EXHIBIT B

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 1 of 10 PageID 8
Service of Process

Transmittal

03/02/2022

CT Log Number 541149236

TO: MetLife Litigation Intake

Metropolitan Life Insurance Company

200 PARK AVENUE

NEW YORK, NY 10166

RE: Process Served in Texas

FOR: Metropolitan Life Insurance Company  (Domestic State: NY)

Page 1 of  1 / SH

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:

 

TITLE OF ACTION: Londi Dennis vs. Metropolitan Life Insurance Company

DOCUMENT(S) SERVED: Citation, Petition

COURT/AGENCY: Tarrant County Judicial District Court, TX

Case # 14133158722

NATURE OF ACTION: Insurance Litigation

ON WHOM PROCESS WAS SERVED: C T Corporation System, Dallas, TX

DATE AND HOUR OF SERVICE: By Certified Mail on 03/02/2022 postmarked on 02/04/2022

JURISDICTION SERVED : Texas

APPEARANCE OR ANSWER DUE: At or before 10:00 a.m. of the Monday next following the expiration of 20 days from

the date of service

ATTORNEY(S) / SENDER(S): Mark S. Humphreys

Mark S. Humphreys, P.C.

702 Dalworth Street

Grand Prairie, TX 75050

972-263-3722

ACTION ITEMS: CT has retained the current log, Retain Date: 03/02/2022, Expected Purge Date:

03/07/2022

Image SOP

Email Notification,  MetLife Litigation Intake  litigationintake@metlife.com

REGISTERED AGENT ADDRESS: C T Corporation System

1999 Bryan Street

Suite 900

Dallas, TX 75201

800-448-5350

MajorAccountTeam1@wolterskluwer.com

The information contained in this Transmittal is provided by CT for quick reference only. It does not constitute a legal opinion, and should not otherwise be

relied on, as to the nature of action, the amount of damages, the answer date, or any other information contained in the included documents. The recipient(s)

of this form is responsible for reviewing and interpreting the included documents and taking appropriate action, including consulting with its legal and other

advisors as necessary. CT disclaims all liability for the information contained in this form, including for any omissions or inaccuracies that may be contained

therein.

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 2 of 10 PageID 9
CEJALAW OFFICE 

702 Dalworth Street 

Grand Prairie TX 75050 

· '· · -7D1 7 . 14 5 D DD D 1 - 8 7 3 3 9 0-9 9 

( . , .. 

-· 9326.6ZE'f2:1-24629J.8 

l'··111'l··l'1·'·'1·ll•••l1l•'1'1•l1·'l••11l1lj11ll1l111l11l11l11 

Metropolitan Life Insurance Company 

B/S-C. T. Corporation System 

1999 Bryan St., Ste. 900 

Dallas TX 75201-4284 -·- , .. _ - - f.~ 1.. -~-.!... -~ •; t 

ANK 

US -S7.33ol. POSTAGE tl ~ FIRST -CLASS 8 

FROM 75050 • lil 

0210412022 ' ::1 •• • CJ) 

stamps "' endicia • g 

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 3 of 10 PageID 10
,, : 

THE STATE OF TEXAS 

DISTRICT COURT, TARRANT COUNTY 

CITATION 

LONDI DENNIS 

VS. 

METROPOLITAN LIFE INSURANCE COMPANY 

Cause No. 141-331587-22 

TO: METROPOLITAN LIFE INSURANCE COMPANY 

B/S CT CORPORATION SYSTEM 1999 BRYAN ST STE 900 CALLAS, TX 75201-4284 

You said CEFENilANT are hereby commanded to appear by filing a written answer to the PLAINTIFF'S FIRS AMENDED PETITION 

at or before 10 o'clock A.M. of the Monday next after 

the expiration of 20 days after the date of service hereof before the 14let District court 

,100 N CALHOUN, in and for Tarrant County, Texas, at the courthouse in the City of Fort worth, Tarrant County, Texas 

said PLAINTIFF being 

LONCI DENNIS 

Filed in said Court on January 31st, 2022 Against 

METROPOLITAN LIFE INSURANCE COMPANY 

For suit, said suit being numbered 141-331587-22 the nature of which demand is as ehown on said 

PLAINTIFF'S FIRS AMENDED PETITION a copy of which accompanies this citation. 

