THE LAW OFFICES OF                                         IN THE DISTRICT COURT

G. DAVID WESTFALL, P.C.                                    OF VAN ZANDT COUNTY

vs.                                                                            294TH JUDICIAL DISTRICT

UDO BIRNBAUM


 TO THE HONORABLE JUDGE OF SAID COURT:

 COMES NOW, THE LAW OFFICES OF G. DAVID WESTFALL, P.C., Plaintiff, complaining of UDO BIRNBAUM, hereinafter referred to as Defendant, and for cause of action would respectfully show the court the following:

 Plaintiff is a professional corporation with its principle office and place of business in Dallas, Dallas County, Texas.

 Defendant is an individual whose residence is in Eustace, Van Zandt County, Texas and may be served with process at Route 1, Eustace, Texas.

 On or about May 5, 1999, Defendant retained Plaintiff to perfon-n legal services in a civil matter in Cause No. 3:99-CV-0696-R in the United District Court for the Northern District of Texas in Dallas, Dallas County, Texas.

 The legal and/or personal services were provided at the special instance and requested of Defendant and in the regular course of business. In consideration of such services, on which systematic records were maintained, Defendant promised and became bound and liable to pay Plaintiff the prices charged for such services and expenses in the amount of $18,12 1. 10, being a reasonable charge for such services. A true and accurate photostatic copy of the accounts for services rendered are attached hereto by reference for all purposes as Exhibit "A!'. Despite Plaintiff s demands upon Defendant for payment, Defendant has refused and failed to pay the

 Plaintijfs Original Petition - I
 

account to Plaintiffs damage in the total amount of $18,121.10. All just and lawful offsets, payments and credits have been allowed.


 Plaintiff is entitled to recover reasonable attorney's fees incurred in the filing of this suit. Demand for payment from Defendant has been made. Plaintiff requests reasonable attorney's fees as determined by the trier of fact.

 WBEREFORE PREMISES CONSIDERED, Plaintiff prays that Defendant be cited to appear and answer and upon final hearing, Plaintiff have judgment against Defendant for $18,12 1. 10 plus prejudgment and postjudgment interest at the highest rate allowed by law, attorney's fees, costs of court and for such other and further relief, both at law and equity, to which Plaintiff may show himself to be justly entitled.

Plaintijfs Original Petition - 2