FILED

DALLAS COUNTY
8/7/2015 12:30:45 PM
FELICIA PITRE
DISTRICT CLERK

Crystal McDowell

DC-15-08920
No. __________________
ASSOCIATION OF TAXICAB
OPERATORS, USA,
Plaintiff,
V.
DALLAS-FORT WORTH
INTERNATIONAL AIRPORT BOARD
Defendant.

IN THE DISTRICT COURT

OF DALLAS COUNTY, TEXAS

________JUDICIAL DISTRICT

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEMPORARY

RESTRAINING ORDER,AND REQUEST FOR TEMPORARY AND PERMANENT
INJUNCTION
COMES NOW, the Plaintiff, Association of Taxicab Operators, USA, complaining of
Defendant, Dallas-Fort Worth International Airport Board, respectfully showing the Honorable Court
the following in this civil cause of action brought under the Uniform Declaratory Judgments Act:
A. Discovery Control Plan
1. Pursuant to Tex. R. Civ. P. 190, Plaintiff intends to conduct discovery under Level 3 of
Tex. R. Civ. P. 190.4.
B. Parties
2.

Plaintiff, Association of Taxicab Operators, USA, (ATO), a domestic non-profit

corporation, is a professional association incorporated in the State of Texas, with its principal place of
business in the City of Dallas, Dallas County, Texas. Plaintiff may be contacted exclusively through
the undersigned counsel of record.
3. Defendant, Dallas-Forth Worth International Airport Board, (DFW Airport Board) a
governmental entity, is a joint board created by the cities of Dallas and Fort Worth under TEX .
PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND
REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 1 of 10

TRANSP. CODE 22.074 for the purpose of operating Dallas-Fort Worth International Airport. DFW
Airport Board will be served with private process through its Chief Executive Officer, Sean Donahue,
its General Counsel, Elaine Rodriguez, or its Executive Vice President of Operations, James M. Crites.

C. Jurisdiction
4. The Court has jurisdiction over the Defendant because the cause of action arises out of
Defendants operations in the State of Texas.

D. Venue
5. Venue is proper in this County, as a substantial part of the events or omissions constituting
the basis for this lawsuit occurred in this County.
F. Statement of the Case
6. Plaintiff seeks to enjoin Defendant from causing harm to Plaintiffs constituent membership
of taxicab drivers that derive their business and economic livelihood primarily from transporting
passengers to and from the Dallas-Fort Worth International Airport (The Airport). Specifically,
Plaintiff seeks equitable relief from the Court to enjoin the Defendant from eliminating the taxicab
permit rules that Plaintiffs constituent members have relied upon to reliably develop and maintain
their business at the airport. Plaintiff seeks to preserve those taxicab permitting rules that have been in
place for approximately 8 years, and are seeking equitable relief that will enjoin the Defendant from
essentially allowing a feeding frenzy to take place at the Airport taxicab queue as a result of the
elimination of the requirement that all transportation for hire vehicles must obtain a permit to operate
at the Airport, permits that have been limited in distribution by the Defendant for close to a decade,
during which time the Plaintiffs constituent members have made long-term business decisions about

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 2 of 10

equipment purchases based on the airport business that they have been able to develop due to the
airport taxicab permitting and passenger pickup procedures status quo that has been in place for many
years.
F. Factual Background
7. The Association of Taxicab Operators, USA, is a non-profit corporation organized for
purposes including those of being able to make better equipment purchasing deals and advocating on
behalf of its constituent members, which are taxicab operators that primarily obtain their business from
the airport.1 The airport has a taxicab queue through which in recent years all taxicabs seeking to pick
up fare paying passengers at the airport must cycle through a line (queue) in order to pick up those
passengers. As of July 31, 2015, there were approximately 1,400 taxicab operators that possessed
valid permits to enter the airport taxicab queue in order to pick up passengers, and on any given day,
an estimated 500 to 700 drivers derive their business from patiently working their way through the
queue to obtain fare paying passengers. Even though the DFW Airport Board has issued a limited
number of taxicab permits in recent years, the airport taxicab queue is a busy place, even under the
permitting and taxicab queue procedures that have been in place in the last decade.
8. Even though they typically work long hours and an overwhelming number of days of the
week in order to have the income they need to have viable businesses as drivers, the Plaintiffs
constituent members have come to rely heavily upon the more predictable amount of business they can
obtain by acquiring the necessary inspections, approvals, and background checks that have been
required of taxicab drivers working the queue at the airport. Plaintiffs constituent drivers have made
long-term financial decisions such as vehicle purchases based on the relative predictability of the

