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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

(Pensacola Division)

INTELLIGENT MANAGEMENT 

SOLUTIONS, LLC d/b/a IMS 

EXPERTSERVICES,

4400 Bayou Boulevard, Suite 6

Pensacola, Florida 32503, 

Plaintiff,

v.

JAY LINK,

P.O. Box 210

Minong, Wisconsin 54859

 Defendant.

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CASE NO.: 

JUDGE: 

COMPLAINT AND DEMAND FOR JURY TRIAL

NOW COMES Plaintiff Intelligent Management Solutions, LLC d/b/a 

IMS ExpertServices (“IMS”), by and through its undersigned counsel, and 

for its Complaint against Defendant Jay Link (“Mr. Link”), hereby alleges

and states as follows:

1. At all times relevant hereto, Plaintiff IMS was and is a limited 

liability company organized under the laws of the State of Florida, having its 

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principal place of business in Pensacola, Florida. Plaintiff IMS was and is in 

the business of providing expert consulting services to consumers. 

2. At all times relevant hereto, there was a single member of said 

limited liability company, namely, Expert Holdings, LLC, which is a limited 

liability company organized under the laws of the State of Texas and having 

its principal place of business in Texas. Further, at all times relevant hereto, 

Expert Holdings, LLC, consisted of two members, IMS Blocker, Inc., which 

owns 80% of Expert Holdings, LLC, and IMS HoldcoFL, Inc., both being 

corporations organized under the laws of the State of Florida. Said entities 

are the only members of Expert Holdings, LLC. 

3. Accordingly, all entities pertaining to Plaintiff IMS, including its 

members, holding companies, and related entities, are citizens of the States of 

Texas or Florida and have their principal place of business in Texas and/or 

Florida.

4. At all times relevant hereto, Defendant Jay Link was and is a 

citizen of the state of Wisconsin, residing in Washburn County, Wisconsin. 

5. This Court has subject matter jurisdiction over this action 

pursuant to 28 U.S.C. § 1332 because Plaintiff and Defendant are citizens of 

different states, including any members of Plaintiff limited liability company,

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and the amount in controversy exceeds Seventy-Five Thousand Dollars 

($75,000.00). 

6. This Court has personal jurisdiction over Defendant as 

Defendant solicited and engaged with Plaintiff IMS in Florida for its business

services, and Defendant has other such other minimum contacts with the State 

of Florida such that he is subject to suit in this State. 

7. Venue is proper under 28 U.S.C. § 1391 because Plaintiff IMS is 

a limited liability company organized under the laws of the State of Florida, 

having principal place of business in Pensacola, Florida, and a substantial part 

of the events or omissions giving rise to this claim occurred in this judicial 

district. 

8. On or about February 16, 2017, Plaintiff and Defendant, through 

its agents, servants, employees, or assigns, entered into a services contract for 

the retention and use of an expert consultant to assist, advise, and render 

opinions to Jay Link in connection with the case of Jay E. Link v. John E. 

Link, Troy J. Link, John A. Hermier, Washburn County Circuit Court, 

Wisconsin, Cir. Ct. No. 2011CV62.

9. On or about February 16, 2017 Defendant Link executed 

engagement letters (hereinafter the “Contracts”) with Plaintiff IMS which set 

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forth the scope and terms of Plaintiff IMS’s services, as well as all payment 

obligations. Specifically, as consideration for the engagement of expert 

witnesses, Defendant agreed to pay the expert consultants’ hourly rate and 

Plaintiff IMS’s fees directly to Plaintiff IMS. 

10. Pursuant to the terms of the Contracts, Plaintiff and Defendant 

agreed invoices would be presented to Defendant Link, or his agents, by 

Plaintiff IMS on a monthly basis, and payment would be due within thirty (30) 

days of the invoice date. 

11. A true and accurate copy of the Contracts which existed between 

Plaintiff IMS and Defendant Jay Link will be separately filed with Court under 

seal. See Exhibit A to Plaintiff’s Complaint.

COUNT I: BREACH OF CONTRACT

12. Plaintiff IMS hereby incorporates the allegations of Paragraphs 

1 through 12 of the Complaint as Paragraphs 1 through 12 of Count I of the 

Complaint, as if fully set forth herein.

13. From February 16, 2017, or thereabouts, Plaintiff IMS and the 

expert consultants it identified to provide services to Defendant Link rendered 

services as requested and pursuant to the Contracts. In association with the 

provision of said services, Plaintiff IMS provided to Defendant itemized 

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invoices for services. Those invoices for services shall be filed separately 

with the Court under seal. See Exhibit B to Plaintiff’s Complaint.

14. Despite the terms of the contracts in question and fulfillment of 

contractual responsibilities by Plaintiff and its agents, Defendant has failed 

and refused to provide the compensation required under the contract for 

services rendered. At present, Defendant is indebted to Plaintiff in the amount 

of Sixty Thousand Nine Hundred Thirty-Five Dollars and Ten Cents 

($60,935.10) for base compensatory damages, not including interest, costs, 

attorneys’ fees, or other damages, all of which Plaintiff IMS is entitled to 

pursuant to the contract in question. See Exhibit A.

15. Pursuant to the parties’ agreement, Defendant is also indebted to 

Plaintiff for interest, attorneys’ fees, and other costs associated with bringing 

this litigation, all of which Plaintiff IMS is entitled to pursuant to the contract 

in question and when combined with base compensatory damages totals an 

amount in controversy in excess of $75,000.00. See Exhibit A.

16. All conditions precedent for Plaintiff to receive payment of the 

amounts owed pursuant to the Contracts have occurred.

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17. Despite reasonable demand, Defendant has failed and refused to 

satisfy this debt, and has forced Plaintiff to seek the services of an attorney, 

thereby breaching the Contracts, and causing Plaintiff to sustain damages.

COUNT II: UNJUST ENRICHMENT

18. Plaintiff IMS hereby incorporates the allegations of Paragraphs 

1 through 18 of Count I of the Complaint as Paragraphs 1 through 18 of Count 

II of the Complaint, as if fully set forth herein.

19. Plaintiff IMS provided Defendant with expert consultants for use 

by Defendant, thereby conferring a benefit on the Defendant.

20. Defendant has failed to compensate Plaintiff for the benefit 

conferred through the provision of the subject experts and the fulfillment of 

other duties by Plaintiff.

21. Under the circumstances, it would be unfair and unjust for 

Defendant to not compensate Plaintiff for the benefit of utilizing said experts

and the benefits conferred by the services of Plaintiff.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff IMS respectfully requests an award of 

compensatory damages, pre-judgment and post-judgment interest, attorneys’ 

fees, court costs, and any additional relief to which Plaintiff may be entitled. 

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JURY DEMAND

A trial by jury is hereby demanded.

Respectfully submitted,

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Brian P. Henry, Esq. (89069)

ROLFES HENRY CO., LPA

5577 Broadcast Court

Sarasota, Florida 34240

Phone: (941) 684-0100

Fax: (941) 684-0109

Service: bhenry@rolfeshenry.com

 srainwater@rolfeshenry.com

Attorney for Plaintiff

Intelligent Management Solutions, 

LLC

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