起訴的形式和具體文件要求
VIA REGISTERED INTERNATIONAL MAIL
May 18, 2005
Deguang Zhang, Esq.
Zhang, Wang & Lee, L.L.P.
666 East Chang’an Blvd.
Beijing 100001, China
Re: Texas Instrumental, Inc. v. China Huaguang Hitech Co.
Dear Mr. Zhang:
Pursuant to your request, enclosed are copies of the Complaint, Demand for Jury Trial
with Exhibits, and Plaintiff’s First Request for Production of Documents, all of which
were personally served on your client’s representative in Texas on March 2, 2005.
It has been over six weeks since your client was served with these pleadings and the
responses are now overdue. Please let me know at your earliest convenience when
you will be providing the responses.
Sincerely,
Baker & Associates, P.C.
____________________
Susan Miller, Esq.
Enclosure
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NORTHERN TEXAS
___________________________________
*
Texas Instrumental, Inc. *
111 Nowhere Lane S.W. * Civil Action No. 00001
College Point, TX 11111 *
Plaintiff *
vi. *
*
China Huaguang Hitech Co. *
111 Happy Road *
__ *
COMPLAINT FOR BREACH OF
CONTRACT
COMES NOW the Plaintiff, Texas Instrumental, Inc., by and through counsel,
Baker & Associates, P.C., and does hereby state the following as and for its complaint:
I. JURISDICTION
Jurisdiction of this Court is founded on Diversity of Citizenship and Amount in
Controversy under U.S.C. Title 28 Sections 1331 and 1332. Plaintiff is a corporation
incorporated under the laws of the State of Delaware and defendant is a corporation
incorporated under the laws of the People’s Republic of China. The matter in
controversy exceeds the sum of Sixty Five Thousand dollars (USD $65,000.00),
exclusive of interest and costs.
II. PARTIES
A. Plaintiff Texas Instrumental, Inc. is a Delaware corporation with its offices
located at 111 Nowhere Lane S.W., College Point, TX 11111.
B. Defendant China Huaguang Hitech Co. is a People’s Republic of China
corporation with its headquarters located at 111 Happy Road, Nowhere City,
China 222222.
III.ALLEGATIONS
1. On or about September 21, 2004, Plaintiff entered into an agreement in writing
with Defendant whereby Defendant contracted to purchase five (5) sets of
automatic chip processing machines. A copy of said agreement is attached
hereto, marked “Exhibit A,” and made a part of this complaint.
2. All terms and conditions of the agreement have been performed by Plaintiff or
have occurred.
3. All goods and services contracted for by Defendant have been rendered by
Plaintiff.
4. Defendant has failed and neglected to pay the sum of USD $170,540.00 (One
Hundred and Seventy Thousand, Five Hundred and Forty U.S. Dollars) or any part
thereof, although payment has been duly demanded by plaintiff.
WHEREOF, Plaintiff Texas Instrumental, Inc., prays this court assume
jurisdiction in this matter and grant to Plaintiff judgment in the amount of USD
$170,540.00, plus accrued interest in the amount of USD $4,321.00 as provided
by the terms of the agreement, and for such other relief as the court may deem
appropriate.
RESPECTFULLY SUBMITTED,
Baker & Associates, P.C.
123 West Putnam Parkway, Suite 1103
Austin, Texas 80012
________________________________
By: Susan Miller, Texas Bar No.: 1234
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