Preview
FILED
4/1/2024 9:39 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Fernando Soto DEPUTY
DC-24-04805
CAUSE NO.
GUERIN WOODGATE AND § IN THE DISTRICT COURT
ANTHONY GUTHRIE
68th
vs. JUDICIAL DISTRICT
FIX HOLD & FLIP
CONSTRUCTION, LLC, ALAN
GABRIEL ANTILLON, AND JAMES
E. WILEY, JR and WILEY
BROTHERS GENERAL
CONTRACTORS, INC OF DALLAS COUNTY, TEXAS
PLAINTIFFS' ORIGINAL PETITION
Plaintiffs Guerin Woodgate and Anthony Guthrie, file this Plaintiffs’ Original
Petition complaining of Defendants Fix Hold & Flip Construction, LLC, Alan
Gabriel Antillon, Wiley Brothers General Contractors, Inc. and James E. Wiley, Jr.,
and for cause of action would show the Court the following:
Discovery Control Plan
1. As provided in Rule 190, Texas Rules of Civil Procedure, Plaintiffs intend
to conduct discovery under Level 2.
Plaintiffs
2. Plaintiff, Guerin Woodgate, is an individual whose address is 1312 Travis
Circle S. Irving, TX 75038. The last three digits of Plaintiff's driver's license
number are 106. The last three digits of Plaintiff's Social Security number are 603.
Plaintiff Woodgate may be served through his counsel of record, Joseph LaFleur,
Winborne LaFleur PC, 216 W. Franklin St. Waxahachie, TX 75165.
Plaintiffs’ Original Petition Page 1
3. Plaintiff, Anthony Guthrie, is an individual whose address is 1312 Travis
Circle S. Irving, TX 75038. The last three digits of Plaintiff's driver's license
number are 256. The last three digits of Plaintiff's Social Security number are 561.
Plaintiff Guthrie may be served through his counsel of record, Joseph LaFleur,
Winborne LaFleur PC, 216 W. Franklin St. Waxahachie, TX 75165.
Defendants
4. Defendant, Fix Hold & Flip Construction, LLC, is a limited liability
company. It can be served with process by serving Gabriel Antillon, its registered
agent, by personal delivery at the registered office located at 2231 Madera Street,
Dallas, Texas 75206.
5. This Court has jurisdiction over Fix Hold & Flip Construction, LLC
because said Defendant is a resident of Texas.
6. Defendant, Alan Gabriel Antillon, a.k.a. Gabriel Antillon is an individual
who may be served with process at Defendant's residence by personal delivery at
3039 Nowitzki Way #4002, Dallas, TX 75219. On information and belief, Gabriel
Antillon is also known as Alan Gabriel Antillon.
7. This Court has jurisdiction over Alan Gabriel Antillon because said
Defendant is a resident of Texas.
8. Defendant, James E. Wiley, Jr., is an individual who may be served with
process at Defendant's place of business by personal delivery at 2803 Virgo Lane,
Dallas, Texas 75229.
Plaintiffs’ Original Petition Page 2
9. This Court has jurisdiction over James E. Wiley, Jr. because said
Defendant is a resident of Texas.
10. Defendant, Wiley Brothers General Contractors, Inc. is a Texas Domestic
Corporation and may be served through its registered agent, James E. Wiley at the
office of its registered agent 9990 Monroe Dr. Dallas, TX 75220.
11. This Court has jurisdiction over Wiley Brothers General Contractors, Inc.
because it is a Texas resident.
Venue
12. Venue is proper in this county in that the events giving rise to this cause
of action occurred within Dallas County.
Jurisdiction
13. The damages sought in this suit are within the jurisdictional limits of the
Court. As required by Rule 47, Texas Rules of Civil Procedure, Plaintiffs state that
Plaintiffs seek monetary relief over $250,000 but not more than $1,000,000.
Notice of Claim
14. Plaintiffs delivered written notice of this claim to Fix Hold & Flip
Construction, LLC on February 8, 2024, advising Fix Hold & Flip Construction,
LLC in reasonable detail of the specific complaint made the subject of this action
and the amount and nature of the damages and expenses sought.
15. Plaintiffs delivered written notice of this claim to Alan Gabriel Antillon
on February 8, 2024, advising Alan Gabriel Antillon in reasonable detail of the
Plaintiffs’ Original Petition Page 3
specific complaint made the subject of this action and the amount and nature of the
damages and expenses sought. The letter also warned Defendants Antillon and
FHFC that Plaintiffs would sue under the Texas Deceptive Trade Practices Act.
16. Plaintiffs contacted Defendant, James E. Wiley, Jr. on March 11, 2024,
demanding that property Defendant James E. Wiley possessed which belonged to
plaintiffs be returned. Wiley refused to cooperate in the return of Plaintiffs’
property.
Facts-As to Defendants FHFC and Antillon
17. On 10/11/2028, Guerin Woodgate, Anthony Guthrie, Fix Hold & Flip
Construction, LLC (“FHFC”), and Gabriel Antillon, FHFC’s sole member and agent,
agreed that FHFC would perform a comprehensive renovation of a rental home
which included such items as replacing the roof, leveling the foundation, replacing
the supply and sewer plumbing, replacing the electrical system, installing a new
kitchen, installing new flooring, and many other cosmetic items to prepare the home
for rent. The agreement is memorialized in an invoice prepared by FHFC’s principal
and formed the basis of a contract. A copy of said agreement is marked P-1 and
incorporated herein for all purposes.
18. The heart of the agreement was a detailed document which detailed the
work to be done. The price set was $156,828.75. Plaintiffs paid $116,004.06 down
with a balance of $40,824.69 to be paid as progress payments. Defendants proposed
additional work to Plaintiffs and Plaintiffs agreed to some of the additional work,
however, discussed below, Defendants fraudulently induced Plaintiffs to agree to
Plaintiffs’ Original Petition Page 4
additional work to repair problems that Defendants themselves intentionally
caused.
19. Defendants Fix Hold & Flip, LLC and Alan Gabriel Antillon, abandoned
the work and failed to complete the work for which they were paid. This
abandonment damaged the Plaintiffs who lost the benefit of the bargain and had to
pay to repair damages intentionally caused by Plaintiffs.
20. Additionally, Antillon removed valuable building materials, including
drywall, lighting, air conditioning units etc. from the rental property and stored
them at 2970 Blystone Lane, #108, Dallas Texas. This address is an address for a
building owned or leased by James Wiley and/or Wiley Brothers General
Contractors, Inc. Despite requests from Plaintiff Woodgate to both Antillon and
Wiley, Wiley refused to return the building materials and equipment from the
Blystone Lane location to Plaintiffs. Discussed below, Wiley first said the building
was empty and that Antillon had opportunity to remove the materials. Antillon
stated he was locked out of the building.
21. Antillon and FHFC promoted themselves as “a Dallas Fort Worth
Roofing, restauration & Construction company that has provided DFW with quality
residential and commercial repairs and replacements since 2008.” See
www.fixholdflip.com. According to the filings at the Texas Secretary of State’s
office, the reality is that FHFC did not come into existence until 2020, and Antillon
formed the LLC on May 7, 2020, while the Covid-19 pandemic ravaged the globe.
Plaintiffs’ Original Petition Page 5
22. The website further warranted, “At Fix, Hold & Flip Construction, LLC,
our mission is to serve our clients with the highest level of customer service through
great communication, best materials in the industry, best installation & warranty
available, and to build a relationship for many years to come.” Not only did Antillon
lack experience and resources to provide the renovations Woodgate and Guthrie
hired Antillon and FHFC to do in a good and workmanlike manner, but the
Defendants also failed to provide the promised “best warranty available.”
23. The business reviews of FHFC are fake.
24. Instead of the “highly trained construction project managers” Defendants
promised, Defendants used a twenty-something year old habitual drunkard, Adil
Awwai, who had no training and no qualifications to manage a total home
renovation. Having knowingly hired this habitual drunkard, Antillon, who knew
about Awaii’s problems blamed Awaii for the failures at the project.
25. Despite numerous requests, Defendants either would not or could not
provide a project plan to Woodgate and Guthrie, despite repeated requests for one.
Instead of the promised work, Defendants delivered defect after defect.
