which the defendant ceased being the owner of the
property (e.g., sale, foreclosure, etc.).
ANSWER:

2. If the responding defendant acquired the premises in any manner other than by
purchase, please provide the following information:
a. the manner in which the defendant acquired an ownership interest in the
property;
b. the nature of the defendant's ownership interest in the property;
c. the dates on which the defendant's ownership interests commenced and
terminated;
d. identify any party or entity that is or was a co-owner, with the defendant,
of the property, and the dates when that party or entity is or was a co-owner
with the defendant;
e. the consideration given in exchange for such acquisition; and
f. if the defendant no longer owns the property, state the date on which the
defendant ceased to be the owner of the property and describe the
circumstances under which each defendant ceased being the owner of the
property (e.g., sale, foreclosure, etc.).
ANSWER:

3. From the date the defendant executed an agreement to purchase the property through
the date the plaintiff vacated the premises, please identify whether the property
was inspected or appraised, including identifying whether any such inspections or
appraisals were conducted by the defendant or by anyone acting on the
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defendant's behalf? For the purpose of this interrogatory, "inspected or appraised"

shall be limited to inspections or appraisals which include condition of the
premises or general inspections so as to encompass the health and safety of the
tenants, but shall not include inspections or appraisals of parts or the property or
equipment on the property which would not include the health and safety of the
tenants.
ANSWER:

4. If the answer to the previous interrogatory is in the affirmative, please provide the
following information:
a. identify the persons or entities who made such inspections;
b. state the date or dates on which the property was inspected or appraised,
and identify each person who was present during each such inspection or
appraisal;
c. state all reasons each such inspection or appraisal was performed;
d. identify each written report or document which was issued as a result of
each such inspection or appraisal;
e. identify any instructions given by the defendant to the inspectors or
appraisers, and the date the instructions were given; and
E identify any instructions given by the inspectors or appraisers to the
defendant, and the date the instructions were given.
ANSWER:

5. Through the date the plaintiff vacated the property, describe any and all construction,
repairs, rehabilitation, remodeling, or other improvements made to the property
by you or on your behalf or on behalf of the defendant, and provide for each such
instance:
a. the nature of the constructions, repair, rehabilitation, remodeling, or other
improvement (the "activity");
b. the approximate start and completion dates of each such activity;
c. the name of the person or entity who completed each such activity;
d. the cost of each such activity;
e. identify all contracts entered into for such activity; and
f. identify any local, state, federal government or other financial assistance
provided to assist in the completion of any such activity.
ANSWER:

6.

If the tenancy of the plaintiff was subject to an oral or written lease; please

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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identify whether it was an oral or written lease, and describe each term of the
lease, including any modifications or proposed modifications..
ANSWER:

Please identify all owners of the premises during the residency or tenancy of
7.
the plaintiff, provide the dates each person owned the premises, and identify the
nature of each person's ownership interest..
ANSWER:

8.
At any time during the defendant's ownership of the premises up until the date
the plaintiff vacated, did the defendant possess or obtain a certificate of apartment
occupancy from the municipality in which the property is situated? If so, please provide
the following information:
a. the date on which each such certificate was obtained;
b. the name of the person and department who issued each such certificate;
c. identify each such certificate or in the alternative provide a copy of each such
certificate.
ANSWER:

Identify each owner of the premises from January 1, 2000 through the current date
9.
and the means by which ownership was transferred.

ANSWER:

Identify each and every partner of HMK, Ltd. since it's initial date of inception
10.
through the present date, the dates from which the partnership interest was acquired
through the date it was relinquished, sold or transferred and the buyer of the interest when
it was relinquished, sold or transferred.
ANSWER:

11.

Identify each and every employee of HMK Ltd. from January 1, 2010 through the
present date by name, address and telephone number. For each such employee,
please provide a job description as well as dates of employment.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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ANSWER:

12.

