Filed: 8/23/2023 9:00 AM

Michael Gould

District Clerk

Collin County, Texas

By Shelby Rawa Deputy

CAUSE no471 -04925-2023 Envelope ID: 78824757

PRUVIT VENTURES, INC., § IN THE DISTRICT COURT

§

Plaintiff, §

§

v. § JUDICIAL DISTRICT

§

BRIANNA BLACKBURN, §

§

;

Defendant. § COLLIN COUNTY, TEXAS

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW Plaintiff, Pruvit Ventures, Inc. (“Pruvit”), and files this its Verified Original

Petition and Application for Temporary Restraining Order, Temporary Injunction, and Permanent

Injunction against Defendant Brianna Blackburn. In support thereof, Pruvit respectfully shows the

Court the following:

I

DISCOVERY LEVEL AND RULE 47 STATEMENT

1 Pruvit intends to conduct discovery under Level 3, pursuant to Rule 190.3 of the

TEXAS RULES OF CIVIL PROCEDURE. Pruvit affirmatively pleads that this lawsuit is not governed

by the expedited action process under Rule 169 of the TEXAS RULES OF CIVIL PROCEDURE, as

Pruvitstates it seeks monetaryrelief over $1,000,000.00, including damages of any kind, penalties,

costs, expenses, pre-judgment interest and attorney fees, and ‘for all other relief to which Pruvit

maybe entitled. See TEX. R. Civ. P. 47(c)(4), (d). As this lawsuit is at its inception and discovery

has not yet been conducted, Pruvit reserves the right to modify and/or amend the foregoing

statement of relief.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Pagel

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 1 of 15 PageID #: 35
I.

PARTIES

2. Pruvit Ventures, Inc. is a domestic corporation authorized to conduct business in

the state of Texas with a principal place of business located in Collin County, Texas at 901 Sam

Rayburn Hwy, Melissa, Texas 75454.

3: Defendant Brianna Blackburn (“Blackburn”) is an individual and a resident of

Crawford County, Ohio. Blackburn resides at her home address of 7182 Leesville Road, Crestline,

OH 44827, and may be served with process by serving the Texas Secretary of State, 1019 Brazos

Street, Austin, Texas 78701 as her agent for service, because Defendant Brianna Blackburn has

engaged in business in Texas but has not designated or maintained a registered agent for service

of process in Texas. TEX. Civ. PRAC. & REM. CODE § 17.044(b). Alternatively, Brianna Blackburn

may be served at her residence located at 7182 Leesville Road, Crestline, OH 44827.

Ii.

JURISDICTION AND VENUE

4. This Court has jurisdiction over the subject matter herein as the amount in

controversy is within the jurisdictional limits of the Court. See TEX. R. Civ. P. 47(6).

5: This Court has personal jurisdiction over Blackburn under the Texas Long-Arm

Statute (TEX. Clv. PRAC. & REM. CODE § 17.042, et. seq.) because Defendant contracted with a

Texasresident and has committed a tort, in whole orin part, against Pruvit in Texas as described

in greater detail herein. Pruvit’s claims and causes of action arise out of Blackburn’s purposeful

actions directed toward Pruvit in the State of Texas. Further Blackburn and Pruvit contractually

agreedthatall disputes betweenthe Parties are subject to Texas law and shall be resolved in Courts

located in Collin County, Texas.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 2

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 2 of 15 PageID #: 36
6. Venue is proper in Collin County, Texas pursuant to §15.002(a)(1) of the TEXAS

CIVIL PRACTICES & REMEDIES CODE as all or substantially all of the events giving rise to Pruvit’s

causes of action arose in Collin County and Defendant agreed to courts in Collin County, Texas.

as the exclusive forum for resolution of disputes. See TEX. CIV. PRAC. & REM. CODE §15.002(a)(1).

IV.

STATEMENT OF FACTS

A. PRUVIT VENTURES, INC. AND ITs AGREEMENTS WITH ITS PROMOTERS.

7. Pruvit is a worldwide leader in ketone technology and a pioneerin selling ketone

products. Pruvit is a community-based marketing companythat has independent promoters,called

Pruvers, that market and sell its unique products throughoutthe country.

