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Filing # 197924000 E-Filed 05/08/2024 05:23:05 PM
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY, FLORIDA
CENTERLINE DIRECTIONAL DRILLING, INC.,
Plaintiff,
V. Case No.: 312024CA000273AXXXVB
Florida Bar No.: 211303
GPRS UTILITY CONTRACTOR, LP,
Defendant.
/
COMPLAINT
Centerline Directional Drilling Service, Inc. (“Centerline”) sues Defendant GPRS Utility
Contractor, LP (“GPRS”) and alleges:
GENERAL ALLEGATIONS
1 This is an action for breach of contract, quantum meruit and unjust enrichment for
damages in an amount exceeding Fifty Thousand Dollars ($50,000.00), exclusive of interest, costs
and attorneys’ fees.
2 Centerline is a Florida corporation authorized to do business in the State of Florida.
3 GPRS is a Wyoming business entity registered as a foreign limited partnership in
the State of Georgia for whom Centerline performed certain labor, work and services relating to
the Vero Beach Connectivity Project (“hereinafter Project”) in Vero Beach, Indian River County,
Florida.
4 Venue is proper in this court pursuant to Chapter 47, Florida Statutes.
5 Centerline satisfactorily performed the work and furnished labor, work and services
necessary for the Project work and requested and directed and overseen by GPRS. All such work,
labor and services have been accepted by GPRS and incorporated into the Project. Amounts are
due to Centerline that remain unpaid by GPRS on the Project.
6. All conditions precedent and necessary to maintaining this action have occurred,
been satisfied, been performed and/or been waived by GPRS.
COUNTI
Breach of Contract
7
Centerline adopts, realleges and incorporates the allegations of paragraphs 1
through 6 above as though fully set forth herein.
8 Centerline entered into an oral contract (“Contract”) with GPRS for Centerline to
perform certain directional boring work for GPRS regarding the Project. In about 2023, Centerline
performed and completed the Project directional boring work for GPRS.
9. GPRS breached the Contract and its agreement with Centerline by, without
limitation, failing to properly and timely pay monies due and owing to Centerline for work
performed by Centerline regarding the Project. Centerline issued the attached invoices to GPRS
for the work performed totaling $568,350.00. A true and correct copy of the invoices are attached
hereto and made a part hereof by reference as Exhibit “A”. GPRS acknowledged that the invoices
were correct but only paid to Underline the amount of $45,800.00 and still owes an obligation to
pay Centerline the remaining amount due of $522,550.00.
10. As a direct result of the aforesaid GPRS breach, Centerline suffered damages due
to nonpayment for the Contract and Project work.
11. Although demand has been made and is made again herein, GPRS failed and
refused to pay the full amounts owed to Centerline. As a direct and proximate result, Centerline
has been damaged.
WHEREFORE, Centerline demands judgment for damages against GPRS in the amount
of $522,550.00, together with costs and interest, and such other and further relief as the Court
deems just and proper.
COUNT II
Quantum Meruit
12. Centerline adopts, realleges and incorporates the allegations of paragraphs 1
through 6 above as though fully set forth herein.
13. Centerline at the request of GPRS provided work and services for the construction
related to the Project in the form of labor, work and services. GPRS assented to and received the
labor, work and services provided by Centerline for the Project.
14. Centerline conferred a benefit upon GPRS by performing the work and labor and
services under circumstances where, in the ordinary course of common affairs, a reasonable person
receiving such a benefit normally would expect to pay for it. Centerline expected to be paid for
the labor, services and work provided by it to GPRS, and GPRS was aware of such expectation.
15. GPRS voluntarily accepted and retained the benefit of Centerline’s labor, work
services but has failed and refused to pay Centerline the value thereof.
16. Should Centerline be unable to recover in an action at law in Count I of the
Complaint, then Centerline is left without an adequate remedy at law.
WHEREFORE, Centerline demands judgment against GPRS for the value of the labor,
work and services supplied by Centerline for the Project, together with interest and costs incurred,
as well as such other and further relief as the Court deems just and proper.
COUNT Il
Unjust Enrichment
17. Centerline adopts, realleges and incorporates the allegations of paragraphs 1
through 6 above as though fully set forth herein.