Up to the date the plaintiff vacated the premises, did you ever inspect or have the
premises inspected for any structural or habitable conditions for financing
purposes or any other reason prior to or during the residency or tenancy of the
plaintiff, and, if so, please state when the inspection occurred, the identity of the
inspector, the purpose of the inspection and the conclusion or results.

ANSWER:

13.

Does the responding defendant employ or otherwise retain persons (e.g., as

consultants) who manage and/or maintain the property owned by the defendant,
and if so, please identify, up to the date the plaintiff vacated:

a. the names of the persons or entities in charge of managing each such

property and the dates they managed the property. Describe their
management responsibilities; and
b. the names of the persons or entities in charge of maintaining each such
property and the dates they maintained the property. Describe their
maintenance responsibilities.
ANSWER:
14.

If any portion of the answer to the previous interrogatory is in the negative,

please describe the manner in which the responding defendant carried out the
management and/or maintenance of each such property, identifying:

a. the names of the persons or entities in charge of managing each such

property, the dates they managed the property and their management
responsibilities; and
b. the names of the persons or entities in charge of maintaining each such
property, the dates they maintained the property and their maintenance
responsibilities.

ANSWER:

15.

If the responding defendant was involved in the management of the property,

please provide the following information:

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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a. the date on which the defendant first was involved in the management of
the property;
b. the name of all owners on whose behalf the defendant acted as a property
manager for the property;
c. the name of the person or entity by which the defendant was employed
while serving as the property manager for the property; and
d. the date on which the defendant first had contact with the plaintiff
concerning the property.
ANSWER:

16. How many mortgages has HMK Mortgage, LLC issued since it's inception in
2012? For each such mortgage, please identify the mortgagor by name, last known
address and last known phone number as well as the physical address of the property
subject to the mortgage and the amount of the mortgage.
ANSWER:

17. How many mortgages has HMK Mortgage, LLC sold on the secondary market,
including, specifically and without limitation, any sold to Fannie Mae or Freddie
Mac? For each such mortgage, please identify the mortgagor by name, last
known address and last known phone number, the purchaser of the mortgage, as
well as the physical address of the property subject to the mortgage and the
amount of the sale mortgage.
ANSWER:

18. For each tenant that has vacated a rental unit since January 1, 2010, please state:
a. the amount of the original security deposit paid by tenant;
b. the amount of the original security deposit returned to tenant on move-out and;
c. a full and final accounting of all security deposits or portions thereof that were
not returned to the tenant.
ANSWER:
19. State the name and street address of the bank where the security deposit of
Defendant's current tenants are presently on deposit, the name of the account, and the
account number at said bank.
ANSWER:

PLAINTIFF'S. ORIGINAL PETITION & REQUEST FOR DISCOVERY

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20.

Identify by name, last known address and last known telephone number, each and
every tenant of yours with whom you have entered into an agreement to reduce
rent in exchange for labor since January 1, 2010.

ANSWER:

21. For each person identified in the answer to interrogatory number 20, state the total
hours of maintenance work completed, the amount paid, or, in the alternative, the final
amount by which that tenant's rent was reduced for such services.
ANSWER:

22. State the total hours of labor completed by Plaintiff, including a complete accounting
of the amount you paid Plaintiff or, in the latemative, the final amount by which his rent
was reduced for such services.
ANSWER:

23. For each complaint as to any condition of any residential rental property since
January 1, 2010, please state:
a. whether the notice was received orally or in writing;
b. where and to whom the notice was given; and
c. what steps were taken to repair or remedy such conditions.
ANSWER:

24. For each residential rental property you have owned or acquired since January 1,
2010, please state the procedure by which you re-keyed and installed statutorily
compliant security devices.
ANSWER:

25. For each residential property you have acquired since January 1, 2010, please state
the procedure by which you ensure the residence does not endanger the health, safety, or
welfare of tenants on delivery to tenant.
ANSWER:

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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26. Did you, or any agent or representative receive any oral or written notices or requests
from Plaintiff alleging defects or violations of the Dallas City Code or items Plaintiff
requested to be repaired or remedied by Defendant? For each occurrence, provide the
date and time of each such notice/request/demand, a summary of each verbal demand, a
copy of each written demand, and the name of the person receiving such notice on behalf
of Defendant.
ANSWER:
27. Was Defendant aware of the fact that the Plaintiff had complained to Defendant or
Defendant's representatives about the need for repairs to the apartment or the building of
which it is a part and/or to the City of Dallas?
ANSWER:

28. If Defendant was aware of Plaintiff's complaint(s) to the City of Dallas, when did
Defendant first have such knowledge and how did such fact(s) come to the knowledge of
Defendant?
ANSWER:

29. Is the Ann Street building now, or has it ever been, the subject matter of
administrative proceedings initiated by or under the auspices of the City of Dallas
Building Department or any other agency of the City of Dallas alleging building code
violations?
ANSWER:

30. Are any of Defendant's properties now, or have they ever been, the subject matter of
administrative proceedings initiated by or under the auspices of the City of Dallas
Building Department or any other agency of the City of Dallas alleging building code
violations?
ANSWER:

31. State the names and positions of each person who made or participated in the
decision to terminate Plaintiff's tenancy.
PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY
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ANSWER:

32. State the reason for the decision to terminate Plaintiff's tenancy.
ANSWER:

33. If you claim that any conditions of disrepair were caused by Plaintiff, describe the
factual basis for this allegation with respect to each condition, including tile date the
condition was caused, how Plaintiff caused the condition, and the information on which
you rely to form such conclusion.
ANSWER:

34. Please describe in detail facts concerning the existence of any rats in the Ann Street
building, including but not limited to your efforts to determine the prevalence of pests,
efforts to fumigate or remedy such prevalence, and any complaints from other tenants on
your Ann Street property regarding the existence of pests of any kind.
35. Please describe in detail any and all repairs or maintenance performed to the Aim
Street building since your asserted acquisition, including any and all visits you made to
the property.
36. For each actual or alleged condition of disrepair, including those asserted by the city
of Dallas, state
a. whether you agree that said condition of disrepair exists or has existed on the property
during the period of your ownership
b. the date and manner in which you first became aware of each condition, and
c. the specific steps, if any, you have taken to address each such condition, including the
date and substance thereof, cost, and persons involved.
37. Identify and describe in detail any and all civil or criminal proceedings against you,
as well any proceedings regarding criminal activity that occurred on properties you own
or have acquired since January 1, 2000.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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VERIFICATION
STATE OF TEXAS
COUNTY OF DALLAS
BEFORE ME, the undersigned authority, personally appeared
, who stated, upon oath, that the statements made in the
foregoing instrument are within his personal knowledge and are true and correct.