8. Overtime,as senior Pruvit promoters bring in new promoters,an up-line and downline structure is created. In many cases, Pruvit’s successful Pruvers have created extensive

downlines of fellow Pruvers totaling in the hundreds.

9. Pruvit invests significant amounts of time, money, and resources into protecting its

technology and the integrity of its community of representatives. Whena

Pruver leaves Pruvit, it

can adversely affect both the compensation of other Pruvers as well as the profits of Pruvit.

10. As part of Pruvit’s business,it holds an exclusive sub-license to market ketone

productsthatutilize BHB salts. For years, Pruvit has actively marketed and sold a product line that

utilizes this ketone technology. In orderto protect this license, the technology, Pruvit’s customers,

and its Pruvers, Pruvit requires each Pruver to agree to its Statement of Policies and Procedures

(the “Pruver Agreement”). ‘To maintain active Pruverstatus and to be eligible for any commissions

and/or bonuses, Pruvers must agree to the terms of the current Pruver Agreement, which Blackburn

did.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page3

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 3 of 15 PageID #: 37
11. The Pruver Agreement, in pertinent part, prohibits a Pruver (such as Blackburn),

during the term of the agreement and for a period of time following separation from Pruvit, from

the following:

» Promoting products for other companies that compete with products

offered by Pruvit;

= Recruiting Pruvit promoters and customers for any other direct sales or

network marketing business;

= Engaging in discourteous, deceptive, misleading, unethical or immoral

conduct and practices in connection with Pruvit and its products and

services; and

= Promoting non-Pruvit products or services on the same social media site

as Pruvit’s products.

12. Defendant Blackburn is a former Pruver who voluntarily terminated her position

with Pruvit on or about July 14,2023. The Pruver Agreementprohibits Defendant Blackburn from

recruiting Pruvers or customers to engage with or become a promoter, customer or distributor for

another company.

13. Defendant Blackburn is actively engaging in efforts to promote and sell products

of a competitor company of Pruvit named Green Compass, Inc. (“Green Compass”). Green

Compass develops and promotes wellness products competitive with those of Pruvit.

14. Defendant’s efforts are a breach of paragraph 3.6 of the Pruver Agreement which

prohibits the promotion of competitive products and the promotion of non-Pruvit products and

services on the same social media sites as Pruvit’s products and services. Defendant is aggressively

recruiting Pruvit’s customers and promoters in further violation of her contractual obligations to

Pruvit. Defendant Blackburn engaged in this conduct prior to and after the termination of her

promoter relationships with Pruvit.

15. Defendant has recruited current Pravers to join Green Compass via Facebook

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 4

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 4 of 15 PageID #: 38
posts and personal interactions. Defendant’s various online and social media accountsare replete

with examples of such breaches. Defendant has posted videos promoting Green Compass over

Pruvit and invited current Pravers to participate and comment. For example:

Brianna Blackburn ove

jily 21 at B13 AM

Beheaeliclsiiu

We'll be hosting an opportunitycall to join our Green

eeRCEeeLal

EST! This is an opportunity you don't want to miss out ©”on! Comment for deets!!!!

00: T comment

0) Like (2 comment > Share

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Cannot WAIT to share with your network!

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PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 5

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 5 of 15 PageID #: 39
16. Defendant is aware that the individuals she is recruiting away from Pruvit are

subject to and bound by non-competition and confidentiality clauses in the Pruver Agreement —

the same contractual obligations that Defendantis bound to follow. Despite such knowledge and

awareness, Defendanthas proceeded to actively solicit other Pruvers and encourage them to leave

Pruvit and purchase and sell competing products.

17. Pruvit recently became aware of Defendant’s improper and malicious efforts

because some Pruvers have rebuffed Defendant. The full breadth of Defendant’s misconduct is

unknown.

18. Defendant’s conduct constitutes a breach of the Pruver Agreement. Defendant’s

conductalso constitutes tortious interference with Plaintiff's contracts, specifically the agreements

with Plaintiffs Pruvers andits current and future customers. There is also a reasonable probability

Pruvit would have recruited and contracted with more Pruvers and customers had Defendantnot

breached her contractual obligations.

