JAMES HOLTEN, INDIVIDUALLY, § IN THE DISTRICT COURT

    AND A/N/F OF MATHEW HOLTEN, §

    A MINOR, LARRY AND SANDRA §

    SOKOLOWSKI, DAVID AND CATHY §

    PRICE, JERRY COOLEY II, §

    GERHARD AND MADELEINE §

    HARDT, DAN AND JEANETTE §

    DAVID, KIM AND DEBRA JESSUP, §

    RANDY LAM, NEAL G. OFIESH, §

    CHRISTOPHER AND LORIE WIJAS, §

    MARILYN AND WALTER ROBB, § HARRIS COUNTY, TEXAS

    GERALD AND MARY COOLEY, §

    AND ROGER D. AND SHARON M. §

    GARDNER §

    §

    -VS- §

    §

    MELALEUCA, INC., LARRY AND §

    CONNIE HAGEN, AND §

    FRANK VANDERSLOOT § 280th JUDICIAL DISTRICT


    
PLAINTIFFS' SECOND AMENDED ORIGINAL PETITION


    
TO THE HONORABLE JUDGE OF SAID COURT:

COME NOW, JAMES HOLTEN, INDIVIDUALLY, and as next friend of his son, MATHEW HOLTEN, a minor, LARRY and SANDRA SOKOLOWSKI, DAVID and CATHY PRICE, JERRY COOLEY II, GERHARD and MADELEINE HARDT, DAN and JEANETTE DAVID, KIM and DEBRA JESSUP, RANDY LAM, NEAL G. OFIESH, CHRISTOPHER and LORIE WIJAS, MARILYN and WALTER ROBB, GERALD and MARY COOLEY, and ROGER D. and SHARON M. GARDNER, KEN AND SANDRA JOLLEY, ROBERT AND BONNIE BUTWIN, DON AND NANCY FAILA, AND MICHAEL BERG, Plaintiffs, and herein bring this suit as against Defendants, MELALEUCA, INC., LARRY and CONNIE HAGEN, and FRANK VANDERSLOOT, and with respect thereto would show unto the court as follows:

Plaintiffs, JAMES HOLTEN, his son, MATHEW HOLTEN, LARRY and SANDRA SOKOLOWSKI, and DAVID and CATHY PRICE, are residents of Harris County, Texas. All other Plaintiffs are either Texas or out of state residents complaining of acts which occurred, among other places, in Texas and in Harris County in particular.

Defendant, MELALEUCA, INC., is a foreign corporation organized under and existing under the laws of the State of Idaho, and does not maintain a regular place of business or a designated agent for service of process in Texas. Defendant has sufficient contacts with Texas that, under the Texas Long-Arm Statute, it can be served with process by serving the Texas Secretary of State. Defendant's home office address is 3910 South Yellowstone Hwy., Idaho Falls, Idaho 83402.

Defendant, FRANK VANDERSLOOT, is an individual, who is a non-resident of Texas, residing in the State of Idaho, and the alter ego of the corporate Defendant, MELALEUCA, INC., and does not maintain a regular place of business or a designated agent for service of process in Texas. Defendant, FRANK VANDERSLOOT, has sufficient contacts with Texas that, under the Texas Long-Arm Statute, he can be served with process by serving the Texas Secretary of State. Defendant's home office address is 3910 South Yellowstone Hwy., Idaho Falls, Idaho 83402.

Defendants LARRY and CONNIE HAGEN are residents of Harris County and may be served at their residence 1005 Bob Smith Road, Harris County, Baytown, Texas, 77521.

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