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PETERSON WATTS LAW GROIJP,LLPGLENN W.PETERSON,ESQ。 (SBN 126173)2267 Lava ttdge Com,Suite 210

Rosevillc,CA 95661

Telephonc:(916)780‐ 8222

Fax Nα (916)780‐ 8775

Attomeys for Plainitt One SOurcc LED Lighting,LLC

ONE SOURCE LED LIGH… G,LLC,aCalifomia Limited Liability Company,

Plainti範

VS

JIJDICIAL COIJNCIL OF CALIFORNIA,ADMnttSTRATIVE OFFICE OF THECOURTS;and MARK R JOHNSON,anindi宙dual;DOESl‐ 50,inclusive,

N IIIE StlPERIOR COURT OF THE STATE OF CALIFORNIA

N ANDFORT羽巴COUNTY OF SACRAMttNTO

Case No

COMPLAINT FOR:

1.ACCOUNTS STATED2.OPEN B00K ACCOU剛3.QUNIIM MERUIT4.PRO■IISSORY ESTOPPEL5.FRAUD

ヽ

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― OCr -3201

01

Defendants.UNLIIИITED JURISDICT10N

PlaintiffONE SOllRCE LED LIGttDJG complains and alleges as follows:

1. Pl江ntiff ONE SOURCE LED LIGHTINGぐ 'Plahtir'Or・ oNE SOURCE")is a

Calif“価a Limited Liability Company.At ali times relevant to」 巨s∞mplaint,ONE SOURCE had

｀

"m●

y business o“ce in EI Dorado County.At J1 6mes relevant herein,ONE SOURCE acted

山Юugh its sole managing member,Barbara Waldron(“ WaldrOn'').

2 Defcndant JUDICIAL COUNCIL OF CALIFORNIA(‖ JCC")iS the policym直 饉ng

body of Califomia's judicial branch. The Judicial Council's staff of approximately 800 is responsible

for implementing council policies and supporting the day-to-day operations of the Supreme Court.

the courts of appeal, and the superior courts. As such, the JCC is responsible for the development,

maintenance, and repairs of owned or managed courthouse facilities throughout the State

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Califomia. (CA Gov. Code 970391) Plaintiff is informed and believes and based thereon alleges

that. at all times relevant to this action, the JCC acted through its staff and representatives stationed

in JCC's administrative offices in Sacramento, Califomia, tluough which alt of the pertinent

transactions, events and occurences underlying this action took place. Additionally, the contracts,

accounts and agreements hereinafler alleged were entered into and required substantial acts of

performance in Sacramento.

3. Plaintiff alleges on information and belief that Defendant MARK R. JOHNSON

C'JOHNSON) is an individual resident of Sacramento County'

4. Plaintiffs allege on information and belief that JOHNSON was a Senior Facilities

Analyst for the Environmental Compliance and Sustainability Department for the JCC. JOHNSON

was promoted in mid-2017, whereupon his title became "Acting Supervisor, Sustainabilily Unit."

5. At all times alleged herein, JoHNSoN was acting, or purporting to act, within the

course and scope of his employment by JCC and in a manner that would, apart from Government

Code $815, give rise to the causes of action against him asserted herein. By way of example and not

limitation, JOHNSON used his actual and apparent authority to bind JCC in a manner calculated to

deceive and manipulate plaintiff into fulfilling millions of dollars' worth of purchase orders in

anticipation ofpayment, as more particularly alleged herein.

6. As provided by Govemment Code $822.2, JCC is legatly responsible for the injuries

caused by JOHNSON's intentional and/or negligent misrepresentations to Plaintiff, as hereinafter

alleged, because JOHNSON is guilty of actual fraud and corruption as described in paragraphs 17

tluough 33 below.