19, Discovery of Green Compass’ distributor and customer lists is expected to reveal

Pruvers and Pruvit customers who were not only recruited, but left Pruvit, and joined Green

Compass due to Defendant’s improper conduct. Pruvit also anticipates that upon the completion

of its investigation, additional entities and/or individuals will be identified to have participated or

conspired with Defendant in the misconduct made the subject of this suit.

Vv.

CAUSES OF ACTION

20. The factual allegations set forth in the foregoing paragraphs are incorporated herein

by reference for all purposesasif set forth in full:

COUNT 1—BREACH OF CONTRACT

21. Pruvit and Defendant entered into the above-referenced Pruver Agreement. The

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 6

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 6 of 15 PageID #: 40
Pruver Agreement specifically provides, in pertinent part, that Defendant is not to: (1) promote

products for other companies that compete with products offered by Pruvit; (2) solicit Pravit

promoters and customers for any other direct sales or network marketing business; (3) engage in

discourteous, deceptive, misleading, unethical or immoral conduct and practices in connection

with Pruvit and its products and services; and (4) promote non-Pruvit products or services on the

samesocial media site as Pruvit’s products and services.

22. Pruvit performed under its agreements with Defendant by supplying her with

services and productsto sell and by giving her a platform to generate income.

23. Defendant Blackburn has breachedthe Pruver Agreement by promoting andselling

competitive products, including on the same social media site as those products and services of

Pruvit, and recruiting other Pruvers for her own benefit and/or that of a competitor. Defendant

further breached the Pruver Agreement by promoting and selling Green Compass’ products to

current and former Pruvers and customers of Pruvit. Pruvit expects that more breaches will be

revealed through discovery in this case.

24. Asa result of these breaches, Pruvit has suffered harm, and will continue to suffer

actual damageotloss, including lost profits, loss of good will and harm to customer relationships,

andloss of future contracts and business prospects, all for which Defendant Blackburn is liable.

COUNT 2-TORTIOUS INTERFERENCE WITH EXISTING CONTRACTS

95. Pruvit was a party to valid contracts with third parties, including its Pruvers and

customers.

26. Defendant Blackburn has willfully and intentionally interfered with those contracts

by encouraging current Pravers and customersofPruvit to cease doing business with Pruvit. Pruvit

fully expects that additional specific Pruvers and contracts will be revealed through discovery in

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page7

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 7 of 15 PageID #: 41
this case. Defendant knew these third parties had contracts with Pruvit when she contacted them.

Defendant’s interference with Pruvit’s contracts proximately caused Pruvit actual damages and

losses, Moreover, Defendant’s interference has caused, and continued to cause, disruption to

Pruvit’s business.

COUNT 3- TORTIOUS INTERFERENCE WITH PROSPECTIVE RELATIONS

27. Additionally, there was a reasonable probability that Pruvit would have entered into

contracts with Pruvers and customers, had Defendant Blackburn not intentionally interfered with

the formation of those relationships. Defendant Blackburn intentionally interfered with those

relationships. Defendant’s interference with Pruvit’s prospective contracts proximately caused

Pruvit actual damages and losses, including loss of those contracts and sales generated therefrom.

Moreover, Defendant Blackburn’s interference has caused, and continues to cause, disruption to

Pruvit’s business.

VIL

APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION

28. The factualallegations set forth in the foregoing paragraphs are incorporated herein

by reference for all purposes asif set forth in full:

29. Pruvit’s Application for Temporary Restraining Order and Temporary Injunction

is authorized by Sections 65.011(2) and (3) of the TEXAS CivIL PRACTICE AND REMEDIES CODE.

30. Pruvit is likely to suffer permanent and irreparable harm if an injunction is not

entered. There is no other adequate remedy at law and Pruvit seeks the equitable intervention of

this Court. Therefore, for the foregoing reasons as stated above in this Petition, Pruvit requests the

Court issue a Temporary Restraining Order and Temporary Injunction immediately restraining and

enjoining the conduct outlined in the preceding paragraphs.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 8

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 8 of 15 PageID #: 42
31. Conduct to be Restrained. In order to preserve the status quo pendingthefinal

trial on the merits of this case, Pruvit asks this Court to issue a Temporary Restraining Order and

Temporary Injunction to restrain and enjoin Defendant Blackburn, both directly and indirectly, as

well as her respective agents, employees, servants, attorneys, representatives, affiliates, entities,

successors, and assigns, and any and all other persons and entities under their control and/or

direction, or acting in active concert and participation with them, from engaging in any of the

following:

32.

