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CAUSE NO. GO
0,
Usaama Abdalmatiyn E-10% ICIAL
Plaintiff,
vs. DISTRICT COURT, DALLAS
Christopher Wells & UC Food Store
Defendants DALLAS COUNTY TEXAS
PLAINTIFF'S ORIGINAL COMPLAINT FOR DAMAGES
To the Honorable Judge of Said Court:
NOW COMES, Usaama Abdalmatiyn, the Plaintiff in the above and entitled
cause of action, and who presents this his Civil complaint for damages against the
defendant Christopher Wells for breach of contract, fraudulent misrepresentation,
defrauding Plaintiff of labor and pay, and emotional distress tort. Defendant UC Food
Store is libel as a registered L.L.C. In support thereof, the Plaintiff would respectfully
show this Court, the following facts:
(1) STATEMENT OF CLAIMS
1. Whether the defendant committed breach of business contract?
2. Whether the defendant committed fraudulent misrepresentation in order to
illegally gain from the Plaintiff through such fraudulent misrepresentation?
3. Whether the Defendant defrauded Plaintiff in order to avoid paying the Plaintiff for
labor?
4, Whether the defendant subjected the Plaintiff to emotional distress tort through
the defendant's fraudulent misrepresentation?
(I).
* STATEMENT OF FACTS
1. Plaintiff and defendant were close friends for approximately seventeen (17)
years, and often planned business ventures so as to pull themselves and their families
out of abject poverty;
2. Over the period of three and a half (3 1/2) years, Plaintiff had masked nearly
ten thousand ($10,000.00) dollars toward a business partnership with anyone that
would be/appear dedicated to the purpose;
3. In about October, 2023, Plaintiff was contacted by Defendant Christopher
Wells and informed that he (defendant) had received a large sum of money totaling
about one hundred fifty eight thousand ($158,000.00) dollars via a settlement from a
vehicle accident;
4. Defendant Wells and Plaintiff immediately began looking for locations to
start a convenient store as a business venture and as a partnership;
5. The first and foremost understanding was that the Plaintiff and defendant
would be business partners in the convenient and discuss the hiring and or firing of
any employees;
6. Almost immediately before "WE" had any contact with the owner, the
defendant offered the previous tenant of the store fifteen thousand ($15,000.00)
dollars for the building, which was wholly a scam and an unnecessary requirement.
2:
Ironically, the previous tenant learning that there was a business partner (Plaintiff) to
the business and hurriedly accepted only ten thousand ($10,000.00) dollars from the
defendant and remained aloft;
7. Plaintiff began cleaning up and working on the building daily until nightfall
and sometimes throughout the night, where the Plaintiff would stay overnight
working and sleeping in the store for as many as fifty (50) consecutive days while the
defendant was absent most of the time, left early and done very little work whenever
he was present; Evidence will established the Defendant was fired from at minimum
of eight (8) consecutive jobs for his laziness;
8, While the Plaintiff had the building under construction, the Defendant would
constantly want to go shopping for store's supplies such as snacks, food, and other
items for selling from the business; This premature shopping resulted in the vast
majority of the supplies facing expiration dates and mold; Defendant still sold off the
expired commissaries produce to the public;
9, Plaintiff built 1.) ALL shelves to stock supplies in the back of the store; to
stock bread in the kitchen cooler; on the customer flooring; and behind the counter;
2.) Plaintiff trapped and killed as many as forty (40) large rats, even into the attic of
the store; 3.) Painted the entire floor and placed paint flakes as a decorate; 4.)