26.Some of the defective work Defendants did included (1) installing
improperly sized windows and attempting to conceal the improper sizing by using
spray foam to fill in gaps; (2) brick masonry with bricks placed in uneven patterns
and mismatched mortar lines; (8) installing a sliding glass door with no base, so to
open and close it, required dragging it along the slab; (4) installing a new roof on top
Plaintiffs’ Original Petition Page 6
of rotten decking and then using spray insulation to cover it up; (5) missing
insulation in parts of the home; (5) improperly installing fencing; and (6) extensive
damage to the garage door.
27. Additionally, in a blatant act of fraud, Defendant FHFC and Antillon
pulled down portions of the brick veneer and exposed the interior sheetrock. After
exposing the sheetrock, Defendants left it uncovered and the interior sheetrock,
which otherwise was in good repair was destroyed, and Plaintiffs had to replace it
unnecessarily. Defendants lied to Plaintiffs and stated that the brown coloring on
the drywall meant it had to be replaced, when it was merely the color of the paper
attached to the drywall in the 1970s.
28. Despite numerous promises to return the money to Plaintiffs, Antillon
has returned none of the money.
29. Upon investigation, Antillon has a pattern of forming companies,
defrauding, and stealing from consumers, and then allowing the companies to go
into forfeiture. For an example of how Defendants Antillon and FHFC repeatedly
defraud consumers, see generally DC-23-02531, currently pending in the 298th
Judicial District Court, which is a case with remarkably similar facts.
Facts-As to Defendants Jim Wiley / Wiley Brothers General Contractors,
Inc.
30. Defendant Antillon stored valuable materials and equipment, including
parts to the home’s HVAC system, that Plaintiffs own, and that Plaintiffs intended
to use for the renovations at a warehouse owned by Jim Wiley and/or Wiley
Plaintiffs’ Original Petition Page 7
Brothers General Contractors, Inc. at 2970 Blystone Lane, #108, Dallas, Dallas
County, Texas. This is the address Antillon used as his business address, and it
appears on the agreement.
31. Because Antillon’s spree of destruction abounds in the metroplex,
Plaintiff Woodgate was able to communicate with another of Antillon’s victims and
learned that Antillon was held in a warehouse owned by Jim Wiley and/or Wiley
Brother’s Construction. Court records demonstrate that Antillon engages in this
same pattern of behavior, and that Antillon habitually abuses the corporate
structure for his own benefit and hides behind the shield of an LLC.
32. Plaintiff Woodgate contacted Jim Wiley about retrieving the materials
and HVAC equipment from the Warehouse. At first Wiley stated that the
warehouse was empty, the later admitted that he had not been to the warehouse in
months.
33. On information and belief, Jim Wiley / Wiley Brothers General
Contractors, Inc. unlawfully disposed of or utilized the property or is holding it
unlawfully with the knowledge that the equipment belongs to Plaintiffs.
Plaintiffs’ Original Petition Page 8
Conditions Precedent
34. Plaintiffs state that Guerin Woodgate and Anthony Guthrie have fully
performed all obligations under the contract.
35. All conditions precedent to the performance by Defendants have been
met.
Breach of Contract
36. Fix Hold & Flip Construction, LLC ("FHFC") is a sham company formed
for the purpose of committing fraud against unwitting customers for the benefit of
its member, Alan Gabriel Antillon. Antillon used FHFC to lure Plaintiffs to pay
him $116,004.06 as consideration for an extensive renovation project to occur at
2205 Avenue C in Grand Prairie, Texas. FHFC and Antillon completed only part of
the paid for work, and the work that was done was defective, and a substantial
portion had to be redone or must be redone. FHFC and Antillon failed to render the
services they were paid to do and failed to perform home repairs in a good and
workmanlike manner.
Breach of Implied Warranty Of Good and Workmanlike Manner
37. Defendants Antillon and FHFC breached the implied warranty that the
work would be performed in a good and workmanlike manner. Defendants used
materials that were of the wrong size and for the wrong purposes such as wrong
sized windows and spray foam as filler. Defendants installed new roofing materials
over rotten wood and failed to professionally install the sliding doors among other
issues.
Plaintiffs’ Original Petition Page 9
Fraudulent Inducement / Common Law Fraud
88. Defendants Antillon and FHFC fraudulently induced Plaintiffs into
entering into this agreement by falsifying facts in its marketing material such as
the age of the company, the experience of the staff and the training of the staff.
Additionally, prior to abandoning the job, Defendants lied to Plaintiffs about the
necessity of replacing some materials. Defendants then purposefully damaged the
home which would require Plaintiffs to spend more money to repair parts of the
home that Defendants intentionally damaged.
39. The above-described statements and representations were material and
were made knowing that they were false when made, or they were made recklessly
without regard for their truth.
40. The above-described statements and representations were made with the
intent that Plaintiffs rely on them, and Plaintiffs did rely on them when entering
the contract.
41. Asa result of Defendants' fraud, Plaintiffs have been damaged, for which
Plaintiffs request judgment.
Restitution
42. Plaintiffs delivered valuable goods or services to Defendants which
resulted in an unconscionable unjust enrichment to Defendants. Plaintiffs therefore
ask for a judgment of restitution in equity against Defendants.
Plaintiffs’ Original Petition Page 10
Negligent Hiring and Negligent Retention
43. The evidence will show that Antillon and FHFC knew about Awaii’s
drinking habits and lack of experience. Antillon complained to Plaintiffs about
Awaii but never terminated him nor hired anyone competent to complete the job as
promised.
Exemplary Damages
44, The conduct of Defendants as described above constituted fraud.
45. Defendants Antillon and FHFC have a pattern of defrauding others.
46. Given the knowledge Antillon had about Awaii, the negligent hiring and
retention of Awaii constituted gross negligence.
47. Plaintiffs seek exemplary damages as provided in Section 41.003, Texas
Civil Practice and Remedies Code, for which Plaintiffs request judgment.
Declaratory Judgment
48. Plaintiffs seek declaratory judgment that there was a contract between
Plaintiffs and Defendants Antillon and / FHFC and that the attached P-1 provides
evidence of the terms and conditions of the contract.
Unjust Enrichment
49. Should the Court find that there was no written contract between
Plaintiffs and Defendants Antillon and FHFC, Plaintiffs ask for a judgment for the
unjust enrichment from which Defendants benefitted by the payments from
Plaintiffs.
Plaintiffs’ Original Petition Page 11
50. As to Defendants Jim Wiley and Wiley Brother’s Construction, Plaintiffs
seek the value of the materials and equipment the Wiley defendants either used in
their own business or disposed of unlawfully.
Damages
51. Plaintiffs seek damages for paid for but incomplete work, consequential
damages, attorney’s fees, loss of benefit of the bargain, reliance damages and all
other damages which the evidence may support.
Economic Damages
52. Asa result of Defendants’ conduct, Plaintiffs suffered economic damages
as defined in Section 41.001, Texas Civil Practice and Remedies Code, for which
Plaintiffs request judgment.
Attorney's Fees and Costs
53. Plaintiffs request judgment for reasonable attorney’s fees and costs
under Sections 37.009 and Chapter 38, Texas Civil Practice and Remedies Code.
Conversion
54. Plaintiffs sue Defendants Jim Wiley / Wiley Brothers General
Contractors, Inc. for conversion. Defendants are either wrongfully retaining
materials and equipment they know belong to Plaintiffs or they utilized the
materials in their own business.
55. Plaintiffs sue Defendants Alan Gabriel Antillon and FHFC for conversion
of their property.
Plaintiffs’ Original Petition Page 12
Alternative Pleadings
56. As provided in Rule 48, Texas Rules of Civil Procedure, claims for relief
made in this petition are presented in the alternative when necessary to preserve
such claim.
Required Initial Disclosures
57. As provided in Rule 194, Texas Rules of Civil Procedure, required Initial
Disclosures of all items listed in Rule 194.2 must be made at or within 30 days after
the filing of the first answer unless a different time is set by the parties’ agreement
or court order.
58. Plaintiffs ask the Court to keep the requirement of Initial Disclosures to
be made within 30 days.
Writ of Sequestration
59. Plaintiffs will seek a writ of sequestration for all of the materials and
equipment taken from Plaintiffs by Antillon and stored at the facility
controlled/owned by the Wiley defendants.
Plaintiffs’ Original Petition Page 13
Prayer
Plaintiffs pray that citation be issued commanding Defendants to appear and
answer herein and that Plaintiffs be awarded judgment against Defendants, jointly
and severally, for the relief requested herein and for all other relief to which
Plaintiffs are entitled both in equity and at law.