MARK S HUMPHREYS 

Attorney for LONDI DENNIS Phone No. (972)263-3722 

Address 702 DAL WORTH ST GRAND PRAIRIE, TX 75050 

Thomag A. Wilder , Clerk of the District Court of Tarrant County, Te:icas. Given under my hand and the seal 

of said court, at office in the City of Fort Worth, this the let day of February, 2022. -~ •. :;,;;~•;;;:;:;. .... •cERT1F1Eoco.v 

~ :8_ ~'i-_ .. ATTEST:02/0112022 

• f' f:.... w ~ ! THOMAS A. WILDER 

ey ---"----=-"""'""''-""" ...... us~=-.._-----\~~ , · ~k:4Bim~~~s AATALIHICJPEN ··~?. ....... ~;.• BY: /1/ Natalio Thigpen 

NOTICE: Y'"1baw:bo"1 llle4. y.., my.,.ploJ .,....,.,,.,., UJ'lll Dr)'llW lllan><JdD"'" file a wrilr.ai .,,._.,.;11i lbocltrt< """ilsllod lbiaclwioa b)' ID:OOAM.1111 lbc Mond.ly out followina lho elpin!loo of 

NaU)' days o/ltr Y'"' were 11:....S Ibis <ii.lion IOd petitioo, a def11UJ1 j1'dgin<n1 may be lltm aalilut JOU. ID addldoa ro lllil>a a '"'1nto answu wilh lbc cltn. you may be l<qlllred ro male llli!W dill:towm 

111 Ibo ocllor pani•• or chi< lllit. Tbue diicloswa g<ocnlly """'be made oo lmcr dwi :!II daya after,.,.. file>""'...._, willl lbc clerk. F'uid OUI more• T...,l.awlielp.ora. 

Thomas A. Wilder, Tarrant County District Clerk, 100 N CALHOUN, FORT WORTH TX 76196-0402 

OFFICER'S RETURN • 14133158722000004* 

Received this Citation on the ___ day of , __ at ___ o'clock _M; and executed at 

-----------------within the county of , State or at o•clock _M 

on the day or • __ by delivering to the within named {Def. I: 

detendant(sl, a true copy or this Citation together with the accompanying copy ot PLAINTIFF'S FIRS AMENDED PETITION 

, having first endorsed on same the date of delivery. 

Authorized Person/Constable/Sheriff: ---------------------

County or------------ state of ____ _ By --------------- Deputy Fees$ ___ _ 

State of ------- County of -------------- (Must be verified if served outside the State of Texas) 

Signed and sworn to by the said ----------------- before me this __ day or ____ , __ 

to certify which witness my hand and seal of off ice 

!Seal) 

county of---------• State of---------

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 4 of 10 PageID 11
CITA110N 

Cause No. 141-331587-22 

LONDI DENNIS 

vs. 

METROPOLITAN LIFE INSURANCE 

COMPANY 

ISSUED 

This 1st day of February, 2022 

Thomas A. Wilder 

Tarrant County District Clerk 

100 N CALHOUN 

FORT WORTH TX 76196-0402 

By NAT ALIE THIGPEN Deputy 

MARK S HUMPHREYS 

Attorney for: LONDI DENNIS 

Phone No. (972)263-3722 

ADDRESS: 702 DALWORTH ST 

GRAND PRAIRIE, TX 75050 

CIVILLAW 

*14133158722000004* 

SERVICE FEES NOT COLLECTED 

BY TARRANT COUNTY DISTRICT CLERK 

ORIGINAL 

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 5 of 10 PageID 12
Landi Dennis 

V. 

Metropolitan Life Insurance Company 

141-331587-22 

Cause No. 141-331587-22 

§ 

§ 

§ 

§ 

§ 

In the 141 ST Judicial 

District Court of 

Tarrant County, Texas 

PLAINTIFF'S FIRS AMENDED PETITION 

TO THE HONORABLE JUDGE OF SAID COURT: 

FILED 

TARRANT COUNTY 

1/31/2022 1 :50 PM 

THOMAS A. WILDER 

DISTRICT CLERK 

NOW COMES Londi Dennis (126/477) (hereinafter Plaintiff) complaining of and about Metropolitan Life Insurance 

Company (hereinafter Defendant) and for cause of action shows unto the Court the following: 

JURISDICTION and VENUE 

1. The subject matter in controversy is within the jurisdictional limits of this court in that Plaintiff seeks recovery 

of $250,000.00 or less excluding interest, statutory or punitive damages and penalties, and attorney fees and costs. 

