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 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN 

 DISTRICT OF FLORIDA 

Onsite HealthCare Services, Inc. ) 

 ) 

 Plaintiff ) Judge R. Smoak 

 ) 

 v. ) 

 ) 

 ) 

Cassi Layne, Tony Layne and ) 

Senior Dental Care, LLC ) 

 ) 

 ) 

 Defendants ) 

 COMPLAINT 

 Jurisdiction and Venue 

1. Plaintiff, Onsite HealthCare Services is a corporation, organized under 

the laws of the State of Delaware and having its principal place of 

business at 210 Pier One Rd. Stevensville, MD, 21666 

2. Plaintiff is a dental practice management company which, in the state of 

Florida, manages the dental practice of Alex Kobb, DDS PA. 

3. Defendant Cassi Layne is an individual residing at 18908 NE State 

Road 69, Blountstown, FL 32424.

4. Defendant Tony Layne is an individual, the spouse of Defendant Cassi 

Layne, residing at 18908 NE State Road 69, Blountstown, FL 32424.

5. Defendant Senior Dental Care, LLC is an limited liability organized 

under the laws of the state of Florida having its principal office at 20120 

Central Avenue West, Blountstown, FL 32424 

6. Jurisdiction of this Court is based on 28 U.S.C. 1332.

7. Venue of this Court is based on 28 U.S.C. 1391 (a).

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Background Facts 

8. Plaintiff employed Defendant Cassi Layne as a dental hygienist from 

June 1, 2009 through November 15, 2009 when said Defendant quit. 

9. Defendant Cassi Layne’s duties included, inter alia, contacting various 

nursing homes to induce them to enter into contracts with the Plaintiff 

to have Dr. Alex PA provide certain dental and oral hygiene services for 

those residents who would sign up for insurance from Fidelity Security 

Life Insurance Company which will cover the services of Dr. Kobb. 

10. While working for Onsite HealthCare Services. Defendant Cassi Layne 

along with the other Defendants came up with a scheme to create a 

business known as Senior Dental Care which would perform the same 

services that Onsite HealthCare Services was performing but would 

perform them on behalf of Defendant Raymond Layne and in 

competition with Onsite HealthCare Services, Inc. and Alex Kobb, 

DDS, PA.. 

11. On July 22, 2009, effective August 1, 2009, Defendant Cassi Layne and 

Defendant Tony Layne formed Senior Dental Care LLC for the 

purpose of entering into the same business as Onsite HealthCare 

Services, Inc. 

12. While employed by Onsite HealthCare Services, Defendant Cassi Layne

and/or her husband, Tony Layne, on behalf of Defendant Senior Dental 

Care contacted on the dates set forth below the following nursing homes 

in an effort to induce them to sign contracts with Senior Dental Care 

August 25, 2009-Pantehon HealthCare of Fort Walton 

September 1, 2009- Riverchase Care Center 

September 8, 2009- Bay Breeze Nursing and Ret. Center 

 Pantheon Healthcare of Crestview 

 September 9, 2009- Delta Health Care 

 Bayside Manor 

 September 10, 2009- Century Care Center Inc. 

 September 14, 2009-Signature Healthcare at the Courtyard 

 September 15, 2009 –Santa Rosa Health and Rehab Center 

 Consulate Health Care of Tallahassee 

 September 23, 2009-Baptist Manor 

 September 25, 2009- Southern Oaks Rehab and Nursing Center 

 September 29, 2009- Heritage Health Care 

 Bonifay Nursing & Rehab Center 

 October 1, 2009- Willow Brooke at Azalea Trace 

 Skoal Creek Rehab Center 

 October 2, 2009- Blountstown Health and Rehab 

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 Nursing Pavilion at Chipala 

 Haven of Our Lady of Peace 

 Westwood Health Care Center 

 Rosewood Manor 

 Consulate Health Care of Pensacola 

 University Hills Health and Rehab 

 Silvercrest Manor 

 Pantheon Healthcare of Blountstown 

 Marianna Health &* Rehab Center 

 Panama City Nursing Center 

 Glencove 

 Pensacola Health Care Facility 

 Sandy Ridge Care Center 

 October 12, 2009- Heritage Healthcare of Santa Rosa 

 

13. While employed by Onsite HealthCare Services, Defendant Cassi Layne 

had use of and made copies of the OHCS training manual’s, forms, and 

procedures for the purpose of using them in a competing business. 