Repaired major water leaks in the ceiling, hot water heater, kitchen and bathroom
leaks, including replacing pipes and fittings; 5.) Repaired electrical outages,
shortages, replaced breakers and wires as well as located the breakers to the electrical
outlets; 6.) took away trash daily; 7.) Set up cameras and led wires throughout the
attic; 8.) Set up the cash registers; 9.) cut down trees and brush from the back of the
building that were harming the structure; 10.) Set up utility bills and sought out
permits for the business; 11.) purchasing store supplies; 12.) purchased a bed and
recliner for the store for rest and overnight stays; 13.) tender to customers at the
3
ye
register; 14.) washing pots, pans and utensils as well as cleaning up the kitchen and
grill; 15.) cleaning up behind the defendant's children; 16.) Painted and repaired the
outside of the building front; 17.) towed a walk-in grill from location to location to
the front of the store; 18.) purchased and replaced the toilet and water lines;
10. Defendant Wells began allowing his family members and friends to have
cooking challenges, which resulted in wasting hundreds of dollars in meat, where
most of the cooking was horrific, resulting in throwing briskets, chicken, and pork
chops in the trash can; Plaintiff complained immediately and defendant ignored the
grievences from the Plaintiff;
11. Without discussion with the Plaintiff, the defendant began hiring several of
his family mbers and friends. They began stealing and wasting supplies until Plaintiff
constantly requested they be fired or had fired them; Defendant was full aware and
had actual knowledge that his (Defendant) family members were thieves and a
detriment to the business (UC Food Store); In addition, the Defendant had one family
member trying to start her own business within the store to make cakes and pies,
while NOT having _ business credentials for her business venture;
12. At some point, defendant purchased a firearm (9mm 22 shot automatic
with laser) that was bought under his friends’ (Steve) name, because the defendant is
on probation for domestic violence and is prohibited from possessing a firearm; On
two (2) occasions the Plaintiff personally witnessed one of the defendants’ fourteen
(14) month old twin girls pick up and drop the gun, whether Plaintiff vigorously
complained that the weapons should be removed from the premises, only to be
ignored by the defendant;
13. Defendants’ relative was seen carrying the same weapon outside of the
business and making threats. In addition, the same family member attempted to
4
attack a female for lude dancing near her (the relative) boyfriend without justification;
Defendants’ family members have an extensive recorded violent history, including the
removal of children due to such violence; several family members have died from
violence and the children are accustom to the violence presented by the adults;
» 14. Defendant and some of his family members and friends openly drink
alcohol and smoke marijuana on the business premises and in the presence and
vicinity of their children;
15. On or about March 8, 2024, an addict was having an episode from drugs
that resulted in the addict assaulting people randomly. When the addict came onto
the UC food store parking lot, Plaintiff instructed Defendant that if the addict was
bother no one, it is none of our business. Instead, the Defendant went after the addict
without any provocation and attacked and violently beat the addict in the presence of
everyone including his (Defendants') own children;
16. Defendant continued seeking out illegal gambling machines to place in the
store against the Plaintiffs’ advice, contending the illegal gambling would bring in
thousands of dollars a day;
17. Plaintiff constantly requested that the defendant pay the employees for
their labor. Defendant contends that he is NOT paying anyone a check until he
recoup the money he has spent on the store, given to his childrens’ mother, gave to
family and friends; utilized to purchase vehicles, store supplies, rent, etc., etc. Plaintiff
has constantly informed the defendant that his acts are illegal and criminal, again
defendant ignored the Plaintiff advice;
18. Defendant has a business account and a personal account with his bank, yet
defendant deposits the business earnings into his personal account. Plaintiff warned
the defendant that such actions are embezzlement and will lead to confinement, but
a
as previous warnings the defendant ignores them; Defendant directed the Plaintiff to
pay himself from the cash register, and Plaintiff refused the offer;
19. The defendant benefitted from the electricity from TXU, where the bill is in
the Plaintiff's name, but for the business. Defendant refuses to pay the electric bill for
one thousand fifty five dollars and twenty nine cents ($1,055.29) and has cancelled
the TXU services and opted for another provider. Defendant has been consistent in
ignoring the Plaintiffs’ warnings for his (Defendant) bad behavior and criminal
a
conduct;
20. Defendant is totally aware that the Plaintiff is on parole and cannot engage
in any type or forms of criminal activities, and defendant himself being on probation
is also required to abstain from any illegal and criminal activities. However, Defendant
Wells opts for illegal and criminal acts to advance himself, where he has defrauded
the Plaintiff to prepare the UC food store through misrepresention so as to gain the
Plaintiffs’ services without paying for such;
21. Defendant requested an invoice and a payment plan for his debt to the
Plaintiff, where Plaintiff went completely broke with his investments into the store
and NEVER being paid for several months of working at the store. Defendant forced
the Plaintiff into a position to borrow thousands of dollars to maintain bills, food, and
gas.
