[Plaintiff's original petition: HIV discrimination case Ingram v. R&D Industries] Page: 1 of 10
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LEONARD CLIFF INGRAM
VS.R & D INDUSTRIES, INC., D/B/A
BEN GRIFFIN TRACTOR COMPANY,
AND RICHARD F. REYNOLDSS
S
SIN THE DISTRICT COURT
OF DALLAS COUNTY, TEXAS.JUDICIAL DISTRICT
PLAINTIFF'S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Leonard Cliff Ingram, plaintiff, complaining of R & D Industries, Inc.,
d/b/a Ben Griffin Tractor Company, and Richard F. Reynolds, defendants, and would
show the court and jury as follows:
I.
The jurisdiction of this Court is invoked to seek a redress of violations of the Texas
Commission on Human Rights Act of 1983, Tex. Rev. Civ. Stat. Ann. art 5221k, 1.01, et
seg., which Act's purpose is to secure to those within the state of Texas freedom from
discrimination in employment.
II.
Plaintiff is a resident of Dallas County, Texas. Plaintiff is a citizen of the United
States and a resident of Dallas, Dallas County, Texas. Plaintiff has been employed by
defendants at its facility in Dallas County, Texas. Plaintiff has been subjected to
unlawful employment practices committed in the State of Texas, County of Dallas.0
PLAINTIFF'S ORIGINAL PETITION - PAGE 1
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[Plaintiff's original petition: HIV discrimination case Ingram v. R&D Industries], legal document, October 27, 1988; (https://texashistory.unt.edu/ark:/67531/metadc915990/m1/1/: accessed June 10, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu.; crediting UNT Libraries Special Collections.