Preview
FILED
2 CIT ESERVE 12/18/2023 4:31 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Shunta Jackson DEPUTY
DC-23-20889
CAUSE NO. ___________
HUSSEIN S. DAABOUL D/B/A § IN THE DISTRICT COURT
CEDAR AUTO SALES, §
Plaintiff, §
§ 95th
vs. § ___ JUDICIAL DISTRICT
§
SALEH MOHD YOUSEF FREIJ, and §
THE FREIJ GROUP, LLC, §
Defendants. § DALLAS COUNTY, TEXAS
ORIGINAL PETITION
Plaintiff Hussein S. Daaboul d/b/a Cedar Auto Sales (“Plaintiff” or “CAS”) files this
Original Petition (the “Petition”) complaining of Saleh Mohd Yousef Freij (“Freij”) and The
Freij Group, LLC (“Freij Group”) (collectively, “Defendants”) and, in support, respectfully
shows as follows:
I. DISCOVERY CONTROL PLAN
1. Plaintiff intends to conduct discovery under Level 2 of Texas Rule of Civil
Procedure 190.3.
II. RELIEF
2. Plaintiff seeks monetary relief over $250,000 but not more than $1,000,000,
including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney fees.
TEX. R. CIV. P. 47(c)(3).
III. PARTIES
3. Plaintiff Hussein Daaboul d/b/a Cedar Auto Sales is a Texas sole proprietorship
with its principal office and principal place of business located at 11147 Harry Hines Blvd, Dallas,
TX 75229, and may be contacted through the undersigned.
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4. Defendant Saleh Mohd Yousef Freij is a Texas resident who is domiciled at 702
Brentwood Lane, Richardson, Texas 75080, or wherever else he may be found.
5. Defendant The Freij Group, LLC is a Texas limited liability company whose
principle office and principle place of business is located at 702 Brentwood Lane, Richardson,
Texas 75080, and may be served by serving its registered agent, Pamela Stevens Freij, at 702
Brentwood Lane, Richardson, Texas 75080, or wherever else she may be found.
IV. JURISDICTION
6. Pursuant to Article 5 of the Texas Constitution and Texas Government Code §§
24.007 & 24.008, the Court has subject matter jurisdiction over this lawsuit because the amount
in controversy exceeds the Court’s minimum jurisdictional requirements and the claims asserted
herein are cognizable by courts of law or equity.
V. VENUE
7. Pursuant to Texas Civil Practice & Remedies Code § 15.002, venue for this suit is
proper in Dallas County, Texas, because all or a substantial part of the acts and/or omissions giving
rise to Plaintiff’s claims occurred in Dallas County, Texas.
VI. CONDITIONS PRECEDENT
8. All conditions precedent to Plaintiff’s claims for relief have been performed or have
occurred.
VII. FACTS
Defendant’s Fraudulent Scheme
9. In or around January 2023, Freij visited CAS and spoke with its owner, Hussein
Daaboul (“Daaboul”). Freij informed Daaboul that he was a lucrative businessman who previously
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worked for Mercedes, owned businesses across the country and abroad, and was looking to
establish an auto salvage yard in Dallas, much like CAS.
10. On or about January 21, 2023, Freij convinced Daaboul to partner with him in
purchasing a 2012 Dodge Ram (the “Ram”) for $15,000, the cost of which they would split 50/50.
Freij told Daaboul that he would sell the vehicle overseas at a higher price and both of them would
split the earnings. Daaboul paid Freij CAS’s $7,500 share of the purchase price. Thereafter, Freij
represented to Daaboul that he sold the Ram for $28,000 overseas but the purchaser of the Ram
found an issue with the vehicle and ended up paying him only $21,000. Accordingly, pursuant to
their agreement, Freij owed $10,500 for his sale of the Ram. However, Freij refused to pay Daaboul
any money from the sale.
11. Similarly, on January 28, 2023, Freij and Daaboul agreed to a 50/50 split of the
approximately $18,000 purchase of a 2017 Dodge Challenger (the “Challenger”) and a 2017
Mercedes CLK (the “CLK”) from a Sheriff’s auction. Daaboul paid Freij CAS’s $9,000 share of
the purchase price. Freij indicated that he never picked the Challenger and CLK up from the
auction, despite Daaboul’s persistent requests that he do so. Upon information and belief, Freij
did obtain the vehicles from the auction and sold the vehicles. To date, Freij has failed and refused
to compensate CAS and Daaboul for his sale of the Challenger and the CLK, much less refund
Daaboul the $9,000 paid for the purchase of these vehicles.