See Appendix at Exhibit 1

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 3 of 10

business they can obtain from working hard in the business of transporting airport passengers to and
from the airport.
9. However, in recent months, it has become evident that transportation network companies
such as Uber (and its sub-brands such as Uber X) and Lyft have aggressively sought to obliterate the
permitting process that the DFW Airport Board has had in place for many years now, and Uber and
Lyft have been lobbying aggressively at both the DFW Airport Board level and at the City of Dallas to
accommodate their business models (which are in conflict with the established policy at the airport to
limit the number of transportation for hire permits). Uber and Lyft and their electronically organized
enthusiasts have been largely successful at intimidating government officials into acquiescing to their
demands for accommodation through electronic flash mobs and hired lobbyists through an extremely
well financed lobbying effort, and the recent decision on May 7, 2015 by the DFW Airport Board to
totally eliminate the taxicab permitting infrastructure at the airport is consistent with that pressure, as
is the establishment of a waiting area for drivers of transportation network companies separate from
the taxicab queue. Additionally, Uber in particular has been able to intimidate the Defendant into
allowing Uber X drivers to operate older personal vehicles owned by Uber X at the airport that are
older than the 2011 model year and newer vehicles that also must be Smartway vehicles that taxicab
operators are required to use for airport business.
10. The entire culture that has developed at the airport taxicab queue is one based on the
American dream of being able to achieve -- through working hard -- a better life for those taxicab
drivers and the families that depend on them for their livelihood and well being. By eliminating the
taxicab permitting structure at the airport, there is real, and not only imminent, but already underway
and ongoing damage to the economic well being of the established airport taxicab drivers, many of

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 4 of 10

whom are recent immigrants to this country originally from many different nations around the world
that have had difficulty finding work in other fields despite a number of them having professional
backgrounds as engineers or other professions requiring significant educational achievement.
11. Historically in the last decade or so, in order to obtain a permit to operate a taxicab at the
airport, a driver had to submit their vehicle for a 20-point inspection, file the proper application for a
permit, and submit to a background check. With the elimination of the requirement for an airport
specific permit -- replaced by the Defendant adopting a policy on May 7, 2015 that provided that as of
August 1, 2015, any transportation for hire vehicle that has obtained an operating permit from either
the City of Dallas or the City of Fort Worth may pick up passengers at the airport -- Plaintiff is
extremely concerned that adequate safeguards are not in place to protect the public, particularly after
an Uber driver that was operating under false pretenses was arrested on July 31, 2015 for sexual
assault of a passenger in Dallas, after having been inadequately screened by Uber.
12. The number of taxicab drivers that will be fighting each other for customers without the
maintenance of the permitting status quo is unknown, but estimates are that the number of drivers
seeking to obtain airport customers could double or triple.

G. Conditions Precedent
13. Plaintiff attests that all conditions precedent to the filing of this lawsuit have been satisfied
or have occurred prior to the filing of this civil action.
H. Plaintiffs Standing to Litigate this Controversy
14. Plaintiff has standing to litigate this controversy as a professional association of taxicab
drivers whose businesses are being harmed and will continue to be harmed by the actions of the

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 5 of 10

Defendant if no injunctive relief is granted. Previous litigation between the parties has settled the issue
of Plaintiffs standing to sue in a representational capacity on behalf of its constituent members.2

H. Declaratory Judgment Action

15. Plaintiff seeks equitable relief under the Uniform Declaratory Judgments Act, TEX . CIV .
PRAC. & REM . CODE 37.001

ET . SEQ .,

to have its rights, status, and other legal relationships

determined with regards the ability of Plaintiffs constituent members to rely upon the airport taxicab
permitting protocol that has been in place for many years now.

