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Filing # 128298128 E-Filed 06/08/2021 10:59:19 AM
IN THE CIRCUIT COURT OF THE
15™ JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50-2020-CA-007471
V.C.A. UNITED, LLC,
Plaintiff,
Vv.
MELISSA L. HANSLER; and INTEGRATED
VASCULAR IMAGING, LLC,
Defendants.
/
PLAINTIFF’S NOTICE OF FILING AFFIDAVIT OF JAMES HANSLER
IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT
COMES NOW, the Plaintiff, V.C.A. UNITED, LLC, by and through its undersigned
counsel, and hereby gives notice of filing the attached Affidavit of James Hansler in Opposition
to Motion for Summary Judgment in the above-styled action.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8" day of June 2021, I electronically filed the
foregoing document with the Clerk of the Court using the Florida Courts eFiling Portal with
nnetinn in Dawid Y Nneleasian Beanies The Marbavinn Qennn 2096 DOA Danlaraed Gute 1A
Service tO Davia K. Maixatian, Gsquire, Tne Marnarian Group, 2525 DGA Douwevara, Suite 205,
Palm Beach Gardens, FL 33410 at dave@businessmindedlawfirm.com and
davidg@businessmindedlawfirm.com.
COHEN, NORRIS, WOLMER, RAY,
TELEPMAN, BERKOWITZ & COHEN
Attorneys for Plaintiff
712 U.S. Highway One, Suite 400
North Paim Beach, FL 33408
(561) 844-3600 - Telephone
jst@feohenlaw.com - Primary Email
sme@fcohenlaw.com - Secondary Email
ds/ James S. Telepman, Esquire
James S. 5. Telepman, Esquire
Florida Bat No. 466786
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED neinainnns 40.50.40 ANA
Hm. PAL DLA VUUINE TT, FL, vUOL I monuecy, ULLIAN, YuruUiZue! tu.g. 1 mitINTHE CIRCUIT COURT OF THE
15™ JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50-2020-CA-007471
V.C.A. UNITED, LLC,
Plaintiff,
ve
MELISSA L. HANSLER; and INTEGRATED
VASCULAR IMAGING, LLC, ;
Defendants.
/
AFFIDAVIT OF JAMES HANSLER
STATE OF FLORIDA
COUNTY OF PALM BEACH
I, James Hansler, being duly sworn, deposes and states as follows:
1 My name is James Hansler, and ] am the managing member of V.C.A. United,
LLC (“VCA”), the Plaintiff in this case. All facts recited below are based upon my own personal
Tees needed
KUUWICUBS,
2. My former wife, Melissa Hansler (“Melissa”), and I formed VCA in March 2018.
3. From the outset, it was understood that I would supply the funds necessary to
operate the company, and Melissa would provide for the operations and service end of the
business.
4, It was agreed that, because I was supplying the money needed to start and run the
company from the outset, I would be the 51% owner of VCA, with Melissa owning 49% of
VCA.Ss. No written aneratina acreamant wae ever eraated nr eveontad
3. No written onerating aorcoment was ever Created or executed,
6. To date, I have put $120,840.95 into VCA, and have recouped $45,950.00 to date.
7. In addition, J alone personally guaranteed payment of the machines needed to
allow VCA to do business, and still owe over $71,000.00.on those contracts. I am paying those
personally due to Melissa’s actions in destroying VCA, as outlined in the Complaint filed in this
case.
8 In lieu of a salary, I paid all of Melissa’s expenses, which averaged approximately
$5,000.00 per month. However, from the beginning of 2019 forward, Melissa made regular
threats to destroy VCA and simply take the customers elsewhere if I did not increase what I was
paying to her. Thus, leading up to the end of May 2019, I was paying Melissa close to
$10,000.00 per month. All told, I paid Melissa somewhere between $75,000.00 and $100,000.00
during the 14 months that VCA operated, before the events of May/June 2019, which are the
subject of this litigation.
9, Melissa, -continued to threaten VCA’s existence, and when I insisted on her
signing a non-competition agreement at the end of May 2019, sherefused, Tiring of paying her
exorbilaiit deiianGS Wuue Ueauing With Her thieats, iGpped by Lier ieLusal 10 agree not to compete
with her own company that I helped her start despite our divorce proceedings, I sent out the June
2, 2019 email, in the hope that it would bring her to her senses, and we could work things out
and move forward from there.
10. Unbeknownst to me, however, she had already fonned a new company before I
sent out the email. This worked out for her nicely, since it provided her with the ability to use
the email as an excuse to break away from VCA, even though she had clearly reached that
decision before the email went out.mv intent ta “dicealue” VCA with an email nor waa it mv
EnY ECE GHSSSAYS ven VWeeeas cost Gusnasag ance Wrasse ay aaay
ly news
J
intent to waive any rights. My intent was to simply make it clear to Melissa that I was not going
to stand by and allow her to continue to make demands and threats without her agreeing to take
reasonable steps to protect my interest in VCA.
FURTHER AFFIANT SAYETH NOT.
J R
T DEDERV CEDTIEYV thet an thic dau hafara ma on nffiror Anly anthnrived in the
2 BRAM QAAN AAR 2 LIGY ll UNIS Gay, UVEULY Aly Gul CLLIWNL GUY GUMLIAA A ML
State aforesaid and in the County aforesaid to take acknowledgments, the foregoing instrument
was acknowledged before me by means of 0 physical presence or o online notarization, this
‘1 aay of Jone 7 2026 by JAMES HANSLER who is personally known to
me or 0 who has produced as identification.
