) ) cause No, OF CA gO dy Ap STATE OF TEXAS, IN THE DISTRICT COUR 6 Plaintift NS LEE rs v. 19344, ~~, INFINITI VACATIONS LLC; BRAD JUDICIAL DISTRICT “%py, A. CORMACK, Individual NAREZ, Individually; and JERALD FRANKLIN JOHNSON, Individually, Defendants DALLAS COUNTY, TEXAS PLAINTIFF’S ORIGINAL PETITION FOR CIVIL PENALTIES AND FOR INJUNCTIVE RELIEF ‘TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, the State of Texas, Plaintiff, acting by and through Attorney General Greg Abbot, and files this Plaintiff’s Original Petition for Civil Penalties and for Injunctive Relief against INFINITI VACATIONS LLC; BRAD A. CORMACK, Individually, CRAIG NAREZ, Individually; and JERALD FRANKLIN JOHNSON, Individually. L PARTY PLAINTIFF 1. This suit is brought by the ATTORNEY GENERAL through the Consumer Protection Division in the name of the STATE OF TEXAS and in the public interest under the authority ‘granted to him by Section 17.47 of the Deceptive Trade Practices-Consumer Protection Act (TDTPA”). ‘The TDTPA permits the Attorney General’s office to bring an action to restrain, by temporary restraining order, temporary injunction, or permanent injunction, the ‘use of any method, act or practice declared to be unlawful by Section 17.46 of the TDTPA. State of Texas v, Infiniti Vacations LLC et al, ‘OAG 4082526856 Plaintiff's Original Petition for Civil Penalties and for Injunctive Relief 1H, PARTY DEFENDANTS 2.1 Defendant INFINITI VACATIONS LLC is a domestic limited liability company organized and existing under the laws of the State of Texas that engages in business in the State of ‘Texas. The registered agent for INFINITI VACATIONS LLC is Brad A, Cormack. Defendant INFINITI VACATIONS LLC may be served with process by serving its Registered Agent, Brad A. Cormack at 12720 Campolina Way, Keller, TX 76248 or at his place of business, 1600 Corporate Court, Suite 140, Irving, Texas 75038 or wherever he may be found. 2.2 Defendant BRAD A. CORMACC is an individual residing in Texas and may be served with citation and process at his home at 12720 Campolina Way, Keller, TX 76248 or at his place of business 1600 Corporate Court, Suite 140, Irving, Texas 75038 or wherever he may be found. 2.3 Defendant CRAIG NAREZ is an individual residing in Texas and may be served with citation and process at his home at $29 Timber Way Dr., Lewisville, TX 75067 or at his place of business 1600 Corporate Court, Suite 140, Irving, Texas 75038 or wherever he may be found. 2.4 — Defendant JERALD FRANKLIN JACKSON is an individual residing in Texas and may be served with citation and process at his home at 4933 Dougal Ave., Fort Worth, TX 76137- 6369, or at his place of business 1600 Corporate Court, Suite 140, Irving, Texas 75038 or wherever he may be found. I, AUTHORITY tate of Texas v. Infiniti Vacations LLC et Plaintiff's Original Petition for Civil Penalties and for Injunctive Relief ‘AG #0825268564.1 42 This action is brought by the Attomey General through his Consumer Protection Division under the authority granted by section 17.47 of the Texas Deceptive Practices-Consumer Protection Act (TDTPA). IV. VENUE ‘Venue of this action lies in Dallas County on the basis of section 15,002(a)(1) and (3) of the ‘Texas Civil Practice and Remedies Code because all or a substantial part of the events or omissions giving rise to this cause of action occurred in Dallas county. ‘Venue of this action also lies in Dallas County pursuant to section 17.47(b) of the TDTPA. because transactions and events giving rise to this action occurred in Dallas County and/or because Defendants have done or are doing business in Dallas County. V. PUBLIC INTEREST By reason of the institution and operation of the unlawful practices set forth herein, Defendants have and will cause immediate and irreparable injury, loss and damage to the STATE OF TEXAS and its citizens, and will also cause adverse effects to legitimate business enterprise which conducts its trade and commerce in @ lawful manner in this State, ‘Therefore, the Attorney General of the State of Texas believes and is of the opinion that these proceedings are in the public interest. VI. ACTS OF AGENTS ‘Whenever inthis petition itis alleged that Defendants did any actor thing, itis meant that Defendants performed or participated in such act or thing and that such act was performed by the officers, agents, oremployees of Defendants, and in each instance, the officers, agents, State of Texas v. Infiniti Vacations LLC et al, ‘OAG #082526856 Plaintiff's Original Petition for Civil Penalties and for injunctive Relief