18. At the request of GPRS, and for GPRS’s use and benefit, Centerline provided
labor, work and services to GPRS for the construction relating to the Project. GPRS knowingly
and voluntarily accepted Centerline’s labor, work and services.
19. The value of all the labor, work and services furnished to GPRS by Centerline has
not been paid by GPRS. Despite demands for payment which demand is made again herein, GPRS
has failed and refused to compensate Centerline for the labor, work and services provided.
20. It would be inequitable for GPRS to retain the benefit of the labor, work and
services provided by Centerline without GPRS paying for the value of the benefit conferred.
21. Should Centerline be unable to recover in an action at law on Count I above, then
Centerline is left without an adequate remedy at law.
WHEREFORE, Centerline demands judgment against GPRS for the reasonable value of
the benefits supplied by Centerline to the Project, together with interest and costs incurred, as well
as such other and further reliefas the Court deems just and proper.
Date: May 8, 2024. Respectfully submitted,
4s/ Joseph W. Lawrence, IT
Joseph W. Lawrence, II
Florida Bar No. 211303
VLP Copenhaver Espino
350 East Las Olas Blvd., Suite 1130
Fort Lauderdale, FL 33301
Telephone: (954) 728-1270
Facsimile: (954) 728-1271
jlawrence@vIplaw.com (Primary)
alvarado@vlplaw.com (Secondary)
Attorneys for Plaintiff
Exhibit “A”
beCENTERLINE
Directional Drilling Service, Inc. Date
Invoice
Invoice #
12/19/2023 GPR-001
P.O. Box 2705 LaBelle, FL 33975
Office: 863-674-0913 Fax: 863-674-0912
Bill To
GPRS, LLC
4281 Roush Rd
Hillsboro, Ohio 45133
P.O. No. Terms Project
Due on receipt Vero Beach Connect
Quantity Description Rate Amount
458 | Ft. 2-2" Directional Bore, HDPE 100.00 45,800.00
Job on: State Road 510
Project: Vero Beach Connectivity
Vero Beach, FL
Happy Holidays ! ! !
Payments are only accepted via check. Please note we will never take payment Total $45,800.00
over the phone or via e-mail.
BeCENTERLINE
Directional Drilling Service, Inc. Date
Invoice
Invoice #
12/19/2023 GPR-001B
P.O. Box 2705 LaBelle, FL 33975
Office: 863-674-0913 Fax: 863-674-0912
Bill To
GPRS, LLC
4281 Roush Rd
Hillsboro, Ohio 45133
P.O. No. Terms Project
Due on receipt Vero Beach Connect
Quantity Description Rate Amount
698 | Ft. 2-2" Directional Bore, HDPE 100.00 69,800.00
Job on: State Road 510
Project: Vero Beach Connectivity
Vero Beach, FL
Thank you for your business.
Payments are only accepted via check. Please note we will never take payment Total $69,800.00
over the phone or via e-mail.
beCENTERLINE
Directional Drilling Service, Inc. Date
Invoice
Invoice #
P.O. Box 2705 LaBelle, FL 33975 12/19/2023 GPR-001C
Office: 863-674-0913 Fax: 863-674-0912
Bill To
GPRS, LLC
4281 Roush Rd
Hillsboro, Ohio 45133
P.O. No. Terms Project
Due on receipt Vero Beach Connect.
Quantity Description Rate Amount
1,688 | Ft. 1-4" Directional Bore, Steel Pipe 125.00 211,000.00
Job on: State Road 510
Project: Vero Beach Connectivity
Vero Beach, FL
Thank you for your business.
Payments are only accepted via check. Please note we will never take payment Total $211,000.00
over the phone or via e-mail.
beCENTERLINE
Directional Drilling Service, Inc.
Invoice
Date Invoice #
P.O. Box 2705 LaBelle, FL 33975 12/19/2023 GPR-001D
Office: 863-674-0913 Fax: 863-674-0912
Bill To
GPRS, LLC
4281 Roush Rd
Hillsboro, Ohio 45133
P.O. No. Terms Project
Due on receipt Vero Beach Connect.
Quantity Description Rate Amount
1,934 | Ft. 1-4" Directional Bore, Steel Pipe 125.00 241,750.00
Job on: State Road 510
Project: Vero Beach Connectivity
Vero Beach, FL
Thank you for your business.