ALEXANDRA LEVY
tate of Florida-Notary Public|
Commission # GG 236276
My Commission Expires
July 09, 2022
aT Mir Ononeninatnes Taretaun ee
— my VOMIUSSIUL LAPUCS, a,
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Filing # 128298128 E-Filed 06/08/2021 10:59:19 AM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 50-2020-CA-007471 V.C.A. UNITED, LLC, Plaintiff, Vv. MELISSA L. HANSLER; and INTEGRATED VASCULAR IMAGING, LLC, Defendants. / PLAINTIFF’S NOTICE OF FILING AFFIDAVIT OF JAMES HANSLER IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT COMES NOW, the Plaintiff, V.C.A. UNITED, LLC, by and through its undersigned counsel, and hereby gives notice of filing the attached Affidavit of James Hansler in Opposition to Motion for Summary Judgment in the above-styled action. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 8" day of June 2021, I electronically filed the foregoing document with the Clerk of the Court using the Florida Courts eFiling Portal with nnetinn in Dawid Y Nneleasian Beanies The Marbavinn Qennn 2096 DOA Danlaraed Gute 1A Service tO Davia K. Maixatian, Gsquire, Tne Marnarian Group, 2525 DGA Douwevara, Suite 205, Palm Beach Gardens, FL 33410 at dave@businessmindedlawfirm.com and davidg@businessmindedlawfirm.com. COHEN, NORRIS, WOLMER, RAY, TELEPMAN, BERKOWITZ & COHEN Attorneys for Plaintiff 712 U.S. Highway One, Suite 400 North Paim Beach, FL 33408 (561) 844-3600 - Telephone jst@feohenlaw.com - Primary Email sme@fcohenlaw.com - Secondary Email ds/ James S. Telepman, Esquire James S. 5. Telepman, Esquire Florida Bat No. 466786 CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED neinainnns 40.50.40 ANA Hm. PAL DLA VUUINE TT, FL, vUOL I monuecy, ULLIAN, YuruUiZue! tu.g. 1 mitINTHE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 50-2020-CA-007471 V.C.A. UNITED, LLC, Plaintiff, ve MELISSA L. HANSLER; and INTEGRATED VASCULAR IMAGING, LLC, ; Defendants. / AFFIDAVIT OF JAMES HANSLER STATE OF FLORIDA COUNTY OF PALM BEACH I, James Hansler, being duly sworn, deposes and states as follows: 1 My name is James Hansler, and ] am the managing member of V.C.A. United, LLC (“VCA”), the Plaintiff in this case. All facts recited below are based upon my own personal Tees needed KUUWICUBS, 2. My former wife, Melissa Hansler (“Melissa”), and I formed VCA in March 2018. 3. From the outset, it was understood that I would supply the funds necessary to operate the company, and Melissa would provide for the operations and service end of the business. 4, It was agreed that, because I was supplying the money needed to start and run the company from the outset, I would be the 51% owner of VCA, with Melissa owning 49% of VCA.Ss. No written aneratina acreamant wae ever eraated nr eveontad 3. No written onerating aorcoment was ever Created or executed, 6. To date, I have put $120,840.95 into VCA, and have recouped $45,950.00 to date. 7. In addition, J alone personally guaranteed payment of the machines needed to allow VCA to do business, and still owe over $71,000.00.on those contracts. I am paying those personally due to Melissa’s actions in destroying VCA, as outlined in the Complaint filed in this case. 8 In lieu of a salary, I paid all of Melissa’s expenses, which averaged approximately $5,000.00 per month. However, from the beginning of 2019 forward, Melissa made regular threats to destroy VCA and simply take the customers elsewhere if I did not increase what I was paying to her. Thus, leading up to the end of May 2019, I was paying Melissa close to $10,000.00 per month. All told, I paid Melissa somewhere between $75,000.00 and $100,000.00 during the 14 months that VCA operated, before the events of May/June 2019, which are the subject of this litigation. 9, Melissa, -continued to threaten VCA’s existence, and when I insisted on her signing a non-competition agreement at the end of May 2019, sherefused, Tiring of paying her exorbilaiit deiianGS Wuue Ueauing With Her thieats, iGpped by Lier ieLusal 10 agree not to compete with her own company that I helped her start despite our divorce proceedings, I sent out the June 2, 2019 email, in the hope that it would bring her to her senses, and we could work things out and move forward from there. 10. Unbeknownst to me, however, she had already fonned a new company before I sent out the email. This worked out for her nicely, since it provided her with the ability to use the email as an excuse to break away from VCA, even though she had clearly reached that decision before the email went out.mv intent ta “dicealue” VCA with an email nor waa it mv EnY ECE GHSSSAYS ven VWeeeas cost Gusnasag ance Wrasse ay aaay ly news J intent to waive any rights. My intent was to simply make it clear to Melissa that I was not going to stand by and allow her to continue to make demands and threats without her agreeing to take reasonable steps to protect my interest in VCA. FURTHER AFFIANT SAYETH NOT. J R T DEDERV CEDTIEYV thet an thic dau hafara ma on nffiror Anly anthnrived in the 2 BRAM QAAN AAR 2 LIGY ll UNIS Gay, UVEULY Aly Gul CLLIWNL GUY GUMLIAA A ML State aforesaid and in the County aforesaid to take acknowledgments, the foregoing instrument was acknowledged before me by means of 0 physical presence or o online notarization, this ‘1 aay of Jone 7 2026 by JAMES HANSLER who is personally known to me or 0 who has produced as identification. ALEXANDRA LEVY tate of Florida-Notary Public| Commission # GG 236276 My Commission Expires July 09, 2022 aT Mir Ononeninatnes Taretaun ee — my VOMIUSSIUL LAPUCS, a,