Respectfully submitted,
/s/ Joseph LaFleur
Joseph LaFleur
Bar No: 24103410
WINBORNE LAFLEUR PC
216 W. Franklin Street
Waxahachie, Texas 75165
Attorney Plaintiffs
Office Phone: (972) 330-2171
Email: JUAFLEUR@WINLAF.COM
Plaintiffs’ Original Petition Page 14
* INVOICE P-1
gabriel@fixholdflip.com
Fix Hold & Flip Construction LLC
2970 Blystone Lane, 108
+1 (214) 892-1910 FIX HOLD
Dallas, TX 75220 https://www.fixholdflip.com
& FLIP
Guerin Woodgate Jr
Bill to
Ship to
Guerin Woodgate Jr
Guerin Woodgate Jr
2205 Aveenue C
205 Aveenue C
Grand Prairie, Tx 75051 USA.
Grand Prairie, Tx 75051 USA
Invoice details
Invoice no.: 1049
Terms: Net 30
Invoice date: 10/11/2023
Due date: 11/10/2023
Qty Rate Amount
Product or service
$16,870.00 $16,870.00
Foundation
Professionally repair foundation of property. Includes adjusting 11 exterior piers. If piers need to be driven down aaditional
cost will be at $100 per pier. If a new pier is required it wil be at a cost of $300 per pier.
Professionally install 11 new piers outside of home.
at a cost of $400 per pier.
Professionally install 12 piers inside the home, if additional piers are needed, it will be
Includes permits, engineering report, and lifetime warranty.
Concrete
$4,900.00 $4,900.00
forms and rebar. Concrete pad will be
Professionally excavate area for new 12x20 concrete pad. Include properly setting up
doweled into home foundation. Brush finish. Includes all materials and labor.
$4,200.00 $4,200.00
Mud Pumping 1
foundation. This will be done after
Professionally pump 10 yards below foundation to eliminate hollow areas underneath
tunneling to best seal off cavities. Includes all materials and labor.
$5,950.00 $5,950.00
Mortar and brick repair
Safe removal and haul off of damaged brick on right side of wall were .brick was not properly braced with framing.
Professionally lay new brick along wall where previous brick was removed. Includes sanding, mortar along seams. Includes
ali materials and labor.
$12,560.00 $12,560.00
HVAC
Professionally install new 2.5 ton Carrier system with heat pump in new area to the right of home behind electrical panel. New
and smart thermostat.
unit will be placed on new concrete pad for unit. Includes disconnect, new ductwork, vent covers
Includes all materials and labor.
$9,100.00 $9,100.00
Exterior Roofing
Remove and repiace existing roofing. Remove and replace rotten decking on roof line. Remove and replace all ventilation
and jack pipe flashing
— IS
Instail new synthetic felt. Insta! ice and water shield. Install starterstrip. Install new 30 year shingies in black. Install ridge cap.
Includes all materials and labor. Material and labor inciuded
Flooring $4,923.00 $4,923.00
Professionally install approximately 1,094 sqft of hybrid resilient flooring and moisture barrier throughout property. Furnace in
closet will be removed with floor to be level with the rest of home. Furnace closet will include shelving, Labor only.
Flooring $6,560.00 $6,560.00
Materials cost for 1,094 sqftof flooring and underlayment/moisture barrier. Includes materiais cost for shelving. Includes the
cost of materials after tax.
htips://www.liflooring.com/p/duravana-7mm-and-pad-foggy-bottom-oak-waterproo-hyb rid-resilient-flooring-7.56-in.-wide-x-
50.63-in.-long-10052741 .html
https://www.liflooring.com/p/underlayment%C2%A0--quietwalk-versa-1 00sft-10056873.htm!
Toilet installation $248.75 $248.75
Professionally install new toilet and existing toilet previously removed for both bathrooms. Includes toilet flange replacement,
new flapper, and new wax ring. Silicone will be properly applied under toilet. Water and leak test will be conducted after
installation to ensure proper flow. Labor only.
10. Toilet $475.00 $475.00
Materials cost for toilet installation including new toilet, flappers, wax rings, silicone, and flanges for both bathrooms. incudes
proper associated plumbing work. This is price of materials after tax.
Ww Shower Wall Tile $2,073.00 $2,073.00
Professionally install shower wall tile (Includes thin-set and grout). Approximately 176 sqft in area. Includes shampoo nook
Includes Labor Only,
12. Shower Wall Tile $650.00 $650.00
Materials cost for installing shower wall tile for both bathrooms. This is the cost of materials after tax.
https://www.secondsandsurplus.comvflooring/floor tile/harbor-gray-porcelain-tie-12-x-24
https://www.flooranddecor.com/schluter-installation-materials/schluter-jolly-ed ge-1 -2in.-matte-black-101009314.html
https://www.flooranddecor.com/tile-grout-installation-materials/mapei-kerapoxy-cq-M 1070. htm!?dwvar_M1070_color=Black
13. Bathtub $1,333.00 $1,333.00
Professionally install bathtubs and curtain rods in both bathrooms of property. Incucies proper associated plumbing work.
Labor only
44. Bathtub $505.00 $505.00
Materials cost for both bathtubs in restrooms. This is the cost of materials after tax.
https://www.homed epot.com/p/Bootz-Industries-Aloha-60-in-x-30-in-Soaking-Bathtub -with-Left-Drain-in-White-01 1-3365-
00/314614191
https://www.homedepot.com/p/Bootz-Industries-Aloha-60-in-x-30-in-Soaking-Bathtub -with-Right-Drain-in-White-01 -3 64-
00/314614199
https://www.amazon.com/Tension-Drilling-Anti-Slip-Waterproof-Bathroom/dp/BOC8NGJSPK/ref=sr_1_3_sspa?
keywords=curved %2Bshower% 2Bcurtain%2Brod % 2B60in&qid= 169457 1938&sr=8-3-
spons&sp_csd=d2IkZ2VOTmFtZT1zcF9hdGy&th=
15. Bathroom Vanity $270.00 $270.00
Professionally install new vanities in both bathrooms of the property. Includes installation of mirrors in both bathrooms. Labor
only.
16. Bathroom Vanity $433.00 $433.00
Materials cost to install 2 new vanities and bathroom mirrors. This is the price of materials after tax.
https://www.secondsandsurplus.convhome-decor/white-framed |-mirror-24-x-30-30-23105
Bathroom Hardware set $1,283.00 $1,283.00
17.
Professionally install new shower/tub faucet combo set, sink faucet, and hardware for both bathrooms. Labor only.
Bathroom Hardware set $860.00 $860.00
18.
Materials cost for shower/tub faucet combo, sink faucet, and hardware set for both bathrooms. This is the cost of materials
after tax.
https://www.boelon.com/products/boelon-shower-system-with-four-functions
https://www.amazon.conv1 4-Pieces-Bathroom-Accessories-Stainless-Hardware/dp/BOBLT47G9B/ref=sr_1_5?
rid=2JOP7FLDTRTJC&keywords=black%2Bbathroom%2Baccessories %2Bset&qid=1 694622748&sprefix=black%2Bbath
%2Caps%2C205&sr=8-5&th=1
https //www.amazon. com/SHACO-Matte-Biack-Bathroom-Faucet/dp/BOC2VK9ZVZ/ref=sr_1_14_sspa?
crid=1DWSSFCAPCEFY&keyword: Jack +sink+faucet+bathroom+3+ hole&qid=1694622858&sprefix=black+sink+faucet+b
athroom+3+%2Caps%2C4598sr= 14-spons&sp_csd=d2|kZ2VOTmFIZT 1zcF9tdGY &psc=1
19. Insulation $2,167.00 $2,167.00
Professionally install R-19 insulation on all exterior walls throughout property and install R-30 insulation in attic. Labor only,
20. insulation $6,906.00 $6,906.00
Materials cost for wall and aitic insulation. This is the cost of materials after tax.