Plaintiff incorporates into this

Declaratory Judgment Action all allegations and supporting statements and evidence set forth in this
pleading.
16. Pursuant to TEX . CIV . PRAC. & REM . CODE 37.009, Plaintiff seeks all taxable costs and
reasonable and necessary attorneys fees, as are equitable and just, which are incurred or which may be
incurred in this matter, including all such fees and expenses:
a.

For trial preparations and for conducting a trial;

b.

For any necessary appeal to the Fifth District Court of Appeals;

c.

For making or responding to an application for writ of error to the Supreme

Court of Texas;

d.

If an application for writ of error is granted by the Supreme Court of Texas.

17. Plaintiff now asks, pursuant to the Uniform Declaratory Judgments Act, TEX . CIV . PRAC. &
REM . CODE 37.001

ET . SEQ .,

for a declaration of the Court that the status quo of the previously

established airport taxicab permitting protocol be maintained.

See Association of Taxicab Operators, USA v. Dallas-Fort Worth International Airport Board, 335 S.W . 3d 361
(Tex. App. -- Dallas 2010). See also Tex. Assn of Business v. Air Control Bd., 852 S.W . 2d 440, 447 (Tex. 1993).
PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND
REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 6 of 10

I. Request for Temporary Restraining Order and Temporary and Permanent Injunction
A. Plaintiff Seeks Equitable Relief Available Within the Sound Discretion of the Court
18. Under the Uniform Declaratory Judgments Act, a person whose rights, status, or other
legal relations are affected by a statute or municipal ordinance may have determined any question of
construction or validity arising under the statute or ordinance and obtain a declaration of rights, status,
or other legal relations thereunder Village of Tiki Island v. Premier Tierra Holdings, 2015 WL
1392378 (Tex. App. -- Houston [14th Dist.] 2015)(quoting TEX . CIV . PRAC. & REM CODE 37.044(a)).
See also Butnaru v. Ford Motor Co., 84 S.W.3d 198, 204 (Tex. 2002)(holding Whether to grant or
deny a temporary injunction is within the trial courts sound discretion.)

B. The Prerequisite Requirements for Issuance of a Temporary Restraining Order Have

Been Met
19.

The Plaintiff seeks injunctive relief to enjoin the Defendant from implementing the

eradication of the airport taxicab permitting protocol that has been in place in the last decade. See
TEX . CIV . PRAC. & REM . CODE 65.011(1).
20. The Plaintiff seeks injunctive relief to preserve the status quo of the subject matter of the
suit until the suit is resolved by a judgment. See City of Dallas v. Wright, 36 S.W.2d 973, 975 (Tex.
1931). See also TEX . CIV . PRAC. & REM . CODE 65.011(2).
a. Imminent and Irreparable Harm
21. The Plaintiff will suffer harm that is not only imminent and irreparable, but already
underway as of August 1, 2015, and that harm will continue without injunctive relief. Plaintiff has
been and will continue to be damaged by Defendants actions due to loss of taxicab fare revenue, loss
of customers and an impaired ability to develop personal taxicab bookings, and business goodwill.

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 7 of 10

The injury is irreparable, partly because the economic impact, while clear and direct, is not conducive
to being quantified with reasonable economic certainty.
b. Probable Right to a Permanent Injunction
22.

Plaintiff has a probable right to a permanent injunction, as the No Airport Permit

Required policy adopted by the Defendant on May 7, 2015 will be devastating to the economic well
being of the dedicated professional drivers that have been operating with an airport taxicab permit in
the last decade, and this satisfies the requirement of showing a probable right to a permanent
injunction as outlined by the Texas Supreme Court in Oil Field Haulers Assn v. Railroad
Commission, 381 S.W. 2d 183, 196 (Tex. 1964)(holding that affidavit testimony that businesses will
be destroyed by an order of the Texas Railroad Commission sufficient to satisfy inquiry regarding
probable right to a permanent injunction).
c. No Adequate Remedy at Law
23. Plaintiff requires injunctive relief in order for its constituent members to not suffer severe
economic damages as a result of Defendants actions, and equitable relief is necessary to avoid
economic devastation of Plaintiffs constituent members taxicab businesses.
J. Request for Injunctive Relief Based in Courts Equitable Powers
24. As the only adequate and effective relief for the Plaintiff is injunctive relief based in the
Courts equitable powers under the common law, Plaintiff requests the Court to restrain the Defendant
from the implementation or enforcement of the eradication of the airport-specific taxicab permitting
policy and protocol that has been in place historically, Pursuant to TEX . R. CIV . P. 680 ET . SEQ . and
TEX . CIV . PRAC. & REM . CODE 65.011

ET . SEQ .

