Sie sind auf Seite 1von 30

1

No. ______________

DAVID WAYNE IN THE DISTRICT COURT
Plaintiff

V. HARRIS COUNTY, TEXAS

JERRY M. RICKY
THE FAMILY LIMITED
PARTNERSHIP,
CITIES AFTER HOURS CLINIC, P.A.,
STAR EVALUATIONS, INC.,
and PAIN CARE & REHAB
CENTER, P.A.,
Defendants _____ JUDICIAL DISTRICT

Plaintiffs Original Petition, Requests for Disclosure, Requests for
Admissions, Interrogatories and Requests for Production

TO THE HONORABLE JUDGE OF SAID COURT:

I. Nature of this Action
1. This is a shareholder oppression and breach of fiduciary duties action arising out
of the squeeze-out by the majority owners of a minority owner of a Texas corporation and a
Texas general partnership, both of which are involved in a Harris County medical practice.
Plaintiff seeks a writ of mandamus to enforce his statutory and common law inspection rights
and seeks equitable relief from the Court as a result of Defendants pattern of oppressive
conduct. Plaintiff further seeks damages from Defendants for various torts suffered at
Defendants hands in connection with his ownership interest in Cities After Hours Clinic,
P.A. and San Family Medicine Clinic, LLP and an accounting and other equitable
relief relating to the dissolution of those entities.

II. Discovery Control Plan
2. Plaintiff intends to conduct discovery under Level 3 of Texas Rules of Civil
Filed 11 January 31 P6:47
Chris Daniel - District Clerk
Harris County
ED101J016158617
By: Furshilla McGee
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
113th
2011-06555
2
Procedure 190.
III. Parties
3. Plaintiff, David Wayne (hereinafter Plaintiff), is an individual who
resides in Pasadena, Harris County, Texas. All pleas, pleadings, motions, discovery, and other
matters related in whole or in part to this case should be served upon Plaintiffs attorney, Mr.
Eric Fryar, with The Fryar Law Firm, P.C., 1001 Texas Avenue, Suite 1400, Houston, TX
77002, Office: 281-715-6396, Facsimile: 281-715-6397.
4. Defendant, Jerry M. is a natural person residing in Harris County,
Texas and may be served at his place of business, W. San Deer Park, Texas
77536, at his residence in Deer Park, Lane, Deer Park, Texas 77536, or where he
may be found.
5. Defendant, Ricky is a natural person residing in Harris County, Texas
and may be served at either of his places of business, W. San Deer Park, Texas
77536, or at Katy Freeway, Houston, Texas 77007, at his residence in Houston,
Street, Houston, Texas 77007, or where he may be found.
6. Defendant, Family Limited Partnership, and/or any predecessors or
successors in interest (hereinafter FLP), is a limited Partnership organized under the
laws of the State of Texas whose principal place of business is in Harris County, Texas.
FLP can be served with citation and/or process on its registered agent for service of
process, which is Jerry M. Lane, Deer Park, Texas 77536.
7. Defendant, Star Evaluations, Inc., and/or any predecessors or successors in
interest (hereinafter Star), is a corporation organized under the laws of the State of Texas
whose principal place of business is in Harris County, Texas. Star can be served with
citation and/or process on its registered agent for service of process, which is Jerry M.
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
3
Lane, Deer Park, Texas 77536, or upon any corporate officer found at its
corporate offices at W. San Deer Park, Texas 77536.
8. Defendant, Pain Care & Rehab Center, P.A., and/or any predecessors or
successors in interest (hereinafter is a professional association organized under the
laws of the State of Texas whose principal place of business is in Harris County, Texas.
can be served with citation and/or process on its registered agent for service of process,
which is CT Corporation System, 350 N. St. Paul Street, Suite 2900, Dallas, Texas 77201-4234.
9. Defendant, Cities After Hours Clinic, P.A., and/or any predecessors or
successors in interest (hereinafter Cities), is a professional association organized under the
laws of the State of Texas whose principal place of business is in Harris County, Texas.
Cities can be served with citation and/or process on its registered agent for service of process,
which is Jerry M. Lane, Deer Park, Texas 77536, or upon any
corporate officer found at that location, or upon any corporate officer found at Katy
Freeway, Houston, Texas 77007.
IV. Jurisdiction & Venue
10. Jurisdiction is proper pursuant to Article 5, 8 of the Texas Constitution. The
amount in controversy exceeds the minimum jurisdictional limits of this Court.
11. Venue is proper in Harris County, Texas, as all or a substantial part of the events
or omissions giving rise to this claim occurred in Harris County, Texas. TEX. CIV. PRAC. & REM.
CODE 15.002(a)(1). In addition, defendants Family Limited Partnership, Cities
After Hours Clinic, P.A., Star Evaluations, Inc., Pain Care & Rehab Center,
P.A.s principal places of business are all in Harris County, Texas. TEX. CIV. PRAC. & REM.
CODE 15.002(a)(3).

Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
4
V. Verified Petition for Writ of Mandamus
12. Plaintiff is a one-third partner in San Family Medicine Clinic, LLP.
(hereinafter the Partnership), which is governed by the Restated and Amended Agreement of
Partnership of San Family Medicine Clinic, L.L.P. (hereinafter the Partnership
Agreement), attached hereto as Exhibit A. Plaintiff is also a 50 percent shareholder in
Cities as evidenced by Form 1120 federal income tax return attached hereto as Exhibit B, and by
the affirmative representations of the other owners, Ricky and Jerry Legal
counsel for the has represented that no stock ledger for the professional association
exists nor is one maintained.
13. In November 2009, Plaintiff demanded and received certain financial records
pertaining to the Partnership, including Quickbooks data files. On March 18, 2010, Plaintiff
through his counsel, made a written demand on Brian counsel for Ricky and Jerry
pointing out questionable self-dealing transactions and numerous problems with the
financial records maintained by the and making specific requests for Partnership
records relating to the deficiencies. In the same letter, Plaintiff requested to be provided access
to the stock ledger and all financial records for Cities. A true and correct copy is attached
hereto as Exhibit C.
14. Receiving no response, Plaintiff, through counsel, e-mailed Brian on April
30, 2010, and renewed Plaintiffs inspection demand; a true and correct copy is attached hereto
as Exhibit D.
15. Defendant never made a formal response to the written demand for Cities
corporate records, but on May 28, 2010, Defendant Cities, through counsel Brian
sent a letter marked FOR SETTLEMENT PURPOSES ONLY NOT ADMISSIBLE FOR ANY
REASON, which offered access to the Cities records if Plaintiff would provide us with a
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
5
written request detailing the specific documents you wish to review, plainly ignoring that
Plaintiff had already made a valid inspection demand.
16. Plaintiff, through counsel, renewed his inspection demand in an e-mail to Brian
dated July 16, 2010; a true and correct copy is attached hereto as Exhibit E. Only then
was Plaintiff informed that a part of the accounting records for Cities were contained in a
password-protected computer file mislabeled as which had been provided to Plaintiff
with the original Partnership records. Defendant Cities supplied the password on July 21,
2010, and counsel Brian stated that the balance of the bookkeeping and accounting
records for Cities was in the possession of & Co., P.C., the corporations
accountant
17. On July 23, 2010, Plaintiff, through counsel, made simultaneous written
inspection demands upon the apparent custodians of the remaining Cities records,
CPA, P.C. and & Co., P.C. ( it appearing that
& Co., P.C. had by that time become defunct or was no longer in use as an entity doing
business in Texas; a true and correct copy of each is attached hereto as Exhibit F and G,
respectively.
18. Defendant in an e-mail dated August 3, 2010, asserted to Plaintiffs
counsel that Arjunani Hasan had exclusive possession and custody of the requested records.
Further inquiries to Arjunani Hasan resulted in a response from Wayne Jr., CPA, Tax
Manager who stated in an e-mail dated September 17, 2010, that [w]e have requested an
authorization of release for tax workpapers many different times from Elaine We
have not been able to have a response either by e-mail or phone call messages. A true and
correct copy of said e-mail is attached hereto as Exhibit H.
19. Thereafter, on October 13, 2010, counsel for Plaintiff contacted Mr. by
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
6
phone in an effort to persuade him to reconsider. Mr. stated that if he received an e-mail or
other written authorization from the attorney for the then he would be happy to
provide any and all financial information in his possession, although he denied that
was now doing the accounting for Cites. Counsel for Plaintiff requested in an e-mail
to Brian that day that Mr. provide written authorization to Mr. for the
release of financial records and for further clarification on who was then doing the accounting
for Cities. On October 20, 2010, Mr. forwarded to Counsel for Plaintiff what he
represented as tax work papers for 2007 and 2008, but nothing more recent than that. Contrary
to the representations by Brian Mr. stated that the accountants had never been the
custodians of Cities financial records and only had their own workpapers from 2007 and
2008. An e-mail to Brian demanding an up to date accounting for Cities produced no
response whatsoever. A true and correct copy of said e-mail is attached hereto as Exhibit I. To
date, the have not produced an up to date accounting for Cities.
20. Based on the foregoing, Defendants have succeeded in stonewalling and delaying
Plaintiffs access to and inspection of Partnership records and corporate records for almost a
year, resulting in substantial expense and attorneys time. To date, Defendants have failed to
permit access of Partnership records including the following: all books and records of account
and Quickbooks data for the period December 2009 to present; CMEDS billing software and
data. To date, Defendants have failed to permit access and inspection of Cities corporate
records including the following: all books and records of account and Quickbooks data for the
period December 2009 to present; CMEDS billing software and data; all bank account records
and statements; invoices, deposits, and billing records; by-laws of the association, minutes of
meetings, and any and all other corporate documents and records.
21. Pursuant to Texas common law, to 152.212 of the Texas Business Organizations
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
7
Code (hereinafter BOC) and to 5.3 of the Partnership Agreement, Defendants have a duty to
disclose and Plaintiff has a right to inspect all the Partnership records he has demanded.
Defendants have violated Plaintiffs common law, statutory, and contract rights. Therefore,
pursuant to BOC 152.211, Plaintiff is entitled to legal and equitable relief to enforce his
Partnership rights, including a writ of mandamus, or in the alternative a permanent injunction,
ordering Defendants to make the requested Partnership records available. Plaintiff is further
entitled to an award of attorneys fees and costs incurred to enforce his rights to inspect the
Partnership records pursuant to 12.11 of the Partnership Agreement and 38.001 of the Texas
Civil Practice and Remedies Code.
22. Pursuant to Texas common law and to 3.151, 3.152, 21.218(b) and 21.218(c)
of the Texas Business Organizations Code, Plaintiff has a right to access and inspection of the
Cities records that he has requested. Plaintiff owns more than 5% of the common stock of
Cities and has been a stockholder for more than six months. Plaintiff made written requests
and stated a proper purpose. Plaintiff has complied fully with the procedures specified in
21.218(b). Therefore, Plaintiff is entitled to a writ of mandamus, or in the alternative a
permanent injunction, from this Court compelling Tri -Cities and its officers and directors to
permit Plaintiffs inspection of corporate records immediately.
23. Furthermore, pursuant to 21.222, Plaintiff is entitled to recover any cost or
expense, including attorneys fees, incurred in enforcing his rights. Plaintiff has been forced to
retain an attorney and has and will continue to incur substantial costs and attorneys fees in
enforcing his rights.
24. All conditions precedent necessary for Plaintiff to obtain the requested relief have
been performed or have occurred. Plaintiff is without adequate remedy at law.

Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
8
VI. Petition for Damages and Equitable Relief
A. Facts
1. Formation of the Partnership and Cities
25. On September 8, 1989, Plaintiff and Dr. Jerry M. entered into a
partnership agreement for the purpose of practicing medicine for profit. That partnership
agreement was later amended on January 1, 1995, in a Restated and Amended Agreement of
Partnership of San Family Medicine Clinic, L.L.P. (hereinafter the Partnership
Agreement), attached hereto as Exhibit A and incorporated herein by reference, and a filing of a
limited liability partnership was made with the Texas Secretary of State around the same time
frame. The practice was originally located in Deer Park, Texas and satellite offices were later
opened in Baytown, Texas and Katy Freeway in Houston. From the beginning, both
Plaintiff and Dr. Jerry practiced occupational medicine, and the Partnership offered
pre-employment and annual physical exams, evaluation and care of work-related injuries, drug
screens, PFTs, audiometry, respiratory fit testing, and company doctor services as well as family
practice medicine. At some point the practice adopted the trade name and began to
use it in conjunction with the practice, although it is not a registered assumed name of the
Partnership. Elaine wife of Dr. Jerry has, almost from the beginning,
served as the bookkeeper and business manager for the Partnership and continues to do so at
present.
26. Throughout the history of the Partnership, Dr. Jerry has acted as the
managing partner. Dr. Jerry and his wife Elaine have exercised complete control over
the Partnerships finances and record-keeping.
27. The Partnership later purchased trucks, trailers and medical equipment as a way to
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
9
provide on-site occupational medical care to corporate clients locally and in other states. When
performing these services, the Partnership did business under the name Mobile. In
addition, the Partnership was able to secure contracts to provide medical services to companies
that had won bids to provide contractor services to the U.S. military overseas, including KBR,
LSI-EG&G and others. Partnership employees screened, examined, tested, immunized and
cleared individuals working for these companies to travel and work abroad in areas with limited
access to medical care, such as Iraq and Afghanistan. When performing these services, the
Partnership did business under the name International.
28. Cities was formed on June 24, 1998. Plaintiff and Dr. Jerry were
the initial shareholders. The Plaintiff and Dr. Jerry also practiced medicine for this
entity under the name Industrial Clinic or Industrial Clinic of Houston.
2. Star Evaluations
29. Separate from the Partnership, and as another facet of their respective medical
practices, Plaintiff and Dr. Jerry performed workmens compensation impairment
ratings for the Texas Department of Insurance Workers Compensation Division through
Churchill Evaluation Centers. This specific type of work was done individually, outside the
Partnership, by mutual agreement of the partners. Over time, Dr. Jerry expressed
dissatisfaction regarding his rate of compensation for this service and proposed starting a
competing business. At some point in 2004, Dr. Jerry decided to form Star
Evaluations, Inc. (registered with the Texas Secretary of State on August 30, 2004) solely in
order to do impairment ratings in competition with Churchill Evaluation Centers and realize
additional profit rather than continuing to do impairment ratings through Churchill Evaluation
Centers. Dr. Jerry offered to allow Plaintiff to become a part owner in the corporation,
but Plaintiff declined because he was happy with Churchill Evaluation Centers. However, at no
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
10
time did Plaintiff authorize or acquiesce in any decision to allow Star to compete with the
Partnership or Cities, neither of which was involved in conducting impairment ratings at that
time or presently. In fact, Dr. Jerry expressly represented that the purpose of Star
was solely to do impairment ratings and that its business would remain limited to impairment
ratings. Given the prior mutual agreement of the partners, Star would not have competed
in the Partnerships line of business or competed with the Partnership, if its business activities
had been restricted to the express representations made by Dr. Jerry
3. Admission of Ricky
30. At some point in 2007, Dr. Ricky Dr. Jerry son, became a
partner of the Partnership and a shareholder in Cities. Dr. Ricky did not make a
capital contribution to the Partnership or pay the other two partners for his one-third interest in
the Partnership, nor was the Partnership agreement amended to reflect his admission. On
information and belief, Dr. Ricky also did not pay for or provide any monetary
consideration for his one-third ownership interest in Cities. At no time did Plaintiff agree
that Dr. Ricky would be transferred any capital or existing equity already owned by
Plaintiff, and none of the Defendants ever disclosed to Plaintiff any intention to effect such a
transfer.
31. Subsequently, Plaintiff and Dr. Jerry acquired real property in Deer
Park under the name of the Partnership, which is the current location of San Family
Medicine Clinic and Industrial. In 2009, another location in Groves, Texas was
purchased, upon information and belief, in the name of Cities. This location operates under
the trade name Groves.
4. Compete with the Partnership and Cities
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
11
32. Over the years, the have focused more and more of their time and
attention on the business of Star. This shift significantly harmed the Partnership, as Dr.
Jerry in particular deprived the Partnership of his services and income. Simultaneously,
the Defendants utilized Partnership assets and personnel for the benefit of Star. The
Defendants greatly expanded the scope of Stars line of business beyond merely
impairment ratings so that Star actually began to compete with the occupational medicine
practice of the Partnership and Cities and to take clients and business opportunities away
from the Partnership and Cities.
33. In addition, Plaintiff has recently discovered that Dr. Jerry and Dr.
Ricky have registered the assumed name International for Star in
Harris County and are billing clients that properly belong to the Partnership through Star
for both occupational medicine services and overseas medical screening. This usurpation of
Partnership and corporate opportunities is a breach of Dr. Ricky and Dr. Jerry
fiduciary duties to the Partnership and to Cities. In addition, the
operate their other business ventures out of the Partnership building and by using Partnership
materials and resources without reimbursing the Partnership.