21 Rough Plumbing $4,000.00 $4,000.00
Professionally change out previous rough plumbing of property and install new pve/pex plumbing system. Includes all new
vaives, fittings. piping runs, and new electrical tankiess water heater. includes ali materials and labor. Includes all materials
and labor.
https://www.homedepot.com/p/Rheem-Performance-27-kw-Self-Modulating-5-27-GPM-Tankless-Electric-Water-Heater-
RETEX-27/300800755
22 Kitchen Cabinets $4,071.00 $4,071.00
Professionally mount and install new kitchen cabinetry in kitchen. Includes installation of butcher block countertops which will
be sealed and finished. Includes painting of kitchen cabinetry. New standard sink and garbage disposal will be installed with
proper plumbing connections. Includes all materials and labor.
https://homeoutlet.comm/preduct/unfinished-oak-cabinets
hittps://homeoutlet.com/product/acacia-butcher-block-countertop -25-x-122-hk
https://www.boelon.com/products/boelon-kitchen-faucet-with-waterfall-design
https://www.homedepot.com/p/inSink Erator-Badger-100-1-3-HP-Continuous-Feed-Kitchen-Garbage-Disposal-Standard-
Series-BADGER-100/321511603
https://www.amazon.com/Westablize-12-Knurled-Aluminum-Charcuterie/dp/BOBY4VZ327/ref=sr_1_357
crid=1EIKZ7XQHSBO1 &keywords=cabinet%2Bpulls %2Bcontemporary&aid: 1694741986&sprefix=cabinet% 2Bpulis%2Bc
ontemporary%2Caps%2C1 10&sr=8-368th=1
23. Kitchen Backsplash $700.00 $700.00
Professionally install kitchen backsplash throughout kitchen, Labor only.
24, Kitchen Backsplash $300.00 $300.00
Materials cost for kitchen backsplash. This is the cost of materials after tax
https://www.flooranddecor.com/shower-decoratives/ocean-honed -marble-tile-100246016.htm!
https://www.flooranddecor.com/schluter-ins
talation-materials/schiuter -jolly-edge-1-2in.-matte-black-101009314.himt
https://www.flooranddecor.com/tile-grout-instaliation-materials/mapei-kerapoxy-cq-M1070.him!?dwvar_M1070_color=Black
25. Drywall, Texture, and Paint $11,469.00 $11,469.00
Professionally hang new gypsum board throughout walls and ceilings in home. Includes tape and bed. Once drywall has
been installed, orange peeV/knockdown texture will be applied on ali newly installed drywall. Includes prime and paint. Walls
to be agreeable grey in satin finish. Ceiling will be flat in white, Labor onty.
26. Drywall, Texture, and Paint $5,515.00 $5,515.00
Materials cost for drywail, texture, paint throughout property. This the price of materials after tax.
Trim Installation $2,103.00 $2,103.00
27
Professionally install approximately 350 lin ft of baseboard and door trim throughout home. labor only.
28. Trim $1,184.00 $1,184.00
Materials cost for block-style baseboard and door trim. This is the price of materials after tax.
29. Interior Painting $809.50 $809.50
Prep, seal, caulk all areas to prepare for painting. Professionally paint all baseboards, door trim, and window sills. Labor only.
30. Interior Painting $224.50 $224.50
Materials cost painting baseboards, window sills, and door trim. This is the cost of materials after tax.
31 Rough Electrical $3,200.00 $3,200.00
Professionally instal! new updated electrical service panel, meter base, and disconnect to update electrical. Includes all
materials and labor.
32. Amazon Exterior lights $114.50 $114.50
Professionally install 2 exterior light fixtures, one located in front and one in back. Labor only.
33 Amazon Exterior lights $70.00 $70.00
Materials cost for 2 exterior light fixtures. This is the cost of materials after tax.
htips://www.amazon.con/BIRITALO-Fixture-Waterproof-Aluminum-Outdoor/dp/BOB2ZKNS2T/ref=sr_1_42?7
crid=3VOMB2EEXENQB&key words=exterior% 2Biight%2Bfixtures&qid= 1695077542&sprefix= exterior %2B light 2B fixtures
%2Caps%2C2658sr=8-428th=
34. Recessed Lights $3,284.50 $3,284.50
Professionally install 19 recessed ceiling lights. Includes proper wiring. Labor only.
Recessed Lights $165.00 $165.00
Materials cost for installing 19 new recessed lights throughout property. This is the costof materials after tax.
https://www.amazon.com/Amico-Ultra-Thin-Selectable-Brightness-Downlight/dp/BO9RZLZN71/ref=sr_1_8?
crid=38PODRABHN1638key words=6in%2Bled %2Brecessed % 2Blight%
2B 20% 2B pack&qid=1694628409&sprefix=6in%2
Bled%2Brecessed % 2Blight%2B20% 2Bpck%2Caps %2C1 12&s1=8-88th=1
36. Ceiling Fan $1,329.00 $1,329.00
Professionally install new ceiling fan. Includes proper mounting to brackets, connecting power to electrical, fitment of trim
plates, and ensuing fan and its remote are functioning properly. Labor only.
37 Ceiling Fan $400.00 $400.00
Materials cost for 4 ceiling fans. This is the cost of ceiling fans after tax.
https://Awww.amazon.com/Honeywell-Barcadero-Contemporary-Mounting-Reversible/dp/BO8LQW893H/ref=sr_1_41?
crid=28CPIY2I276Z7&key
words=modern% 2B black % 2B ceiling % 2B fan&gid= 16947395 1 4&sprefix=modern% 2Bblack%2Bc
eiling%2Bfan%2Caps
%2C 138&sr=8-41 &th=
38. Electrical Outlet{s) $4,404.50 $4,404.50
Professionally install 23 electrical outlets throughout property including 4 GFCI outlets for wet areas. Includes new wiring.
Labor only.
$85.00
39 Electrical Outiet(s) $85.00
Materials cost for electrical outiets. This is the cost of materials after tax.
GHB8X/ref=sr_ 1_2_sspa?
https://www.amazon .com/ELEGRP-Decorator-Electrical-Receptacle-Sef-Grounding/dp/BOBEF
crid=39F42IPMU2Q1 R&keywords=o 2Bpack&qid=1 694557757&sprefix=outiets %2B20%2Bpack%2Caps%
%2B20%utlets
2C02548s1=8-2-spons&sp_csd=C2IkZ2VOTMFIZT1zcF9hdGY&th=1
_5?
https://www.amazon.com/Indicator-Tamper-Resistant-Weather-Resistant- Receptacie/dp/BOBNSK7XTY/ref=st_1
outlets +4% 2Caps
fci+ %2C1498s1=8-
crid=118SRZWB412CS&keywords=gfci+outlets+4+pack&qid=1 694557657 &sprefix=g
5
40. Switch Installation $3,809.00 $3,809.00
are to be
Professionally install 17 new light switches with new wiring. Additional 6 fight switches which will be installed which
dimmer switches. Labor only.
Switch Installation $115.00 $115.00
4t
Materials cost for new paddle-styie switches throughout property. This is the cost of materials after tax
https://www.amazon.com/ELEGRP-Digital-Dimmab'e-Incandescent-Inciuded/dp/BOS9RJ2HRN‘ref: oe - spa?
%2Bswit
%2B paddle
crid= 16NBWST7K9W7D&keywords=light chesd= 1694566541 &sprefi
%2Bdimmer&qi ight%2Bswitch
%2Bpaddie% 2Bdimmer%2Caps %2C 1608st=8-1 -spons&sp_csd=d2ikZ2VOTMFIZT 1zcF9hdGY&th=1
https://www.amazon.com/20-Pack-ELECTECK-Included-Certified/dp/BO9T6WNLHO/ret=sr_1_7?
crid=15XIS HENBW
words=light%2Bs 2B paddle %2B20% ey
witches % YLA&k 2Bpack&qid=1 6945673438sprefix=light%2Bswi
tches %2Bpaddle%2B20%2Bpack%2Caps %2C2338sr=8-7 &th=1
42. Vanity Light(s) $487.00 $487.00
Professionally install vanity lights in both bathrooms of property. Includes associated wiring. Labor only.
43. Vanity Light(s) $135.00 $135.00
Materials cost for vanity lights in both bathrooms. This is the cost of materiais after tax.
https://www.amazon. com/SOLFART-Rotatable-Fixtures-Aluminum-Bathroon/dp/B0881NVNLD/ref=sr_1_1_sspa?
crid=2EVTYMJ3BW3D7&keywords=vanity %2Blights %2Bsolfart&qid=1 694568808&sprefix=vanity %2Blights %2Bsolfart%2
Caps%2C1488sr=8-1 -spons&sp_csd=d2ikZ2VOTMFIZT 1zcF9hdGY&th=1
44, Exhaust Fan $716.00 $716.00
Professionaily install exhaust fans in bathrooms. Includes proper ductwork to be able to vent out to out of home. New
exhaust fans will use electrical connections and switches made during electrical work. Labor only.