7. Defendants Does I through 50, inclusive, are sued pursumt to the provisions of

califomia code of civil Procedure section 474. Plaintiffs are ignorant of the true Dames and

capacities of defendants Does I through 50 and will seek to amend this Complaint to set forth theirl

true names and capacities when ascertained. Plaintiffs are informed and believe, and on that hasis]

allege that each of these fictitiously-named defendants is responsible in some manner for the

occrrrences herein alleged in that Plaintiffs damages as herein alleged were proximately caused by I

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COI,PLAtNTF

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such defendants. Allegations herein applicable to"JCC,""JOHNSON"or"Defendantsn are also

applicablc to and shall includc I)ocs l through 50,inclusive,L[iCSS spccincally averred othc― se

8 1n doing the acts herein allcged, unless speciflcally averred othepise, cach of thc

defendants, including those flctitiously―narned, acted as the agent, employee, partner, alter ego,

representat市e or co‐ conSpirator of Defendants as well as each other,and in sO doing,they wcrc

acthg within the course and scope of such agcncy, employment, partncrshP, reprcsclltation or

cOnsplracy

9 1n compliance nith the Tort Claims Act,PlamtifF prcscnted Defendant JCC with a

Govenlment Claim pursuantto Gove― ent Code secion 910 4 on December 10,2018 That claim

was reiected by letter“ m■eJCC on均西15,2019 h JCC's correspondencc denying Plaintrs

claim,JCC professed to be“ conducung蝕慟er hvestigatior'intO the allegations,but was“ reiecing

the claim at this time for statutO▼ reasons.''PlaintifFalleges on infomation and beliefthat pHor tO

flling the Government Claim,Waldron had pro宙 ded infomation surlcient to reveal― ni■ minimal

investigation the JCC's mtemalcomption compltt ofherein

GENERAL ALLEGAΠONS

10. ONE SOURCE'S bustEss dealings with the JCC began near the end of May 2017

whcn Bill McNalnaraj WhO at that tlnte was a director of the Califonda Conservation Corps

(“CCC"),reCClmmcndcd Waldron and her company to the JCC for thc Pttect.ONE SOURCE was

meant to`つЮ宙de a lvide vaiety of cnergy saving LED lattps,LED flxmes,flxture replaccment

parts as needed,controls and suppol services"to thc ProieCt・

H Waldron had previously worked with the CCC to help them with product

procuremcnt and installation m,SO her∞ mpany was a stЮng candidate to submit a bid forths

new opportunlty、納th the JCC Witt the CCC acting as a relay,Waldron submitted`、 p∝ial

o能Hngs,"ie.,Ietters,product quotcs,cost∞ mttsonS,budgets and misccllancous other

docurnents to JOHNSON,who orered feedback and odits to makc her prescntation morc amcive

to thc JCC's comnlttcc(thC COmlmttcc that Pl油 nifFwas told would approve her involvement in the

PtteCt and establish an approved budget and encumber the ttds necessary to purchase the requ“ d

goods and services hm ONE SOURCE)

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12. JOHNSON directed Waldron !o emphasize the custom-made aspoct of the products in

order to validate Plaintiff as a sole source under ttre NCB Contract. With JOHNSON spearheading

the Project, armed with the budget that Plaintiff helped establistU the NCB Contract was accepted

and ONE SOURCE was approved as the vendor to provide fulfillment. The Project also included

approval for Plaintiff to be paid $160.00 per hour for project management services, which included

raining the ccc members to install oNE souRCE's custom-made lighting, developing the

lighting schedules and audits for the courthouses, and sharing Waldron's expertise in the latest

lighting technologies. Plaintiff was promised compensation for lighting survey support and on-site

technical support at $130.00 and $175.00 an hour, respectively.

13. On May 3:,2O:7,JOHNSON called Waldron to congratulate her, as her comp'rny

was approved by JCC for the NCB Contract. Shortly after the call, JoHNSoN sent waldron an

email and a form to add oNE souRcE to JCC',s procurement system so that oNE souRCE was

listed as an approved vendor. JOHNSON commenced the development and ordering process with

ONE SOURCE shortly thereafter in June 2017; however, when Waldron asked for the written

contract JOHNSON explained the JCC didn't have time to issue the written contract until the next

fiscal year and that the deparEnent had funds for the orders now, but it was on a "Spend It or Lose

It" basis.

