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CAUSE NO Dc. (@4015;
JEANNIE WOOLSLAYER, IN THE DISTRICT COURT
Plaintiff,
V.
LEE C. MOORE, INC., A/K/A
WOOLSLAYER COMPANIES, INC,
RANDY WOLF, IN HIS CAPACITIES AE
.‘
>
VOTING TRUSTEE FOR THE ROBERT T.
WOOLSLAYER GST TRUST, VOTING
TRUSTEE FOR THE HOMER
WOOLSLAYER GST TRUST, VOTING
”a
WWWWWWWWWDWDWWDWWWWWWWWDWWWW
TRUSTEE FOR THE JOHN WOOLSLAYER JUDICIAL DISTRICT OF
GST TRUST, AND VOTING TRUSTEE OF
THE JOSEPH WOOLSLAYER GST TRU ST,
ROBERT T. WOOLSLAYER, HOMER
WOOLSLAYER, JOHN WOOLSLAYER,
AND JOSEPH WOOLSLAYER,
INDIVIDUALLY, AND IN THEIR
CAPACITIES AS CO-TRUSTEES OF TH E
WOOLSLAYER GST TRUSTS,
Defendants. DALLAS COUNTY, TEXAS
TEMPORARY RESTRAINING ORDER
On this date, Plaintiff Jeannie Woolslayer’s (“Plaintiff’) Application for Temporary
Restraining Order came before the Court for consideration. The Court, having considered the
pleadings, the evidence, the arguments of counsel, and the relevant legal principles, orders that
Plaintiff’s Application for Temporary Restraining Order is hereby GRANTED.
The Court has determined to grant a Temporary Restraining Order (“TRO”), because
Plaintiff has complied with, and met, the requirements under the Texas Rules of Civil Procedure,
including, but not limited t0, Rules 680 and 682. Plaintiff has presented evidence demonstrating
that Defendants have interfered with her contractual rights, and that the continued interference of
TEMPORARY RESTRAINING ORDER PAGE 1
Defendants will result in irreparable injury, including but not limited to, excessive delay and costs
in complying with Lee C. Moore, Inc., A/K A Woolslayer Companies, Inc., (“WCI’s) contractual
rights, and the disruption of WCI’s business. Because of the continuing and ongoing nature of
Defendants’ interference, and the possibility of total disruption of WCI’s business, this Court’s
ability t0 grant complete relief upon a full trial would be frustrated, impaired, or, rendered
impossible by the continuing actions of Defendants, Randy Wolf, John Woolslayer, Homer
Woolslayer, Robert T. Woolslayer, and Joseph Woolslayer (collectively, “Enjoined Defendants”).
Thus, in the absence of injunctive relief, Plaintiff would suffer imminent and irreparable harm.
The Court finds that Plaintiff has shown a likelihood of success in connection with
Plaintiffs claims of tortious interference with the existing contract. The Court also finds that
w
Plaintiff has demonstrated irreparable hand in the event that Defendants are permitted to continue
such interference, by threats or other me s, with the operation of WCI, its Board of Directors,
and WCI’s contractual obligations. Such interference will result in WCI’s business and cause
substantial delay and additional costs in W I’s ability to fulfill its contractual rights.
Plaintiff has shown that Without i ediate injunctive relief, the Enjoined Defendants
would continue t0 interfere with Plaintif s contractual rights and damage WCI, making any
‘.
potential monetary judgment inadequat If the Enjoined Defendants threatened actions,
specifically, removal 0f the WCI Board, are not enjoined, the damages would be imminent,
continuing, irreparable, and there is no adeguate remedy at law to address these damages.
IT IS THEREFORE ORDERED that each of the Enjoined Defendants, and all of their
officers, directors, agents, servants, empl<$yees, attorneys, and all of those in active concert or
i
\
participation With them who receive ac‘pual notice of this TRO, are hereby immediately
RESTRAINED and ENJOINED from taki+g or assisting in any and all of the following actions:
TEMPORARY RESTRAINING ORDER 1
PAGE 2
Holding any Shareholder’s m
etings for the purpose of removing or electing new
members of the Board 0f Direct rs for WCI;
Voting, whether at a meeting 0r ‘hrough written consent, any share ofWCI voting stock
for the purpose 0f removing or lecting members of the Board of Directors of WCI;
\
Taking any actions to remove afiy current members of the Board of Directors for WCI;
Making any further comments, or insinuations about removing any
statements, threats,
current member of the Board ofi Directors for WCI; and
e. Interfering with any actions of the Board 0f Directors of WCI.
TRO aflgggm.
This has been issued on
Q% . 2019 and expires on
M
l ,
w
l
g ,
2019 atLlQPm, but mfiy be extended in accordance with the Texas Rules of
Civil Procedure if mutually agreed upon iniwriting by all parties, or as ordered by the Court.
1
The Court hereby sets and providlés notice to all parties in this lawsuit that Plaintiff’s
Application for Temporary Injunction is set? for hearing in they! Eiflfi‘dicial District Court ofDallas
i
County, Texas mg IQHQ ll , 2019 aflzwm.
\
SOC
’—
A bond is hereby set in the amount kf $ .
.