In order to preserve the status quo during the

pendency of this case, Plaintiff seeks a temporary restraining order, and upon hearing, a temporary and

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 8 of 10

permanent injunction, ordering and immediately restraining Defendant, including the Defendants
agents, servants, employees, independent contractors, attorneys, representatives, and those persons or
entities in active concert or participation with them (collectively, the Restrained Parties) as follows:

(a)

Defendant is restrained and enjoined from implementing the amendment, adopted on

May 7, 2015, to Chapter 4 of the Code of Rules and Regulations of the Dallas/Fort
Worth International Airport Board that Remove[s] limitations on the number of
taxicab companies, vehicles and taxicab drivers that are authorized at DFW airport, an
amendment3 that eliminates the DFW airport taxicab permitting system that has been in
place for the better part of the last decade;

(b)

Defendant shall not issue or honor any new taxicab permits that are either sought or
were acquired after July 31, 2015, during the pendency of this litigation.
J. Attorneys Fees

25. Because of the acquiescent nature of the Defendants action in eradicating the established
taxicab permitting protocol at the airport, Plaintiff has been forced to engage the services of an
attorney to prosecute this civil action in order to seek equitable relief for its constituent members.
Under the Uniform Declaratory Judgments Act, Plaintiff is entitled to plead with the Court to award a
reasonable sum for the necessary services of counsel in the preparation for and conduct of a trial in this
action, and for any appeals necessary to the Court of Appeals or the Supreme Court of Texas.
Therefore, the Plaintiff makes its plea to the Court for an award of attorneys fees, an award which is
authorized by TEX . CIV . PRAC. & REM . CODE 37.009.

See Appendix at Exhibit 2

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 9 of 10

Respectfully Submitted,

_________________________
D. SHAWN STEVENS
LAW OFFICES OF D. SHAWN STEVENS
TEXAS BAR NO . 24034693
P.O. BOX 190268
DALLAS, TX 75219-0268
SHAWN @LAWYERHELP .US
TEL: (972)752-3147
FAX : (972)499-1931
COUNSEL FOR PLAINTIFF
Certificate of Counsel
I, D. Shawn Stevens, do hereby certify that, to the best of my knowledge, this case is not
subject to transfer under Local Rule 1.06. Additionally, though immediate effort is being made to
notify counsel for the Defendant of this application for a Temporary Restraining Order, I certify
pursuant to Local Rule 2.02(b)(1) that there is insufficient time to give prior notice to the Defendant of
this request for injunctive relief, as the Plaintiffs harm regarding which injunctive relief is sought is
imminent and irreparable.

_________________________
D. SHAWN STEVENS

PLAINTIFFS ORIGINAL PETITION, APPLICATION FOR TEM PORARY RESTRAINING ORDER,AND

REQUEST FOR TEM PORARY AND PERM ANENT INJUNCTION - Page 10 of 10

STATE OF TEXAS
COUNTY OF DALLAS

AFFIDAVIT OF AL-F ATIH AMEEN

Before me, the undersigned notary, on this day personally appeared AI-Fatih Ameen, a person
whose identity is known to me. After I administered an oath to him, upon his oath he said that he
is the Chairman of the Association of Taxicab Operators. USA, and that he had read the Plaintiffs
Original Petition, Application for TemporalY Restraining Order, and Request for Temporary and
Permanent Injunction, and that the factual statements contained "e ,']1 are within his personal
knowledge and are true and correct.

