CAUSE NO.

_______________

ASHLEY MINGA, INDIVIDUALLY § IN THE DISTRICT COURT

AND ON BEHALF OF THE §
ESTATE OF HAYLEY FARR §
AND ALL WRONGFUL DEATH §
BENEFICIARIES, §
Plaintiff, §
§
V. § _____ JUDICIAL DISTRICT
§
ANJALI HOSPITALITY LLC DBA §
AMERICAS BEST VALUE INN & §
SUITES, MAHESH PATEL, and §
DIPAVILI PATEL, §
Defendants. § MONTGOMERY COUNTY, TEXAS

PLAINTIFF’S ORIGINAL PETITION AND REQUEST FOR DISCLOSURE

TO THE HONORABLE JUDGE OF THIS COURT:

COMES NOW, Plaintiff ASHLEY MINGA, INDIVIDUALLY AND ON BEHALF OF

THE ESTATE OF HAYLEY FARR AND ALL WRONGUL DEATH BENEFICIARIES, and

files this Original Petition and Request for Disclosure complaining of DEFENDANTS ANJALI

HOSPITALITY LLC DBA AMERICAS BEST VALUE INN & SUITES, MAHESH PATEL, and

DIPAVIL PATEL as a result of its knowingly benefitting from the human trafficking of Hayley

Farr. In support of her claims, Plaintiff would show as follows:

I. CLAIM FOR RELIEF

1. Plaintiff seek damages within the jurisdictional limits of the Court and monetary

relief over $1,000,000.

2. Plaintiff brings this action under the Survival statutes, Texas Civil Practices and

Remedies Code, §§ 71.021.

Plaintiff’s Original Petition & Request for Disclosure Page | 1

 II. DISCOVERY CONTROL PLAN

3. Plaintiff intends to conduct discovery under Level 3 of Texas Rule of Civil

Procedure 190.4 and affirmatively pleads that this suit is not governed by the expedited-actions

process in Texas Rules of Civil Procedure 169 because Plaintiff seeks monetary relief over

$1,000,000.00.

III. PARTIES

4. Plaintiff ASHLEY MINGA is an individual who resides in Harris County. The last

three numbers of Plaintiff’s driver’s license number are 624. The last three numbers of Plaintiff’s

Social Security number are 391. Plaintiff brings this lawsuit as a survival and wrongful death

action on behalf of herself and the estate of Hayley Farr, Decedent. Plaintiff is the surviving

parent and next of kin of Decedent.

5. Defendant ANJALI HOSPITALITY LLC DBA AMERICAS BEST VALUE INN

& SUITES is a Texas limited liability company that owns and operates the Americas Best Value

Inn & Suites hotel located at 19565 I H 45 S, Shenandoah, Texas 77385. Defendant may be

served by serving its registered agent Mahesh Patel at 4117 King St. in Houston, Texas 77026 or

19565 I H 45 S, Shenandoah, Montgomery County, Texas 77385 or wherever he may be found.

6. Defendant, MAHESH PATEL is an individual residing in Montgomery County,

and may be served at 4117 King St. in Houston, Texas 77026 or 19565 I H 45 S, Shenandoah,

Montgomery County, Texas 77385 or wherever he may be found.

7. Defendant, DIPAVALI PATEL is an individual residing in Montgomery County,

and may be served at 19565 I H 45 S, Shenandoah, Montgomery County, Texas 77385 or

wherever he may be found.

Plaintiff’s Original Petition & Request for Disclosure Page | 2

 IV. JURISDICTION AND VENUE

8. This Court has subject matter jurisdiction over the lawsuit because the amount in

controversy exceeds the Court’s minimum jurisdictional requirements, and personal jurisdiction

because all the Defendants are residents of Montgomery County, and the property where the

events took place is located in Shenandoah, Montgomery County, Texas.

9. Venue is proper in Montgomery County under Texas Civil Practice and Remedies

Code section 15.002 because all or a substantial part of the events or omissions giving rise to

the claim occurred in Montgomery County.

V. FACTUAL BACKGROUND

10. Plaintiff’s Decedent, Hayley Farr was trafficked at the Americas Best Value Inn

and Suites in the 19500 block of Interstate 45 South between 2015 and November 2016. On

November 26, 2016, Hayley Farr, at nineteen (19) years old, was brutally murdered by a gunshot

wound fired by her pimp inside room 217 of the Defendants’ hotel. She is survived by her

mother, Ashley Minga.

11. Mahesh Patel and Dipivali Patel are directors and members of Anjali Hospitality

L.L.C DBA Americas Best Inn & Suites, and have been, and are engaged in fraudulent, illegal

and ultra vires acts.

12. Defendants were aware of the illegal activities, including human trafficking, at

the Americas Best Value Inn & Suites yet still rent rooms to known pimps and drug dealers to

conduct the illegal activities herein complained of on their premises. Human traffickers are

known to use the America’s Best Value Inn & Suites in Shenandoah as a base of operations and

facility for the sex trade. Defendants tolerate these illegal activities, and purposefully turn a

“blind eye,” because by doing so they have acquired a steady stream of income from renting

Plaintiff’s Original Petition & Request for Disclosure Page | 3

rooms to those conducting these activities.

