Motion for Judgment on the Pleadings in Vertical Intergration Consulting, LLC and Randall Stanley vs. Jason Ledbetter, Nicole Ledbetter, My Med Spa, LLC, Try Wellness Group, LLC, W.P. Offices, LP, and Richard Rehman, John Blanchard, and Medical Device Alliance| Trellis.Law

On June 29, 2021 a Complaint,Petition was filed involving a dispute between Stanley, Randall, Stanley, Randall Wayne, Vertical Intergration Consulting, Llc, and Blanchard, John, Ledbetter, Jason, Ledbetter, Nicole, Medical Device Alliance, My Med Spa, Llc, Rehman, Richard, Try Wellness Group, Llc, W.P. Offices, Lp, for All Other Civil Cases in the District Court of Collin County.

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Filed: 10/23/2023 6:02 PM
Michael Gould
District Clerk
Collin County, Texas
By Kathy Richardson Deputy
Envelope ID: 80887333
NO. 471-03452-2021

VERTICAL INTERGRATION § IN THE DISTRICT COURT
CONSULTING, LLC, AND RANDALL §
STANLEY, §
§
Plaintiffs, §
v. § 471ST JUDICIAL DISTRICT
§
MY MED SPA, LLC, TRY WELLNESS §
GROUP, LLC, W.P. OFFICES, LP, AND §
RICHARD REHMAN, JOHN §
BLANCHARD, AND MEDICAL §
DEVICE ALLIANCE, §
Defendants. § COLLIN COUNTY, TEXAS

PLAINTIFFS’ FIRST SUPPLEMENTAL PLEADING
TO PLAINTIFFS’ ORIGINAL PETITION

TO THE HONORABLE COURT

Vertical Integration Consulting, LLC and Randall Stanley, Plaintiffs in the above styled

and numbered cause, files this FIRST SUPPLEMENTAL PLEADING TO PLAINTIFFS’

ORIGINAL PETITION, and would show this Court the following:

I.
SUPPLEMENTAL PLEADING

1. This pleading is in supplement to the parties live pleading. It is NOT an amendment, and

it does NOT supplant the current live pleading. This pleading is in addition to the live pleading

already on file.

II.
FACTUAL BACKGROUND

2. Plaintiffs entered into a written agreement with Defendant Nicole Ledbetter and/or

Defendant My Med Spa, LLC to lease out for their use certain medical spa equipment that was

defined as the Equipment in Plaintiffs’ Original Petition. Exhibit 1.

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3. The same contract between Plaintiffs and the contract’s specified defendant became the

subject of interference by the landlord W.P. Offices, L.P., and Mr. Richard Rehman when they

prevented Plaintiffs from inspecting and accessing the Equipment, removing the Equipment when

payment for leasing it was prevented.

IV.
CAUSES OF ACTION

4. Plaintiffs incorporate by reference and re-alleges in full all prior paragraphs herein.

A. TORTIOUS INTERFERENCE OF CONTRACT

5. Plaintiffs had a contract with Defendant Nicole Ledbetter and/or My Med Spa, LLC to

lease the Equipment made basis to this litigation.

6. Defendants WP Office and Rehman willfully and internally interfered with these contracts

by preventing Plaintiffs under threat of force and unlawful show of authority from both accessing

and retrieving Plaintiffs property from the possession of My Med Spa and Ms. Ledbetter.

7. Plaintiffs were damaged by WP Office and Rehman when they were deprived of the ability

to retrieve pieces of Equipment before it was stolen and sold wrongfully—and their conduct caused

significant delays before which Plaintiffs were able to finally retrieve their Equipment—thus the

delay of all the Equipment (that wasn’t sold off) caused a loss of the time upon which it could have

been leased to alternative persons.

8. WP Office and Rehman knew about the leasing of this Equipment and still willfully

interfered with its rights in and to the Equipment, and their conduct resulted in the damages

Plaintiffs suffered. And their conduct caused the additional breach by My Med Spa and/or Led

Better by stopping the return of the Equipment, which was their duty once payments for leasing

the Equipment failed.