22. Defendant now claims that he had informed the Plaintiff that there was NO
partnership, and that the UC food store was a family business set up for his family
members, and that Plaintiff was entitled to NO finances and had only purchased a
toilet and some fasteners to fix things. Therefore, the offer from the Plaintiff is now
voided, and defendant should be required to pay Plaintiff full relief sought.
RELIEF SOUGHT
WHEREFORE PREMISES CONSIDERED, the Plaintiff seeks this Honorable Court
to issue an ORDER for the following relief that is fair, just and equitable in this case
against UC food store and Christopher Wells;
1. Actual Damages for unpaid labor in the amount of thirty two thousand two
hundred sixty ($32,260.00) dollars;
a
2. Breach of business contract in the amount of twenty five thousand
($25,000.00) dollars;
3. Fraudulent misrepresentation in the amount of fifty thousand ($50,000.00)
dollars;
4. Hostile work environment in the amount of one hundred thousand
($100,000.00) dollars;
5, Emotional distress tort damages in the amount of seven thousand
($7,000.00) dollars;
6. Punitive damages in the amount of thirty five thousand seven hundred forty
($35,740.00) dollars;
7. Injunctive relief ORDERING the complete closure of defendants’ business for
any and all criminal, illegal and unlawful acts that are apparent in and through said
business;
8. Any other relief and judgments that this Honorable Court deems fair, just
and necessary.
Respectfully submitted,
Usaneni Ldobmabgy
Usaama Abdalmatiyn
3201 Hamilton Avenue
#105
Dallas, Texas 75210
(214) 229-1661
ti ny eo gma (. com
useomanbdalwec
cc:usa/file
ee
Dallas coal Clerk
600 Commerce Street
May 2.2024
Dallas, Texas 75201
RE: Civil Action: Usaama Abdalmatiyn vs. UC Food Store & Christopher Wells
Dear Clerk:
Enclosed please find the Plaintiff's Original Complaint for damages for filing
within the appropriate civil court.
Thank you for your time and assistance in this matter.
Respectfully submitted,
Usoome Allele
Usaama Abdalmatiyn
3201 Hamilton Ave. #105
Dallas, Texas 75210
(214) 229-1661
Cause No.
District
Usaama Abdalmatiyn Dallas er Texas
Plaintiff,
Vs. Judicial District
Christopher Wells & UC Food Store
Defendants. puller coun
Sworn Affidavit of Facts
|, Usaama Abdalmatiyn verify that the forementioned Plaintiffs Suit for
damages is made truthfully and from personal knowledge regarding the facts therein,
where the Plaintiff makes the same and sign herein under the penalties of perjury
pursuant to the Texas Code of Civil Procedures on this 2) day of , 2024.
Usaama Abdalmatiyn
3201 Hamilton Ave. #105
Dallas, Texas 75210
(214) 229-1661
—- ——° —
ADDRESSES OF PARTIES INVOLVED
Usaama Abdalmatiyn Christopher Wells
PLAINTIFF DEFENDANT
3201 Hamilton Ave. #105 2301 Dathe Street
Dallas, Texas 75210 Dallas Texas 75210
Ph. # (214) 229-1661 Ph. # (469) 219-0583
UC Food Store
DEFENDANT
REGISTERED L.L.C.
