Friend PETERSON; and of RUBY PETERSON; FriendofRUBY LONNY and LONNY § PETERSON, PETERSON, § GPI VS. VS. ry SILVERADO SILVERADO SENIOR SENIOR LIVING, LIVING, INC. INC. § d/b/aSILVERADO SILVERADO SENIOR LIVING - §
LZ d/b/a SENIOR LIVING - SUGAR SUGAR LAND LAND § HARRIS HARRIS COUNTY, COUNTY, TE S TEXZ4S
DEFENDANT'S DEFENDANT'S FIRSTSUPPLEMENT FIRST SUPPLEMENT TO FIRSTAMENDED T0 FIRST AMENDED PLEA TO THEJURISDICTION PLEAT0 THE JURISDICTION & FIRSTAMENDED &FIRST ANSWER AMENDED ANSWER
Silverado Senior Living,Inc. Defendant, Silverado d/b/aSilverado Living, Inc. d/b/a SeniorLivingSugarLand Silverado Senior Living Sugar Land
("Silverad0") ("Silverado") thisFirst files this Supplement First Supplement itsFirst toits to Amended First Amended Pleato Plea theJurisdiction tothe andFirst Jurisdiction and First
Amended Amended Answer previously Answer tiledon previously filed September onSeptember 25, andrespectfully 25, 20141 and requests respectfully requests ruling. aa ruling.
SUPPLEMENTATION SUPPLEMENTATION
Plaintiffs filedaa Fifth Plaintiffs filed Fifth Amended Petition Amended Petition tojointheir to join their respective spouses, respective spouses, Tonya Peterson TonyaPeterson and and
CarolPeterson, Carol Peterson, Thursday, onThursday, on December December 4,2014 4, inan 2014 in improper animproper attempt attempt tore-litigate to claims re-litigate claims which which
have eensettled havebbeen and/or settled and/or otherwise otherwise adjudicated adjudicated butforthemeritless but breach for the meritless breach offiduciary of dutycause fiduciary duty cause whichmay which alsobedismissed mayalso foraa lack be dismissed for ofsubject lackof matter subject matter the Court isisaware, jurisdiction.2 AsAsthe aware,
Onfile with 1 On theCourt withthe andincorporated Court and byreference incorporated by if setout asif set reference as fullyherein. out fully herein. Onfile with 2 0n and incorporated the Court and with theCourt incorporated bybyreference reference as set out ffully asififsetout ullyherein. (Plaintiffs herein. Compare (Plaintiffs Amended FifthAmended Fifth Petition) Petition) (Plaintiffs' with (Plaintiffs' Original Original Petition, Petition, Amended Amended Petition Petition andJury and Demand, Jury Demand, SecondA Second mended Amended Petitionand Petition andJuryDemand, Amended P Third Amended Jury Demand, Third etitionand Petition andContest to Guardianship Contest to Guardianship Application, Application, andFourth and Amended Fourth Amended Petition) Petition) allofwhich all areon of which are filewiththisCourt on file and/orthe with this Court and/or thel29th 129th Judicial District Judicial Court aand District Court ndare incorporated are incorporated byreference as if by reference as setout if set fullyherein. out fully Seealso herein.See Silverado's Silverado's Motion 9la Motion 91a T TooDismiss Plaintiffs' Dismiss Plaintiffs' Sole Remaining SoleRemaining Claim Claim Breach Breach OfTmst Of and/or Trust and/or Breach Breach OfFiduciary Of Fiduciary Duty currently Dutycurrently pending pending which which isalso is also on with the onfile with court and the court incorporate and incorporate by by reference reference asififset as setout fullyherein. out fully herein. (footnote (footnote ccontinued) ontinued)
4831-8080-3104.1
Silverado Appx. 0445 No. 1-15-567-CV 1509 existing existing Plaintiffs Plaintiffs recently recently settled settled w ithCarol Manley with and David Manley and David P eterson. Peterson. TheRule The Rule11 lIAgreement Agreement
onfile with on with theCourt admits the Court admits and acknowledges: andacknowledges: a)the1993 a) Power the 1993 Power ofAttorney of remains Attorney remains inforce in force a nd and
effect;b) effect; theNovember b) the 2013revocation November 2013 revocation w invalid;aand, as invalid;