Amended Complaint - Insurance Coverage Blog

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elation to its business.106. Defendants were obligated to provide an account to Plaintiff for the amounts of allincome and debits in the operation of the SKG and to pay Plaintiff such monies as are due to thepartners of the SKG.107. Defendants continue to perpetrate breaches, illegalities, and wrongs againstPlaintiff by withholding money that belongs to the Plaintiff.108. Plaintiff, as one partner, is unable to take control of the partnership and is unable totake action to prevent such damages as being inflicted by Defendant partners of the SKG.109. As a proximate result of the breach of fiduciary duties, Plaintiffs suffered substantialdamages as alleged herein.Count IV - Usurpation110. Plaintiff adopts by reference herein the allegations contained in the foregoingparagraphs.111. The Defendants through their actions have prevented the Plaintiff from procuringother legal work and representing other clients as well as being associated to do legal work withother law firms.112. As a result of the Defendants’ actions, the Plaintiff has suffered substantialdamages.Count V - Conversion113. Plaintiff adopts by reference herein the allegations contained in the foregoingparagraphs.114. Defendants currently possess monies due to Plaintiff as its share of partnershipPage 18 of 25
profits.115. Defendants wrongfully possess for their own use and exercise dominion overmonies due to Plaintiff and refuse to pay those monies due to the Plaintiff.116. Plaintiff has demanded that the property be turned over to it.117. Defendants have refused to turn over the property that rightfully belongs toPlaintiff.118. These acts also constitute such egregious and wrongful conduct as to justifypunitive damages.119. As a result of the Defendants’ actions, the Plaintiff has suffered substantialdamagesCount VI - Intentional Interference with Prospective Business Advantage120. Plaintiff adopts by reference herein the allegations contained in the foregoingparagraphs.121. Defendants intentionally and willfully committed acts that were calculated tocause damage and loss to Plaintiff.122. Defendants intentionally interfered with Plaintiff’s established rights as a partnerin the SKG.123. Actual damages resulted in that Defendants attempted to remove the Plaintiff as apartner and deny the Plaintiff rights in the partnership.124. Losses occurred as Plaintiff has been denied monies due after full performance onbehalf of the SKG.125. The modus operandi of Defendants is to lure the work of others through falsePage 19 of 25
Page 1: IN THE CIRCUIT COURT OF LAFAYETTE C
Page 4 and 5: may be served with process by servi
Page 6 and 7: 22. Plaintiff’s work and performa
Page 8: Plaintiff’s right to arbitration.
Page 11: 55. Jones and Funderburg asked for
Page 14 and 15: paid by State Farm for settlement o
Page 16 and 17: 90. This conduct is set forth in at
Page 21 and 22: 135. Defendants, as partners, are c
Page 23 and 24: action of some of the Defendants an
Page 25: 165. The Plaintiff demands all fore

Amended Complaint - Insurance Coverage Blog

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