Payments are only accepted via check. Please note we will never take payment Total $241,750.00
over the phone or via e-mail.
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Filing # 197924000 E-Filed 05/08/2024 05:23:05 PM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY, FLORIDA CENTERLINE DIRECTIONAL DRILLING, INC., Plaintiff, V. Case No.: 312024CA000273AXXXVB Florida Bar No.: 211303 GPRS UTILITY CONTRACTOR, LP, Defendant. / COMPLAINT Centerline Directional Drilling Service, Inc. (“Centerline”) sues Defendant GPRS Utility Contractor, LP (“GPRS”) and alleges: GENERAL ALLEGATIONS 1 This is an action for breach of contract, quantum meruit and unjust enrichment for damages in an amount exceeding Fifty Thousand Dollars ($50,000.00), exclusive of interest, costs and attorneys’ fees. 2 Centerline is a Florida corporation authorized to do business in the State of Florida. 3 GPRS is a Wyoming business entity registered as a foreign limited partnership in the State of Georgia for whom Centerline performed certain labor, work and services relating to the Vero Beach Connectivity Project (“hereinafter Project”) in Vero Beach, Indian River County, Florida. 4 Venue is proper in this court pursuant to Chapter 47, Florida Statutes. 5 Centerline satisfactorily performed the work and furnished labor, work and services necessary for the Project work and requested and directed and overseen by GPRS. All such work, labor and services have been accepted by GPRS and incorporated into the Project. Amounts are due to Centerline that remain unpaid by GPRS on the Project. 6. All conditions precedent and necessary to maintaining this action have occurred, been satisfied, been performed and/or been waived by GPRS. COUNTI Breach of Contract 7 Centerline adopts, realleges and incorporates the allegations of paragraphs 1 through 6 above as though fully set forth herein. 8 Centerline entered into an oral contract (“Contract”) with GPRS for Centerline to perform certain directional boring work for GPRS regarding the Project. In about 2023, Centerline performed and completed the Project directional boring work for GPRS. 9. GPRS breached the Contract and its agreement with Centerline by, without limitation, failing to properly and timely pay monies due and owing to Centerline for work performed by Centerline regarding the Project. Centerline issued the attached invoices to GPRS for the work performed totaling $568,350.00. A true and correct copy of the invoices are attached hereto and made a part hereof by reference as Exhibit “A”. GPRS acknowledged that the invoices were correct but only paid to Underline the amount of $45,800.00 and still owes an obligation to pay Centerline the remaining amount due of $522,550.00. 10. As a direct result of the aforesaid GPRS breach, Centerline suffered damages due to nonpayment for the Contract and Project work. 11. Although demand has been made and is made again herein, GPRS failed and refused to pay the full amounts owed to Centerline. As a direct and proximate result, Centerline has been damaged. WHEREFORE, Centerline demands judgment for damages against GPRS in the amount of $522,550.00, together with costs and interest, and such other and further relief as the Court deems just and proper. COUNT II Quantum Meruit 12. Centerline adopts, realleges and incorporates the allegations of paragraphs 1 through 6 above as though fully set forth herein. 13. Centerline at the request of GPRS provided work and services for the construction related to the Project in the form of labor, work and services. GPRS assented to and received the labor, work and services provided by Centerline for the Project. 14. Centerline conferred a benefit upon GPRS by performing the work and labor and services under circumstances where, in the ordinary course of common affairs, a reasonable person receiving such a benefit normally would expect to pay for it. Centerline expected to be paid for the labor, services and work provided by it to GPRS, and GPRS was aware of such expectation. 15. GPRS voluntarily accepted and retained the benefit of Centerline’s labor, work services but has failed and refused to pay Centerline the value thereof. 