1326 Martin Luther king Jr. Blvd.
Dallas, Texas 75210
Ph, # (214) 484-4842
Preview
Q 0x7, JC7#/ 0 BY.073/4 \ % %Yy UfNLS CAUSE NO. GO 0, Usaama Abdalmatiyn E-10% ICIAL Plaintiff, vs. DISTRICT COURT, DALLAS Christopher Wells & UC Food Store Defendants DALLAS COUNTY TEXAS PLAINTIFF'S ORIGINAL COMPLAINT FOR DAMAGES To the Honorable Judge of Said Court: NOW COMES, Usaama Abdalmatiyn, the Plaintiff in the above and entitled cause of action, and who presents this his Civil complaint for damages against the defendant Christopher Wells for breach of contract, fraudulent misrepresentation, defrauding Plaintiff of labor and pay, and emotional distress tort. Defendant UC Food Store is libel as a registered L.L.C. In support thereof, the Plaintiff would respectfully show this Court, the following facts: (1) STATEMENT OF CLAIMS 1. Whether the defendant committed breach of business contract? 2. Whether the defendant committed fraudulent misrepresentation in order to illegally gain from the Plaintiff through such fraudulent misrepresentation? 3. Whether the Defendant defrauded Plaintiff in order to avoid paying the Plaintiff for labor? 4, Whether the defendant subjected the Plaintiff to emotional distress tort through the defendant's fraudulent misrepresentation? (I). * STATEMENT OF FACTS 1. Plaintiff and defendant were close friends for approximately seventeen (17) years, and often planned business ventures so as to pull themselves and their families out of abject poverty; 2. Over the period of three and a half (3 1/2) years, Plaintiff had masked nearly ten thousand ($10,000.00) dollars toward a business partnership with anyone that would be/appear dedicated to the purpose; 3. In about October, 2023, Plaintiff was contacted by Defendant Christopher Wells and informed that he (defendant) had received a large sum of money totaling about one hundred fifty eight thousand ($158,000.00) dollars via a settlement from a vehicle accident; 4. Defendant Wells and Plaintiff immediately began looking for locations to start a convenient store as a business venture and as a partnership; 5. The first and foremost understanding was that the Plaintiff and defendant would be business partners in the convenient and discuss the hiring and or firing of any employees; 6. Almost immediately before "WE" had any contact with the owner, the defendant offered the previous tenant of the store fifteen thousand ($15,000.00) dollars for the building, which was wholly a scam and an unnecessary requirement. 2: Ironically, the previous tenant learning that there was a business partner (Plaintiff) to the business and hurriedly accepted only ten thousand ($10,000.00) dollars from the defendant and remained aloft; 7. Plaintiff began cleaning up and working on the building daily until nightfall and sometimes throughout the night, where the Plaintiff would stay overnight working and sleeping in the store for as many as fifty (50) consecutive days while the defendant was absent most of the time, left early and done very little work whenever he was present; Evidence will established the Defendant was fired from at minimum of eight (8) consecutive jobs for his laziness; 8, While the Plaintiff had the building under construction, the Defendant would constantly want to go shopping for store's supplies such as snacks, food, and other items for selling from the business; This premature shopping resulted in the vast majority of the supplies facing expiration dates and mold; Defendant still sold off the expired commissaries produce to the public; 9, Plaintiff built 1.) ALL shelves to stock supplies in the back of the store; to stock bread in the kitchen cooler; on the customer flooring; and behind the counter; 2.) Plaintiff trapped and killed as many as forty (40) large rats, even into the attic of the store; 3.) Painted the entire floor and placed paint flakes as a decorate; 4.) Repaired major water leaks in the ceiling, hot water heater, kitchen and bathroom leaks, including replacing pipes and fittings; 5.) Repaired electrical outages, shortages, replaced breakers and wires as well as located the breakers to the electrical outlets; 6.) took away trash daily; 7.) Set up cameras and led wires throughout the attic; 8.) Set