2. Pursuant to Texas Civil Practice & Remedies Code §15.032, venue in Tarrant County is proper in this cause 

in that it is where the insured resided at time of death. 

SERVICE 

3. Defendant Metropolitan Life Insurance Company is an insurance company, doing business in the State of 

Texas. Said Defendant can be served through its attorney for service: 

C.T. Corporation System, 1999 Bryan St., Ste. 900, Dallas TX 75201-4284 

AGENCY AND VICARIOUS LIABILITY 

4. Whenever in this Petition it is alleged that Defendant did any act or thing or omission, it is meant that 

Defendant, its officers, agents. employees, or represent<itives did such rir.t or thing or omission rind that at the time 

sur.h act or thing was done, it was done with the full authorization or ratification of Defendant or was done in the 

normal and routine course and scope of employment of Defendant, its officers, agents, employees, or 

representatives. 

WRITTEN NOTICE GIVEN 

5. Plaintiff has fully complied with all of the conditions precedent prior to bringing this suit. 

Plaintiff's First Amended Petition Page 1 

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 6 of 10 PageID 13
6. Notice letter was issued August 4, 2020, and this lawsuit is being filed after the expiration of 60 days. 

7. Anthony Troy Dennis, Jr. ("Troy") had a policy of insurance with Defendant, group policy number 5973562. 

8. The policy was in full force and effect. 

9. On June 15, 2021, Troy died and Plaintiff made a timely claim for life insurance benefits and cooperated 

with the investigation of the claim. 

10. Defendant had initial concerns about who was to be paid the policy benefits. 

11. Defendant eventually agreed that Plaintiff was entitled to the benefits but then stated that there was 

concerns about the conversion period and Troy's last day of employment. 

12. In a letter dated October 25, 2021, Plaintiffs claim was denied based on Defendant's contention that Troy 

was not an eligible employee. 

13. The fact is that Troy had not quit employment nor was he terminated from employment prior to his death. 

14. The continued refusal to pay benefits is unjustified. 

15. Defendant had or should have had all the information it needed to pay the benefits by October 25, 2021. 

16. Due to the conduct of Defendant, Plaintiff has suffered pain and mental anguish resulting in emotional pain, 

torment, and suffering, exhibited by headaches, upset stomach, an inability to sleep well, and an inability to 

concentrate and carry own with daily activities. 

VIOLATIONS OF THE TEXAS INSURANCE CODE 

17. Plaintiff incorporates herein all the FACTS as set forth above. 

18. Defendant's conduct in this matter appears to be in violation of numerous laws, including but not limited to 

Texas Insurance Code (TIC), as follows: 

a) TIC §541.060(a)(1 ): Defendant violated this section by misrepresenting to a claimant a material fact 

relating to coverage at issue by telling claimant there appears to be no coverage because of some issues 

with Troy's last day of employment and conversion periods. 

b) TIC §541.060(a)(2)(A): Defendant violated this section by failing to attempt in good faith to effectuate a 

prompt, fair, and equitable settlement of a claim with respect to which the insurer's liability has become 

reasonably clear in that research would show the Facts Defendant seems to be using as justification for its 

refusal to pay this claim. 

Plaintiff's First Amended Petition Page 2 

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 7 of 10 PageID 14
BREACH OF CONTRACT 

19. Plaintiff incorporates herein all the FACTS as set forth above. 

20. Defendant's conduct in this matter appears to be in Breach of Contract. 

21. There is a valid, enforceable contract of insurance between and Defendant and Plaintiff as the beneficiary of 

the life insurance policy. 

22. Plaintiff is a proper party to bring a lawsuit against Defendant. 

23. Plaintiff has perfor111eu under the contract by timely reporting the claim and cooperating with the 

investigation and supplying necessary information. 