14. plaintiff was informed by JOHNSON that the reason for ordering large quantities of

materials from ONE SOURCE without a contract was based on this "Spend It or Lose It" deadline'

and his need to ensure ihat for the next fiscal year he would be awarded a higher budget by JCC for a

project that was well into development. Marketing materials, awards applications, and a letter to the

Govemor were geared with the goal of enlarging the budget foremost in mind, and to create a

posirive public relations narrative which emphasized the cooperation of the JCC and ccc in

retrofi tting the courthouses.

15. Because JCC,s purchase orders required thar Plaintiff encurnber itself with large

extensions of credit and/or targe deposit payments to Plaintiffs suppliers overseas, waldron

expressed concern to JOHNSON about fulfilling large purchase orders without a contract, since

Plaintiff would be taking on gargantuan financial commitments on purchase orders that could take

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scvcral wecks or morc to ilf111.JOIINSON assurcd■/aldron that PlaintifF was an approved JCC

vendor and that hc had the au血

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サ and ability to approve Plaintirs invoices for payment.And,

initially,JO圏SON proved ths fact to Waldron by singularly authoHzing payment ofthe invoices

sumrnarized in Eヌ亜bit“r'heretO,totding nearly S2.7 milllon As shown in this cxhibit payment

PlainiFs invoices conlmenced in November 2017 and continued to latc March 2018.

16. Thus, Waldron was convinced that JoHNSON',s word was good. However, she did

not know in 2017, nor have reason to know, that she was being groomed by JOHNSON to later be

victimized as alleged herein below.

17 . Plaintiff alleges on information belief that JOHNSON saw a way to exploit his power

and authority over the hoject. He recognized early on that the financial magnitude of the Project

presented abundant opportunities to enrich himself. To capitalize on these opportunities, he planned

to manipulate Plaintiff to become financially dependent upon his good graces. In this way, he

assured that Plaintiffs precarious financial dependency could be exploited to his advantage. He was

able to do this only by official acts and exercise ofthe powers and authority JCC vested in him.

lg. First, JOHNSON would demonstrate his singular authority to approve purchase

orders and payment of Plaintiffs invoices, as noted above. once Plaintiff was convinced

JOHNSON'S absolute power and authority to order and approve payment for goods and services

from plaintifl he was ready to execute a shocking series of comrpt acts in order to enrich himself'

which he soon did as alleged herein below (see, e.g., fl 32).

19 Aner establishing a rcasonably reliable track record of paying pldntiffs invoices,

upon which phntiff reasonably rclied,JOHNSON began to exploit his autho五 ty in a mamer that

was calculated to mmdpulatc Waldron,p五 marily by enstt that Plantiffwas funcially dependent

upon staying in JOHNSON'S good graces.

20. The first step JOHNSON took toward leveraging Plaintiff was to require that

pre‐order equipment and mateHals required for the Proiect.JOHNSON'S explanation for this was

that hc did not wantthc PttccttO bC dclayed by long Lad dmcs associatcd宙 th overseas s“ mcntS

“

m PlaintiFs suppliers.JOIINSON動耐n explJned that he wanted to conlmt and appropnate

Pr●CCtfmdS for Phase Two.On Novembcr 16,2017,JO困 SON info■ 1..cd Pl誠ndfFand GLLUSA,

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one ofPldnirs manufactuers,he is processing JCC's ncxt order for S10‐ 15 Mi■ ion in the next 2‐ 3

weeks and nccded them to ramp up production Both Pliniff and GLLUSA relied upon thcsc

representations.PlaintfF is infomcd and believes that GLLUSA opened up a warehouse near the

Los Angeles portin order to stock inventory to getit Plalntiffand JCC more quickly.

