FILED
6/12/2020 3:39 PM
Mary Angie Garcia
Bexar County District Clerk
Accepted By: Martha Medellin
2020CI10729
NO. _______________________
CIT PPS
THE STATE OF TEXAS, § IN THE DISTRICT COURT OF
Plaintiff §
§
v. §
§ BEXAR COUNTY, TEXAS
EDUCATION SOLUTIONS, LLC d/b/a §
MY EDUCATION SOLUTIONS, LLC §
and CHRISTINA RANDELL, Individually, §
§
Defendants §
407th
§ ________ JUDICIAL DISTRICT
PLAINTIFF’S ORIGINAL PETITION AND APPLICATION FOR TEMPORARY
INJUNCTION AND PERMANENT INJUNCTION
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff the STATE OF TEXAS, acting by and through its Attorney General Ken Paxton,
and his Consumer Protection Division, complains of EDUCATION SOLUTIONS LLC d/b/a, MY
EDUCATION SOLUTIONS LLC and CHRISTINA RANDELL, Individually. In this action, the
State alleges that Defendants engaged in false, misleading, and deceptive acts and practices in
violation of §17.46 of the Texas Deceptive Trade Practices Act, Tex. Bus. & Com. Code
(hereinafter, “DTPA”). In support thereof, the State will respectfully show the Court the
following:
DISCOVERY CONTROL PLAN
1. Discovery in this case should be conducted under Level 2 pursuant to TEX. R. CIV.
P. 190.3.
2. This case is not subject to the restrictions of expedited discovery under TEX. R. CIV.
P. 169 because:
A. The relief sought by the State includes non-monetary injunctive relief; and