SUBSCRIBED AND SWORN TO BEFORE ME on

by

Notary Public, State of Texas

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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"EXHIBIT B"
PLAINTIFF'S FIRST REQUEST FOR PRODUCTIONS
DEFINITIONS AND INSTRUCTIONS
1.
As used herein, the terms "you" and "your" shall mean the Defendant
named herein, and all attorneys, agents, and other natural persons or business or legal
entities acting or purporting to act for or on behalf of Defendant, whether authorized to
do so or not.
2.
As used herein, the term "incident"' or "date of incident" refers to the
events described as occurring on June 17, 2012 in Part III of Plaintiff's Original Petition.
3.
As used herein, the term "documents" shall mean all writings of every
kind, source and authorship, both originals and all non-identical copies thereof, in your
possession, custody, or control, or known by you to exist, irrespective of whether the
writing is one intended for or transmitted internally by you, or intended for or transmitted
to any other person or entity, including without limitation any government agency,
department, administrative, or private entity or person. The term shall include
handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall
include communications in words, symbols, pictures, sound recordings, films, tapes, and
information stored in, or accessible through, computer or other information storage or
retrieval systems, together with the codes and/or programming instructions and other
materials necessary to understand and use such systems. For purposes of illustration and
not limitation, the term shall include: affidavits; agendas; agreements; analyses;
announcements; bills, statements, and other records of obligations and expenditures;
books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other
records of payments; charts or drawings; check registers; checkbooks; circulars; collateral
files and contents; contracts; corporate bylaws; corporate charters; correspondence; credit
files and contents; deeds of trust; deposit slips; diaries or drafts; files; guaranty
agreements; instructions; invoices; ledgers, journals, balance sheets, profit and loss
statements, and other sources of financial data; letters; logs, notes, or memoranda of
telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from
any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists;
papers; press releases; printed matter (including books, articles, speeches, and newspaper
clippings); purchase orders; records; records of administrative, technical, and financial
actions taken or recommended; reports; safety deposit boxes and contents and records of
entry; schedules; security agreements; specifications; statements of bank accounts;
statements or interviews; stock transfer ledgers; technical and engineering reports,
evaluations, advice, recommendations, commentaries, conclusions, studies, test plans,
manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other
records and recordings of any conferences, meetings, visits, statements, interviews or
telephone conversations; telegrams; teletypes and other communications sent or received;
transcripts of testimony; UCC instruments; work papers; and all other writings, the

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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contents of which relate to, discuss, consider, or otherwise refer to the subject matter of
the particular discovery requested.

4.
In accordance with Tex. R. Civ. P. Rule 192.7, a document is deemed to
be in your possession, custody or control if you either have physical possession of the
item or have a right to possession of the item that is equal or superior to the person who
has physical control of the item.
5.
"Person" or "persons" means any natural persons, firms, partnerships,
associations, joint ventures, corporations and any other four of business organization or
arrangement, as well as governmental or quasi-governmental agencies. If other than a
natural person, include all natural persons associated with such entity..
Any and all data or information which is in electronic or magnetic form
6.
should be produced in a reasonable mariner.
7.
As used herein, the term "lease" or "rental contract" refers to the
document described in Part III of Plaintiff's Original Petition ("At all times relevant to
this pleading, Plaintiff was a tenant of Defendant pursuant to a lease entered into on or
about August 25, 2010").
As used herein, the term "premises" "or premises made the basis of this
8.
suit" refers to , Dallas City Block 1262, Block 18 and Lot 5 & 6, also known as 917-921
Ann Avenue, Dallas, Texas 75223.

USE OF DEFINITIONS
The use of any particular gender in the plural or singular number of the words
defined under paragraph "1", "Definitions" is intended to include the appropriate gender
or number as the text of any particular request for production of documents may require.
TIME PERIOD
Unless specifically stated in a request for production of documents, all
information herein requested is for the entire time period from June 17, 2000, through the
date of production of documents requested herein.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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DOCUMENTS TO BE PRODUCED
1.

All documents which memorialize any agreements you made with Plaintiff related
to his tenancy at the premises, such as leases, rental contracts, rent payments,
receipts, and notices to Plaintiff from you in your capacity as landlord / lessor.

2.

All photographs taken of the premises, the scene of the incident or the
surrounding area of the scene of the incident in the possession, constructive
possession, custody or control of Defendants, Defendants' attorney or anyone
acting on Defendants' behalf

3.

All photographs taken of Plaintiff or the premises which may be in-the possession,
constructive possession, custody or control Defendants, Defendants' attorney or
anyone acting on Defendants' behalf.

4.

All pictures, motion pictures, movies, films, or photographic material of any kind
taken of Plaintiff or the premises which are in the possession, constructive
possession, custody or control of Defendants, Defendants' attorney or anyone
acting on Defendants' behalf.

5.