45. Exhaust Fan $270.00 $270.00
Materials cost for exhaust fan/light combo for both bathrooms. This is the cost of materials after tax.
https://www,.amazon,com/Homewerks-Worldwide-7 141-1 10-Integrated-Ventilation/dp/BO7X6W4N37/ref=sr_1_35?
crid=3BA9EE1GLAYCG&keywords=exhaust%2Blight%2Bcomboaqid=1 684877629&sprefix=exha ust%
2Blight% 2Bcomb%2
Caps%2C262&sr=8-35&th=1
1 $2,698.00 $2,698.00
Preview
FILED 4/1/2024 9:39 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Fernando Soto DEPUTY DC-24-04805 CAUSE NO. GUERIN WOODGATE AND § IN THE DISTRICT COURT ANTHONY GUTHRIE 68th vs. JUDICIAL DISTRICT FIX HOLD & FLIP CONSTRUCTION, LLC, ALAN GABRIEL ANTILLON, AND JAMES E. WILEY, JR and WILEY BROTHERS GENERAL CONTRACTORS, INC OF DALLAS COUNTY, TEXAS PLAINTIFFS' ORIGINAL PETITION Plaintiffs Guerin Woodgate and Anthony Guthrie, file this Plaintiffs’ Original Petition complaining of Defendants Fix Hold & Flip Construction, LLC, Alan Gabriel Antillon, Wiley Brothers General Contractors, Inc. and James E. Wiley, Jr., and for cause of action would show the Court the following: Discovery Control Plan 1. As provided in Rule 190, Texas Rules of Civil Procedure, Plaintiffs intend to conduct discovery under Level 2. Plaintiffs 2. Plaintiff, Guerin Woodgate, is an individual whose address is 1312 Travis Circle S. Irving, TX 75038. The last three digits of Plaintiff's driver's license number are 106. The last three digits of Plaintiff's Social Security number are 603. Plaintiff Woodgate may be served through his counsel of record, Joseph LaFleur, Winborne LaFleur PC, 216 W. Franklin St. Waxahachie, TX 75165. Plaintiffs’ Original Petition Page 1 3. Plaintiff, Anthony Guthrie, is an individual whose address is 1312 Travis Circle S. Irving, TX 75038. The last three digits of Plaintiff's driver's license number are 256. The last three digits of Plaintiff's Social Security number are 561. Plaintiff Guthrie may be served through his counsel of record, Joseph LaFleur, Winborne LaFleur PC, 216 W. Franklin St. Waxahachie, TX 75165. Defendants 4. Defendant, Fix Hold & Flip Construction, LLC, is a limited liability company. It can be served with process by serving Gabriel Antillon, its registered agent, by personal delivery at the registered office located at 2231 Madera Street, Dallas, Texas 75206. 5. This Court has jurisdiction over Fix Hold & Flip Construction, LLC because said Defendant is a resident of Texas. 6. Defendant, Alan Gabriel Antillon, a.k.a. Gabriel Antillon is an individual who may be served with process at Defendant's residence by personal delivery at 3039 Nowitzki Way #4002, Dallas, TX 75219. On information and belief, Gabriel Antillon is also known as Alan Gabriel Antillon. 7. This Court has jurisdiction over Alan Gabriel Antillon because said Defendant is a resident of Texas. 8. Defendant, James E. Wiley, Jr., is an individual who may be served with process at Defendant's place of business by personal delivery at 2803 Virgo Lane, Dallas, Texas 75229. Plaintiffs’ Original Petition Page 2 9. This Court has jurisdiction over James E. Wiley, Jr. because said Defendant is a resident of Texas. 10. Defendant, Wiley Brothers General Contractors, Inc. is a Texas Domestic Corporation and may be served through its registered agent, James E. Wiley at the office of its registered agent 9990 Monroe Dr. Dallas, TX 75220. 11. This Court has jurisdiction over Wiley Brothers General Contractors, Inc. because it is a Texas resident. Venue 12. Venue is proper in this county in that the events giving rise to this cause of action occurred within Dallas County. Jurisdiction 13. The damages sought in this suit are within the jurisdictional limits of the Court. As required by Rule 47, Texas Rules of Civil Procedure, Plaintiffs state that Plaintiffs seek monetary relief over $250,000 but not more than $1,000,000. Notice of Claim 14. Plaintiffs delivered written notice of this claim to Fix Hold & Flip Construction, LLC on February 8, 2024, advising Fix Hold & Flip Construction, LLC in reasonable detail of the specific complaint made the subject of this action and the amount and nature of the damages and expenses sought. 15. Plaintiffs delivered written notice of this claim to Alan Gabriel Antillon on February 8, 2024, advising Alan Gabriel Antillon in reasonable detail of the Plaintiffs’ Original Petition Page 3 specific complaint made the subject of this action and the amount and nature of the damages and expenses sought. The letter also warned Defendants Antillon and FHFC that Plaintiffs would sue under the Texas Deceptive Trade Practices Act. 16. Plaintiffs contacted Defendant, James E. Wiley, Jr. on March 11, 2024, demanding that property Defendant James E. Wiley possessed which belonged to plaintiffs be returned. Wiley refused to cooperate in the return of Plaintiffs’ property. Facts-As to Defendants FHFC and Antillon 17. On 10/11/2028, Guerin Woodgate, Anthony Guthrie, Fix Hold & Flip Construction, LLC (“FHFC”), and Gabriel Antillon, FHFC’s sole member and agent, agreed that FHFC would perform a comprehensive renovation of a rental home which included such items as replacing the roof, leveling the foundation, replacing the supply and sewer plumbing, replacing the electrical system, installing a new kitchen, installing new flooring, and many other cosmetic items to prepare the home for rent. The agreement is memorialized in an invoice prepared by FHFC’s principal and formed the basis of a contract. A copy of said agreement is marked P-1 and incorporated herein for all purposes. 18. The heart of the agreement was a detailed document which detailed the work to be done. The price set was $156,828.75. Plaintiffs paid $116,004.06 down with a balance of $40,824.69 to be paid as progress payments. Defendants proposed additional work to Plaintiffs and Plaintiffs agreed to some of the additional work, however, discussed below, Defendants fraudulently induced Plaintiffs to agree to Plaintiffs’ Original Petition Page 4 additional work to repair problems that Defendants themselves intentionally caused. 19. Defendants Fix Hold & Flip, LLC and Alan Gabriel Antillon, abandoned the work and failed to complete the work for which they were paid. This abandonment damaged the Plaintiffs who lost the benefit of the bargain and had to pay to repair damages intentionally caused by Plaintiffs. 20. Additionally, Antillon removed valuable building materials, including drywall, lighting, air conditioning units etc. from the rental property and stored them at 2970 Blystone Lane, #108, Dallas Texas. This address is an address for a building owned or leased by James Wiley and/or Wiley Brothers General Contractors, Inc. Despite requests from Plaintiff Woodgate to both Antillon and Wiley, Wiley refused to return the building materials and equipment from the Blystone Lane location to Plaintiffs. Discussed below, Wiley first said the building was empty and that Antillon had opportunity to remove the materials. Antillon stated he was locked out of the building. 21. Antillon and FHFC promoted themselves as “a Dallas Fort Worth Roofing, restauration & Construction company that has provided DFW with quality residential and commercial repairs and replacements since 2008.” See www.fixholdflip.com. According to the filings at the Texas Secretary of State’s office, the reality is that FHFC did not come into existence until 2020, and Antillon formed the LLC on May 7, 2020, while the Covid-19 pandemic ravaged the globe. Plaintiffs’ Original Petition Page 5 22. The website further warranted, “At Fix, Hold & Flip Construction, LLC, our mission is to serve our clients with the highest level of customer service through great communication, best materials in the industry, best installation & warranty available, and to build a relationship for many years to come.” Not only did Antillon lack experience and resources to provide the renovations Woodgate and Guthrie hired Antillon and FHFC to do in a good and workmanlike manner, but the Defendants also failed to provide the promised “best warranty available.” 