16. Should Centerline be unable to recover in an action at law in Count I of the Complaint, then Centerline is left without an adequate remedy at law. WHEREFORE, Centerline demands judgment against GPRS for the value of the labor, work and services supplied by Centerline for the Project, together with interest and costs incurred, as well as such other and further relief as the Court deems just and proper. COUNT Il Unjust Enrichment 17. Centerline adopts, realleges and incorporates the allegations of paragraphs 1 through 6 above as though fully set forth herein. 18. At the request of GPRS, and for GPRS’s use and benefit, Centerline provided labor, work and services to GPRS for the construction relating to the Project. GPRS knowingly and voluntarily accepted Centerline’s labor, work and services. 19. The value of all the labor, work and services furnished to GPRS by Centerline has not been paid by GPRS. Despite demands for payment which demand is made again herein, GPRS has failed and refused to compensate Centerline for the labor, work and services provided. 20. It would be inequitable for GPRS to retain the benefit of the labor, work and services provided by Centerline without GPRS paying for the value of the benefit conferred. 21. Should Centerline be unable to recover in an action at law on Count I above, then Centerline is left without an adequate remedy at law. WHEREFORE, Centerline demands judgment against GPRS for the reasonable value of the benefits supplied by Centerline to the Project, together with interest and costs incurred, as well as such other and further reliefas the Court deems just and proper. Date: May 8, 2024. Respectfully submitted, 4s/ Joseph W. Lawrence, IT Joseph W. Lawrence, II Florida Bar No. 211303 VLP Copenhaver Espino 350 East Las Olas Blvd., Suite 1130 Fort Lauderdale, FL 33301 Telephone: (954) 728-1270 Facsimile: (954) 728-1271 jlawrence@vIplaw.com (Primary) alvarado@vlplaw.com (Secondary) Attorneys for Plaintiff Exhibit “A” beCENTERLINE Directional Drilling Service, Inc. Date Invoice Invoice # 12/19/2023 GPR-001 P.O. Box 2705 LaBelle, FL 33975 Office: 863-674-0913 Fax: 863-674-0912 Bill To GPRS, LLC 4281 Roush Rd Hillsboro, Ohio 45133 P.O. No. Terms Project Due on receipt Vero Beach Connect Quantity Description Rate Amount 458 | Ft. 2-2" Directional Bore, HDPE 100.00 45,800.00 Job on: State Road 510 Project: Vero Beach Connectivity Vero Beach, FL Happy Holidays ! ! ! Payments are only accepted via check. Please note we will never take payment Total $45,800.00 over the phone or via e-mail. BeCENTERLINE Directional Drilling Service, Inc. Date Invoice Invoice # 12/19/2023 GPR-001B P.O. Box 2705 LaBelle, FL 33975 Office: 863-674-0913 Fax: 863-674-0912 Bill To GPRS, LLC 4281 Roush Rd Hillsboro, Ohio 45133 P.O. No. Terms Project Due on receipt Vero Beach Connect Quantity Description Rate Amount 698 | Ft. 2-2" Directional Bore, HDPE 100.00 69,800.00 Job on: State Road 510 Project: Vero Beach Connectivity Vero Beach, FL Thank you for your business. Payments are only accepted via check. Please note we will never take payment Total $69,800.00 over the phone or via e-mail. beCENTERLINE Directional Drilling Service, Inc. Date Invoice Invoice # P.O. Box 2705 LaBelle, FL 33975 12/19/2023 GPR-001C Office: 863-674-0913 Fax: 863-674-0912 Bill To GPRS, LLC 4281 Roush Rd Hillsboro, Ohio 45133 P.O. No. Terms Project Due on receipt Vero Beach Connect. Quantity Description Rate Amount 1,688 | Ft. 1-4" Directional Bore, Steel Pipe 125.00 211,000.00 Job on: State Road 510 Project: Vero Beach Connectivity Vero Beach, FL Thank you for your business. Payments are only accepted via check. Please note we will never take payment Total $211,000.00 over the phone or via e-mail. beCENTERLINE Directional Drilling Service, Inc. Invoice Date Invoice # P.O. Box 2705 LaBelle, FL 33975 12/19/2023 GPR-001D Office: 863-674-0913 Fax: 863-674-0912 Bill To GPRS, LLC 4281 Roush Rd Hillsboro, Ohio 45133 P.O. No. Terms Project Due on receipt Vero Beach Connect. Quantity Description Rate Amount 1,934 | Ft. 1-4" Directional Bore, Steel Pipe 125.00 241,750.00 Job on: State Road 510 Project: Vero Beach Connectivity Vero Beach, FL Thank you for your business. Payments are only accepted via check. Please note we will never take payment Total $241,750.00 over the phone or via e-mail.