9- TRÍCH ĐƠN KIỆN TRƯỚC TOÀ # 2 HARRIS COUNTY

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THS2018 – Trích 3 trang trong tổng số 13 trang đơn kiện Al Hoàng tức Hoàng Duy Hùng

Excert first 3 pages  from the Lawsuit:

 NO. 991617
DAVID NG, § IN THE COUNTY COURT
WENYUAN DING, KENNETH §
K. GEE, I-LE LU, AND JODY §
T. PAY §

Plaintiffs §

vs. § AT LAW NUMBER 2

HOAT KHOA NGUYEN, §
CUC T. DO, TAM PHAM, §
RANG HOANG, and HUY DUNG HOANG, § a/k/a ALOYSIUS “AL” HOANG §

Defendants § HARRIS COUNTY, TEXAS
PLAINTIFFS’ FIRST SUPPLEMENTAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

David Ng, Wenyuan Ding, Kenneth K. Gee, I-Le Lu, and Jody T. Pay, Plaintiffs herein, complain of Huy Dung Hoang, a/k/a Aloysius ―Al Hoang, Hoat Khoa Nguyen, Cuc T. Do, Tam Pham, and Rang Hoang, Defendants herein, and file this their first Supplemental Petition and for cause of action shows:

DISCOVERY LEVEL

Plaintiff requests that discovery be conducted under Level 2.

PARTIES

1.Plaintiffs David Ng (Ng), Wenyuan Ding (Ding), Kenneth K. Gee (Gee), I-Le Lu (Lu), and Jody T. Pay (Pay) are residents of Harris County, Houston, Texas. Specifically, they reside and own real property abutting Turtlewood Drive.

2. Defendant Huy Dung Hoang, a/k/a Aloysius – Al Hoang (Defendants or Al Hoang herein) is an individual residing in Harris County, Houston, Texas and may be served with process at: 6865 Turtlewood, Houston, Texas 77072 or wherever he may be found.

3. Defendants Hoat Khoa Nguyen (Defendants or Nguyen‖), Cuc T. Do (Defendants or Do), Tam Pham (Defendants‖ or Pham), and Rang Hoang (Defendants‖ or Hoang‖) have made appearances in this case and filed an answer.

JURISDICTION AND VENUE

1. This Court has jurisdiction over Defendants for the reason that it conducts business in the State of Texas, has sufficient minimum contacts with the State of Texas, or resides in the State of Texas. Additionally, Defendant has committed wrongful actions in the State of Texas as set forth in this petition.

2. Venue is proper pursuant to TEX. CIV. PRAC. & REM. CODE, § 15.002.

3. Plaintiff is seeking damages within the jurisdictional limits of this Court.

FACTS/CAUSES OF ACTION

Defendants Al Hoang, Hoat Khoa Nguyen, Cuc T. Do, Tam Pham, and Rang Hoang have forged signatures in a purported petition, submitted to the City of Houston Planning and Development Department to change their neighborhood street name from Turtlewood Drive to LITTLE SAIGON DRIVE.

Turtlewood Square Community consists of forty-nine (49) property owners in the heart of District F, in Harris County, Texas. Defendants Al Hoang, Hoat Khoa Nguyen, Cuc T. Do, Tam Pham, and Rang Hoang circulated a purported petition to change Turtlewood Dr. to LITTLE SAIGON DRIVE.

Per the City of Houston’s Planning & Development Department seventy-five percent (75%) of the abutting property owners on Turtlewood Drive must sign a petition authorizing the name change. Plaintiffs are property owners abutting Turtlewood  Drive.

On or about March 28, 2011, Defendants submitted a petition to the City of Houston’s Planning

& Development Department containing forged signatures purportedly showing that 75% of the property owners abutting Turtlewood Drive approve the street name change. Defendants Al Hoang, Hoat Khoa Nguyen, Cuc T. Do, Tam Pham, and Rang Hoang conspired with each other to forge and submit forged signatures to petition the City of Houston to change Turtlewood Dr. to LITTLE SAIGON DRIVE.

Specifically, Defendants Al Hoang, Hoat Khoa Nguyen, Cuc T. Do, Tam Pham, and Rang Hoang forged Plaintiffs Jody Pay and I-Le Lu’s signatures on the name change petition.

Homeowner Furthermore, Al Hoang’s involvement in the forgeries is confirmed by Co-Defendant, Defendant Hoat Nguyen. Co-Defendant Nguyen admits that Co-Defendant Al Hoang submitted an unauthorized letter, containing false statements, and forged homeowner signatures to change a Houston public street name from Turtlewood Drive to Little Saigon Drive. Co-Defendant Nguyen, individually, and on behalf of the other Defendants blame Al Hoang for any forged signatures contained in the petition after number 24.

Defendants claim that it was Al Hoang’s idea to change a Houston public street to Little Saigon Drive. Co-Defendant Al Hoang prepared all the paperwork and petition for the street name change. Defendants allege that they gave the petition to Al Hoang with only 23 signatures, well short of the 75% requirement to change a public street name. Thereafter, Al Hoang submitted the petition under his Houston City Council letterhead and seal containing the forged signatures. Co-Defendant Al Hoang claims that the petition was given to his nanny‖ to collect signatures. However, Co-Defendant Hoat Nguyen, has testified that he has never seen a nanny at Co-Defendant Al Hoang’s house. In fact, Co-Defendant Al Hoang claims that the nanny no longer works for him and he cannot remember the nanny’s name. “

………. (Page 3 of 13).

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