I N T H E D IS T R IC T COURT OF CLEVELAND
STATE OF OKLAHOMA
COUNTY
HI TECH AIR SOLUTIONS, LLC,A
domestic limited liability company;
RAY ROBISON, an individual,
Plaintiffs;
case
No.aJ' aot 5 . Lttt- y
vs.
HEALTHY HABITATS, LLC, A
foreign limited liability company;
CARL GRIMES, an individual,
Defendant,
SUMMONS
T<rthe above-named Defendant
Carl Grimes
1811 S QuebecWay
Suite 99
Denver, CO 80231
You have been sued by the above-named Plaintiff and you are directed to file a wdtten Answer to
the attached Petition in the Court at the above addtess within twenty (20) days after service of this
sunlmons upon you, exclusive of the day of service. Within tfre same time, a copy of your Answer
must be deliveted ot mailed to the attorney for the Plaintiff.
answet the Petition within the time stated, judgment wili be rendered against you with
dayof
&r'tA
,201s.
oBA #20233
SuiteA
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.SUCHATTORNEY SHOULD BE CONSULTED
IMMEDIATELY SO THAT AN ANSWER MAY BE FILED WITHIN THE TIME LIMIT
STATED IN THE SUMMONS.
lftSlfinBlsEffiprylu'
APR
e22015
HI TECH AIR SOLUTIONS LLC,a.
domesticlimited liability company;
RAY ROBISON, an individual,
'",,FJl'l*Bfl
6i,Etfr%"
Plaintiffs;
No.C^]' aO t5' qtl' Y
case
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 counselin this casefot Plaintiffs, Hi Tech Ait
Solutions,T.TC, and RayRobison.
I certify that I "m admitted to practice in this Coutg
4^LL- Lol 6
Date
a- '6
Chris Hammons, OBA #20233
LAIRD Flamrtot'ls Larno, PLI,C
1230 S.\ilfl89d'St., SuiteA
OHahoma CitY, OK 73739
405'703.4567
TelePhone
405.703.4061
Facsimile
E-mail: Chris@lhllaw'com
ATTONNBVTORPL{INTIFF
rNrHEDrsrRrcrcouRroF.LE'ELAND
ffifif$tr$6i]fiF$r
. u
FrLFjf,r
srATE, OF OKLAHOMA
ApR
zeZ0tf
Hr TECH AIR SOLUTTONS, LLC, a
domestic limited liability company;
RAY ROBISON, an individual,
co*FcTl,?
Bff6R
El,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 causeof action against Defendants,
Healthy Habitats, TJ.C, a foreign iimited Lability company and Carl Grimes, an individual
@ereinafter Defendants) and state as follows:
THE
7. Plahtiff
PARTIES
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 salestearnsand 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 statementsconcerning 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.
77. CurlGdmes published false statementsthat Hi Tech Air Solutions is a scdh.-+
_
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 defarneHi 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 falsestatementsabout 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 statemefltswere 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 reasonablycareful person would use under the
citcumstances to determine vrhether the statementswere true or false.
28. CarLGdmes's statementscausedPlaintiffs 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
c- 'F
-
-re'i{
CAUSE OF ACTION:
TORTIOUS
INTERFERENCE
coNTRAcT
32. ?laintiffs incotporates asif firlly restatedali of the allegationspreviously written.
33. Plaintiffs had numerous purchasing contracts with customers.
WITH
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 JURY TRIAL
46. The Plaintiff domandsa juy tial for all issuesof fact presentedby this action'
-
e- 'b
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 requiredfot 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\doNS
LaIRD,PLLC
1230S.W89hSt.,SuiteA
OklahomaCity,OK 73739
Telephone 405.703.4567
405.7A3.4061
Facsimile
E-mai} [email protected]
Arroruqnv noRPI",\NI:FF
ATTOR}{EYLIEN
CLAIMED
ao
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