24. Defendant breached the contract by not providing benefits. 

25. The breach of the contract has caused injury to Plaintiff. 

PROMPT PAYMENT OF CLAIMS ACT 

26. Plaintiff incorporates herein all the FACTS as set forth above. 

27. Defendant had all the information needed to pay Plaintiff's claim on or before October 25, 2021. As a result, 

this claim should have been accepted and paid by October 25, 2021. 

28. Defendant is liable as penalty at an interest of 18% a year on the policy benefits plus attorneys' fees. 

DAMAGES 

29. Plaintiff incorporates herein all the FACTS as set forth above. 

30. Plaintiff sustained the following economic and actual damages as a result of the actions and/or omissions of 

Defendant described herein: 

a) $100,000.00 

b} $25,000.00 

c) $10,000.00 

d) $????.?? 

- Actual damages 

- Exemplary damages due to the knowing and intentional conduct on Defendant's part. 

- Mental anguish damages resulting from Defendant's conduct. 

- Penalty at 18%, on actual damages from October 25, 2021, until paid. 

Plaintiff's First Amended Petition Page 3 

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 8 of 10 PageID 15
' . 

USE OF DOCUMENTS 

31. NOTICE pursuant to Rule § 196, you are hereby given Notice that all documents produced by you in 

response to this Request for Production may be used at the trial of this cause pursuant to Rule 196, Texas Rules of 

Civil Procedure. 

32. Pursuant to Rule §193.7 of the Texas Rules of Civil Procedure, Plaintiff hereby gives notice to the 

Defendant that Plaintiff intends to use all documents exchanged and produced between the parties (including, but not 

limited to, correspondence, pleadings, records, and discovery responses) during the trial of this matter. 

ATTORNEY'S FEES 

33. Request is made for all costs and reasonable and necessary attorney's fees incurred by or on behalf of 

Plaintiff herein, including all fees necessary in the event of an appeal of this cause to the Court of Appeals and the 

Supreme Court of Texas, as the Court deems equitable and just, as provided by: (a) §541.152(a)(1 ), of the Texas 

Insurance Code; (b) Chapter 38 of the Texas Civil Practice and Remedies Code; and, (c) common law. 

PRE-JUDGMENT INTEREST 

34. As a result of the injuries sustained by Plaintiff as aforesaid and in addition to such damages, Plaintiff will 

show that Plaintiff is entitled to pre-judgment interest on each separate element of damages as awarded by the jury 

during the trial of this case, from and after the date of accrual of such damages, through the date of judgment, such 

interest to accrue at the highest prevailing rate then applicable on the date of judgment. 

POST JUDGMENT INTEREST 

35. As a result of the injuries sustained by Plaintiff and in addition to such damages, Plaintiff will show that 

Plaintiff is entitled to post-judgment interest on damages awarded by the jury during the trial of this case, from and 

after the date of judgment, such interest to accrue at the highest prevailing rate then applicable until paid in full. 

COSTS OF SUIT 

36. In addition, Plaintiff seeks all related costs of suit in this cause of action through the trial, post-trial, appeal, 

and/or post-judgment discovery, etc. of this matter. 

37. Wherefore, Plaintiff seeks reimbursement of court costs incurred in the trial of this case and thereafter. 

Plaintiff's First Amended Petition Page4 

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 9 of 10 PageID 16
• \ I ' 

REQUEST FOR JURY TRIAL 

38. Plaintiff respectfully requests that a Jury be impaneled on final hearing of this cause of action. 

PRAYER 

39. WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays that the Defendant be cited to appear 

and answer herein, and that upon a final hearing of the cause, judgment be entered for the Plaintiff against 

Defendant for and such other and further relief to which the Plaintiff may be entitled at law or in equity, whether pied 

or unpled. 

SIGNED on January 31, 2021. 

Respectfully submitted, 

/s/ Mark S. Humphreys 

Mark S. Humphreys - SBOT #00789762 

MARKS. HUMPHREYS, P.C. 

702 Dalworth Street, Grand Prairie, Texas 75050 

Tel. (972) 263-3722 * Fax. (972) 237-1690 

Email: texaslaw94@yahoo.com 

Attorney For Plaintiff 

Plaintiff's First Amended Petition Page 5 

Case 4:22-cv-00208-P Document 1-2 Filed 03/23/22 Page 10 of 10 PageID 17