Quote Quoting adjusterjack
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I thought that was the case but couldn't find an authority for it. Could you please cite one so I can add it to my reference material? Thanks.
Texas Civil Practice and Remedies Code 38.001:

Sec. 38.001. RECOVERY OF ATTORNEY'S FEES. A person may recover reasonable attorney's fees from an individual or corporation, in addition to the amount of a valid claim and costs, if the claim is for:
(1) rendered services;
(2) performed labor;
(3) furnished material;
(4) freight or express overcharges;
(5) lost or damaged freight or express;
(6) killed or injured stock;
(7) a sworn account; or
(8) an oral or written contract.