Al-Fatih Ameen
/\ssociation of Taxicab Operators, USA

Sworn to and subscribed before me by AI-Fatih Ame

[imprint seal above]

AFFIDA VIT OF AL-FATIH AMEEN - Page Solo

EXHIBIT 1

'I

ARTICLE OF INCQRPORATION

OF

IfUD

In lilt Ofb oflhe

8ecnIIwy of StICe of T_

MAY 142001
0'1' Wi '.SIf*In

ASSOCIATION OF UNITED1AXICAB OPERATORS

We die 1lIIdonipod D8I\Inl)lClSOlli oftbe 86e ofei81=n (18))'WI or more, midcuts of!be
IlIlO of T-. 8CliDg 81 inOOiJXlialotS of 8 c:orporaUQllIlllda' die TIlXlI!I busi_ COIPOfIliOll act.
411 bcroby adopt die followiDg erticIa fOr lIlIdI WijMatioa:

ARTICLE ONE
Name ofCorpontioD
no _

ofdle iADjHAation is ASSOCIATION Of UNITa>fAXICAB OPEJtATOIlS.

ARTICLE TWO
Type dCarpanlian

"!be llOipcxatiCII is a NllII1JIOfIt COIpOIIlio:n.

ARTICLE THREE
DwlIIioaofCorponliDII

The period crib duratioD is porpcIDaJ.

ARTICLE FOUR
PuIpose

1biI axpcn1iCIII is a IIOII-pnlfit lIIpIIi2aticm for TuicIb driven_ should _ be miscalllllnlCd

CIt iIlmrproled .. a uaicm.

Ttlc purpose ofdalsCXlijHAlIIioa is. foUows:

L To II

b.

c.
d.
II.

8-

., t1ZJY ad lIIIlawfiaI basiD_ for which _jIOl1di.mS IIIlIY be inCOlponled """"'" die

T_ Ba.sina:II CorporlIIioa At/..

To ck:!lIIIIe ...... pramola die m.aa oflAicob ilJlilI- in Ibc ..-DoII8IlIDd fort Worth

uea.

To plOVide b.. &'1 to lIIXicIb drivers sad their

Ahistaneo ill die proclliUliCllC of 5IIpJIIiGt, equiw'llt and scrvieeslbruugb 1IJlI1Ip and
wholesale ~ To provida Legal lIDd FiDam:iaI serYica to all qualified mcmbcn.
To iIlIprove lIlll\'iees to !be Gilics. GOIIIIlic:s. &I8lOl, au blIsin_1IIId IIllCllllicB.

To iIJlprtm llIxieab drivers IIUIIId8id of opalIIian lIlId prdOllllllllCllIbrough niniDa. drivers

edw:8liDIIII pnl8J'8lllll and JDIIIIitllriDa.

To Improve mstomer sarvico Ihroagh pOlllCltiOJ4ll, markctin& IIdvcrtina IIDll public R1lIIiou.

,.....'i.

"

No pan ofthe Dot earaius efthe c:orpoiation shall inure 10 the beaeSt of; or be distributed to its

members, directors. officas, Dr other private pmons. Except that the corporation shall be

. autbotiZed lIlId empowen:d to pay reasonable compeiIS8liOD for services readered tmd to IlllIke
payments IIIld distributions in fiutbermoe of tho pmpose set forth in lIIe neill.
No substantial part of the activities of the corpDJaIion shall be for canyiDlJ out or atleuiptiJl8 to
iDO_ IllllislatioD.
NOIWithstalidillg &rJy other provisiou of these articles, the ClIIpOI'8Iiou shall DOt l:8rI)' OIl lIII)' other
Edivities Dot permitted to be tarried OD (a) by al:OlpOl1lliOD exempted from federal iDcome lBX
mcler SUQliOIl 'OI(cX3)of'the mtcnW revooue code, or COMSPCndiDa sectioo of'aoy fidure
fcderallllX code. Or by a corporaliOll, coulributions to which IlI'e deductible Wider the sectioII
1'0(cX2) of the iDtemal nMliiiIe code, or corresponding sectioa of lIIi)' fuhire CederallllX code.