All pictures, motion pictures, movies, films, or photographic material of any kind
concerning the premises or the events and happenings made the basis of the
lawsuit taken before, during or after the incident in question which are in the
possession, constructive possession, custody or control of Defendants,
Defendants' attorney or anyone acting on Defendants' behalf.

6.

All written statements made by the Plaintiff in the possession, constructive

possession, custody or control of Defendants, Defendants' attorney or anyone
acting on Defendants' behalf.

7.

All oral statements made by Plaintiff which were either recorded or taped on an
electronic device or recorder which are in the possession, constructive possession,
custody or control of Defendants, Defendants' attorney or anyone acting on
Defendants' behalf.

8. A copy of all documents filed with any state, county, city, federal or governmental
agency, institution or department containing information about Plaintiff or the
premises which are in the possession, constructive possession, custody or control of
Defendants, Defendants' attorney or anyone acting on Defendants' behalf.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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9. Any and all copies of investigation documentation, reports and/or memoranda

made by or submitted to Defendant, as a result of the incident which has been
made the basis of Plaintiffs lawsuit.

10.Any and all written communications, including but not limited to letters and/or
memorandums, between agents, employees and/or representatives of Defendant
that Defendant prepared as a result of the incident made the basis of Plaintiffs
lawsuit.

11. All corporate records for HMK, Ltd.

12. All records reflecting your purchase and ownership of the promises.

13. All documents reflecting Code violations of any premises you have owned since
August 25, 2000.
14. Any and all receipts, invoices, contracts, and agreements for work performed in or
on the premises from January 1, 2005 through the present date.
15. All documents memorializing communication between you and Rep. Eric Johnson
from January 1, 2010 through the present date.
16. All documents demonstrating any contracts or agreements you have made with
any person or entity to provide extermination and / or fumigation services at any
property owned by you since January 1, 2010.
17. All documents demonstrating any contracts or agreements you have made with
any person or entity to provide repair services at any property owned by you since
January 1, 2010.
18. All documents demonstrating any contracts or agreements you have made with
any person or entity to provide services at any property owned by you since
January 1, 2010.
19. All documents reflecting any communication between you and Dallas Central
Appraisal District regarding the premises at any time since June 1, 2000.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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"EXHIBIT C"
PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS
DEFINITIONS AND INSTRUCTIONS
1.
As used herein, the terms "you" and "your" shall refer to Defendants,
Defendants' attorneys, agents, and all other natural persons or business or legal entities
acting or purporting to act for or on behalf of Defendants, whether authorized to do so or
not.
"Person": The term "person" shall include individuals, associations,
2.
partnerships, corporations, and any other type of entity or institution whether formed for
business purposes or any other purposes.
As used herein, the term "incident" or "date of incident" refers to the
3.
events described as occurring on June 17, 2012 in Part III of Plaintiff's Original Petition.
Unless a specific date or dates is set forth in any specific question herein,
4.
you are directed that each question shall be answered for the period of time from August
25, 2000 up to and including the present date.
As used herein, the term "lease" or "rental contract" refers to the
5.
document described in Part III of Plaintiff's Original Petition ("At all times relevant to
this pleading, Plaintiff was a tenant of Defendant pursuant to a lease entered into on or
about August 25, 2010").
As used herein, the term "premises" "or premises made the basis of this
6.
suit" refers to , Dallas City Block 1262, Block 18 and Lot 5 & 6, also known as 917-921
Ann Avenue, Dallas, Texas 75223.

PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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REQUESTS FOR ADMISSION

Admit on the date that on August 25, 2010 you owned more than one hundred
rental properties.
ADMIT OR DENY:
2.

Admit that the lease did not comply with the Texas Property Code.

ADMIT OR DENY:
3. Admit that you had awareness of your duties as a landlord / lessor under Texas
Property Code section 96 on August 25, 2010.

ADMIT OR DENY:
4. Admit that you had awareness of your duties as a landlord / lessor under Texas
Property Code section 92 on August 25, 2010.

