PLAINTIFF’S ORIGINAL PETITION Page 1

Cause No. ____________________

CAUSE NO. _________________

AMERICAN ACCESS § IN THE JUSTICE COURT 

CASUALTY COMPANY § 

As Subrogee of Maribel Rodriguez §

 Plaintiff, §

vs. § PRECINCT 2

§

UNITED STATES POSTAL SERVICE §

 Defendant. § ROCKWALL COUNTY, TEXAS

PLAINTIFF’S ORIGINAL PETITION

Plaintiff AMERICAN ACCESS CASUALTY COMPANY As Subrogee of Maribel 

Rodriguez, a company which was at all times relevant to this suit authorized to transact the 

business of auto insurance in the State of Texas, complains of Defendant UNITED STATES 

POSTAL SERVICE and respectfully shows as follows:

A. Parties

1. Defendant United States Postal Service is a government entity doing business in the State 

of Texas. Defendant can be served with process by serving the Civil Process Clerk at the United 

States Attorney’s Office, 1000 Louisiana Street, Suite 2300, Houston, Texas 77002. Issuance of 

citation is requested at this time.

2. Plaintiff seeks monetary relief of less than $10,000.00.

B. Facts

3. On or about June 19, 2021, near the intersection of Southwood Drive and Southlake Drive in

Rockwall, Rockwall County, Texas, a motor vehicle owned by Plaintiff’s insured Maribel 

Rodriguez, (hereinafter “Insured”) was damaged by a vehicle negligently operated by Americo 

Lopes. Mr. Lopes’s negligence proximately caused the collision and damages in the amount of 

$6,893.33. At the time of the accident, Americo Lopes was acting within the course and scope of 

employment with Defendant. Defendant is liable for the negligent conduct of its employee, Mr. 

Lopes, under the legal doctrine of respondeat superior. Plaintiff compensated its insured for the loss, 

thereby becoming subrogated to the claim herein. The total amount sought is $6,893.33 plus court 

costs.

4. Pursuant to Texas Transportation Code 601.335, it is requested that the Court, as part of its 

judgment, allow the parties to enter into written installment payment agreements without further 

order of the Court.

FOR JURY PURPOSES ONLY: If a jury trial is held, the Plaintiff requests that the Plaintiff’s 

Insured be designated as the nominal plaintiff to avoid informing the jury of the existence of 

insurance.

CV2-22-0218

Rockwall County - JP Precinct 2

Filed: 9/12/2022 5:13 PM

Cathy Penn,

Justice of the Peace, Pct. 2

Rockwall County, Texas

Michael Humphrey

Case 3:22-cv-02135-G Document 1-5 Filed 09/26/22 Page 1 of 3 PageID 12
PLAINTIFF’S ORIGINAL PETITION Page 2

Cause No. ____________________

Prayer

Plaintiff prays that Defendant be cited to answer and appear, and after final trial, Plaintiff 

have judgment against Defendant for a sum of $6,893.33 with pre-judgment and post-judgment

interest, costs of suit and other relief which Plaintiff is entitled.

Respectfully submitted,

KERAMIDAS LAW FIRM

____________________________________

T. Cass Keramidas

State Bar No. 24027101

801 E. Campbell Road, Suite 625

Richardson, Texas 75081

(214) 299-8016 Office

(214) 299-8017 Fax

cass@keramidaslaw.com

ATTORNEYS FOR PLAINTIFF

AMERICAN ACCESS 

CASUALTY COMPANY

Case 3:22-cv-02135-G Document 1-5 Filed 09/26/22 Page 2 of 3 PageID 13
801 E. Campbell Rd., Suite 625

Richardson, Texas 75081

Phone 214.299.8016

Fax 214.299.8017

Michelle Jenkins

Direct phone extension 113

michelle@keramidaslaw.com

September 12, 2022

Clerk of the Court VIA ELECTRONIC FILING

Justice Court, Precinct 2

1111 E Yellowjacket Lane

Suite 302

Rockwall, TX 75087

Re: American Access Insurance Company as Subrogee of Maribel Rodriguez v. United States 

Postal Service; 

Cause No. _____________

(Justice Court, Precinct 2, Rockwall County, Texas)

Dear Clerk:

Enclosed for filing, find Plaintiff’s Original Petition in regards to the above referenced 

matter. 

Issuance of the citation is requested at this time. Please send the citation via email to 

michelle@keramidaslaw.com.

If you should have any questions, please feel free to contact me directly at (214) 299-

8016, ext. 113 or michelle@keramidaslaw.com.

With kind regards, 

Michelle Jenkins

Enclosure as stated.

CV2-22-0218

Case 3:22-cv-02135-G Document 1-5 Filed 09/26/22 Page 3 of 3 PageID 14 Rockwall County - JP Precinct 2