23. The business reviews of FHFC are fake. 24. Instead of the “highly trained construction project managers” Defendants promised, Defendants used a twenty-something year old habitual drunkard, Adil Awwai, who had no training and no qualifications to manage a total home renovation. Having knowingly hired this habitual drunkard, Antillon, who knew about Awaii’s problems blamed Awaii for the failures at the project. 25. Despite numerous requests, Defendants either would not or could not provide a project plan to Woodgate and Guthrie, despite repeated requests for one. Instead of the promised work, Defendants delivered defect after defect. 26.Some of the defective work Defendants did included (1) installing improperly sized windows and attempting to conceal the improper sizing by using spray foam to fill in gaps; (2) brick masonry with bricks placed in uneven patterns and mismatched mortar lines; (8) installing a sliding glass door with no base, so to open and close it, required dragging it along the slab; (4) installing a new roof on top Plaintiffs’ Original Petition Page 6 of rotten decking and then using spray insulation to cover it up; (5) missing insulation in parts of the home; (5) improperly installing fencing; and (6) extensive damage to the garage door. 27. Additionally, in a blatant act of fraud, Defendant FHFC and Antillon pulled down portions of the brick veneer and exposed the interior sheetrock. After exposing the sheetrock, Defendants left it uncovered and the interior sheetrock, which otherwise was in good repair was destroyed, and Plaintiffs had to replace it unnecessarily. Defendants lied to Plaintiffs and stated that the brown coloring on the drywall meant it had to be replaced, when it was merely the color of the paper attached to the drywall in the 1970s. 28. Despite numerous promises to return the money to Plaintiffs, Antillon has returned none of the money. 29. Upon investigation, Antillon has a pattern of forming companies, defrauding, and stealing from consumers, and then allowing the companies to go into forfeiture. For an example of how Defendants Antillon and FHFC repeatedly defraud consumers, see generally DC-23-02531, currently pending in the 298th Judicial District Court, which is a case with remarkably similar facts. Facts-As to Defendants Jim Wiley / Wiley Brothers General Contractors, Inc. 30. Defendant Antillon stored valuable materials and equipment, including parts to the home’s HVAC system, that Plaintiffs own, and that Plaintiffs intended to use for the renovations at a warehouse owned by Jim Wiley and/or Wiley Plaintiffs’ Original Petition Page 7 Brothers General Contractors, Inc. at 2970 Blystone Lane, #108, Dallas, Dallas County, Texas. This is the address Antillon used as his business address, and it appears on the agreement. 31. Because Antillon’s spree of destruction abounds in the metroplex, Plaintiff Woodgate was able to communicate with another of Antillon’s victims and learned that Antillon was held in a warehouse owned by Jim Wiley and/or Wiley Brother’s Construction. Court records demonstrate that Antillon engages in this same pattern of behavior, and that Antillon habitually abuses the corporate structure for his own benefit and hides behind the shield of an LLC. 32. Plaintiff Woodgate contacted Jim Wiley about retrieving the materials and HVAC equipment from the Warehouse. At first Wiley stated that the warehouse was empty, the later admitted that he had not been to the warehouse in months. 33. On information and belief, Jim Wiley / Wiley Brothers General Contractors, Inc. unlawfully disposed of or utilized the property or is holding it unlawfully with the knowledge that the equipment belongs to Plaintiffs. Plaintiffs’ Original Petition Page 8 Conditions Precedent 34. Plaintiffs state that Guerin Woodgate and Anthony Guthrie have fully performed all obligations under the contract. 35. All conditions precedent to the performance by Defendants have been met. Breach of Contract 36. Fix Hold & Flip Construction, LLC ("FHFC") is a sham company formed for the purpose of committing fraud against unwitting customers for the benefit of its member, Alan Gabriel Antillon. Antillon used FHFC to lure Plaintiffs to pay him $116,004.06 as consideration for an extensive renovation project to occur at 2205 Avenue C in Grand Prairie, Texas. FHFC and Antillon completed only part of the paid for work, and the work that was done was defective, and a substantial portion had to be redone or must be redone. FHFC and Antillon failed to render the services they were paid to do and failed to perform home repairs in a good and workmanlike manner. Breach of Implied Warranty Of Good and Workmanlike Manner 37. Defendants Antillon and FHFC breached the implied warranty that the work would be performed in a good and workmanlike manner. Defendants used materials that were of the wrong size and for the wrong purposes such as wrong sized windows and spray foam as filler. Defendants installed new roofing materials over rotten wood and failed to professionally install the sliding doors among other issues. Plaintiffs’ Original Petition Page 9 Fraudulent Inducement / Common Law Fraud 88. Defendants Antillon and FHFC fraudulently induced Plaintiffs into entering into this agreement by falsifying facts in its marketing material such as the age of the company, the experience of the staff and the training of the staff. Additionally, prior to abandoning the job, Defendants lied to Plaintiffs about the necessity of replacing some materials. Defendants then purposefully damaged the home which would require Plaintiffs to spend more money to repair parts of the home that Defendants intentionally damaged. 39. The above-described statements and representations were material and were made knowing that they were false when made, or they were made recklessly without regard for their truth. 40. The above-described statements and representations were made with the intent that Plaintiffs rely on them, and Plaintiffs did rely on them when entering the contract. 41. Asa result of Defendants' fraud, Plaintiffs have been damaged, for which Plaintiffs request judgment. Restitution 42. Plaintiffs delivered valuable goods or services to Defendants which resulted in an unconscionable unjust enrichment to Defendants. Plaintiffs therefore ask for a judgment of restitution in equity against Defendants. Plaintiffs’ Original Petition Page 10 Negligent Hiring and Negligent Retention 43. The evidence will show that Antillon and FHFC knew about Awaii’s drinking habits and lack of experience. Antillon complained to Plaintiffs about Awaii but never terminated him nor hired anyone competent to complete the job as promised. Exemplary Damages 44, The conduct of Defendants as described above constituted fraud. 45. Defendants Antillon and FHFC have a pattern of defrauding others. 46. Given the knowledge Antillon had about Awaii, the negligent hiring and retention of Awaii constituted gross negligence. 47. Plaintiffs seek exemplary damages as provided in Section 41.003, Texas Civil Practice and Remedies Code, for which Plaintiffs request judgment. Declaratory Judgment 48. Plaintiffs seek declaratory judgment that there was a contract between Plaintiffs and Defendants Antillon and / FHFC and that the attached P-1 provides evidence of the terms and conditions of the contract. Unjust Enrichment 49. Should the Court find that there was no written contract between Plaintiffs and Defendants Antillon and FHFC, Plaintiffs ask for a judgment for the unjust enrichment from which Defendants benefitted by the payments from Plaintiffs. Plaintiffs’ Original Petition Page 11 50. As to Defendants Jim Wiley and Wiley Brother’s Construction, Plaintiffs seek the value of the materials and equipment the Wiley defendants either used in their own business or disposed of unlawfully. Damages 51. Plaintiffs seek damages for paid for but incomplete work, consequential damages, attorney’s fees, loss of benefit of the bargain, reliance damages and all other damages which the evidence may support. Economic Damages 52. Asa result of Defendants’ conduct, Plaintiffs suffered economic damages as defined in Section 41.001, Texas Civil Practice and Remedies Code, for which Plaintiffs request judgment. Attorney's Fees and Costs 53. Plaintiffs request judgment for reasonable attorney’s fees and costs under Sections 37.009 and Chapter 38, Texas Civil Practice and Remedies Code. Conversion 54. Plaintiffs sue Defendants Jim Wiley / Wiley Brothers General Contractors, Inc. for conversion. Defendants are either wrongfully retaining materials and equipment they know belong to Plaintiffs or they utilized the materials in their own business. 