\
IT IS SO ORDERED ON THIS
‘3‘,
DAY OF
fl . ,
2019
PRESIDING JUDGE
TEMPORARY RESTRAINING ORDER PAGE 3
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CAUSE NO Dc. (@4015; JEANNIE WOOLSLAYER, IN THE DISTRICT COURT Plaintiff, V. LEE C. MOORE, INC., A/K/A WOOLSLAYER COMPANIES, INC, RANDY WOLF, IN HIS CAPACITIES AE .‘ > VOTING TRUSTEE FOR THE ROBERT T. WOOLSLAYER GST TRUST, VOTING TRUSTEE FOR THE HOMER WOOLSLAYER GST TRUST, VOTING ”a WWWWWWWWWDWDWWDWWWWWWWWDWWWW TRUSTEE FOR THE JOHN WOOLSLAYER JUDICIAL DISTRICT OF GST TRUST, AND VOTING TRUSTEE OF THE JOSEPH WOOLSLAYER GST TRU ST, ROBERT T. WOOLSLAYER, HOMER WOOLSLAYER, JOHN WOOLSLAYER, AND JOSEPH WOOLSLAYER, INDIVIDUALLY, AND IN THEIR CAPACITIES AS CO-TRUSTEES OF TH E WOOLSLAYER GST TRUSTS, Defendants. DALLAS COUNTY, TEXAS TEMPORARY RESTRAINING ORDER On this date, Plaintiff Jeannie Woolslayer’s (“Plaintiff’) Application for Temporary Restraining Order came before the Court for consideration. The Court, having considered the pleadings, the evidence, the arguments of counsel, and the relevant legal principles, orders that Plaintiff’s Application for Temporary Restraining Order is hereby GRANTED. The Court has determined to grant a Temporary Restraining Order (“TRO”), because Plaintiff has complied with, and met, the requirements under the Texas Rules of Civil Procedure, including, but not limited t0, Rules 680 and 682. Plaintiff has presented evidence demonstrating that Defendants have interfered with her contractual rights, and that the continued interference of TEMPORARY RESTRAINING ORDER PAGE 1 Defendants will result in irreparable injury, including but not limited to, excessive delay and costs in complying with Lee C. Moore, Inc., A/K A Woolslayer Companies, Inc., (“WCI’s) contractual rights, and the disruption of WCI’s business. Because of the continuing and ongoing nature of Defendants’ interference, and the possibility of total disruption of WCI’s business, this Court’s ability t0 grant complete relief upon a full trial would be frustrated, impaired, or, rendered impossible by the continuing actions of Defendants, Randy Wolf, John Woolslayer, Homer Woolslayer, Robert T. Woolslayer, and Joseph Woolslayer (collectively, “Enjoined Defendants”). Thus, in the absence of injunctive relief, Plaintiff would suffer imminent and irreparable harm. The Court finds that Plaintiff has shown a likelihood of success in connection with Plaintiffs claims of tortious interference with the existing contract. The Court also finds that w Plaintiff has demonstrated irreparable hand in the event that Defendants are permitted to continue such interference, by threats or other me s, with the operation of WCI, its Board of Directors, and WCI’s contractual obligations. Such interference will result in WCI’s business and cause substantial delay and additional costs in W I’s ability to fulfill its contractual rights. Plaintiff has shown that Without i ediate injunctive relief, the Enjoined Defendants would continue t0 interfere with Plaintif s contractual rights and damage WCI, making any ‘. potential monetary judgment inadequat If the Enjoined Defendants threatened actions, specifically, removal 0f the WCI Board, are not enjoined, the damages would be imminent, continuing, irreparable, and there is no adeguate remedy at law to address these damages. IT IS THEREFORE ORDERED that each of the Enjoined Defendants, and all of their officers, directors, agents, servants, empl<$yees, attorneys, and all of those in active concert or i \ participation With them who receive ac‘pual notice of this TRO, are hereby immediately RESTRAINED and ENJOINED from taki+g or assisting in any and all of the following actions: TEMPORARY RESTRAINING ORDER 1 PAGE 2 Holding any Shareholder’s m etings for the purpose of removing or electing new members of the Board 0f Direct rs for WCI; Voting, whether at a meeting 0r ‘hrough written consent, any share ofWCI voting stock for the purpose 0f removing or lecting members of the Board of Directors of WCI; \ Taking any actions to remove afiy current members of the Board of Directors for WCI; Making any further comments, or insinuations about removing any statements, threats, current member of the Board ofi Directors for WCI; and e. Interfering with any actions of the Board 0f Directors of WCI. TRO aflgggm. This has been issued on Q% . 2019 and expires on M l , w l g , 2019 atLlQPm, but mfiy be extended in accordance with the Texas Rules of Civil Procedure if mutually agreed upon iniwriting by all parties, or as ordered by the Court. 1 The Court hereby sets and providlés notice to all parties in this lawsuit that Plaintiff’s Application for Temporary Injunction is set? for hearing in they! Eiflfi‘dicial District Court ofDallas i County, Texas mg IQHQ ll , 2019 aflzwm. \ SOC ’— A bond is hereby set in the amount kf $ . . \ IT IS SO ORDERED ON THIS ‘3‘, DAY OF fl . , 2019 PRESIDING JUDGE TEMPORARY RESTRAINING ORDER PAGE 3