Upon dissolutiOD of the corponltiou. lISSeI9 sbaI1 !Ill distribullld for one or mon: - p l JlIIIPOSC
within the mElllIliDlJ ofsectien SOJ(3) of the internal reveaue code, or shall be distributed to Ihe
fcdaal goVernJIIelll, or to SlIite, or local AOvemDilliil Cor II publie pwpose.
Any SUcllllS$OlS not disposed ofby the COW1 of common pleas ofthe colllity in wbicll the
priDcipaI office ofllie corporatioa is located, exclusively for the purpose or to IIICh cq.aaiglioo
or organizatiODs, B!I said court shaI1 dlitlJlmiDe, lllhich 8I'B organized 8Ild operated llIZA:lusively for
IIICh purpose.
ARTICLE FIVE

Requirement

The COl]lOratiou will DOt COIDlnenoe business until it has received &om her me:mbe:s 8
cousidenttion ofthe value of Doe 1II0llSBlld doUIn (I.POO.OO) COlISislinIl ofmonl:)'. labor dliliC, or
property 8CIUBIly received.

ARTICLE SIX

LocaIiOlI md Agent

The &lI'lllIt Bddtuss of ilS iDitial JeBiSleRd office is 7S06 Wesz JohII Capanter FRlllWlI)'. Suite 200.
DIllas, Texas 75247.11iiC1 its initial Je3isterod BgeDt afthal eddre&s is Doufllas A. Ucbc::ndu.

ARTICLE SEVEN

Board ofDin:ctors

The number ofdirectors cooslitutin3 the initial Board ofDireclors is fifteen IIIId the name and
address orlbe persllIiS who Bre to l!OI'Ve as Directors unti1lhe fim: lIIIDuaJ IIlClCliDs ofmcmbeq or
lIlllillheir successors is elected 8IId qus\ified 1II'il:
NAMES AND ADDRESSES ARE AS FOLLOWS:
Mohammad T. Xliaii

2402 MIG Arthur Blvd #1307

lrvin& TllXlIlI, 75062

0.

"

Ankamah AllefIiIJI
5212 KoDy HiD drive

ArlinsloD. T-. 76017

MulugrJ11 B. Gizaw

10435 Eest North_ Hishway lID

DII1aa, TCXlIS, "238

Jimu-
2442 Chaning Dr.
Onmd Prairie, Texas, 7S052
Hinuy A. I>8gDo
8209 Me8dow ROId #2011

n.nu. T-.75231

H.bi SA Hassan
1228 NOJIh BrillIin 1J2T1
Jrvma, TIIUI, 75061

AzmarJIMld
U06 Sopopiiiido blvd
EuIeu, TlllaIS, 76040

XODII Sihlnlh
ll32~Road

IrviD& TlllaIS, 75061

JOSllPIl A&Yctum
2504 Si1vabrook 1Ine 1#705
Adinpm, T-. 76006
Clabrilll Upge
1'1' R-mgbrook #2020

Arlington, Texas, 76010

ClIIaTGYGb
307 Vine Snct 1#128
Eul-. Taxas, 76040

AbdlIA.Amm

2791 JcmIoo Cir. flI16F

Da1lu, TClDI, 75229
1lftwly S4llela

1423 W.-su Road '141

ArliDgtou, Texas, 76010

'

S1Illllai ADpalllll8!w1

3110 Poc8IilIIo S1I1llil

IrviJIll, TBIl8II, 75062.

Dou3'lIS A. O. Ucbcadll
3]09 Wesz NOI1IIpIl;l Drlw 111025

IrviD& TllIl8II, 75062

ARTICLE EIGHT

Powa-oflhQ Bo8nI

The Board ofDinll:tors shaD have !be JlOMI'Io maIw. alter. 8IIIllIId or repeal the byl_ orlbe

COlpOilllion or 10 adopt DIlW bybnrtI.

ARTICLENlNE
.