12. In or around February 2023, Freij convinced Daaboul to open a line of credit in
CAS’s name with Axel Funding and to list Freij as an auto dealer, which would enable Freij to
purchase vehicles from auto auctions and to draft the amount from CAS’s line of credit. Freij
promised that if Daaboul opened the line of credit, he would pay off all amounts he drafted back to
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CAS. Thereafter, Freij began purchasing vehicles by drafting on CAS’s line of credit. However,
Freij failed and refused to pay CAS back, forcing Daaboul to pay off the amounts owed to Axel
Funding.
13. Daaboul discovered Freij was selling the vehicles and auto parts he purchased with
CAS’s money and was transferring the money he obtained to an account held by Defendant Freij
Group. In addition, Freij was selling CAS’s vehicles without any authority from Daaboul or CAS.
Such sales were made in Freij Group’s name, and the funds were also funneled into Freij Group.
14. On or about February 13, 2023, Freij purchased a 2011 Volkswagen Tiguan (the
“Tiguan”) for $3,590 from Manheim Dallas using CAS’s line of credit. Freij told Daaboul that he
purchased the Tiguan for CAS to sell at a profit. However, Daaboul later discovered that Freij gave
the Tiguan to his wife, Pamela Freij. On or about May 16, 2023, Freij purchased a 2015 Nissan
Rogue (the “Rogue” and, together with the Tiguan, the “Vehicles”) for $5,500 from American
Auto Auction using CAS’s line of credit. Freij told Daaboul that he was purchasing the vehicle for
his son, Saif Freij, who lives in Florida and promised that he would pay the entire purchase price
back to CAS. Freij promised Daaboul that he would pay Daaboul back the entire purchase price for
the Vehicles. To date, Freij has failed and refused to pay Daaboul or CAS the amounts owed for
the purchase of the Vehicles despite numerous demands that he do so.
15. On or about December 5, 2023, Daaboul received notice from the Texas
Department of Motor Vehicles indicating that Freij had applied for a bonded title for the Vehicles
despite not having paid for them.
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VIII. CAUSES OF ACTION
FRAUD
16. All paragraphs above are incorporated by reference as if fully set forth herein.
17. Defendant Freij represented to Plaintiff that he would pay Plaintiff back from the
sales proceeds he obtained from the sales of vehicles purchased with CAS and on CAS’s line of
credit. Freij’s misrepresentations were material because it induced Daaboul and Plaintiff to give
Freij money for the purchase or certain vehicles, to open a line of credit in CAS’s name, to list Freij
as an auto dealer, which allowed him to purchase vehicles in CAS’s name, and to allow Freij to
draw on CAS’s line of credit. Freij’s representations were a false promise of future performance.
Freij made these misrepresentations knowing they were false and/or recklessly, as a positive
assertion, and without knowledge of its truth. Freij intended for Plaintiff to rely on his false
representations. Plaintiff justifiably relied on Freij’s false representations. Freij’s false
representations directly and proximately caused injury to Plaintiff. Plaintiff seeks damages,
including exemplary damages, attorneys’ fees, court costs and expenses, within the jurisdictional
limits of this Court.
CONVERSION
18. All paragraphs above are incorporated by reference as if fully set forth herein.
19. Plaintiff owns the Vehicles, which are personal property.
20. Defendants have in the past and continue to wrongfully exercises dominion and
control over the Vehicles despite notice that Defendants do not have any ownership rights with
respect to the Vehicles and do not have any right to possess the Vehicles.
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21. At the time Defendants came into possession of the Vehicles, Defendants did not
own the Vehicles and did not have any right to possess the Vehicles.
22. Plaintiff has been damaged by Defendants’ continued actions with respect to the
Vehicles.
23. As a result of Defendants’ conversion of the Vehicles, Plaintiff seeks the return of
the vehicles or actual monetary damages in the sum of money necessary to compensate Plaintiff
for the vehicles.
24. Plaintiff’s injury resulted from Defendants’ malice or actual fraud, which entitles
Plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41.003(a).
