IN THE DISTRICT COURT OF CLEVELAND COUNTY STATE OF OKLAHOMA
HI TECH AIR SOLUTIONS, LLC,A domestic limited liability company; RAY ROBISON, an individual,
Plaintiffs; caseNo. aJ' aot 5 .Lttt- y vs.
HEALTHY HABITATS, LLC, A foreign limited liability company; CARL GRIMES, an individual,
Defendant,
SUMMONS T
dayof&r'tA ,201s.
oBA #20233 Suite A Deputy Court Cletk oK 73139 405.703.4567 ,ofacsimile: 405.703.4061 E-mail: [email protected]
YOU MAY SEEK THE ADVICE OF AN ATTORNEY ON AhIY MATTER CONNECTED WITH THIS SUIT ORYOUR ANSWER.SUCH ATTORNEY SHOULD BE CONSULTED IMMEDIATELY SO THAT AN ANSWER MAY BE FILED WITHIN THE TIME LIMIT STATED IN THE SUMMONS. lftSlfinBlsEffiprylu' APRe2 2015
HI TECH AIR SOLUTIONS LLC,a. domesticlimited liability company; '",,FJl'l*Bfl6i,Etfr%" RAY ROBISON, an individual,
Plaintiffs; caseNo. C^]' aO t5' qtl' Y
HEALTF{Y HABITATS, LLC, A foteign limited liability company; CARL GRIMES, an individual,
Defendant.
ENTRY OF APPEARANCE
To the Clerk of this Coutt and all parties of recotd:
I hereby enter my appearanceas counsel in this casefot Plaintiffs, Hi Tech Ait
Solutions,T.T C, and RayRobison.
to practice in this Coutg I certify that I "m admitted
4^LL- Lol 6 Date Chris Hammons, OBA #20233 LAIRD Flamrtot'ls Larno, PLI,C 1230 S.\ilfl89d' St., SuiteA OHahoma CitY, OK 73739 TelePhone 405'703.4567 '6 a- Facsimile 405.703.4061 E-mail: Chris@lhllaw'com ATTONNBVTORPL{INTIFF rNrHE DrsrRrcr couRr oF .LE'ELAND ffifif$tr$6i]fiF$r . u srATE, OF OKLAHOMA FrLFjf,r ApRze Z0tf Hr TECH AIR SOLUTTONS, LLC, a domestic limited liability company; co*FcTl,? RAY ROBISON, an individual, Bff6REl,lrl r.
Plaintiffs; caseNo'eJ'ao \5' L{8t- Y vs.
HEALTHY HABITATS, LLC, A foreign limited liability company; CARL GRIMES, an individual,
Defendant.
PETITION
COME NO!7 Plaintiffs, Hi Tech Air Solutions,IIC, a dosrestic limited liability company
and Ray Robison, an individual, ftereinafter ?laintiffs) for their cause of action against Defendants,
Healthy Habitats, TJ.C, a foreign iimited Lability company and Carl Grimes, an individual
@ereinafter Defendants) and state as follows:
THE PARTIES
7. Plahtiff Ray Robison was a citizen and rcsident of Cieveland County, Oklahoma at all
relevant times hereinafter described.
2. Plaintiff Hi Tech Ait Solutions, IIC, is a domesric limited iiability company tlat is primarily
owned and operated out of Cleveland County, Oklahoma. a-'Q' 3. Defendant Healthy Habitats, LLC, is a Colorado limited liability company.
4. Defendant Cad Gdmes was a citizen and resident of Colorado at all televant times
hereinafter described. JURISDICTION AND VENUE
5. This is an action arising ftom Defendantb intentional conduct that was exptessly aimed at
?laiatiffs and caused harm to the Plaintiffs, the brunt of which was suffeted in OHahoma
and which the Defendants knew was likely to be suffered in OHahoma.
6. Because the intentional conduct was aimed at an individual and business in Cleveiand
CountySOHahoma, the prcpet veoue is ClevelzrrdCounty.
THE CAUSE OF ACTION
7 . Ray Robison ourns and opetates Hi Tech Air Solutions, Tr .Q'.
8. Hi Tech Ait Solutions sells machines that emdicatemold and toxins'
9. Hi Tech Air Solutions rnarkets its products via salestearns and intemet matketing.
10. Hi Tech Ait Solutions has teceived many salesftom referals on Facebook.
77. Catl Grimes ovrns and operates Healthy Habitats, LLC.
12. Hedthy Habitats, LLC is a competitor of Hi Tech Air Solutions, LLC.
13' catt Gdmes, as owner and opetatot of Healthy Habitats' T'Tc' is an active participant in
online forum.s concerning rnachines and servicesthat eradicatemold and toxins.