Inducing, in any manner, any existing customer of Pruvit to terminate

his/her/its business relationship with Pruvit;

. Inducing, in any manner, any existing promoter of Pruvit to terminate

his/her/its business relationship with Pruvit;

Inducing, in any manner, any existing promoter of Pruvit to violate or

breach the terms of his/her/its Pruver Agreement,

. Directly or indirectly recruiting, in any manner, any other Pruvit

promoters and customersfor any other direct sales or network marketing

business;

Promoting, in any manner, non-Pruvit products or services on any social

media sites or platforms used to promote Pruvit’s products previously;

Directly or indirectly disclosing or otherwise using, in any manner, any

confidential and/or proprietary information relating to Pruvit or any of

its products and services;

. Promoting or marketing Competitors’ products, to existing customers

and promoters of Pruvit; and

. Making and/or publishing false or misleading claims about Pruvit’s

products.

Plaintiff is Likely to Succeed on the Merits, Pruvit has a probable right to relief

upon final hearing.In particular, Pruvit will present evidence of Defendant Blackburn’s breach of

and interference with contracts and evidence of causation and the extent of Pruvit’s damages.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 9

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 9 of 15 PageID #: 43
‘

33. Harm to Plaintiff is Imminent and Irreparable. Harm to Pruvit is imminent and

irreparable. Defendant Blackburn conduct is ongoing and has caused and will continue to cause

irreparable harm to Pruvit. The damage to Pruvit’s reputation and thatofits products, as well as

the continuing disruption caused by Defendant Blackburn to Pruvit’s business is immeasurable.

Moreover, so long as Defendant Blackburn’s conduct continues, it will be impossible to identify

andcalculate the extent ofthe harm to Pruvit and quantify Pruvit’s damages.

34. No Adequate Remedy at Law. In the absence of injunctive relief, Pruvit has no

adequate remedyat law. Breach of non-compete, non-disclosure, and non-solicitation agreements

is the epitome of irreparable harm justifying injunctive relief. Further, Defendant is not a Texas

resident and upon information and belief lacks property or assets in Texas sufficient to satisfy a

judgment for damages.It is essential that the Court immediately restrain Defendant Blackburn

from continuing the conduct described herein. Pruvit is willing to post a bond in accordance with

TEX. R. CIv. P. 684.

35. Hearing. In compliance with the TEXAS RULES OF CIVIL PROCEDURE, Pruvit is

entitled to a hearing providing the relief requested above to give it an opportunity to be heard by

the Court. Pruvit requests that the Court set a hearing to consider whether temporary injunctive

relief should be granted pendinga trial on the merits.

36. Permanent Injunctive Relief. Pruvit further pleads for a permanent injunction,

enjoining Defendant Blackburn from engagingin the above acts for the appropriate time period as

agreed by the parties, followinga

trial of this cause.

VIL.

CONDITIONS PRECEDENT

37. All conditions precedentto Pruvit’s right to bring the above causes of action, and

for recovery requested herein, have been performed, excused, or otherwise already occurred.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 10

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 10 of 15 PageID #: 44
VU.

EXEMPLARY DAMAGES

38. Pruvit is entitled to exemplary damages for Defendant Blackburn’s intentional

conduct, because such acts were committed with that level of mental culpability for which Texas

law allowsajury to impose punitive damages. Pruvit seeks an award of such damages.

IX.

ATTORNEY FEES

39, Pruvit seeks the recovery of attorney’s fees pursuant to TEX CIv. PRAC. & REM.

CovE§ 38.001.

X.