VIOLATION OF THE TEXAS THEFT LIABILITY ACT
25. All paragraphs above are incorporated by reference as if fully set forth herein.
26. At all times Plaintiff had a possessory right to the Vehicles.
27. Defendants appropriated the Vehicles with the intent to deprive Plaintiff of the
Vehicles.
28. Defendants unlawfully appropriated, secured, or stole the Vehicles by taking them
without Plaintiff’s effective consent in violation of Section 31.03 of the Texas Penal Code.
29. Defendants were informed by Plaintiff that the Vehicles were stolen and
Defendants appropriated the Vehicles knowing that the Vehicles were stolen.
30. Plaintiff sustained and continues to sustain monetary damages as a result of the
theft.
31. Upon proof of actual damages, Plaintiff seeks additional statutory damages up to
$1,000 from each Defendant pursuant to Tex. Civ. Prac. & Rem. Code § 134.005(b).
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32. Plaintiff’s injury resulted from Defendants’ malice or actual fraud, which entitles
Plaintiff to exemplary damages under Tex. Civ. Prac. & Rem. Code § 41.003(a).
BREACH OF CONTRACT
33. All paragraphs above are incorporated by reference as if fully set forth herein.
34. Plaintiff and Defendant Freij entered into oral agreements pursuant to which CAS
would provide money to Freij for the purchase of certain vehicles, Freij would purchase and sell
the vehicles, and Freij would then pay Plaintiff fifty percent of the total sales proceeds. Freij
breached the agreement by failing and refusing to pay Plaintiff the amounts owed from the total
sales proceeds. Freij’s breach proximately caused Plaintiff to incur damages.
35. Additionally, Plaintiff seeks its recover reasonable and necessary attorneys’ fees
under Tex. Civ. Prac. & Rem Code Chapter 38.
DECLARATORY RELIEF
36. All paragraphs above are incorporated by reference as if fully set forth herein.
37. Pursuant to the Texas Uniform Declaratory Judgments Act (“UDJA”), Tex. Civ.
Prac. & Rem. Code § 37.001, et seq., Plaintiff respectfully seeks a declaration of its rights and status
with respect to the Vehicles. Specifically, Plaintiff seeks a declaration that:
1) Plaintiff is the sole and exclusive title owner of the Vehicles;
2) Defendants do not own and do not have any right to the Vehicles; and
3) Defendants do not have the right to apply for a bonded title for the Vehicles
INJUNCTIVE RELIEF
38. Plaintiff seeks all necessary supplemental and ancillary relief, including injunctive
relief, based on the declaratory judgment. Specifically, Plaintiff seeks a preliminary injunction
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barring Defendants from obtaining title to the Vehicles. ECB further seeks a permanent injunction
barring Defendants obtaining title to the Vehicles.
IX. ATTORNEYS’ FEES
39. Plaintiff seeks an award of its costs, expenses, and reasonable and necessary
attorneys’ fees under the UDJA, pursuant to Tex. Civ. Prac. & Rem. Code § 38.001, and as
otherwise provided under the law.
X. JURY DEMAND
40. Plaintiff respectfully demands a trial by jury.
PRAYER
Plaintiff respectfully prays that Defendants be cited to appear and answer herein and that,
upon final hearing, Plaintiff be awarded judgment for:
a. actual and exemplary damages;
b. declaratory, supplemental, and ancillary relief, including injunctive relief,
under the UDJA as requested herein;
c. attorneys’ fees;
d. pre-judgment and post-judgment interest at the highest lawful rate;
e. court costs and expenses; and
f. all other relief, at law or in equity, to which Plaintiff is entitled.
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Respectfully submitted.