up the cash registers; 9.) cut down trees and brush from the back of the building that were harming the structure; 10.) Set up utility bills and sought out permits for the business; 11.) purchasing store supplies; 12.) purchased a bed and recliner for the store for rest and overnight stays; 13.) tender to customers at the 3 ye register; 14.) washing pots, pans and utensils as well as cleaning up the kitchen and grill; 15.) cleaning up behind the defendant's children; 16.) Painted and repaired the outside of the building front; 17.) towed a walk-in grill from location to location to the front of the store; 18.) purchased and replaced the toilet and water lines; 10. Defendant Wells began allowing his family members and friends to have cooking challenges, which resulted in wasting hundreds of dollars in meat, where most of the cooking was horrific, resulting in throwing briskets, chicken, and pork chops in the trash can; Plaintiff complained immediately and defendant ignored the grievences from the Plaintiff; 11. Without discussion with the Plaintiff, the defendant began hiring several of his family mbers and friends. They began stealing and wasting supplies until Plaintiff constantly requested they be fired or had fired them; Defendant was full aware and had actual knowledge that his (Defendant) family members were thieves and a detriment to the business (UC Food Store); In addition, the Defendant had one family member trying to start her own business within the store to make cakes and pies, while NOT having _ business credentials for her business venture; 12. At some point, defendant purchased a firearm (9mm 22 shot automatic with laser) that was bought under his friends’ (Steve) name, because the defendant is on probation for domestic violence and is prohibited from possessing a firearm; On two (2) occasions the Plaintiff personally witnessed one of the defendants’ fourteen (14) month old twin girls pick up and drop the gun, whether Plaintiff vigorously complained that the weapons should be removed from the premises, only to be ignored by the defendant; 13. Defendants’ relative was seen carrying the same weapon outside of the business and making threats. In addition, the same family member attempted to 4 attack a female for lude dancing near her (the relative) boyfriend without justification; Defendants’ family members have an extensive recorded violent history, including the removal of children due to such violence; several family members have died from violence and the children are accustom to the violence presented by the adults; » 14. Defendant and some of his family members and friends openly drink alcohol and smoke marijuana on the business premises and in the presence and vicinity of their children; 15. On or about March 8, 2024, an addict was having an episode from drugs that resulted in the addict assaulting people randomly. When the addict came onto the UC food store parking lot, Plaintiff instructed Defendant that if the addict was bother no one, it is none of our business. Instead, the Defendant went after the addict without any provocation and attacked and violently beat the addict in the presence of everyone including his (Defendants') own children; 16. Defendant continued seeking out illegal gambling machines to place in the store against the Plaintiffs’ advice, contending the illegal gambling would bring in thousands of dollars a day; 17. Plaintiff constantly requested that the defendant pay the employees for their labor. Defendant contends that he is NOT paying anyone a check until he recoup the money he has spent on the store, given to his childrens’ mother, gave to family and friends; utilized to purchase vehicles, store supplies, rent, etc., etc. Plaintiff has constantly informed the defendant that his acts are illegal and criminal, again defendant ignored the Plaintiff advice; 18. Defendant has a business account and a personal account with his bank, yet defendant deposits the business earnings into his personal account. Plaintiff warned the defendant that such actions are embezzlement and will lead to confinement, but a as previous warnings the defendant ignores them; Defendant directed the Plaintiff to pay himself from the cash register, and