[Plaintiff's original complaint Moore v. Roberts et. al.] Page: 3 of 24
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.I
II.
2.1 The Plaintiff is an adult citizen of the United
States of America and resides in Celina, Texas, in the
Eastern District of Texas.
2.2 Defendant, the County of Collin, Texas, is a
county duly organized and constituted under the laws and
Constitution of the State of Texas. The address of the
County's executive officer, County Judge Bill Roberts,
is 210 S. McDonald, McKinney, Texas 75069.
2.3 At all times relevant hereto, Defendants, County
Judge Bill Roberts, Commissioner Howard Thornton, Precinct 1,
Commissioner Jerry Hoagland, Precinct 2, Commissioner John
Witherspoon, Precinct 3, Commissioner Jack Hatchell, Precinct 4,
comprised the Commissioners Court of Collin County, Texas,
whose administrative offices are located at 210 S. McDonald,
McKinney, Texas 75069.
2.4 At all times relevant hereto, Defendant Sheriff
Terry Box was the elected Sheriff of Collin County, Texas.
His address is c/o Collin County Sheriff's office located at
200 S. McDonald, McKinney, Texas 75069.
2.5 At all times relevant hereto, Defendant Terry
Kimbell was a deputy sheriff of Collin County, Texas. His
address is c/o Collin County Sheriff's office located at
200 S. McDonald, McKinney, Texas 75069.
2.6 At all times relevant hereto, Defendant Larry
Denison was a deputy sheriff of Collin County, Texas. His
address is c/o Collin County Sheriff's office located at
200 S. McDonald, McKinney, Texas 75069.
2.7 At all times relevant hereto, Defendant Randy
Norton was deputy Sheriff of Collin County, Texas. His
address is c/o Collin County Sheriff's office located at
200 S. McDonald, McKinney, Texas 75069.
2.8 At all times relevant hereto, De ndant Tom
O'Connell was the elected District attorney of Collin County,
Texas. His address is c/o Collin COnty District Attorney's
office located at 210 S. McDonald, ' Kinney, Texas 75069 or
his law office located at 1404 Gables Court, Suite 205,
Plano, Texas 75075.PLAINTIFF'S ORIGINAL COMPLAINT - Page 2
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[Plaintiff's original complaint Moore v. Roberts et. al.], report, April 18, 1989; (https://texashistory.unt.edu/ark:/67531/metadc916875/m1/3/: accessed June 4, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu; crediting UNT Libraries Special Collections.