AKERMAN LLP
/s/ Rola Daaboul
David V. Jones
State Bar No. 10869825
112 E Pecan, Suite 2750
San Antonio TX 78205
210.582.0220 (Phone)
512.623.6701 (Fax)
david.jones@akerman.com
Rola Daaboul
State Bar No. 24068473
500 W 5th Street, Suite 1210
Austin, Texas 78701
737.999.7107 (Phone)
512.623.6701 (Fax)
rola.daaboul@akerman.com
ATTORNEYS FOR HUSSEIN
DAABOUL D/B/A CEDAR
AUTO SALES
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Preview
FILED 2 CIT ESERVE 12/18/2023 4:31 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Shunta Jackson DEPUTY DC-23-20889 CAUSE NO. ___________ HUSSEIN S. DAABOUL D/B/A § IN THE DISTRICT COURT CEDAR AUTO SALES, § Plaintiff, § § 95th vs. § ___ JUDICIAL DISTRICT § SALEH MOHD YOUSEF FREIJ, and § THE FREIJ GROUP, LLC, § Defendants. § DALLAS COUNTY, TEXAS ORIGINAL PETITION Plaintiff Hussein S. Daaboul d/b/a Cedar Auto Sales (“Plaintiff” or “CAS”) files this Original Petition (the “Petition”) complaining of Saleh Mohd Yousef Freij (“Freij”) and The Freij Group, LLC (“Freij Group”) (collectively, “Defendants”) and, in support, respectfully shows as follows: I. DISCOVERY CONTROL PLAN 1. Plaintiff intends to conduct discovery under Level 2 of Texas Rule of Civil Procedure 190.3. II. RELIEF 2. Plaintiff seeks monetary relief over $250,000 but not more than $1,000,000, including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney fees. TEX. R. CIV. P. 47(c)(3). III. PARTIES 3. Plaintiff Hussein Daaboul d/b/a Cedar Auto Sales is a Texas sole proprietorship with its principal office and principal place of business located at 11147 Harry Hines Blvd, Dallas, TX 75229, and may be contacted through the undersigned. __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 1 of 9 74088184;1 4. Defendant Saleh Mohd Yousef Freij is a Texas resident who is domiciled at 702 Brentwood Lane, Richardson, Texas 75080, or wherever else he may be found. 5. Defendant The Freij Group, LLC is a Texas limited liability company whose principle office and principle place of business is located at 702 Brentwood Lane, Richardson, Texas 75080, and may be served by serving its registered agent, Pamela Stevens Freij, at 702 Brentwood Lane, Richardson, Texas 75080, or wherever else she may be found. IV. JURISDICTION 6. Pursuant to Article 5 of the Texas Constitution and Texas Government Code §§ 24.007 & 24.008, the Court has subject matter jurisdiction over this lawsuit because the amount in controversy exceeds the Court’s minimum jurisdictional requirements and the claims asserted herein are cognizable by courts of law or equity. V. VENUE 7. Pursuant to Texas Civil Practice & Remedies Code § 15.002, venue for this suit is proper in Dallas County, Texas, because all or a substantial part of the acts and/or omissions giving rise to Plaintiff’s claims occurred in Dallas County, Texas. VI. CONDITIONS PRECEDENT 8. All conditions precedent to Plaintiff’s claims for relief have been performed or have occurred. VII. FACTS Defendant’s Fraudulent Scheme 9. In or around January 2023, Freij visited CAS and spoke with its owner, Hussein Daaboul (“Daaboul”). Freij informed Daaboul that he was a lucrative businessman who previously __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 2 of 9 74088184;1 worked for Mercedes, owned businesses across the country and abroad, and was looking to establish an auto salvage yard in Dallas, much like CAS. 10. On or about January 21, 2023, Freij convinced Daaboul to partner with him in purchasing a 2012 Dodge Ram (the “Ram”) for $15,000, the cost of which they would split 50/50. Freij told Daaboul that he would sell the vehicle overseas at a higher price and both of them would split the earnings. Daaboul paid Freij CAS’s $7,500 share of the purchase price. Thereafter, Freij represented to Daaboul that he sold the Ram for $28,000 overseas but the purchaser of the Ram found an issue with the vehicle and ended up paying him only $21,000. Accordingly, pursuant to their agreement, Freij owed $10,500 for his sale of the Ram. However, Freij refused to pay Daaboul any money from the sale. 11. Similarly, on January 28, 2023, Freij and Daaboul agreed to a 50/50 split of the approximately $18,000 purchase of a 2017 Dodge Challenger (the “Challenger”) and a 2017 Mercedes CLK (the “CLK”) from a Sheriff’s auction. Daaboul paid Freij CAS’s $9,000 share of the purchase price. Freij indicated that he never picked the Challenger and CLK up from the auction, despite Daaboul’s persistent requests that he do so. Upon information and belief, Freij did obtain the vehicles from the auction and sold the vehicles. To date, Freij has failed and refused to compensate CAS and Daaboul for his sale of the Challenger and the CLK, much less refund Daaboul the $9,000 paid for the purchase of these vehicles. 