INDEX OF STATE COURT DOCUMENTS 1 | P a g e

 9600427 v1 (41730.00075.000) 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

KACEY MARQUEZ, 

 Plaintiff, 

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vs. § CIVIL ACTION NO. 4:22-cv-00910 

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HYATT CORPORATION, § 

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Jury Demand 

Defendant. § 

INDEX OF STATE COURT DOCUMENTS 

DOCUMENT DATE 

1. Plaintiff's Original Petition 09/26/2022 

2. Issued Citation on Hyatt Corporation 09/28/2022 

3. Defendant Hyatt Corporation d/b/a Hyatt Centric The 

Woodlands’ Original Answer 

10/07/2022 

4. Civil Docket Sheet 

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 1 of 22 PageID 22
EXHIBIT 1

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 2 of 22 PageID 23
PLAINTIFF’S ORIGINAL PETITION PAGE 1 

CAUSE NO. __________________ 

KACEY MARQUEZ,

PLAINTIFF, 

V. 

HYATT CORPORATION, 

DEFENDANT.

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IN THE DISTRICT COURT

______ JUDICIAL DISTRICT

TARRANT COUNTY, TEXAS

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES, KACEY MARQUEZ, Plaintiff, complaining of and against HYATT 

CORPORATION, Defendant, and for cause of action would respectfully show the following: 

I. DISCOVERY CONTROL PLAN LEVEL

1.01 Pursuant to Rule 190.2 of the Texas Rules of Civil Procedure, this case will be 

governed according to Discovery Control Plan, Level 1. 

1.02 Plaintiff seeks monetary relief no greater than $250,000. 

II. PARTIES, JURISDICTION, AND VENUE

2.01 Plaintiff is an individual residing in San Benito County, Texas. 

2.02 Defendant, HYATT CORPORATION, is a Delaware corporation with its principal 

office in Illinois. Defendant can be served with process by serving its registered agent, United 

States Corporation Co, and can be served through its registered address 211 E. 7th Street, Suite 620 

Austin, Texas 78701. 

2.03 This Court has jurisdiction over the parties to and subject matter of these claims 

because the amount in controversy is within the jurisdictional limits of this Court and venue is

348-337132-22

FILED

TARRANT COUNTY

9/26/2022 2:59 PM

THOMAS A. WILDER

DISTRICT CLERK

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 3 of 22 PageID 24
PLAINTIFF’S ORIGINAL PETITION PAGE 2

proper because all or a substantial part of the events or omissions giving rise to the claims herein 

occurred in Tarrant County, Texas.

III. STATEMENT OF FACTS

3.01 On or about October 8, 2020, Plaintiff was a guest at Defendant’s hotel property 

known as Hyatt Regency DFW Airport. Plaintiff patronized the bar at the property and was served 

by an employee of Defendant. 

3.02 After Plaintiff returned to her room, Defendant’s employee who had served Plaintiff 

entered Plaintiff’s room where he sexually assaulted Plaintiff and caused her to suffer serious 

bodily injury and mental anguish.

3.03 At all material times, Defendant failed to develop, maintain, implement, and/or enforce 

policies and procedures to prevent employees from entering guest rooms in a social capacity and 

other such acts by its employees. 

3.04 At all material times, Defendant failed to properly educate and train its employees in 

appropriate policies and procedures to prevent employees from entering guest rooms in a social 

capacity and other such acts by its employees.

IV. CAUSE OF ACTION 

4.01 At all material times, Defendant owed Plaintiff a duty to develop, maintain, 

implement, and enforce policies and procedures to prevent employees from entering guest rooms 

in a social capacity and other such acts by its employees. Defendant further owed Plaintiff a duty 

to educate and train its employees in appropriate policies and procedures to prevent employees 

from entering guest rooms in a social capacity and other such acts by its employees.

4.02 At all material times, Defendant failed to act reasonably in the development, 

maintenance, implementation, and enforcement of policies and procedures to prevent employees 

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 4 of 22 PageID 25
PLAINTIFF’S ORIGINAL PETITION PAGE 3

from entering guest rooms in a social capacity and other such acts by its employees. Defendant 

further failed to act reasonably in the education and training of its employees in appropriate 

policies and procedures to prevent employees from entering guest rooms in a social capacity and 

other such acts by its employees.

4.03 Such failures by Defendant proximately caused Plaintiff to suffer injuries and 

damages.

V. DAMAGES

5.01 As a proximate result of Defendant’s negligence, Plaintiff suffered severe 

physical injuries. As a result of her injuries, Plaintiff has suffered the following damages:

a. Physical pain and mental anguish in the past and future;

b. Mental anguish in the past and future;

c. Physical impairment in the past and future; and

d. Medical expenses in the past and future.

WHEREFORE, PREMISES CONSIDERED, Plaintiff requests that Defendant be cited to 

appear and answer, and that on final trial she has judgment against Defendant in a sum in excess 

of the minimum jurisdictional limits of the Court; prejudgment and postjudgment interest as 

provided by law; costs of suit; and such other and further relief to which Plaintiff may be justly 

entitled.