PRAYER

40. Pruvit therefore requests that Defendant Brianna Blackburn be cited to appear and

answer, and that upon final hearing, Pruvit be awarded the following:

(1) A Temporary Restraining Order, Temporary Injunction, and Permanent Tnjunction

be issued restraining and enjoining Defendant Blackburn, both directly and

indirectly, as well as her respective agents, employees, servants, attorneys,

representatives, affiliates, entities, successors, and assigns, and any and all other

personsand entities undertheir control and/or direction, or acting in active concert

and participation with them, from the conduct described herein;

(2) Pruvit be granted judgment against Defendant Brianna Blackburn for damages

within the jurisdictional limits of this Court;

(3) Defendant Brianna Blackburn be disgorged of any profits obtained because of the

subject breaches and improper conductreferenced herein;

(4) Pruvit be granted judgmentagainst Defendant Blackburn for exemplary damages

within the jurisdictional limits of this Court,

(5) Pruvit be granted judgment against Defendant Brianna Blackburn for reasonable

and necessary attorney’s fees, costs of suit, and pre- and post-judgment interest;

and

(6) Pruvit be granted such other relief, at law or in equity, as is just and proper.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 11

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 11 of 15 PageID #: 45
Respectfully submitted,

SCHEEF & STONE, LLP

BYRON K. HENRY

State Bar No. 24008909

byron.henry@solidcounsel.com

KELLY E. KLEIST

State Bar No. 24046229

kelly. kleist@solidcounsel.com

2600 Network Blvd., Suite 400

Frisco, Texas 75034

Tel: (214) 472-2100

Fax: (214) 472-2150

ATTORNEYS FOR PLAINTIFF

PRUVIT VENTURES, INC.

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARYINJUNCTION, AND PERMANENT INJUNCTION Page 12

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 12 of 15 PageID #: 46
VERIFICATION

STATE OF TEXAS §

§

COUNTY OF COLLIN §

Before me, the undersigned Notary Public, on this day personally appeared Jenifer Grace,

who, after being duly sworn, stated under oath that she is the Chief Legal Officer for Pruvit

Ventures, Inc., that she has read Plaintiff Pruvit Ventures, Inc.’s Verified Original Petition and

Application for Temporary Restraining Order, Temporary Injunction, and Permanent Injunction

(the “Application”), and that she is authorized to make this verification and apply for injunctive

relief, Jenifer Grace further stated that every statementoffact contained in the Statementof Facts

(Paragraphs 7-19) are true and correct.

+

SUBSCRIBED AND SWORN TO BEFORE ME on theZ1” day of August, 2023, to

certify which witness my hand and official seal.

seiititg, :

SEERnotary Public, State of Texas Notary Public for the State of Texas

Ok. 3= Comm. Expires 03-30-2024

KARI STANISH

33 12s aise Notary 1D 128939336

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 13

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 13 of 15 PageID #: 47
LOCAL RULE 2.4 CERTIFICATE

In accordance with Local Rule 2.4(b), the undersigned certifies that irreparable harm is

imminent and there is insufficient time to notify Brianna Blackburn of Pruvit’s Application for

Temporary Restraining Order.

BYRON K. HE

PLAINTIFF PRUVIT VENTURES, INC.’S VERIFIED ORIGINAL PETITION

AND APPLICATION FOR TEMPORARY RESTRAINING ORDER,

TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Page 14

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 14 of 15 PageID #: 48
Automated Certificate of eService

This automated certificate of service was created by theefiling system.

The filer served this document via email generated by the efiling system

on the date and to the persons listed below. The rules governing

certificates of service have not changed. Filers muststill provide a

certificate of service that complies with all applicable rules.

Jeri Hamman on behalf of Byron Henry

Bar No. 24008909

jeri.hamman@solidcounsel.com

Envelope ID: 78824757

Filing Code Description: Plaintiff's Original Petition (OCA)

Filing Description: Plaintiff Pruvit Ventures,Inc.'s Verified Original Petition

and Application for Temporary Restraining Order, Temporary Injunction,

and Permanent Injunction

Status as of 8/23/2023 11:29 AM CST

Associated Case Party: Pruvit Ventures,Inc.

Name BarNumber |

Email TimestampSubmitted |

Status

Byron Henry byron.henry@solidcounsel.com 8/23/2023 10:51:30 AM |

SENT

Kelly Kleist kelly.kleist@solidcounsel.com 8/23/2023 10:51:30 AM |

SENT

Leslie Sanderson leslie.sanderson@solidcounsel.com }

8/23/2023 10:51:30 AM |

SENT

Jenifer Grace filings@gracefirm.com 8/23/2023 10:51:30 AM |

SENT

Case 4:23-cv-00811-ALM Document 2 Filed 09/12/23 Page 15 of 15 PageID #: 49