21. In reliance upon JOIINSON'S assurances of later payment,Plaintiff ob熊 ined credit

hm an invoice factoHng vendor,and also directly with suppliers.Conscquently,Plainti∬ becamc

flnancially levcraged under the weight oforders totalhg面 uiolls Ofdollars hen JOHNSCpN was

ultimatcly rmα oved mm the PtteCt,Plainiff was hancially obligated for pre‐ ordered custom‐

made matttals amounting to S5,811,013.36.

22 ¶に next step that JOHNSON look as part of hs scheme wasto¬ inold paymcnton

cσtth invoices fbm Plainitt JOHNSON explained to Waldron that∝ rtaln puFChaSe orders were

nOt宙thin thc PtteCt'S frst phase budget,butthat they would be pid in Phase Two.JOINSON

orered the salte cxPlanation about binings hm Pldnti∬ for hourly servおes,assurhg W」 drOn that

働ey"dd口 d“m the Phase Twcl budget

23. In appro対mately March 2018,JOIINSON infomed Waldron that Plaintiff would

need to submit a competitive bid proposal to contmuc with thc P● cCt ThiS calnc as a surprisC t。

WaldroL sincc she had bcen convlllced Carlier by JOnヾ soN that Pl譴ntiff had already re∝ ived a

noncompetitive contract. Under JOIINSON'S drectiOn,and with hS assistance,Plalntiff submi■ed

a proposal.

24 WhiC that proposal was pending,JOHNSON'S conuption began to prescnt itscl■At

JOHNSON'S request,Waldron attendcd a``Green Technology''event With some of Plaintirs

vendors,including Daniel Yu of GLLUSA,one of PlantifPs manufacarcrs. At the event,

JOm(SON solidtcd(and rece市 edl Cash bribes fbmヽ任 Yu As a vendOr m■ lling JCC/ONE

SOURCE purchase orders for the ProJeCt,JOHNSON knew that GLLUSA was moivated to makc

‖quid pro quo''payments to receive the Phase Twcl COntract,and could well afFord thcm based on the

inancial magnindc of theきヽ ect and thc proit margins achiCVablc on ProieCt purchase orders.

JOHNSON had madc the sallte dcmand on Waldron,whch shc dismissed because she thought he

wasjoking

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25 Plaintir alleges on infomation and beliefthat JOHNSON met¬ 1■ Mr.Yu,told him

that cash payments would ensure that PIttndff would be awarded the compeiiVe contract,and that,

for that reason,ヽ璧.Yu pro宙 ded JOttSON宙th personal bank cardsヽ仕.Yu thereater pressed

Waldron to give JOHNSON what he wanted,but Waldron remsed.

26.On April 13,2018,ЮHNSON called Waldron at her offl∝ and was obViOusly upset,

randng and raving about Pnヽ nmbers not wOrking and enraged that he had to drive to multiple

A■M's to pu1l out as much caSh as the cards Would allow Waldron∞ntonted JOHNSON about

the legaltt of what he n7as dOing,and hOW he Wasjeopardizlng the Proiect and oNE SOURCE

would not give in to hiS demands.

27 A■er this Call,Waldron contacted n.Yu to VCri,What had happened and to

cofont him― 卜曇 Yu laughed and sald he reported the cards Stolen and lnalled JOHNSON three

more cards to usc at hiS disposal.Aner」 巨s,waldron phoncd George Geffen,the CEO of GLLUSA,

who co―ed he Was aware thatヽほ Yu pttd JOHNSON,that it was stupia but that it was

necessary to protect their invesment inthc Proiect. .