5. Squeeze-Out of Plaintiff
34. Over time, Dr. Ricky and Dr. Jerry began to restrict Plaintiffs
practice until his only work for the Partnership or Cities was working in the family practice
clinic in Deer Park. As part of that process, Dr. Jerry and Dr. Ricky
purported to create an artificial partition or Chinese Wall of the Partnership into
Industrial, which handled only occupational medicine patients, and San Family
Medicine Clinic, which handled only family medicine patients. However, in reality, there is no
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
12
formal separation of the Partnership into separate divisions. There is no segregation of funds,
records or accounts. Plaintiff was restricted to the family medicine side, which was the less
lucrative side. This despite the fact that Plaintiff has practiced occupational medicine his entire
career and is well qualified to practice in this field.
35. In 2004, 2006 and again in 2008, Defendants filed tax returns for the Partnership
and issued a K-1 to Plaintiff showing taxable income roughly twice the amount of distributions
to Plaintiff. Defendants have never accounted for the phantom income. As a result,
Defendants saddled Plaintiff with a tax liability that he could not afford to pay.
36. During the spring of 2009, Defendants abruptly stopped paying Plaintiff. Dr.
Jerry and Dr. Ricky represented to Plaintiff that because of the weakening
economy, business had slowed and the Partnership could no longer afford to pay Plaintiff his
monthly draws. This caused a significant hardship to Plaintiff who was forced to tap into his
retirement savings (causing another significant tax liability) to make ends meet and pay the
mortgage for his personal residence. While the also purported to cease to taking
draws, they were being paid by Star based on its business in competition with the
Partnership and Cities.
37. Simultaneously, Dr. Jerry proposed that the Partnership be split up so
that the doctors could go their separate ways. Plaintiff asked to review the books and records of
the Partnership in order to determine what his Partnership interest was worth and in order to
enter into negotiations armed with information. Several proposals have been made to Plaintiff
none of them fair or in good faith.
38. On July 19, 2010, Dr. Jerry called a meeting of the partners of the
Partnership and a meeting of the members of Cities, to be held consecutively on July 19,
2010, for the purpose of considering and voting on a resolution to dissolve and wind up the
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
13
Partnership and Cities. At the meetings, which, as it happened, were held simultaneously,
despite several material financial issues that were raised by the Plaintiff and Plaintiffs expressed
willingness to continue to attempt to resolve the issues and work toward an amicable resolution,
Dr. Jerry and Dr. Ricky voted for, and Plaintiff voted against, motions to
dissolve the Partnership and Cities, respectively. The resolution also appointed Dr. Jerry
as the liquidating partner who would formulate and circulate a written, formal plan of
dissolution. Two days later, July 21, 2010, while Plaintiff was undergoing surgery and thus
unable to intervene, the closed the family medicine portion of the clinic and fired all
of the employees of the family medicine portion. In contrast, the industrial medicine portion of
the clinic, where Dr. Jerry and Dr. Ricky practice, remained open to treat
patients and remained fully staffed. Plaintiff maintains that Dr. Jerry and Dr. Ricky
voted to dissolve the Partnership in bad faith in an effort to wrongfully squeeze out
Plaintiff and ratify their misappropriations and malfeasance regarding Partnership property,
clients and funds.

