despite theirsignatures, their signatures,RUBY RUBYPETERSON PETERSONwas movedanddied notmoved wasnot astheyfeared and diedas they fearedatat O SILVERADO. SILVERADO. LL 22.PLAINTIFFS 22. PLAINTIFFSfiledthislawsuit filed this lawsuitto savetheirmother's tosave their mother's llife ifeand and spent over $200,000, spentover $200,000,which which
theyhave not beenreimbursed. they have not Atthe been reimbursed.At sametime,they the same werelied time, theywere to,threatened liedto, threatenedaand ndforcedinto forced into the corner as theywatched the corneras they watched theirmotherdie their mother die andinheritance and inheritance sstolen tolenby by DEFENDANTS. DEFENDANTS.RUSS RUSS JONES JONES stated statedtthat hatifthey if they did did not signthe not sign theagreement, agreement, RUBY RUBY P ETERSON PETERSONwould everleave wouldnnever leave SILVERADO SILVERADO SENIOR SENIOR L IVING LIVING((the thefacility facilityddrugging ruggingher todeath herto deathandfalsely and falselyiimprisoning mprisoning her) her) andthis was enough and this was to effectively enoughto estroythePLAINTIFFS' effectivelyddestroy the PLAINTIFFS'freewill.It was anoffertheytruly free will. Itwasan offer they truly could not afford could not to refuse, afford to otheysigned refuse, sso it. Clearly,theforegoing they signed it.Clearly, andfinancial the foregoingeemotional motional and financialduress duress is to satisfy is sufficient to satisfy T exasllaw, Texas aw,rrendering enderingtheContract the Contractvoid. void.SSee ee AffidavitofMack of MackPPeterson. eterson. III. III.PRAYER PRAYERFORRELIEF FOR RELIEF
22.In lightof thearguments 22. In light of the argumentsaand ndauthorities authorities ccited itedherein, herein,aand ndDEFENDANTS' DEFENDANTS'duress, duress,ffraud, raud, lack of consideration, and the illegality ofthe lack of consideration, and theillegalityof Rule the Rulell,11,ititmust mustbe set aside beset as void. aside as void. PLAINTIFFS thatthisHonorableJudge setasidethe pray that this Honorable Judgeset PLAINTIFFSpray aside the purportedRulell Rule 11Agreement Agreementas as void.PLAINTIFFS void. PLAINTIFFS further request allotherandfurtherreliefo which request all other and further relieftto they arejustly which theyare entitled justly entitled at lawor inequity. at law or in equity. submitted, Respectfully submitted, PhilipM.Ross SBN17304200 Philip M. Ross Holbrook Road SBN 17304200 1006 Holbrook Road 210/326-2100 Phone: SanAntonio,Texas78218 San Antonio, Texas 78218 Phone: 210/326-2100 ross Email: ross lawhotmail.com
'F5'airfnee- a-ona.,/ Pv% Candice Leonard Schwager Candice Leonard Schwager SCHWAGER LAWFIRM SBN SCHWAGER LAW FIRM SBN 24005603
Silverado Appx. 0611 No. 1-15-567-CV 2090 1417 Dr. Ramada Dr. Houston, Texas77062 Houston, Texas 77062 TEL: TEL: 832.315.8489 FAX: FAX: 832.514.4738 schwagerlawfinnAlive.com FORDON ATTORNEYS LESLIE PETERSON, ATTORNEYS FOR DON LESLIE PETERSON, MACKEY PETERSON, GLEN ANDLONNY PETERSON MACKEY GLEN PETERSON, AND LONNY PETERSON
CERTIFICATE OFSERVICE CERTIFICATE OF SERVICE
CANDICESCHWAGER, I, CANDICE I, SCHWAGER,hereby hereby certify that on this that on dayof this 23"1 day MARCH, of MARCH, 2015, 2015, the pleading the foregoing pleading was e-filed and was and served upon allcounsel upon all ofrecord counsel of inaccordance record in with accordance with theTexas Rulesof the Texas Rules ofCivil Civil Procedure.
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Silverado Appx. 0612 No. 1-15-567-CV 2091 TAB 75 ' PILED 4/3/2016 2:19:28 PM Sion Simon I DATA EN I, RY County Clork T61 TIUS DATE Harris County
Cause No. 427208 PROBATE COURT 1 · wN INTHE IN THEGUARDIANSHIP GUARDIANSHIP OF OF §§ IN THE PROBATE COURT INTHE COURT
RUBYS. RUBY S.PETERSON, PETERSON, §§ NUMBER NUMBER ONE(1) ONE (1)OF OF
ANINCAPACITATED PERSON AN INCAPACITATED PERSON § § COUNTY, HARRIS TEXAS HARRIS COUNTY, TEXAS
AD LITEMS' AD