2S.onApril2T,2olS,MR.JoHNsoNsentWaldrontheJCC'snoticeofintenttoaward

oNE SOURCE's Cotrtraot, but only after sending her a countrfeit notice listing her competitor's

name, a tactic of intimidation and a reminder to Watdron that JOHNSON was in contol'

29. After waldron confronted JoHNSON about the quid pro quo payment from Mr' Yu'

JOHNSON dismissed Waldron's concems and was quick to share how he had covered up the

impropercashpayments.HesharedwithWaldronthefollowingtextmessagethathehadsentto

Mr. Yu on MaY 7, 2018:

Yo'..Dan the Man... Thank you for the nice get well card' I ju9! lovg the b.lue

i#h-*a ir*tliiii,. i"' tt"'i iuch a way frth words' So looking-forward to

;.;i"'ri,,s tlt p.ffi;il;Jrg" ;i1; uuti't' I'tt cherish this one for a month

torrrli"nyoogotit-amt'iitwillbeshriveledupliketheflowersyougaveme'

30. JOHNSON told Waldron he sent the text to Mr' Yu as a coverup effort because Mr'

YusentPlNnumbersandhisownbankaccountlogintoJoHNsoN'sworkphonenumber.

plaintiff alleges on information and belief that JoHNSON shared this information with waldron in

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an attempt to convince her that she was already involved in the impropriety, because the quid pro

quo payments were made by a manufacturer utilized by ONE SOURCE on the Project'

31. Later, on May 20, 2018 JOHNSON made his demands on Plaintiff explicitly clear:

JOHNSON called Waldron to pick him up from Sam's Club, as he was getting his tires replaced.

while waiting for the work to be done, JoHNSON wanted a personal meeting with waldron and she

was directed to drive him back to the oNE SOURCE offices to have a discussion.

32. In the meeting and discussions that ensued, JOHNSON told waldron, "I need to

secure my futue. My wife is driving on bald tires," and "It's not a want. It',s a need." JoHNSON

demanded from waldron the following: (l). $3,000 cash per month; (2). $160,000 per year salary;

and(3).24.5% ownership or equitv in ONE SOURCE.

33. When Waldron refused to concede to JOHNSON'S attempts at extortio& JOHNSON

.,flipped out, slammed his laptop closed and said, "Fuck it. I'm Done." Later that day' Waldron sent

JOHNSON text messages in which she told him she was not willing to break the law on his

and that her refusal was firm.

t4. on May 28, 2018, Waldron contacted JCC Director Steve Bonde to report

JOHNSON'S actions. Mr. Bonde treated waldron with discernable hostility and said he would not

discuss the matter further with her, eventually forwarding her to another director, Aurora Rezapore'

Ms. Rezapore, hearing Waldron's story, assured her the JCC would cooperate with the Department

of Justice in handling this matter and would make sure waldron knew when JoHNSON was to be

confronted so she could take precautions in case JoHNSON retaliated against her or her family'

35.Atthispoint,withtheencoumgementofMs'Rezapore,WaldroncontactedtheEl

Dorado county Sheriffs offrce on May 30, 2018 to report the harassment and extortion in an effort

to get a restraining order. The Sheriffs Office put her in touch with Special Agent Brian Fitchner'

who eventually advised Waldron to record anotler meeting with JOHNSON'

36. on June I, 2018, Waldron met with JOHNSON in an aftempt to discuss business as

usual; however, an hour into the meeting, waldron shifts the conversation to discuss the bank cards,

the manipulation, and her fears about the Project falling apart. JOHNSON responds carefully, and

attempts to explain to Waldron that his scheme is legal'

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37. On June 4,2018,, JOHNSON was pulled from the Project. Later, he resigned from

the JCC altogether and on June 8, 2018, ONE SOURCE'S contract was terminated "for

convenience," leaving unpaid invoices, pre-ordered materials, a soured business relationship with

their manufacturers, and overhead expenses incuned at the JCC's request.

38. As a result, oNE souRcE was financially ruined. All of its employees were laid

off, and its leasehold office space was lost. It was left burdened with debt tlrat was all incurred in

reliance upon Defendants' representations and for the benefit ofthe Project'

JCC)

39. plaintiff realleges and incorporates here by reference the allegations of paragraphs I

through 38 above.