6. Financial Misconduct and Need for Accounting
39. Even a cursory review of the accounting records of the Partnership thus far
available to the Plaintiff reveals that the bookkeeping and accounting for the Partnership is
confused, disorganized, fails to account for significant amounts of missing funds and reveals that
significant amounts of Partnership funds have been comingled with the funds of other entities or
misappropriated by the or their affiliated entities. As the managing partner of the
Partnership, Dr. Jerry bears responsibility for maintaining accurate books and records
for the Partnership, particularly because he insisted on retaining sole responsibility for this task
and delegated its execution to Elaine In failing to properly perform the task, he bears
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
14
full responsibility to account for any and all funds of the Partnership and to make up for any
short falls or misappropriated or missing funds.
40. Dr. Jerry has a duty both as the managing partner and as the partner in
charge of winding up to render an accurate accounting of the partnership assets. Plaintiff
concedes that there are personal expenses and payments made by the Partnership to all three of
the partners which must be accounted for. However, the conduct of the Defendants to date
constitutes little more than wholesale theft.
41. A review of the limited accounting records for the Partnership that Plaintiff was
able to obtain revealed that Elaine Dr. Jerry and Dr. Ricky in both
their individual capacities and in their capacities as officers and/or directors of the various
entities they own, had misappropriated large sums of Partnership property and funds, used
Partnership credit cards to purchase items for their personal benefit or to benefit entities in which
the Plaintiff had no ownership interest.
42. Elaine caused loans to be made from the Partnership to the
FLP in the amount of $274,337.00. Upon information and belief, this amount has never been
repaid to the Partnership. Another loan was made from the Partnership to in the
amount of $423,914.00, however, it is not clear which entity actually received this loan nor
whether it was ever repaid.
43. Furthermore, Plaintiff has learned that Elaine took out an American
Express credit card in the name of the Partnership and on the Partnership credit. Elaine
Dr. Jerry Dr. Ricky and about a dozen Partnership employees are
all authorized users on the account. Plaintiff is not an authorized user on the account. Plaintiff
has learned that the have charged tens of thousands of dollars to the Partnership
American Express account for purely personal expenses, including, for example, to repair
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
15
damage to the automobile owned by the daughter which was damaged in a traffic
accident she allegedly caused. In addition, tens of thousands of dollars of charges are for non-
Partnership expenses or for supplies for Star, FLP or Upon
information and belief, all of these expenses have been paid for with Partnership funds. Also,
Plaintiff has not benefitted from any reward points or airline miles accumulated as a result of
these purchases, unlike the
44. Plaintiff has also discovered that Elaine or one of her authorized agents
has been collecting cash payments that patients of the Partnership pay for services (for example,
office visit co-pays or cash paying patients) and depositing them in unknown bank accounts
rather than depositing them in the Partnership bank account. This misappropriation amounts to
over three hundred thousand dollars during the short time frame for which Plaintiff has been able
to examine the records, and, upon information and belief, more likely amounts to more than five
hundred thousand dollars.
45. Upon information and belief, some of the trucks, trailers, and mobile medical
equipment with which the Partnership practiced, under the trade name Mobile, were
sold on or about September 15, 2009, and the proceeds have been misappropriated by Dr. Jerry
Dr. Ricky and Elaine for their own personal benefit and/or have
been misappropriated by one of the other entities they own or control.
46. Throughout the time period preceding this suit in which the Plaintiff and the
were attempting to negotiate regarding a split up of the Partnership, the
repeatedly represented that they had made cash infusions into the Partnership in order to make
payroll. Upon information and belief, these cash infusions came not from the
personal funds but rather from accounts under the name of Star and were paid out of funds
that had been accumulated from business that properly belonged to the Partnership. Therefore,
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
16
the should not be able to claim a credit for any of these alleged cash infusions unless
and until they prove the source of said funds.
7. Misconduct During Winding Up
47. Defendants misconduct has continued unabated during the winding up of the
Partnership and the liquidation of Cities. Plaintiff has learned that the after
expelling Dr. immediately re-opened the family clinic, which belonged to the
Partnership, and it is now operating under the name San Family Medicine Clinic
and is seeing patients that were previously treated exclusively by Dr. Furthermore, the
occupational practices of the Partnership and Cities have continued without interruption as
well. This is a breach of fiduciary duty and a blatant misappropriation of the business goodwill
Dr. established with his patients and a tortious interference with his business relationship
with those patients. More than 90 days has passed since the majority of the partners voted to
dissolve the Partnership, however, despite that vote, the Partnership is still operating as San
Family Medicine Clinic and no steps whatsoever have been taken to dissolve the
Partnership. Under Section 152.709 of the Texas Business Organizations Code, a Partnership
that is continuing in business 90 days after the vote to dissolve is prima facie evidence of an
agreement by the partners to continue in business. Because Plaintiff is being excluded from the
Partnership building and premises and prevented from seeing his patients, the have
effected a de facto expulsion of the Plaintiff from the Partnership, have misappropriated
Plaintiffs business goodwill and Partnership assets.
48. In an effort to make sure that the cash receipts of the Partnership actually made it
to the bank, Plaintiff had instructed an employee of the Partnership to collect all cash payments
and checks obtained during the day and from incoming mail and deposit such funds in the
Partnership account personally. On July 22, 2010, Amanda Plaintiffs assistant, was in
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
17
her private vehicle in the process of taking the checks and cash to the bank to be deposited in the
Partnership account when she was called on her cell phone from the clinic by Becky
an employee of the Partnership, informing her that Dr. Jerry was threatening to call the
police unless Ms. returned to the clinic with the cash and checks. When Ms.
refused, Dr. Jerry held Becky at the clinic against her will, and stated in her
presence that Ms. Morse is going down! Ms. Morse perceived this as a threat.
49. In addition, since the July 19
th
meeting, during which time Dr. had been
unable to be at the clinic because he was recuperating from major surgery (a fact of which
defendants were quite well aware), representatives of the have been informing
patients of the San Family Medicine Clinic that: Dr. went on vacation and
while there he called and said to shut down the clinic and he wont be back or We dont know
what happened to Dr. he just walked out one day and he hasnt come back or Dr.
died or Dr. had a nervous breakdown one Friday afternoon and he just
abandoned all of his patients. In addition, one or more representatives of the
informed patients that: we will not be practicing medicine the way Dr. did.
Furthermore, these representatives have been giving out other physicians business cards to
patients of the family medicine clinic when asked by patients for information on how to contact
Dr. This is an obvious attempt to take advantage of Dr. unavoidable absence to
blacken Dr. professional reputation, tortiously interfere with Dr. doctor-patient
relationship and misappropriate the goodwill that he has been able to cultivate with his patients.
50. Plans of Liquidation for the Partnership and for Cities were sent to Plaintiff on
September 3, 2010 along with a schedule of assets and liabilities and Notices of Meeting setting
a follow-up special meeting of the partners and shareholders for September 13, 2010. On
September 13th, Revised Plans of Liquidation were circulated and, at the special meeting, Drs.
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
18
Jerry and Ricky voted to adopt, and Dr. voted not to adopt, the Revised Plans of
Liquidation. At the special meeting, Drs. Jerry and Ricky promised to change the
phone message for the family medicine clinic to inform individuals calling the clinic that Dr.
had now established a new practice at a new location along with contact information for
Dr. Despite this promise, the phone message was never changed.
51. A review of the Revised Plans of Liquidation reveals that the schedule of assets
and liabilities fails to list as assets of the Partnership the clinic building, owned by the
Partnership and currently with over $500,000 in equity, accounts receivable and cash on hand,
and the purchase price of the Partnerships ownership interest in Renaissance Physicians
Organization which, upon information and belief, was repurchased from the Partnership in
October 2010. It appears that these omissions were intentionally made in an effort to undervalue
the Partnership and deny Dr. his pro rata share of the ownership of the Partnership.
52. As a result of the foregoing, Plaintiff has been forced to bring this action and to
retain attorneys for that purpose. All conditions precedent to the relief sought herein have
occurred or have been otherwise satisfied.
B. Causes of Action
1. Breach of Partnership Duties
53. By the acts alleged herein, Dr. Jerry and Dr. Ricky have
breached fiduciary duties of loyalty, care and good faith owed directly to Plaintiff as partners of
the Partnership by acting in bad faith and for the purpose of benefiting themselves and harming
Plaintiff by misappropriating Partnership property, clients and funds, by usurping Partnership
opportunities, by failing to keep and maintain accurate and reliable books and accounting
records, and by wrongfully and in bad faith pretending to dissolve the Partnership in order to
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
19
effect a de facto expulsion of Plaintiff from the Partnership, and by interfering with Plaintiffs
rights to Partnership information and records. These actions violate duties imposed by statute
and common law and constitute a breach of the implied or express terms of the Partnership
Agreement. Plaintiff is entitled to recover his actual damages for this breach of fiduciary duties
and further equitable relief including an accounting, disgorgement, constructive trust, and
injunction. Because Dr. Jerry and Dr. Ricky acted knowingly, intentionally,
maliciously and with reckless disregard of Plaintiffs rights, Plaintiff is further entitled to
exemplary damages. Plaintiff is further entitled to recovery of reasonable and necessary
attorneys fees pursuant to TCPRC 38.001. Presentment has been made. All conditions
precedent have been satisfied or have occurred.