14. C^rJ,Gdmes has made numef,ous false statements concerning Ray Robison and Hi Tedr Air
Solutions, LLC.
15. Caxl Gdmes's false statement: were published on Facebook forums where individuals seek
information conceraing machines and servicesthat eadicate mold and toxins.
16, CarI Gdmes published false statements tlat Hi Tech Air Solutions and Ray Robison
ptactices deception.
Solutions is a scdh.-+ 77. CurlGdmes published false statements that Hi Tech Air _ aa's/ r
18. Cad Gdmes published false statements that Hi Tech Air Solutions and Ray Robison is
preying on mold sensitivepeoP1e' 19. Carl Gtimes has encouragedothers to defarne Hi Tech Air Solutions.
20. C^A Grimes has encouraged custorners of Hi Tech Air Solutions to return the ptoducts
pwchased from Hi Tech Air Solutions.
21. C^A Grimes published falsestatements about Hi Tech Ail solutiont testing methods.
22. CatL Grimes published false statements about Hi Tech Air Solution's and Ray Robison's
cornmunications with testing facilities.
23. Cac' Grimes's false statements have exposed Plaintiffs to public hafted, contemp! ridicule,
and disgtace.
24. CatI Grimes's false statemeflts were communicated to persons othet than Plaintiffs.
25. Catl Gdnres's false statementswere reasonablyunderstood to be about Plaintiffs.
26. CeA Gdmes's statementswere false.
27. Cafl Grimes did not exercisethe cate which a reasonably careful person would use under the
citcumstances to determine vrhether the statements were true or false.
28. CarLGdmes's statements causedPlaintiffs to suffer a firrancial loss.
29.. C^d, Gdrnes's satements caused Plaintjffs to suffer damages to its rcputation andf or
emotional-i*y.
EIRST CAUSE OF ACTION: DEFAMATION
30. Plaintiffs incorporates asif fully restatedall of the allegationsprwiously wtitten.
31. Plaintiffs were subjected to public haffed, contempt, ddicule or disgrace and suffered
financiai loss as a result of Cad Grimes'sintentional false statsments'
SECOND CAUSE OF ACTION: TORTIOUS INTERFERENCE WITH c- 'F coNTRAcT - -re'i{
32. ?laintiffs incotporates as if firlly restatedali of the allegationspreviously written.
33. Plaintiffs had numerous purchasing contracts with customers. 34. Defendants knew, or under the circumstances, reasonably should have known about the
conttacts.
35. Defendants interfered with the contracts.
36. Defendants induced the custornersto breach the contracts.
37. Defendants' actionswere intentional.
38. Defendants' used improper ot unfait meansin interfering with the contracts.
39. As a direct result of Defendants' acdons,Plaintiffs havesuffeted damages.
CAUSATION OF PLAINTIFF'S DAMAGES
40. As a ditss! and proximate result of the Defendants' acdons, Plaintiff has suffered damages
described hereafter.
DAMAGES SUSTAINED BY PLAINTIFES
41. Plaintiffs have suffered losses as a result of Defendants' interference rpith the prxchasing
contfacts.
42. Plaintiffs have suffered financial losses, such as loss of eamings and ptofits as a result of
Defendants' acts of defamation.
43. Plaintiffs have suffered mi*y to rcputation, and standing in the com:rrunity, as a result of
Defendants' acts of defamation.
44. Plaintiffs have suffered personal humiliation as a result of Defendants' acts of defa:rration.
45. Plaintiffs have suffeted mental anguish and suffedng as a result of Defendants' acts of
defamation.
DEMAND FOR JURYTRIAL e- 'b 46. The Plaintiff domandsa juy tial for all issuesof fact presentedby this action' - RESERVATTONOE Ap.QTTTONALCLArr\4S
47. Tbe Plaintiff reserves the dght to plead further upon completion of discovery to state
additional claims and to name additiond parties to this action.
WHEREFORE, Plaintiffs pray for judgnent against the Defendants, in a sum in excess of
$10,000,but less than $75,000as required fot diversityjurisdiction undet 28 U.S.C.S 1332 (crmently
$75,000.00) plus interest, costs, attorney's fees, punitive darnages,and all such other and fi:rther telief as to which Piaintiff mav be entided.
Respectftrlly submitted,
I-rno HAIvE\doNSLaIRD, PLLC 1230S.W 89h St., Suite A OklahomaCity, OK 73739 Telephone 405.703.4567 Facsimile 405.7A3.4061 E-mai} [email protected] Arroruqnv noRPI",\NI:FF
ATTOR}{EYLIEN CLAIMED
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