Plaintiff refused the offer; 19. The defendant benefitted from the electricity from TXU, where the bill is in the Plaintiff's name, but for the business. Defendant refuses to pay the electric bill for one thousand fifty five dollars and twenty nine cents ($1,055.29) and has cancelled the TXU services and opted for another provider. Defendant has been consistent in ignoring the Plaintiffs’ warnings for his (Defendant) bad behavior and criminal a conduct; 20. Defendant is totally aware that the Plaintiff is on parole and cannot engage in any type or forms of criminal activities, and defendant himself being on probation is also required to abstain from any illegal and criminal activities. However, Defendant Wells opts for illegal and criminal acts to advance himself, where he has defrauded the Plaintiff to prepare the UC food store through misrepresention so as to gain the Plaintiffs’ services without paying for such; 21. Defendant requested an invoice and a payment plan for his debt to the Plaintiff, where Plaintiff went completely broke with his investments into the store and NEVER being paid for several months of working at the store. Defendant forced the Plaintiff into a position to borrow thousands of dollars to maintain bills, food, and gas. 22. Defendant now claims that he had informed the Plaintiff that there was NO partnership, and that the UC food store was a family business set up for his family members, and that Plaintiff was entitled to NO finances and had only purchased a toilet and some fasteners to fix things. Therefore, the offer from the Plaintiff is now voided, and defendant should be required to pay Plaintiff full relief sought. RELIEF SOUGHT WHEREFORE PREMISES CONSIDERED, the Plaintiff seeks this Honorable Court to issue an ORDER for the following relief that is fair, just and equitable in this case against UC food store and Christopher Wells; 1. Actual Damages for unpaid labor in the amount of thirty two thousand two hundred sixty ($32,260.00) dollars; a 2. Breach of business contract in the amount of twenty five thousand ($25,000.00) dollars; 3. Fraudulent misrepresentation in the amount of fifty thousand ($50,000.00) dollars; 4. Hostile work environment in the amount of one hundred thousand ($100,000.00) dollars; 5, Emotional distress tort damages in the amount of seven thousand ($7,000.00) dollars; 6. Punitive damages in the amount of thirty five thousand seven hundred forty ($35,740.00) dollars; 7. Injunctive relief ORDERING the complete closure of defendants’ business for any and all criminal, illegal and unlawful acts that are apparent in and through said business; 8. Any other relief and judgments that this Honorable Court deems fair, just and necessary. Respectfully submitted, Usaneni Ldobmabgy Usaama Abdalmatiyn 3201 Hamilton Avenue #105 Dallas, Texas 75210 (214) 229-1661 ti ny eo gma (. com useomanbdalwec cc:usa/file ee Dallas coal Clerk 600 Commerce Street May 2.2024 Dallas, Texas 75201 RE: Civil Action: Usaama Abdalmatiyn vs. UC Food Store & Christopher Wells Dear Clerk: Enclosed please find the Plaintiff's Original Complaint for damages for filing within the appropriate civil court. Thank you for your time and assistance in this matter. Respectfully submitted, Usoome Allele Usaama Abdalmatiyn 3201 Hamilton Ave. #105 Dallas, Texas 75210 (214) 229-1661 Cause No. District Usaama Abdalmatiyn Dallas er Texas Plaintiff, Vs. Judicial District Christopher Wells & UC Food Store Defendants. puller coun Sworn Affidavit of Facts |, Usaama Abdalmatiyn verify that the forementioned Plaintiffs Suit for damages is made truthfully and from personal knowledge regarding the facts therein, where the Plaintiff makes the same and sign herein under the penalties of perjury pursuant to the Texas Code of Civil Procedures on this 2) day of , 2024. Usaama Abdalmatiyn 3201 Hamilton Ave. #105 Dallas, Texas 75210 (214) 229-1661 —- ——° — ADDRESSES OF PARTIES INVOLVED Usaama Abdalmatiyn Christopher Wells PLAINTIFF DEFENDANT 3201 Hamilton Ave. #105 2301 Dathe Street Dallas, Texas 75210 Dallas Texas 75210 Ph. # (214) 229-1661 Ph. # (469) 219-0583 UC Food Store DEFENDANT REGISTERED L.L.C. 1326 Martin Luther king Jr. Blvd. Dallas, Texas 75210 Ph, # (214) 484-4842