2. Equitable Accounting/Declaratory Judgment
54. Plaintiff is entitled to an order requiring Defendants to render an accurate
accounting of the Partnership and to disgorge any profits. Plaintiff further requests that the Court
appoint a special master to supervise and certify the accuracy of the accounting.
55. As shown herein, justiciable issues exist regarding the rights and status of the
Plaintiff in relation to his Partnership interest and interest in Cities. Pursuant to Chapter 37 of
the Texas Civil Practice & Remedies Code, Plaintiff seeks a declaratory judgment determining:
a. the status of each partners capital account as of the date Dr. Ricky was
admitted as a partner;
b. the rights of each partner upon wind up of the Partnership;
c. the final accounting of the Partnership.
56. Pursuant to 37.009 of the Texas Civil Practices & Remedies Code, Plaintiff is
entitled to an award of attorneys fees and costs.
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
20

3. Breach of Fiduciary Duties in Cities
57. In addition, Dr. Jerry and Dr. Ricky as controlling
shareholders of Cities, have breached fiduciary duties owed as controlling shareholders
directly to Plaintiff and/or caused Cities to breach fiduciary duties owed by it to Plaintiff by
virtue of his share ownership and/or arising from the personal confidential relationship. Dr. Jerry
and Dr. Ricky acted in bad faith and for the purpose of benefiting themselves
and harming Plaintiff by diminishing the value of Plaintiffs investment in Cities, interfering
with his legal rights and reasonable expectations as a shareholder of Cities, and denying
Plaintiff the payment of constructive dividends from Cities that Dr. Jerry and Dr.
Ricky paid to themselves. Plaintiff is entitled to recover his actual damages for this
breach of fiduciary duties and further equitable relief including an accounting, disgorgement,
constructive trust, and injunction. Furthermore, Plaintiff is entitled, under sections 152.608 and
11.054 of the Texas Business Organizations Code to have the court supervise the winding up of
the Partnership and Cities or to have the court appoint a person to carry out the winding up of
the Partnership and Cities. Because Dr. Jerry and Dr. Ricky acted
knowingly, intentionally, maliciously and with reckless disregard of Plaintiffs rights, Plaintiff is
further entitled to exemplary damages.

4. Derivative Claim
58. Dr. Jerry and Dr. Ricky have breached fiduciary duties to
Cities that they owe as officers, directors, and controlling shareholders by misappropriating
assets, excessive compensation, and the other misconduct alleged herein. Cities has suffered
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
21
actual damages as a result of the breach of fiduciary duties. Cities is entitled to recover actual
damages for this breach of fiduciary duties and further equitable relief including disgorgement,
constructive trust, and injunction. Because Dr. Jerry and Dr. Ricky acted
knowingly, intentionally, maliciously and with reckless disregard of Plaintiffs rights, Plaintiff is
further entitled to exemplary damages. Plaintiff is further entitled to his reasonable attorneys
fees.
59. Plaintiff has standing to bring a derivative action on behalf of Cities. All
conditions precedent have been satisfied. Plaintiff is entitled to recover his expenses and
reasonable and necessary attorneys fees pursuant to section 21.561 of the Texas Business
Organizations Code. Cities is a closely-held corporation with less than 35 shareholders,
and no shares listed on a national securities exchange or regularly quoted in an over the counter
market by one or more members of a national securities association. Pursuant to section
21.563(a) of the Texas Business Organizations Code, Plaintiff requests that, in the interests of
justice, this action be treated by the Court as a direct action brought by the plaintiff for his own
benefit and that the recovery be paid directly to plaintiff. Furthermore, Plaintiff is entitled to
recover his reasonable and necessary attorneys fees and expenses pursuant to BOC 21.561.