ADMIT OR DENY:
5. Admit that you charged Plaintiff a $200.00 deposit at the time he began his
tenancy of the premises in September 2010.

ADMIT OR DENY:
6. Admit that on August 25, 2010, you were aware that under the Texas Property
Code you were not allowed to shift the responsibility for extermination of the
premises to Plaintiff.

ADMIT OR DENY:
7. Admit that in the lease you misrepresented to Plaintiff that you had no
responsibility to provide extermination of the premises and that it was his
responsibility.

ADMIT OR DENY:
8. When Khraish H. Khraish has represented in court pleadings filed in Dallas
County (e.g. Cause No. DC-14-09120 in the 298t1 District Court) over the past
PLAINTIFF'S ORIGINAL PETITION & REQUEST FOR DISCOVERY

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four years that he, individually, is entitled to judicial relief as a result of a dispute
against Dallas Central Appraisal District with respect to the premises, he was
misrepresenting facts and making false allegations to a court of law.

ADMIT OR DENY:
9. When Hannah Khraish has represented in court pleadings filed in Dallas County
over the past four years (e.g. Cause No. DC-14-09120 in the 298th District Court)
that he, individually, is entitled to judicial relief as a result of a dispute against
Dallas Central Appraisal District with respect to the premises, he was
misrepresenting facts and making false allegations to a court of law.

ADMIT OR DENY:
10.Admit that in the past six years you have knowingly allow drug dealers to operate
out of a premises you own located at 4422 Canal Street, Dallas, Texas.

ADMIT OR DENY:

11. Admit that you filed a fraudulent affidavit in Cause No. CC-14-02577-D when
you represented that Khraish H. Khraish was not the owner of the premises on
the date of the incident made the basis of this suit.

ADMIT OR DENY:

12. Admit that you have represented to the Dallas Central Appraisal District that
Khraish H. Khraish, individually, was the owner of the premises from June
2000 through April 25, 2014.

ADMIT OR DENY:
13.On August 25, 2010, you knew that it was illegal under the Texas Property Code
for you to attempt to place a burden on Plaintiff to provide for extermination
and / or fumigation for pests and rodents.

ADMIT OR DENY:

PLAINTIFF'S ORIGINAL, PETITION & REQUEST FOR DISCOVERY

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14.Admit that the language in the lease that illegally attempts to shift the burden to
tenants such as Plaintiff to "fumigate...for rodents" is fraudulent.

ADMIT OR DENY:
15. Admit that the language in the lease that illegally attempts to shift the burden to
tenants such as Plaintiff -to "fumigate...for rodents" is to discourage tenants
such as Plaintiff from making any complaints to you about rodents on the
premises.

ADMIT OR DENY:
16.Admit that, upon receiving complaints from tenants of vermin, insects, rodents, or
other pests, you have not fumigated or taken remedial steps, on the grounds
that such actions are the responsibility of tenants pursuant to your lease
agreements.

ADMIT OR DENY:
17.Admit that you did not install and re-key statutorily compliant security devices in
- 6 your residential rental units.

ADMIT OR DENY:
18. Admit that you induced Plaintiff to enter into a lease agreement based on an
advertised "$200 FIRST MONTH MOVE-IN SPECIAL"

ADMIT OR DENY:
19. Admit that you actually required Plaintiff to pay a security deposit when he
entered into the lease agreement.

ADMIT OR DENY:
20. Admit that you did not return Plaintiff's security deposit or an accounting for
the related expenses after he vacated the unit.

ADMIT OR DENY:

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21. Admit that you habitually do not return tenants' security deposits, or provide
an accounting for them.

ADMIT OR DENY:

22. Admit that when Plaintiff presented himself at your office to complain of a toe
amputation because of your unsanitary premises, you told him that rats inside his
apaitment are not your problem.

ADMIT OR DENY:

ADMIT OR DENY:

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