[Plaintiff's original petition: HIV discrimination case Ingram v. R&D Industries] Page: 3 of 10
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III.
1. Defendant Richard F. Reynolds, resides in Dallas County, Texas, and may be
served with process at 2525 Irving Blvd., Dallas, TX 75207.
2. Defendant R&D Industries, Inc., is, on information and belief, a duly
chartered, domestic corporation, doing business in Dallas, Dallas County, Texas, under
the assumed name of Ben Griffin Tractor Company. The defendant corporation may be
served with process through its president, Richard F. Reynolds, at 2525 Irving Blvd.,
Dallas, TX 75207.
3. Defendants R&D Industries, Inc., d/b/a Ben Griffin Tractor Company, is an
employer within the meaning of the Texas Commission on Human Rights Act of 1983,
Tex. Rev. Civ. Stat. Ann. art 5221k, 2.01(5).
IV.
This is a proceeding for a declaratory judgment, injunctive and other relief to
secure the rights of plaintiff under the Texas Commission on Human Rights Act of 1983,
Tex. Rev. Civ. Stat. Ann. art. 5221k, et se . It is brought to prevent defendants from
maintaining a policy, practice, custom or usage, of discriminating against plaintiff in
regard to compensation, terms, conditions and privileges of employment.
V.
Plaintiff says defendants discriminated against him on account of handicap in the
following and other respects:
A. From on or about May 4, 1981, and through the course of his employment with
defendant R&D Industries, Inc., d/b/a Ben Griffin Tractor Company, plaintiff was a
dedicated and productive employee at defendants' facility in Dallas County, Texas. On
March 4, 1988, defendant Richard F. Reynolds discriminated against plaintiff on account
of handicap in the following, and other, respects:
1. By terminating him on account of his handicap;
PLAINTIFF'S ORIGINAL PETITION - PAGE 2
[CvR5/HAND5221k]
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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/m1/3/: accessed June 2, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu.; crediting UNT Libraries Special Collections.