5. Shareholder Oppression

60. Dr. Jerry and Dr. Ricky exercise dominance and control over
Cities through their powers as the majority shareholders and officers and directors of
Cities. The acts alleged herein constitute a continuing pattern of shareholder oppression in that
Dr. Jerry and Dr. Ricky have repeatedly violated Plaintiffs rights as a
shareholder, substantially defeated Plaintiffs objectively reasonable expectations as a
shareholder that were central to his decision to join the venture, and acted in a manner
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
22
constituting burdensome, harsh and wrongful conduct, a lack of probity and fair dealing in the
affairs of the company to the prejudice of Plaintiff, and/or a visible departure from the standards
of fair dealing and a violation of fair play on which every shareholder who entrusts his money to
a company is entitled to rely. As a result, Plaintiff seeks his actual damages, exemplary damages,
reasonable and necessary attorneys fees, pre and post judgment interest, court costs, injunctive
relief, and requests that a compulsory buy-out be ordered at a fair price determined by this Court
and/or other relief necessary to do equity. Because Dr. Jerry and Dr. Ricky
acted knowingly, intentionally, maliciously and with reckless disregard of Plaintiffs rights,
Plaintiff is further entitled to exemplary damages. Plaintiff is without adequate remedy at law.

6. Knowing Participation/Joint and Several Liability
61. Upon information and belief, FLP, Star and/or had
actual knowledge, by virtue of the fact that Dr. Jerry Dr. Ricky and/or
Elaine were officers, directors, partners, controlling shareholders and/or owners of
these entities, that they were receiving funds, and performing work for and billing clients that
rightfully belonged to the Partnership or to Cities, and had been misappropriated or diverted
by the Under established principles of Texas law, FLP, Star and/or
knowingly participated in and aided and abetted Dr. Jerry and Dr. Ricky
breach of their fiduciary duties to Plaintiff and are jointly and severally liable to
Plaintiff for any and all misappropriated Partnership funds or property which was transferred to
them.

7. Tortious Interference

62. After Defendants wrongfully forced Plaintiff out of the Partnership, they
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
23
maliciously interfered with his ability to continue practicing medicine by preventing his patients
from finding him. Plaintiff had an on-going or potential contractual relationship to provide
medical care with his patients at San Family Medicine Clinic, L.L.P. Many of these
patients would want to, and did want to, continue that relationship with Plaintiff even after he
could no long practice medicine at the Partnership. Defendants had reason to know of Plaintiffs
contractual relationships with his patients. Defendants willfully and intentionally interfered with
Plaintiffs contractual relationship with his patients. Defendants interference proximately caused
injury to Plaintiff, which resulted in the following actual loss or damage: lost revenues from the
practice of medicine from patients who sought medical care elsewhere or who have transferred
their care to other physicians permanently. Plaintiff seeks unliquidated damages within the
jurisdictional limits of this court. Plaintiffs injury resulted from Defendants actual malice or
actual fraud, which entitles Plaintiff to exemplary damages under Texas Civil Practice &
Remedies Code section 41.003(a).

8. Defamation

63. Defendants, or their authorized agents, published statements by oral
communication asserting as a fact that Dr. had died, had a nervous breakdown and
abandoned his patients or abandoned his practice at the clinic for no apparent reason. The
statements involved a private matter. The statements referred to Plaintiff by name. The
statements were defamatory because they unambiguously asserted that Dr. was mentally
unstable, erratic, irresponsible, undependable and that he had breached his professional
responsibilities to his patients and abandoned his medical practice for frivolous or irrational
reasons. The statement was false because Dr. did not abandon, and had no intention of
abandoning, his practice and he had not died. Defendants false statement caused injury to
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
24
Plaintiff, which resulted in the following damages: injury to reputation, lost revenues from the
practice of medicine from patients who sought medical care elsewhere or who have transferred
their care to other physicians permanently (i.e. loss of past and future income), loss of personal
standing in the community, personal humiliation, and mental anguish and suffering. Plaintiff
seeks damages within the jurisdictional limits of this court. Plaintiffs injury resulted from
Defendants malice, which entitles plaintiff to exemplary damages under Texas Civil Practice &
Remedies Code section 41.003.