Respectfully submitted,

RAD LAW FIRM

BY: /s/Mackenzie Linyard

MACKENZIE B. LINYARD

State Bar No. 24083399

8001 LBJ Fwy, Suite 300

Dallas, Texas 75251

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PLAINTIFF’S ORIGINAL PETITION PAGE 4

Phone (972) 661-1111

Fax (972) 661-3537

E-Mail: mlinyard@radlawfirm.com

E-File: efileML@radlawfirm.com

ATTORNEY FOR PLAINTIFF

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 6 of 22 PageID 27
PLAINTIFF’S ORIGINAL PETITION PAGE 1 

CAUSE NO. __________________ 

KACEY MARQUEZ,

PLAINTIFF, 

V. 

HYATT CORPORATION, 

DEFENDANT.

§

§ 

§ 

§ 

§ 

§ 

§

IN THE DISTRICT COURT

______ JUDICIAL DISTRICT

TARRANT COUNTY, TEXAS

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES, KACEY MARQUEZ, Plaintiff, complaining of and against HYATT 

CORPORATION, Defendant, and for cause of action would respectfully show the following: 

I. DISCOVERY CONTROL PLAN LEVEL

1.01 Pursuant to Rule 190.2 of the Texas Rules of Civil Procedure, this case will be 

governed according to Discovery Control Plan, Level 1. 

1.02 Plaintiff seeks monetary relief no greater than $250,000. 

II. PARTIES, JURISDICTION, AND VENUE

2.01 Plaintiff is an individual residing in San Benito County, Texas. 

2.02 Defendant, HYATT CORPORATION, is a Delaware corporation with its principal 

office in Illinois. Defendant can be served with process by serving its registered agent, United 

States Corporation Co, and can be served through its registered address 211 E. 7th Street, Suite 620 

Austin, Texas 78701. 

2.03 This Court has jurisdiction over the parties to and subject matter of these claims 

because the amount in controversy is within the jurisdictional limits of this Court and venue is

348-337132-22

FILED

TARRANT COUNTY

9/26/2022 2:59 PM

THOMAS A. WILDER

DISTRICT CLERK

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 7 of 22 PageID 28
PLAINTIFF’S ORIGINAL PETITION PAGE 2

proper because all or a substantial part of the events or omissions giving rise to the claims herein 

occurred in Tarrant County, Texas.

III. STATEMENT OF FACTS

3.01 On or about October 8, 2020, Plaintiff was a guest at Defendant’s hotel property 

known as Hyatt Regency DFW Airport. Plaintiff patronized the bar at the property and was served 

by an employee of Defendant. 

3.02 After Plaintiff returned to her room, Defendant’s employee who had served Plaintiff 

entered Plaintiff’s room where he sexually assaulted Plaintiff and caused her to suffer serious 

bodily injury and mental anguish.

3.03 At all material times, Defendant failed to develop, maintain, implement, and/or enforce 

policies and procedures to prevent employees from entering guest rooms in a social capacity and 

other such acts by its employees. 

3.04 At all material times, Defendant failed to properly educate and train its employees in 

appropriate policies and procedures to prevent employees from entering guest rooms in a social 

capacity and other such acts by its employees.

IV. CAUSE OF ACTION 

4.01 At all material times, Defendant owed Plaintiff a duty to develop, maintain, 

implement, and enforce policies and procedures to prevent employees from entering guest rooms 

in a social capacity and other such acts by its employees. Defendant further owed Plaintiff a duty 

to educate and train its employees in appropriate policies and procedures to prevent employees 

from entering guest rooms in a social capacity and other such acts by its employees.

4.02 At all material times, Defendant failed to act reasonably in the development, 

maintenance, implementation, and enforcement of policies and procedures to prevent employees 

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 8 of 22 PageID 29
PLAINTIFF’S ORIGINAL PETITION PAGE 3

from entering guest rooms in a social capacity and other such acts by its employees. Defendant 

further failed to act reasonably in the education and training of its employees in appropriate 

policies and procedures to prevent employees from entering guest rooms in a social capacity and 

other such acts by its employees.

4.03 Such failures by Defendant proximately caused Plaintiff to suffer injuries and 

damages.

V. DAMAGES

5.01 As a proximate result of Defendant’s negligence, Plaintiff suffered severe 

physical injuries. As a result of her injuries, Plaintiff has suffered the following damages:

a. Physical pain and mental anguish in the past and future;

b. Mental anguish in the past and future;

c. Physical impairment in the past and future; and

d. Medical expenses in the past and future.

WHEREFORE, PREMISES CONSIDERED, Plaintiff requests that Defendant be cited to 

appear and answer, and that on final trial she has judgment against Defendant in a sum in excess 

of the minimum jurisdictional limits of the Court; prejudgment and postjudgment interest as 

provided by law; costs of suit; and such other and further relief to which Plaintiff may be justly 

entitled.

Respectfully submitted,

RAD LAW FIRM

BY: /s/Mackenzie Linyard

MACKENZIE B. LINYARD

State Bar No. 24083399

8001 LBJ Fwy, Suite 300

Dallas, Texas 75251

Case 4:22-cv-00910-O Document 1-1 Filed 10/11/22 Page 9 of 22 PageID 30
PLAINTIFF’S ORIGINAL PETITION PAGE 4

Phone (972) 661-1111

Fax (972) 661-3537

E-Mail: mlinyard@radlawfirm.com

E-File: efileML@radlawfirm.com

ATTORNEY FOR PLAINTIFF

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EXHIBIT 2

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EXHIBIT 3

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EXHIBIT 4

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