IIldemnlfiCllljoD

The COIpwmon IhallIo die fhlIesr exteIIt 10 which it il ampoWllllld 10 do 80 by die TGIl8S
BusiDBII Corpondioa set or lIII)' other applicabla lawllS msy from tima 10 time ill afl'llCI,
indmmifY lII1Y JIllI'SOD who was, ill or iIIlbre8lenBd 10 lie made e party 10 llIIY t1uiOlllim.m, peodins
or camplded ectioo, nit or procmD& wbdher civil, crimimll, edmiDi&tralive or iDvosliptlva,
by reasoa oflhe tlu:t Ihet he ill or W1llI8 diJeclor or officer oftbe COI]lOiilliOll, or ill or WlIlIlICrYiq
IIllberequest oflbecorpwatillllllS 1I direclb., ofti=~ liIiiployee, lIpIIt, or simiIIr
filagjOlllll)' of OIlolller eJlIPWIllioll, lniIl or oI!IIlr Iliiteiprise, IlIIIliIIBt 111 mqllIiillll ('iIlc:llllliDa
IIlImDey'B rOllll),~ !iDes aad amoilllll paid iD !9It1_tlldull BJUlreuan""ly iDCIImld
by him ill ~lIII wiIh l5lldi IIl:IioD, IIIit or pnICOllCliiJ3. The GOi]lOIliIioa's ob1ipdOlillllldllr
Ibis r<ction iDdude, but me DOl limiled to, the c:onveainS ohllY rneetin& IIIId lbe CCIlIllidmtion or
1m _ _ thereby, nlIj1Iirad by _
in arde:I- to dr:acrp>iDe lhe clftPbiJity olllll)' om_ 01" c1h__
fDl'iDdcnmilicatiOlL Expenses inc:onal in defending Bcivil or criminallUion, IIUit or proceedina
sba1J be paid by Ibe ~ ill Ild_ of tile fiIlIjl cIisposidon of sudl8dion, lILIit or
proceedina upon receipt of8lilllldenalriDll by or on bl:balfoftbe clirec1or. officer. employee or
llpDI wh<I rDlI)' be cmitled 10 lII1Ch indmmifio:alion, tq "'P")' ouch IlIDCIIIIIt ifi. sIuaIJ uJlimaieIy be
d61ermin1ld thl1l be is ilOt enIitled 10 be inckmnify by \be corplli1Ilion, The COipotatilill'. obIilIIlion
10 lndmnnity ad 10 pn:poY llllplliISClIlIIIder this secdQII arise, IIIId all riBhls gIlIiIiIld 10 clireclor,
om...... amplO)l'ill:S or Il8llJdB hel'llllllllm Ihall WlIi, IIlIbe lime ofoccurrence oflbe li1IiIIliCdon 01"
lMIiIIlo wbicb snch IIClion or CODduet 10 MIlch 81Ich ,cliOD, sui. or pro ccc~iDlI re1IltIls _ flnt
takell or llilllBllBd in (or ClIlIiUed 10 ba takeD or CIIlIIllIBd ill), nlJlllIdless Whllillll1Ch I.ClioD, IlIit or
pr~m rIina i. first thmmmed, ("'IiIi1 eacad or CODIplCllld. NoIWidllll!lndjna 8Y otbllr)llVYillion of
tbeae Bybmu or Articles or CertifIcllIe oflDcolpOllllion oflbe cmporatioD, iIO mion takea by the
QllpoiEJlion, ailhcr by 8IDmufmllilt of the Bylaws or tips I:mIi1ilzlIl of~ of dta or
cdJerwim, shall diminis), or adversely alJed lIII)' riglm 10 indemnification or PJfPiYiiIllIlI of
cxpeiIICll ermud m>der this sectiQll which uball have become vesr88 lIfozesaid prior 10 die dille
IbIIl lOCh mnoodmstt or oIhcr CIOfIIOIBlll Bdiou is ~ Fnr1IJcr, if IliIY pnMsion of !bill SllCtion
&ball be held 10 lie illvaJid or uaeofClnlell!lle, the validity IIild eofClJQ:llbility of the remlinillll
)lfOYisiODS shallililt ill rta'I W5Iy ba pffi>c .00 ctl impaiJ'Id.

or

.. .

ARTICLE TEN
InCOI jlOIatlll'
The 1IIID8 lIIId address ofdle Inco!pontor is:
NAME AND ADDRESS
Hartri Sharif Ali Hassan

1228 NortII BrillliD .227

1rviDg. Texas, 75061
IN WITNESS WHEREOF. J, the undcrsigllM !Dcc>1jIOiidUJ of tills
corpondiOll, have executed thc:sc Articles OflnCOijlOlation Oil this dayO oS .h1i'iOOl.