VII. Prayer
64. For these reasons, Plaintiff asks that the defendants be cited to appear and answer
and that Plaintiff have judgment against the Defendants for the following:
a. A writ of mandamus or permanent injunction ordering defendants to make the
Partnership records and the corporate books and records of Cities available for
inspection;
b. Actual, and exemplary damages as allowed by law;
c. An order requiring an accounting, together with
d. Equitable relief including disgorgement, injunction, constructive trust, forced buy-out,
accounting, declaratory relief, and court supervision or appointment of a receiver and/or a
special master to supervise the winding up and final accounting of the Partnership and
Cities;
e. Reasonable and necessary attorneys fees and expenses;
f. Prejudgment and post-judgment interest as allowed by law;
g. Costs of suit; and
h. All other relief, general and special, legal and equitable, to which Plaintiff may be
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
25
entitled.
65. Plaintiff demands his right to trial by jury.
IX. Written Discovery
66. Pursuant to the Texas Rules of Civil Procedure, each of the Defendants must respond
to the following requests for written discovery within 50 days after service of this Petition:
a. Pursuant to Rule 194, each Defendant is requested to disclose the information or material
described in Rule 194.2(a)-(i), inclusive.
b. Pursuant to Rule 198, each Defendant must admit or deny the following:
1. Plaintiff owns 50% of the shares of Cities.
2. Exhibit A is genuine.
3. Exhibit B is genuine.
4. Exhibit C is genuine.
5. Exhibit D is genuine.
6. Exhibit E is genuine.
7. Exhibit F is genuine.
8. Exhibit G is genuine.
9. Exhibit H is genuine.
10. Exhibit I is genuine.
11. Plaintiff has made a written demand for inspection of corporate books and records
of Cities, stating a proper purpose.
12. Cities refused to permit Plaintiff to inspect all the corporate books and records
requested by Plaintiff.
c. Pursuant to Rule 197, respond to each of the following written interrogatories under oath:
1. If you have denied any of the requests for admissions, state in detail the reasons
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
26
why and what you contend the true facts are with regard to the matter about which
the admission was requested.
2. State the fair value of Cities and the basis for your calculation, the method of
valuation, and describe all documents or financial information used to answer.
3. Identify the current, and all prior, accountant or bookkeeper of Cities and all
other persons who have knowledge of the financial performance of the
corporation.
4. Identify all persons or entities with whom any of the Defendants has discussed or
submitted information relating to the value of Cities, including banks and
other lenders, brokers, prospective investors or shareholders, potential buyers and
creditors.
5. State the date, amount, reason and nature of the transaction for each and every
cash disbursement or other benefit or transfer from Cities to each officer,
director or shareholder from inception to present, including salary, commissions,
bonuses, loans, gifts and any other transfer or transaction whatsoever, including
personal use of corporate assets.
6. State whether Cities or the Partnership has agreed to advance attorneys fees
or other expenses related to this action to Dr. Jerry Dr. Ricky
and/or Elaine and if so, state the complete terms and conditions under
which such advancement is made, and identify the persons who made the decision
on behalf of the corporation to make such advancement.
d. Pursuant to Rule 196, produce the following documents on the date that your response is
due at the offices of the undersigned or at such other place that may be mutually agreed.
These requests include electronic data and records. Please produce financial and
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
27
accounting data in native format and textual records as searchable PDFs.
1. The complete corporate book for Cities, including but not limited to the
certificate of formation, all organizational documents, the by-laws, all minutes of
meetings or consents in lieu of meeting, all resolutions, all shareholder
agreements, all stock certificates and the complete shareholder ledger or other
records showing the shareholder names and all issuances and transfers of shares.
2. All financial records of Cities, including the general ledger, all schedules,
balance sheets, income statements, profit and loss statements, reports from
accountants, accountants work papers, interim and draft statements, or otherwise,
including for the Groves location.
3. All financial records of the Partnership, including the general ledger, all
schedules, balance sheets, income statements, profit and loss statements, reports
from accountants, accountants work papers, interim and draft statements, or
otherwise.
4. Any and all business records of the Partnership, including but not limited to,
records of all cash payments made by patients, co-pays, cash receipts, insurance
reimbursements, the daily ledger of all cash payments collected from patients, and
invoices.
5. Any and all credit card statements, American Express statements, invoices, and
any other documents evidencing expenses, disbursements, debits or outlays of the
Partnership.
6. All bank accounts statements since 2000 for any and all bank accounts on which
Dr. Jerry Dr. Ricky Elaine or Dr. David Wayne
are signatories, and the operating, checking, business and/or savings
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
28
accounts for the Partnership, Cities, FLP, Star and
7. All financial records of Star, including the general ledger, all schedules,
balance sheets, income statements, profit and loss statements, reports from
accountants, accountants work papers, interim and draft statements, or otherwise.
8. All financial records of including the general ledger, all schedules,
balance sheets, income statements, profit and loss statements, reports from
accountants, accountants work papers, interim and draft statements, or otherwise.
9. All data from the medical billing software for the Partnership in its original
electronic format, whether designated as Industrial or San
Family Medicine Clinic and regardless of where it is stored or maintained.
10. All data from the medical billing software for Cities in its original electronic
format, whether designated as Industrial Mobile,
International, or Groves and regardless of
where it is stored or maintained.
11. All state and federal tax returns or reports of Cities and the Partnership.
12. All payroll records of Cities, the Partnership, Star and
13. All documents showing or relating to any transaction, transfer or disbursement
involving Cities, the Partnership and the
14. All bank or brokerage account records, statements, and check or account registers
for Cities, the Partnership, Star, the FLP and
15. All documents stating, reflecting or relating to the value of the Partnership and
Cities or of its shares, including but not limited to, internal memoranda, offers
to buy or offers to sell, appraisals, financial statements of any defendant, loan
applications, credit applications, or any other document relating to value.
Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
29
16. Invoices and billing records of any attorney representing Cities or the
Partnership for any services in any way relating to Plaintiff.
17. Invoices and billing records of any accountant, bookkeeper, or tax preparer who
has provided services to the Partnership or Cities.
18. Any written commitment, promise, or stated obligation made by the to
the Partnership or Cities.
19. Personal financial statements and tax returns for the
20. All records, including, but not limited to, invoices, check stubs, records of
payment, contracts or any other documents related to Dr. Jerry and/or
Dr. Ricky relationship with Minu Rx.
21. All records evidencing or recording use of mobile medical units (whether trucks,
trailers or semi tractor-trailers), regardless of which defendant or entity was using
such mobile medical unit at the time, including, but not limited to, any and all
logs, invoices, payments, mileage reports, gas receipts, or any other item or
document evidencing use of such mobile medical units.
22. All records or documents related to any retirement, profit-sharing or other
employee benefit plan for which the Partnership or Cities were or are
administrators or other fiduciaries, including, but not limited to, the PayChex
401(k) Plan for Drs. and Jerry
23. All records or documents related to the purchase of stock or ownership interests in
Renaissance Physicians Organization and/or Pasadena I.P.A. from the
Partnership, whether the sale was merely contemplated or, in fact, consummated.

Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com
30
Respectfully Submitted,

FRYAR LAW FIRM, P.C.




__________________________
Eric Fryar
SBN 07495770
1001 Texas Ave. Ste 1400
Houston, Texas 77002-3194
Tel. 888-481-9995
281-715-6396
Main Fax: 281-715-6397
Direct Fax: 281-605-1888
Email: efryar@fryarlawfirm.com
ATTORNEYS FOR PLAINTIFF



Names redacted to protect privacy
www.FryarLawFirm.com
Fryar Law Firm, P.C.
1001 Texas Ave., 14th Floor
Houston, TX 77002
(888) 481-9995
www.ShareholderOppression.com

Das könnte Ihnen auch gefallen