[Cause No. 3677: Defendant's Plea of Privilege] Page: 1 of 4
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I,
NO. 3677.
T.. 0. RAINWATER IN TE JUSTICE COuRT,
Vs. PWJCIN\iCT NO. 1
INDIAN TER3TORY ILLUMINATING JONES COUNTY, TEXAS.
OIL COMPAI{Y.
TO SAID HONORABLE COURT:
Now comes Indian Territo-ry illuminating Oil Company, defendant
in the above entitled and numbered case and files this its plea of
privilege, sowing to the court as grounds therefor, the following:
1.
The defendant, the party claiming such privilege, was not, at the
institution of such suit, nor at the time of service of process thereon,
nor at the time of filing of such plea domiciled in Jines County, Texas,
the county in which such suit was instituted.
2.
The defendant, the party claiming such privilege did not have and
does not have, at the institution of such suit, nor at the tie of
service of process thereon, nor at the time of filing such plea, an
office, agent, officer or representative situated, located or residing
in J 1nes County, Texas, the county in which suit was instituted.
3.
The defendant, Indian Territory Illuminatin Oil Company, had and
has an office located at Abilehe, Taylor County, Texas, at the time of
such plea, as well as at the time of the filing of sane.
4.
That defendant, Indian Territory Illuminating Oil Company, had and
has a local representative and agent residing in Abilene, Taylor County,
Texas, at the time of such plea, as well as at the tire of the filing
of same.
5.
That no exception to exclusive venue in the county of one's resi-
dence provided by law exists in said cause.
WHELFORE, premises considered this defendant prays the court to
sustain this plea of privilege.
Jack Sayles,
Attorney for defendant, Indian
Territory Illuminating Oil Company.
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Sayles, Jack. [Cause No. 3677: Defendant's Plea of Privilege], legal document, April 22, 1938; (https://texashistory.unt.edu/ark:/67531/metapth1157328/m1/1/: accessed June 12, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu; crediting Hardin-Simmons University Library.