12. In or around February 2023, Freij convinced Daaboul to open a line of credit in CAS’s name with Axel Funding and to list Freij as an auto dealer, which would enable Freij to purchase vehicles from auto auctions and to draft the amount from CAS’s line of credit. Freij promised that if Daaboul opened the line of credit, he would pay off all amounts he drafted back to __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 3 of 9 74088184;1 CAS. Thereafter, Freij began purchasing vehicles by drafting on CAS’s line of credit. However, Freij failed and refused to pay CAS back, forcing Daaboul to pay off the amounts owed to Axel Funding. 13. Daaboul discovered Freij was selling the vehicles and auto parts he purchased with CAS’s money and was transferring the money he obtained to an account held by Defendant Freij Group. In addition, Freij was selling CAS’s vehicles without any authority from Daaboul or CAS. Such sales were made in Freij Group’s name, and the funds were also funneled into Freij Group. 14. On or about February 13, 2023, Freij purchased a 2011 Volkswagen Tiguan (the “Tiguan”) for $3,590 from Manheim Dallas using CAS’s line of credit. Freij told Daaboul that he purchased the Tiguan for CAS to sell at a profit. However, Daaboul later discovered that Freij gave the Tiguan to his wife, Pamela Freij. On or about May 16, 2023, Freij purchased a 2015 Nissan Rogue (the “Rogue” and, together with the Tiguan, the “Vehicles”) for $5,500 from American Auto Auction using CAS’s line of credit. Freij told Daaboul that he was purchasing the vehicle for his son, Saif Freij, who lives in Florida and promised that he would pay the entire purchase price back to CAS. Freij promised Daaboul that he would pay Daaboul back the entire purchase price for the Vehicles. To date, Freij has failed and refused to pay Daaboul or CAS the amounts owed for the purchase of the Vehicles despite numerous demands that he do so. 15. On or about December 5, 2023, Daaboul received notice from the Texas Department of Motor Vehicles indicating that Freij had applied for a bonded title for the Vehicles despite not having paid for them. __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 4 of 9 74088184;1 VIII. CAUSES OF ACTION FRAUD 16. All paragraphs above are incorporated by reference as if fully set forth herein. 17. Defendant Freij represented to Plaintiff that he would pay Plaintiff back from the sales proceeds he obtained from the sales of vehicles purchased with CAS and on CAS’s line of credit. Freij’s misrepresentations were material because it induced Daaboul and Plaintiff to give Freij money for the purchase or certain vehicles, to open a line of credit in CAS’s name, to list Freij as an auto dealer, which allowed him to purchase vehicles in CAS’s name, and to allow Freij to draw on CAS’s line of credit. Freij’s representations were a false promise of future performance. Freij made these misrepresentations knowing they were false and/or recklessly, as a positive assertion, and without knowledge of its truth. Freij intended for Plaintiff to rely on his false representations. Plaintiff justifiably relied on Freij’s false representations. Freij’s false representations directly and proximately caused injury to Plaintiff. Plaintiff seeks damages, including exemplary damages, attorneys’ fees, court costs and expenses, within the jurisdictional limits of this Court. CONVERSION 18. All paragraphs above are incorporated by reference as if fully set forth herein. 19. Plaintiff owns the Vehicles, which are personal property. 20. Defendants have in the past and continue to wrongfully exercises dominion and control over the Vehicles despite notice that Defendants do not have any ownership rights with respect to the Vehicles and do not have any right to possess the Vehicles. __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 5 of 9 74088184;1 21. At the time Defendants came into possession of the Vehicles, Defendants did not own the Vehicles and did not have any right to possess the Vehicles. 22. Plaintiff has been damaged by Defendants’ continued actions with respect to the Vehicles. 