Exhibit A-2 

Case 1:20-cv-00589-LY Document 1-5 Filed 06/03/20 Page 1 of 6
Plaintiff’s Original Petition and Jury Demand Page 1

CAUSE NO.: ______________ 

DANIEL FREEMAN, § IN THE DISTRICT COURT

§ 

Plaintiff, § 

§ 

v. § ____ JUDICIAL DISTRICT

§ 

WYNDEN STARK, LLC § 

d/b/a/ GQR GLOBAL MARKETS, § 

§ 

Defendant. § TRAVIS COUNTY, TEXAS

PLAINTIFF’S ORIGINAL PETITION AND JURY DEMAND

TO THE HONORABLE COURT: 

Plaintiff Daniel Freeman files this Original Petition and Jury Demand and for 

cause of action would show the court as follows:

DISCOVERY CONTROL PLAN

1. Mr. Freeman intends discovery to be conducted under the Level 3 

discovery plan set forth in Texas Rule of Civil Procedure 190.4.

SERVICE OF PROCESS

2. Defendant Wynden Stark, LLC d/b/a GQR Global Markets (GQR) is a 

foreign corporation with its principal place of business in Dallas County, Texas. 

GQR may be served with process by serving its registered agent, National 

Registered Agents Inc., 1999 Bryan Street, Suite 900, Dallas, Texas 75201-3136. 

BACKGROUND FACTS

3. This is a case of retaliation by an employer against an employee for 

having to take time off to serve on a jury. 

D-1-GN-20-002206

353RD

4/20/2020 7:53 PM 

Velva L. Price 

District Clerk 

Travis County 

D-1-GN-20-002206

Ruben Tamez

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Plaintiff’s Original Petition and Jury Demand Page 2

4. Defendant GQR chose not to supervise its manager to prevent him 

from violating laws protecting those who serve as jurors. GQR retaliated against 

Mr. Freeman who was following the law and serving as a juror. GQR did not care 

enough about the law or a person serving as a juror.

5. GQR recruited Mr. Freeman as Executive Vice President to manage its 

Austin, Texas, operation finding and placing nurses with hospitals. 

6. Previous to GQR, Mr. Freeman resided and had a previous position in 

North Carolina. The new position with GQR started on January 31, 2020.

7. On January 15, 2020, Mr. Freeman received a summons to appear in 

court in North Carolina on February 17, 2020, as a prospective juror.

8. On February 12, 2020, while Mr. Freeman was performing his work in 

Austin, GQR expressed concern for Mr. Freeman’s jury service requirements and 

asked Mr. Freeman if he was able to get out of jury service. Mr. Freeman responded 

that he did not have grounds to avoid responding to the summons in North 

Carolina. GQR instructed Mr. Freeman to nevertheless return to work in Austin by 

February 24, 2020.

9. On February 20, 2020, GQR expressed continuing concern for Mr. 

Freeman’s service as a juror and demanded proof of requirement of jury duty 

service. GQR informed Mr. Freeman that it expected him to work during the hours 

of the day that he was not on jury duty. Mr. Freeman agreed and complied.

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Plaintiff’s Original Petition and Jury Demand Page 3

10. GQR continued to express frustration at Mr. Freeman’s jury duty 

service. On February 27, 2020, GQR informed Mr. Freeman that it no longer 

wanted him to perform work while on jury duty. 

11. On February 28, 2020, GQR informed Mr. Freeman that it would no 

longer pay him while he was on jury duty. After GQR instructed Mr. Freeman to 

stop working, it began to ignore Mr. Freeman’s communications. 

12. On March 18, 2020, the court informed Mr. Freeman that the trial

would be stayed pending resolution of the coronavirus pandemic. Mr. Freeman 

immediately informed GQR that he could return to work.

13. GQR ignored Mr. Freeman and terminated his employment on March 

26, 2020.

14. GQR stated that Mr. Freeman’s termination had nothing to do with his 

performance, that he was being laid off because of a downturn in work related to 

COVID-19. 

15. GQR’s reason given for Mr. Freeman’s termination is not believable 

because Mr. Freeman’s job was to find nurses and place them in employment at 

hospitals, a need that increased dramatically during the COVID-19 crisis. 

Additionally, the timeline of events shows GQR’s frustration at jury service and 

motivation to intimidate and terminate before the crisis. 

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Plaintiff’s Original Petition and Jury Demand Page 4

CAUSE OF ACTION

Texas Statute

16. GQR discharged, threatened to discharge, intimidated, or coerced Mr. 

Freeman because Mr. Freeman served as a juror or because of Mr. Freeman’s 

attendance or scheduled attendance in connection with the service, in a court in the 

United States.

17. GQR’s actions violated Section 122.001 of the Texas Civil Practice & 

Remedies Code which prohibits an employer from discharging, intimidating, or 

coercing an employee because the employee serves as a juror in a court in the 

United States. 

18. Section 122.002 of the Texas Civil Practice & Remedies Code provides 

that a person who violates Section 122.001 is liable for damages in an amount not 

less than an amount equal to one year’s compensation nor more than an amount 

equal to five years’ compensation at the rate at which the person was compensated 

when summoned for jury service. The injured person is also entitled to reasonable 

attorney’s fees in an amount approved by the Court.

JURY DEMAND

19. Mr. Freeman requests a trial by jury.

WHEREFORE, Mr. Freeman requests that GQR be cited to appear and 

answer and that on final trial, Mr. Freeman have judgment against GQR for 

statutory and compensatory damages, reinstatement, attorneys’ and expert fees, 

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Plaintiff’s Original Petition and Jury Demand Page 5

declaratory and injunctive relief as alleged, interest as provided by law, costs of 

suit, the monetary relief being over $1,000,000, and any further relief to which Mr. 

Freeman may be entitled.

Respectfully Submitted,

 /s/ Brian P. Sanford 

Brian P. Sanford 

Texas Bar No. 17630700

 bsanford@sanfordfirm.com

David Norris 

Texas Bar No. 24060934

 dnorris@sanfordfirm.com

 Elizabeth “BB” Sanford

 Texas Bar No. 24100618

 esanford@sanfordfirm.com

THE SANFORD FIRM

1910 Pacific Ave., Ste. 15400

Dallas, Texas 75201

PH: (214) 717-6653

FAX: (214) 919-0113

ATTORNEYS FOR PLAINTIFF

DANIEL FREEMAN

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