\-t 9. v''-x

~.Q.. ~ ") ~f "'i-.

HaitIl SIIarif' Ali Ha-.

IncoIpOrlilli'

TIlE STATE OF TEXAS

COUNTY OF DALLAS

Nqr~~Pf
cf/P61 '4!~

TCX4S

II. expua
.
~on

,. v

EXHIBIT 2

DALLAS FORT WORTH INTERNATIONAL AIRPORT BOARD

OFFICIAL BOARD ACTION/RESOLUTION
Date
05/07/2015

Committee
Operations

Subject
Amendment to the Code of Rules and Regulations of the
Dallas/Fort Worth International Airport Board - Chapter 4,
Ground Transportation

Resolution #

Action
That the Airport Board approve amendments to Chapter 4 of the Code of Rules and Regulations of the
Dallas/Fort Worth International Airport Board relating to Vehicles for Hire.
Description
This action will approve amendments to Chapter 4, Ground Transportation
Retains conformity with Owner Cities Rules governing Transportation for Hire services
Major revisions include
Require Transportation for Hire companies, such as taxicab or pre-arranged operators, to
obtain either a City of Dallas or City of Fort Worth Operating Authority in order to obtain
Operating Authority at DFW Airport
Enable pre-arranged Transportation Network Companies (TNCs) to be authorized to obtain
Operating Authority at DFW Airport
Remove limitations on the number of taxicab companies, vehicles and taxicab drivers that are
authorized at DFW Airport
Require vehicle operators to obtain either a City of Dallas or City of Fort Worth driver permit in
order to operate at DFW Airport
Remove DFW Airport from issuing driver permits for taxicab or pre-arranged drivers
Justification
Supports our Owner Cities in simplifying and further aligning DFW regulations related to
Transportation for Hire services at DFW Airport
Eliminates redundant permitting fees and administration, and ensures conformity with Owner Cities'
rules governing Transportation for Hire
Enables high demand new transportation service offering which is in conformity with Owner Cities
strategic product offering

D/S/M/WBE Information
N/A - Not subject to the Board's D/S/M/WBE Program Policies (Board policies and amendments).
Contract #

Agreement #

For Information contact

F. Paul Martinez
3-7150

Fund

Purchase Order #

Project #

Action Amount

Revised Amount

$0

$0

External Funding Source

Amount
$0

Resolution #
Additional Information
Per State Law and the 1968 Contract and agreement, these amendments will also need to be
approved by the Dallas and Fort Worth City Councils and will be effective upon such approval being
obtained.

Additional Attachments: N
BE IT RESOLVED BY THE DALLAS-FORT WORTH INTERNATIONAL AIRPORT BOARD
Section 1. That the attached amendments to the Code of Rules and Regulations of the Dallas/Fort Worth
International Airport Board be and are hereby approved. Section 2. That the Chief Executive Officer, or
Designee, be and is hereby directed to forward the attached amended Code of Rules and Regulations of the
Dallas/Fort Worth International Airport Board to the Cities of Dallas and Fort Worth along with a request that
their respective City Councils take action to approve same. Section 3. That the Chief Executive Officer, or
Designee, be and is hereby authorized to take such further action as he deems necessary to see to the
passage and enforceability of the attached amended Code of Rules and Regulations of the Dallas/Fort
Worth InternationalAirport Board.
Approved as to Form by

Approved as to Funding by

Approved as to M/WBE by

Rodriguez, Elaine
Legal Counsel
Apr 23, 2015 11:46 am

Miyashita, Glenn
AVP Capital Planning
Finance
Apr 23, 2015 7:29 am

Lee, Tamela
VP Business Diversity & Dev
Business Diversity and
Development
Apr 23, 2015 12:05 am

SIGNATURE REQUIRED FOR APPROVAL

Approved by

Department Head
Operations
Apr 22, 2015 6:25 pm

Pending
Chief Executive Officer

Date