23. As a result of Defendants’ conversion of the Vehicles, Plaintiff seeks the return of the vehicles or actual monetary damages in the sum of money necessary to compensate Plaintiff for the vehicles. 24. Plaintiff’s injury resulted from Defendants’ malice or actual fraud, which entitles Plaintiff to exemplary damages under Texas Civil Practice & Remedies Code section 41.003(a). VIOLATION OF THE TEXAS THEFT LIABILITY ACT 25. All paragraphs above are incorporated by reference as if fully set forth herein. 26. At all times Plaintiff had a possessory right to the Vehicles. 27. Defendants appropriated the Vehicles with the intent to deprive Plaintiff of the Vehicles. 28. Defendants unlawfully appropriated, secured, or stole the Vehicles by taking them without Plaintiff’s effective consent in violation of Section 31.03 of the Texas Penal Code. 29. Defendants were informed by Plaintiff that the Vehicles were stolen and Defendants appropriated the Vehicles knowing that the Vehicles were stolen. 30. Plaintiff sustained and continues to sustain monetary damages as a result of the theft. 31. Upon proof of actual damages, Plaintiff seeks additional statutory damages up to $1,000 from each Defendant pursuant to Tex. Civ. Prac. & Rem. Code § 134.005(b). __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 6 of 9 74088184;1 32. Plaintiff’s injury resulted from Defendants’ malice or actual fraud, which entitles Plaintiff to exemplary damages under Tex. Civ. Prac. & Rem. Code § 41.003(a). BREACH OF CONTRACT 33. All paragraphs above are incorporated by reference as if fully set forth herein. 34. Plaintiff and Defendant Freij entered into oral agreements pursuant to which CAS would provide money to Freij for the purchase of certain vehicles, Freij would purchase and sell the vehicles, and Freij would then pay Plaintiff fifty percent of the total sales proceeds. Freij breached the agreement by failing and refusing to pay Plaintiff the amounts owed from the total sales proceeds. Freij’s breach proximately caused Plaintiff to incur damages. 35. Additionally, Plaintiff seeks its recover reasonable and necessary attorneys’ fees under Tex. Civ. Prac. & Rem Code Chapter 38. DECLARATORY RELIEF 36. All paragraphs above are incorporated by reference as if fully set forth herein. 37. Pursuant to the Texas Uniform Declaratory Judgments Act (“UDJA”), Tex. Civ. Prac. & Rem. Code § 37.001, et seq., Plaintiff respectfully seeks a declaration of its rights and status with respect to the Vehicles. Specifically, Plaintiff seeks a declaration that: 1) Plaintiff is the sole and exclusive title owner of the Vehicles; 2) Defendants do not own and do not have any right to the Vehicles; and 3) Defendants do not have the right to apply for a bonded title for the Vehicles INJUNCTIVE RELIEF 38. Plaintiff seeks all necessary supplemental and ancillary relief, including injunctive relief, based on the declaratory judgment. Specifically, Plaintiff seeks a preliminary injunction __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 7 of 9 74088184;1 barring Defendants from obtaining title to the Vehicles. ECB further seeks a permanent injunction barring Defendants obtaining title to the Vehicles. IX. ATTORNEYS’ FEES 39. Plaintiff seeks an award of its costs, expenses, and reasonable and necessary attorneys’ fees under the UDJA, pursuant to Tex. Civ. Prac. & Rem. Code § 38.001, and as otherwise provided under the law. X. JURY DEMAND 40. Plaintiff respectfully demands a trial by jury. PRAYER Plaintiff respectfully prays that Defendants be cited to appear and answer herein and that, upon final hearing, Plaintiff be awarded judgment for: a. actual and exemplary damages; b. declaratory, supplemental, and ancillary relief, including injunctive relief, under the UDJA as requested herein; c. attorneys’ fees; d. pre-judgment and post-judgment interest at the highest lawful rate; e. court costs and expenses; and f. all other relief, at law or in equity, to which Plaintiff is entitled. __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 8 of 9 74088184;1 Respectfully submitted. AKERMAN LLP /s/ Rola Daaboul David V. Jones State Bar No. 10869825 112 E Pecan, Suite 2750 San Antonio TX 78205 210.582.0220 (Phone) 512.623.6701 (Fax) david.jones@akerman.com Rola Daaboul State Bar No. 24068473 500 W 5th Street, Suite 1210 Austin, Texas 78701 737.999.7107 (Phone) 512.623.6701 (Fax) rola.daaboul@akerman.com ATTORNEYS FOR HUSSEIN DAABOUL D/B/A CEDAR AUTO SALES __________________________________________ PLAINTIFF’S ORIGINAL PETITION Page 9 of 9 74088184;1