40. Within the last two years, in sacramento, califomi4 Defendant became indebted to

plaintiff on an open book account and/or account stated for money due in the principal sum

$270,711.17 for certain construction materials, equipmen! services and supplies sold by Plaintiff to

Defendant at its special instance and request, for which Defendant agreed to pay the above sum.

41. Although demand therefore has been made, the entire sum has not been paid and

there is now due, owing and unpaid from Defendant to Plaintiff the sum of $45,866.46, together with

interest at the legal rate of ten perc enl (10o/o) per anrzm tluough date of entry ofjudgment herein'

42. Plaintitr has engaged the undersigned law firm to cornmence and prosecute this

action. Therefore, pusuant to the open book account and/or account stated, Plaintiff is entitled to an

award of its attomeYs' fees.

(Open

43. plaintiff realleges and incorporates here by reference the allegations of paragraphs 1

th,rough 38 above.

44.Withinthepasttwoyea$,DefendantbecameindebtedtoPlaintiffonanopenbook

account for money due in the srun of $270,711.17 for the goods ordered at Defendant's special

instance and request and for which Defendant agreed to pay the above sum'

JCC)

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TIImD CAUSE OF ACT10N

45. Neither the whole nor any pa of the above sum has been pai4 although a demand

for payment has been made, and there is now due, owing, an unpaid balance, with interest, late fees,

attomey's fees, and costs.

(Complaint for Constru-don Work, Lebm, Equipment, And Mrterials -Reasonable Value

-Against Defendant JCC)

46. Plaintiff realleges and incorporates here by reference the allegations of paragraphs I

through 38 above.

47 . Within the last two years, in sacramento, califomia, Defendant became indebted to

Plaintiff tbr construction materials, equipment, services and supplies sold and delivered by

at Defendant's special instance and request, for the agreed sum of$45,866.46, which sum Defendant

then and there agreed to pay Plaintiff.

48. Additionally, Plaintiff was requested by JCC, through JoHNSON, to provide hourly

services to JCC for the Project. Plaintiff was promised that it would be compensated for services

rendered in Phase I of the Project an onward. These services included lighting survey support, on

site technical support, and lighting retrofit project management, which were to billed at the agreed

hourly rate of$130.00, $175.00, and $160.00, respectively'

49. Plaintiffs' services for the Project began in 20i7 during Phase I; however, JoHNSON

instructed that Plaintiff not be allowed to bill for hourly services until the nexl fiscal year when a

new budget would be encumbered for such services. On this basis, Plaintiff rendered hourly services

at JOHNSON'S request in reliance upon his assurance of payment from JCC's next fiscal year's

budget.

50. plaintiff is entitled to recover money from JCC at the agreed rate or, alternatively, in

an amount determined by this Court to be the reasonable value ofthe goods and services provided to

the Project for the benefit ofJCC.

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(Promissory

51. Plaintiff realleges and incorporates here by reference the allegations of paragraphs I

through 38 above.

52. Through the foregoing acts and conduct described above in paragraphs 12 through 32,

Defendants made nrunerous promises to Plaintiff, which Defendants knew would induce Plaintiff to

rely upon those promises.

53. plaintiff did in fact reasonably rely on those promises when it continued to place

orders at JoHNSON'S and JCC'S request and provide valuable services for the Project.

54. Defendants further promised Plaintiff that it would receive a written NCB Contract

with JCC, which would compensate Plaintifffor goods and services based on its ptoposals.

55. plaintilf did in fact rely on such promises and its reliance was both reasonable and

foreseeable.

56. Becagse of the promises stated in paragraphs 12 th,rough 22, Plairrtrff relied to its

detriment and suffered significant damages, as alleged herein above. Particularly, in reliance upon

JOHNSON'S assurances of later paymen! Plaintiff obtained credit from an invoice factoring vendor,

and also directly with suppliers. Consequently, Plaintiff became financially leveraged under the

weigbt of orders totaling millions of dollars. When JOHNSON was ultimately removed from the

project, plaintiff was financially obligated for pre-ordered custom-made materials amounting to

$5,811,013.36. Unable satisfi these obligations, Plaintiff was rendered insolvent and forced out of

business.