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9. WP Offices and Rehman willfully and internally interfered with this prospective business

relationship by committing the additional torts of Conversion, Texas Theft Liability, and Tresspass

to Chattel when they prohibited (without legal cause to do so because My Med Spa and Ledbetter

did not own the Equipment) Plaintiffs from retrieving the Equipment because Plaintiffs had title

and greatest right to possession with the conscious desire (or acted to cause this result to occur

with knowledge that such outcome was) to specifically prevent Plaintiffs from obtaining

possession.

V.
CONDITIONS PRECEDENT

10. Plaintiff incorporates and re-alleges, by reference, all prior paragraphs herein.

11. All conditions precedent to file suit have been satisfied.

VI.
DAMAGES & ATTORNEY’S FEES

12. Plaintiff incorporate and re-allege, by reference, all prior paragraphs herein.

13. Plaintiffs were deprived of the benefit from leasing the Equipment during the period it was

kept from them for all pieces.

14. Plaintiffs were deprived of the lost value of the Equipment because of the deferred

maintenance (that didn’t occur) that must now occur because the Equipment was still being used—

wrongfully—during the period of unlaw retention.

15. Plaintiffs were deprived of the Equipment that has been unlawfully sold that they no longer

have.

16. Exemplary damages for malice/malicious conduct. See TEX. CIV. PRAC. & REM. CODE

ANN. § 41.003(a) (West 2017). Plaintiff is entitled to Exemplary Damages because Defendants

acted with malice, ill will, bad or evil motive, or with such gross indifference to or reckless

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disregard of the rights of others as amounts to willful or wanton act; or because Defendants

engaged in wrongful conduct that is intentional and without just cause or excuse, regardless of

whether there is additional evidence of ill will or an intent to injure. See Courtesy Pontiac, Inc. v.

Ragsdale, 532 S.W.2d 118, 121 (Tex. Civ. App.—Tyler 1975, writ ref’d n.r.e.).

17. Exemplary damages in excess of any statutory caps. See TEX. CIV. PRAC. & REM. CODE

ANN. § 41.008(c) (West 2017).

PRAYER

WHEREFORE, premises considered, Plaintiffs requests that this Court compel Defendant(s) to

answer and appear and GRANT Plaintiffs the following relief:

i. Judgment for actual and consequential damages within this Court’s jurisdictional limits;

ii. Post- and prejudgment interest to the maximum extent provided by law;

iii. Exemplary damages to the maximum extent provide by law; and

iv. Any other relief in law or equity to which the Plaintiff is entitled.

By: /s/ William Chu
William Chu
State Bar No. 04241000
wmchulaw@aol.com

THE LAW OFFICES OF WILLIAM CHU
4455 LBJ Freeway, Suite 1008
Dallas, Texas 75244
T: (972) 392-9888
F: (972) 392-9889
ATTORNEY FOR PLAINTIFFS

CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of this document has been
contemporaneously e-Served on all parties or their counsel of record with the e-Filing of this
document via efile.txcourts.gov and to their email addresses on file therein on 10/23/2023.

/s/ William Chu

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Lease Agreement 1
VerticiU Inlcryration, Ll.C., (hereafter rcferwt to as "LcssoO, is ;i 'I'CM(S I.iinitcd
Liability Company \\ho provides otTlcc I'urnitiirc, medical cquipmcnl, aiul tnscrs lor
lease. My Mcdspa, LLC,,, (hereaner rcrcrrccl to as "Lessee"), is ti 'I'CNas I.itnitcrinled Name (title)
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

William Chu
Bar No. 04241000
wmchulaw@aol.com
Envelope ID: 80887333
Filing Code Description: Supplemental
Filing Description:
Status as of 10/24/2023 10:30 AM CST

Associated Case Party: RandallWayneStanley