55. Plaintiffs sue Defendants Alan Gabriel Antillon and FHFC for conversion of their property. Plaintiffs’ Original Petition Page 12 Alternative Pleadings 56. As provided in Rule 48, Texas Rules of Civil Procedure, claims for relief made in this petition are presented in the alternative when necessary to preserve such claim. Required Initial Disclosures 57. As provided in Rule 194, Texas Rules of Civil Procedure, required Initial Disclosures of all items listed in Rule 194.2 must be made at or within 30 days after the filing of the first answer unless a different time is set by the parties’ agreement or court order. 58. Plaintiffs ask the Court to keep the requirement of Initial Disclosures to be made within 30 days. Writ of Sequestration 59. Plaintiffs will seek a writ of sequestration for all of the materials and equipment taken from Plaintiffs by Antillon and stored at the facility controlled/owned by the Wiley defendants. Plaintiffs’ Original Petition Page 13 Prayer Plaintiffs pray that citation be issued commanding Defendants to appear and answer herein and that Plaintiffs be awarded judgment against Defendants, jointly and severally, for the relief requested herein and for all other relief to which Plaintiffs are entitled both in equity and at law. Respectfully submitted, /s/ Joseph LaFleur Joseph LaFleur Bar No: 24103410 WINBORNE LAFLEUR PC 216 W. Franklin Street Waxahachie, Texas 75165 Attorney Plaintiffs Office Phone: (972) 330-2171 Email: JUAFLEUR@WINLAF.COM Plaintiffs’ Original Petition Page 14 * INVOICE P-1 gabriel@fixholdflip.com Fix Hold & Flip Construction LLC 2970 Blystone Lane, 108 +1 (214) 892-1910 FIX HOLD Dallas, TX 75220 https://www.fixholdflip.com & FLIP Guerin Woodgate Jr Bill to Ship to Guerin Woodgate Jr Guerin Woodgate Jr 2205 Aveenue C 205 Aveenue C Grand Prairie, Tx 75051 USA. Grand Prairie, Tx 75051 USA Invoice details Invoice no.: 1049 Terms: Net 30 Invoice date: 10/11/2023 Due date: 11/10/2023 Qty Rate Amount Product or service $16,870.00 $16,870.00 Foundation Professionally repair foundation of property. Includes adjusting 11 exterior piers. If piers need to be driven down aaditional cost will be at $100 per pier. If a new pier is required it wil be at a cost of $300 per pier. Professionally install 11 new piers outside of home. at a cost of $400 per pier. Professionally install 12 piers inside the home, if additional piers are needed, it will be Includes permits, engineering report, and lifetime warranty. Concrete $4,900.00 $4,900.00 forms and rebar. Concrete pad will be Professionally excavate area for new 12x20 concrete pad. Include properly setting up doweled into home foundation. Brush finish. Includes all materials and labor. $4,200.00 $4,200.00 Mud Pumping 1 foundation. This will be done after Professionally pump 10 yards below foundation to eliminate hollow areas underneath tunneling to best seal off cavities. Includes all materials and labor. $5,950.00 $5,950.00 Mortar and brick repair Safe removal and haul off of damaged brick on right side of wall were .brick was not properly braced with framing. Professionally lay new brick along wall where previous brick was removed. Includes sanding, mortar along seams. Includes ali materials and labor. $12,560.00 $12,560.00 HVAC Professionally install new 2.5 ton Carrier system with heat pump in new area to the right of home behind electrical panel. New and smart thermostat. unit will be placed on new concrete pad for unit. Includes disconnect, new ductwork, vent covers Includes all materials and labor. $9,100.00 $9,100.00 Exterior Roofing Remove and repiace existing roofing. Remove and replace rotten decking on roof line. Remove and replace all ventilation and jack pipe flashing — IS Instail new synthetic felt. Insta! ice and water shield. Install starterstrip. Install new 30 year shingies in black. Install ridge cap. Includes all materials and labor. Material and labor inciuded Flooring $4,923.00 $4,923.00 Professionally install approximately 1,094 sqft of hybrid resilient flooring and moisture barrier throughout property. Furnace in closet will be removed with floor to be level with the rest of home. Furnace closet will include shelving, Labor only. Flooring $6,560.00 $6,560.00 Materials cost for 1,094 sqftof flooring and underlayment/moisture barrier. Includes materiais cost for shelving. Includes the cost of materials after tax. htips://www.liflooring.com/p/duravana-7mm-and-pad-foggy-bottom-oak-waterproo-hyb rid-resilient-flooring-7.56-in.-wide-x- 50.63-in.-long-10052741 .html https://www.liflooring.com/p/underlayment%C2%A0--quietwalk-versa-1 00sft-10056873.htm! Toilet installation $248.75 $248.75 Professionally install new toilet and existing toilet previously removed for both bathrooms. Includes toilet flange replacement, new flapper, and new wax ring. Silicone will be properly applied under toilet. Water and leak test will be conducted after installation to ensure proper flow. Labor only. 10. Toilet $475.00 $475.00 Materials cost for toilet installation including new toilet, flappers, wax rings, silicone, and flanges for both bathrooms. incudes proper associated plumbing work. This is price of materials after tax. Ww Shower Wall Tile $2,073.00 $2,073.00 Professionally install shower wall tile (Includes thin-set and grout). Approximately 176 sqft in area. Includes shampoo nook Includes Labor Only, 12. Shower Wall Tile $650.00 $650.00 Materials cost for installing shower wall tile for both bathrooms. This is the cost of materials after tax. https://www.secondsandsurplus.comvflooring/floor tile/harbor-gray-porcelain-tie-12-x-24 https://www.flooranddecor.com/schluter-installation-materials/schluter-jolly-ed ge-1 -2in.-matte-black-101009314.html https://www.flooranddecor.com/tile-grout-installation-materials/mapei-kerapoxy-cq-M 1070. htm!?dwvar_M1070_color=Black 13. Bathtub $1,333.00 $1,333.00 Professionally install bathtubs and curtain rods in both bathrooms of property. Incucies proper associated plumbing work. Labor only 44. Bathtub $505.00 $505.00 Materials cost for both bathtubs in restrooms. This is the cost of materials after tax. https://www.homed epot.com/p/Bootz-Industries-Aloha-60-in-x-30-in-Soaking-Bathtub -with-Left-Drain-in-White-01 1-3365- 00/314614191 https://www.homedepot.com/p/Bootz-Industries-Aloha-60-in-x-30-in-Soaking-Bathtub -with-Right-Drain-in-White-01 -3 64- 00/314614199 https://www.amazon.com/Tension-Drilling-Anti-Slip-Waterproof-Bathroom/dp/BOC8NGJSPK/ref=sr_1_3_sspa? keywords=curved %2Bshower% 2Bcurtain%2Brod % 2B60in&qid= 169457 1938&sr=8-3- spons&sp_csd=d2IkZ2VOTmFtZT1zcF9hdGy&th= 15. Bathroom Vanity $270.00 $270.00 Professionally install new vanities in both bathrooms of the property. Includes installation of mirrors in both bathrooms. Labor only. 16. Bathroom Vanity $433.00 $433.00 Materials cost to install 2 new vanities and bathroom mirrors. This is the price of materials after tax. https://www.secondsandsurplus.convhome-decor/white-framed |-mirror-24-x-30-30-23105 Bathroom Hardware set $1,283.00 $1,283.00 17. Professionally install new shower/tub faucet combo set, sink faucet, and hardware for both bathrooms. Labor only. Bathroom Hardware set $860.00 $860.00 18. Materials cost for shower/tub faucet combo, sink faucet, and hardware set for both bathrooms. This is the cost of materials after tax. https://www.boelon.com/products/boelon-shower-system-with-four-functions https://www.amazon.conv1 4-Pieces-Bathroom-Accessories-Stainless-Hardware/dp/BOBLT47G9B/ref=sr_1_5? rid=2JOP7FLDTRTJC&keywords=black%2Bbathroom%2Baccessories %2Bset&qid=1 694622748&sprefix=black%2Bbath %2Caps%2C205&sr=8-5&th=1 https //www.amazon. com/SHACO-Matte-Biack-Bathroom-Faucet/dp/BOC2VK9ZVZ/ref=sr_1_14_sspa? crid=1DWSSFCAPCEFY&keyword: Jack +sink+faucet+bathroom+3+ hole&qid=1694622858&sprefix=black+sink+faucet+b athroom+3+%2Caps%2C4598sr= 14-spons&sp_csd=d2|kZ2VOTmFIZT 1zcF9tdGY &psc=1 19. Insulation $2,167.00 $2,167.00 Professionally install R-19 insulation on all exterior walls throughout property and install R-30 insulation in attic. Labor only, 20. insulation $6,906.00 $6,906.00 Materials cost for wall and aitic insulation. This is the cost of materials after tax. 21 Rough Plumbing $4,000.00 $4,000.00 Professionally change out previous rough plumbing of property and install new pve/pex plumbing system. Includes all new vaives, fittings. piping runs, and new electrical tankiess water heater. includes ali materials and labor. Includes all materials and labor. https://www.homedepot.com/p/Rheem-Performance-27-kw-Self-Modulating-5-27-GPM-Tankless-Electric-Water-Heater- RETEX-27/300800755 22 Kitchen Cabinets $4,071.00 $4,071.00 Professionally mount and install new kitchen cabinetry in kitchen. Includes installation of butcher block countertops which will be sealed and finished. Includes painting of kitchen cabinetry. New standard sink and garbage disposal will be installed with proper plumbing connections. Includes all materials and labor. https://homeoutlet.comm/preduct/unfinished-oak-cabinets hittps://homeoutlet.com/product/acacia-butcher-block-countertop -25-x-122-hk https://www.boelon.com/products/boelon-kitchen-faucet-with-waterfall-design https://www.homedepot.com/p/inSink Erator-Badger-100-1-3-HP-Continuous-Feed-Kitchen-Garbage-Disposal-Standard- Series-BADGER-100/321511603 https://www.amazon.com/Westablize-12-Knurled-Aluminum-Charcuterie/dp/BOBY4VZ327/ref=sr_1_357 crid=1EIKZ7XQHSBO1 &keywords=cabinet%2Bpulls %2Bcontemporary&aid: 1694741986&sprefix=cabinet% 2Bpulis%2Bc ontemporary%2Caps%2C1 10&sr=8-368th=1 23. Kitchen Backsplash $700.00 $700.00 Professionally install kitchen backsplash throughout kitchen, Labor only. 24, Kitchen Backsplash $300.00 $300.00 Materials cost for kitchen backsplash. This is the cost of materials after tax https://www.flooranddecor.com/shower-decoratives/ocean-honed -marble-tile-100246016.htm! https://www.flooranddecor.com/schluter-ins talation-materials/schiuter -jolly-edge-1-2in.-matte-black-101009314.himt https://www.flooranddecor.com/tile-grout-instaliation-materials/mapei-kerapoxy-cq-M1070.him!?dwvar_M1070_color=Black 25. Drywall, Texture, and Paint $11,469.00 $11,469.00 Professionally hang new gypsum board throughout walls and ceilings in home. Includes tape and bed. Once drywall has been installed, orange peeV/knockdown texture will be applied on ali newly installed drywall. Includes prime and paint. Walls to be agreeable grey in satin finish. Ceiling will be flat in white, Labor onty. 26. Drywall, Texture, and Paint $5,515.00 $5,515.00 Materials cost for drywail, texture, paint throughout property. This the price of materials after tax. Trim Installation $2,103.00 $2,103.00 27 Professionally install approximately 350 lin ft of baseboard and door trim throughout home. labor only. 28. Trim $1,184.00 $1,184.00 Materials cost for block-style baseboard and door trim. This is the price of materials after tax. 29. Interior Painting $809.50 $809.50 Prep, seal, caulk all areas to prepare for painting. Professionally paint all baseboards, door trim, and window sills. Labor only. 30. Interior Painting $224.50 $224.50 Materials cost painting baseboards, window sills, and door trim. This is the cost of materials after tax. 31 Rough Electrical $3,200.00 $3,200.00 Professionally instal! new updated electrical service panel, meter base, and disconnect to update electrical. Includes all materials and labor. 32. Amazon Exterior lights $114.50 $114.50 Professionally install 2 exterior light fixtures, one located in front and one in back. Labor only. 33 Amazon Exterior lights $70.00 $70.00 Materials cost for 2 exterior light fixtures. This is the cost of materials after tax. htips://www.amazon.con/BIRITALO-Fixture-Waterproof-Aluminum-Outdoor/dp/BOB2ZKNS2T/ref=sr_1_42?7 crid=3VOMB2EEXENQB&key words=exterior% 2Biight%2Bfixtures&qid= 1695077542&sprefix= exterior %2B light 2B fixtures %2Caps%2C2658sr=8-428th= 34. Recessed Lights $3,284.50 $3,284.50 Professionally install 19 recessed ceiling lights. Includes proper wiring. Labor only. Recessed Lights $165.00 $165.00 Materials cost for installing 19 new recessed lights throughout property. This is the costof materials after tax. https://www.amazon.com/Amico-Ultra-Thin-Selectable-Brightness-Downlight/dp/BO9RZLZN71/ref=sr_1_8? crid=38PODRABHN1638key words=6in%2Bled %2Brecessed % 2Blight% 2B 20% 2B pack&qid=1694628409&sprefix=6in%2 Bled%2Brecessed % 2Blight%2B20% 2Bpck%2Caps %2C1 12&s1=8-88th=1 36. Ceiling Fan $1,329.00 $1,329.00 Professionally install new ceiling fan. Includes proper mounting to brackets, connecting power to electrical, fitment of trim plates, and ensuing fan and its remote are functioning properly. Labor only. 37 Ceiling Fan $400.00 $400.00 Materials cost for 4 ceiling fans. This is the cost of ceiling fans after tax. https://Awww.amazon.com/Honeywell-Barcadero-Contemporary-Mounting-Reversible/dp/BO8LQW893H/ref=sr_1_41? crid=28CPIY2I276Z7&key words=modern% 2B black % 2B ceiling % 2B fan&gid= 16947395 1 4&sprefix=modern% 2Bblack%2Bc eiling%2Bfan%2Caps %2C 138&sr=8-41 &th= 38. Electrical Outlet{s) $4,404.50 $4,404.50 Professionally install 23 electrical outlets throughout property including 4 GFCI outlets for wet areas. Includes new wiring. Labor only. $85.00 39 Electrical Outiet(s) $85.00 Materials cost for electrical outiets. This is the cost of materials after tax. GHB8X/ref=sr_ 1_2_sspa? https://www.amazon .com/ELEGRP-Decorator-Electrical-Receptacle-Sef-Grounding/dp/BOBEF crid=39F42IPMU2Q1 R&keywords=o 2Bpack&qid=1 694557757&sprefix=outiets %2B20%2Bpack%2Caps% %2B20%utlets 2C02548s1=8-2-spons&sp_csd=C2IkZ2VOTMFIZT1zcF9hdGY&th=1 _5? https://www.amazon.com/Indicator-Tamper-Resistant-Weather-Resistant- Receptacie/dp/BOBNSK7XTY/ref=st_1 outlets +4% 2Caps fci+ %2C1498s1=8- crid=118SRZWB412CS&keywords=gfci+outlets+4+pack&qid=1 694557657 &sprefix=g 5 40. Switch Installation $3,809.00 $3,809.00 are to be Professionally install 17 new light switches with new wiring. Additional 6 fight switches which will be installed which dimmer switches. Labor only. Switch Installation $115.00 $115.00 4t Materials cost for new paddle-styie switches throughout property. This is the cost of materials after tax https://www.amazon.com/ELEGRP-Digital-Dimmab'e-Incandescent-Inciuded/dp/BOS9RJ2HRN‘ref: oe - spa? %2Bswit %2B paddle crid= 16NBWST7K9W7D&keywords=light chesd= 1694566541 &sprefi %2Bdimmer&qi ight%2Bswitch %2Bpaddie% 2Bdimmer%2Caps %2C 1608st=8-1 -spons&sp_csd=d2ikZ2VOTMFIZT 1zcF9hdGY&th=1 https://www.amazon.com/20-Pack-ELECTECK-Included-Certified/dp/BO9T6WNLHO/ret=sr_1_7? crid=15XIS HENBW words=light%2Bs 2B paddle %2B20% ey witches % YLA&k 2Bpack&qid=1 6945673438sprefix=light%2Bswi tches %2Bpaddle%2B20%2Bpack%2Caps %2C2338sr=8-7 &th=1 42. Vanity Light(s) $487.00 $487.00 Professionally install vanity lights in both bathrooms of property. Includes associated wiring. Labor only. 43. Vanity Light(s) $135.00 $135.00 Materials cost for vanity lights in both bathrooms. This is the cost of materiais after tax. https://www.amazon. com/SOLFART-Rotatable-Fixtures-Aluminum-Bathroon/dp/B0881NVNLD/ref=sr_1_1_sspa? crid=2EVTYMJ3BW3D7&keywords=vanity %2Blights %2Bsolfart&qid=1 694568808&sprefix=vanity %2Blights %2Bsolfart%2 Caps%2C1488sr=8-1 -spons&sp_csd=d2ikZ2VOTMFIZT 1zcF9hdGY&th=1 44, Exhaust Fan $716.00 $716.00 Professionaily install exhaust fans in bathrooms. Includes proper ductwork to be able to vent out to out of home. New exhaust fans will use electrical connections and switches made during electrical work. Labor only. 45. Exhaust Fan $270.00 $270.00 Materials cost for exhaust fan/light combo for both bathrooms. This is the cost of materials after tax. https://www,.amazon,com/Homewerks-Worldwide-7 141-1 10-Integrated-Ventilation/dp/BO7X6W4N37/ref=sr_1_35? crid=3BA9EE1GLAYCG&keywords=exhaust%2Blight%2Bcomboaqid=1 684877629&sprefix=exha ust% 2Blight% 2Bcomb%2 Caps%2C262&sr=8-35&th=1 1 $2,698.00 $2,698.00