57. It was not until June 8,201E that the JCC informed Plaintiff that it would not be

compensated as previously promised. JCC Principal Manager of Branch Accounting and

procurement issued a termination letter canceling ONE SOURCE'S contract for convenience. a

mere two weelcs ofter the date it was signed by ICC.

58. In addition to unpaid goods delivered and services rendered, the JCC also failed to

account for custom-made materials JOHNSON had instructed Plaintiff to pre-order from its

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manufacturers, CLLUSA, in the amount of $5, 811,013.36, on the promise that JCC would pay for

these materials.

59. As a result of Defendants' breach of promise, and the consequent financial injury it

caused to Plaintiff, Plaintiff was forced out of business, and left with business loans it is unable to

pay, which were taken out for the benefit of the Project and in reliance on Defendants' promises.

Additionally, Plaintiff was unable to pay sales taxes incuned on goods that were provided to JCC in

reliance on Defendants' promises.

60. Equity and faimess now require that Defendants be estopped to deny their promises

made to Plaintiff.

61. Notwithstanding its good faith efforts to mitigate the danages caused by Defendants,

Plaintiff has been damaged in an amount subject to proof at rial, but not less than $l million.

62. plaintiff realleges and incorporates here by reference the allegations of paragraphs 1

tfuougb 38 above.

63. The representations made by JoHNSON, as described above in paragpphs 12-32

were fraudulent and comrpt, and made by JOHNSON acting within lhe course and scope of his

employment and official authority on behalf of JCC.

64. plaintiff reasonably relied upon Defendants' fraudulent representations, all to its harm

and detriment, including the financial injury it caused to Plaintiff, which forced Plaintiff out

business, and left with business loans and other debt that it is unable to pay, which was incurred for

the benefit ofthe Project and in reliance on Defendants' fraud and misrepresentations.

65. Notwithstanding good faith efforts to mitigate the damages caused by Defendants,

Plaintiffhas been damaged in an amount subject to proof at trial, but not less than $l million,

66. Plaintiff is further entitled to an award of exemplary damages pursuant to code o

C市.Proc.§§3294‐3296,in an atnount sdEcicnt to punlsh and dctcr亜 d Defendants,aC∞ 山 tO

prOofat“ al

_12‐

COⅣPLAINT FOR DAMACES

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PRAYER FOR RELIEF

WHEREFORE,PlaintirpraySjudgment against Defendants,and each ofthem,as follows:

UPON THE FIRST,SECOND AND TIIIRD CAUSES OF ACT10N:

l For money due on the accounts,ac∞ rding to prool and the agreed valuc oL

altematively,adiudicated reasonable valuc ofthe goods,equipment and services pro宙 ded to JCC at

its instance and request;

2. For an award ofmoney damages,額 珈血 g to prool and

3. Preiudgment interest on ali sulns due and owing

UPON THE FOURTH AND FIFTE CAUSES OF ACT10N:

4. For compensatory,special and gcneral damges according to proof at饉 al,but in no

event less than Sl million.

5. Forpreiudpentinterest tt the nlammum legal rate dlowed by law;and

6. For pututive and exemplaγ damages(aS tO the Fitt Causc of Action)as a110Wed by

law;

UPON ALL CAUSES OF ACr10N:

7 ForFttjudgmentinterett atthe maximuln lega r山;and

8. For cost of suitincwed hercin;and

9. ForsuchotherandmherreliefaseqtutyrequiresortheComdeemsjust ‐

Htthereby硼“曲a“d byiu.70ぷW IDATED: Octobcr 3,2019

Respectftrlly submitted,

PETERSON WATTS LAW GROUP, LLP

By:

認 雪 Iλ駐 :`嘱 d彎ェLC

CORIPLAlNT FOR DAMACES