VI. CAUSES OF ACTION FOR TRAFFICKING OF PERSONS

13. Under Texas Civil Practices & Remedies Code, Chapter 98. Liability for

Trafficking of Persons, Sec. 98.002:

A defendant who engages in the trafficking of persons or who

intentionally or knowingly benefits from participating in a venture that
traffics another person is liable to the person trafficked, as provided by this
chapter, for damages arising from the trafficking of that person by the
defendant or venture.

14. Sec. 98.006. LIBERAL CONSTRUCTION AND APPLICATION. Chapter 98.

Liability for Human Trafficking shall be liberally construed and applied to promote its

underlying purpose to protect persons from human trafficking and provide adequate remedies to

victims of human trafficking.

15. Hayley Farr was trafficked while at the Americas Best Value Inn & Suites during

all relevant times.

16. Defendants, Anjali Hospitality, LLC DBA Americas Best Value Inn & Suites,

Mahesh Patel, and Dipavali Patel knowingly benefited from the human trafficking of Hayley

Farr and other victims during all relevant times in the form of a steady of stream of income from

renting rooms to those who conduct these illegal activities on the premises.

17. Hayley Farr was killed as a consequence of the trafficking occurring at the Best

Value Inn & Suites, including all actual damages, including physical and mental abuse, Post

Traumatic Stress Disorder (PTSD), pain and suffering, mental anguish, as well as economic loss.

Wrongful-death claimants, including victim’s mother, Ashley Minga, suffered and continue to

suffer damages, including mental anguish in the past and future, and loss of companionship and

society in the past and future.

Plaintiff’s Original Petition & Request for Disclosure Page | 4

 VII. LIABILITY OF INDIVIDUAL DEFENDANTS

18. Plaintiff alleges that Defendants, Mahesh Patel, and Dipavali Patel, individually

and directly and indirectly benefited from the illegal enterprise.

19. Plaintiff further alleges Defendants, Mahesh Patel, and Dipavali Patel,

individually used the Defendant entity Best Value Inn & Suites for the purposes of perpetuating,

and did perpetuate, an actual fraud on Hayley Farr and other similarly situated individuals for

their own personal benefit.

20. Plaintiff further alleges that Defendants, Mahesh Patel, and Dipavali Patel, used

the entity Best Value Inn & Suites as a means of evading and circumventing an existing statute

for the purpose of perpetuating, and did perpetuate, an actual fraud on Hayley Farr, and other

similarly situated individuals for the primary purpose of obtaining a personal benefit.

VIII. EXEMPLARY DAMAGES

21. Plaintiff hereby incorporates and realleges the matters set forth in Sections 10–21

as if set forth at length in this section.

22. Plaintiff further alleges that Defendants Anjali Hospitality, LLC DBA Americas

Best Value Inn & Suites, Mahesh Patel, and Dipavali Patel’s actions and conduct were committed

with conscious indifference and reckless disregard for persons’ safety and with willful and

wanton negligence towards others including Plaintiff’s decedent. Therefore, Defendants’ actions

were grossly negligent. Therefore, Plaintiff requests that exemplary damages be awarded against

Defendants in a sum within the jurisdictional limits of the Court.

IX. JURY DEMAND

23. Plaintiff demands a jury trial and tenders the appropriate fee with this petition.

X. CONDITIONS PRECEDENT

24. All conditions precedent to Plaintiff’s claim for relief have been performed or

Plaintiff’s Original Petition & Request for Disclosure Page | 5

have occurred.

XI. REQUEST FOR DISCLOSURE

25. Under Texas Rule of Civil Procedure 194, Plaintiff requests that Defendants

disclose, within 50 days after service of this request, the information or material described in

Rule 194.2.

PRAYER

WHEREFORE, PREMISES CONSIDERED, for all of the foregoing reasons, Plaintiff

Ashley Minga, as Representative on Behalf of the Estate of Hayley Farr, respectfully requests

that Defendants Anjali Hospitality, LLC DBA Americas Best Value Inn & Suites, Mahesh Patel,

and Dipavali Patel be cited to appear and answer herein, and that after trial, Plaintiff be awarded

a judgment against Defendants for Wrongful Death damages and Survival damages under Texas

Civil Practices & Remedies Code, Sec. 98.003:

(1) actual damages, including damages for mental anguish even if an injury other
than mental anguish is not shown;

(2) court costs;

(3) reasonable attorney’s fees;

(4) exemplary damages; and

(5) such other and further relief to which Plaintiff may be justly entitled.

Respectfully submitted,

BUSSARD LAW FIRM

By: ___________________
Ross D. Bussard
State Bar No 24082756
500 E. 4th St., Ste. 541
Austin, Texas 78701

Plaintiff’s Original Petition & Request for Disclosure Page | 6

 512-518-1332- Office
512-957-2332 – Fax
rdb@bussardlawfirm.com

-and-

Ryan Runkle
State Bar No 24011425
HOTZE RUNKLE PLLC
1101 South Capital of Texas Hwy
Bldg C, Suite 100
Austin, Texas 78746
512-476-7771 - Office
512-476-7781 – Fax
ryan@hotzerunkle.com

ATTORNEYS FOR PLAINTIFF

Plaintiff’s Original Petition & Request for Disclosure Page | 7