14. Upon termination of her employment with Onsite HealthCare Services, 

Defendant Cassi Layne began to provide the same services that the 

Onsite HealthCare services would provide to the nursing homes listed 

in Paragraph 10 and in competition with Onsite HealthCare Services, 

Inc. 

15. Upon termination of her employment with Onsite HealthCare Services, 

Defendant Cassi Layne and the two other defendants began to use 

Onsite HealthCare Services manuals, forms and procedures to provide 

services to residents of the nursing homes listed in Paragraph 10. 

16. Defendant Cassi Layne also induced Dr. Chaudhry, a dentist who had a 

contract to perform services for Alex Kobb DDS PA to serve as a 

contract dentist for Senior Dental Care in violation of his contract with 

Alex Kobb DDS PA., thereby violating the provision in his contract 

with Alex Kobb, PA not to provide services in nursing homes except as 

a contract dentist for Dr. Kobb. 

17. Defendant Cassi Layne and Defendant Senior Dental Care were aware 

of Dr. Chaudhry’s contract with OHCS by reason of Defendant Cassi 

Layne’s employment with Plaintiff and they had no privilege to cause 

Dr. Chaudhry to breach such contract. 

18. All wrongful conduct alleged in this complaint was motivated solely by 

all of the Defendants’ efforts to make unreasonable financial gain and 

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that the unreasonably dangerous nature of the conduct, together with 

the high likelihood of injury resulting from the conduct, was actually 

known by the managing agent, director, officer, or other person 

responsible for making policy decisions on behalf of Defendant Senior 

Dental Care as well as to the individual Defendants. 

 Count I- Violation of Fiduciary Duty 

19. Plaintiff incorporates paragraphs 1 through 20 as though fully set forth 

herein. 

20. Defendant Cassi Layne violated her fiduciary duties to the Plaintiff, 

which she owed by reason of being a servant and agent of the Plaintiff, 

by the following actions taken during the course of her employment: 

a. establishing a competing business while employed by Plaintiff, 

b. soliciting nursing homes which she was supposed contacting on behalf 

of the Plaintiff to sign contracts with Senior Dental Care. 

c. making copies of Plaintiff’s manuals, procedures, and forms for use in 

by Senior Dental Care 

d. divulging Plaintiff’s Trade secrets to Senior Dental Care and Tony 

Layne. 

 

21. Such actions have damaged the Plaintiff’s business in excess of $75,000 

WHEREFORE, Plaintiff demands the following against Defendant Cassie Layne on 

this count: 

a. Compensatory damages in excess of $75,000 

b. Punitive Damages 

c. Court Costs 

Count II- Tortuous Interference with Contractual Relations 

22. Plaintiff incorporate paragraph 1 through 23 as though fully set forth 

herein. 

23. Defendants Cassie Layne, Tony Layne and Senior Dental Care, LLC 

committed tortuous interference with the contract between Dr. 

Chaudhry and Plaintiff by inducing Dr. Chaudhry to break his contract 

not to compete with Alex Kobb DDS PA by signing an agreement with 

Senior Dental Care to provide dental services to the patients it was 

servicing in nursing homes. 

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24. Such actions have damaged the Plaintiff’s business in excess of $75,000 

WHEREFORE, Plaintiff demands the following against Defendants Cassie Layne, 

Tony Layne and Senior Dental Care, jointly and severally on this count: 

a. Compensatory damages in excess of $75,000 

b. Punitive Damages 

c. Court Costs 

Count III- Interference with Prospective Economic Advantage 

25. Plaintiff incorporate paragraph 1 through 26 as though fully set forth 

herein. 

26. Defendants Cassi Layne, Tony Layne and Senior Dental Care have 

without any privilege interfered and continue to interfere with 

Plaintiff’s prospective contractual relations with the nursing homes that 

Defendant Cassi Layne contacted as an employee of OHCS and was 

supposedly trying to get them to contract with OHCS. 

27. Such actions have damaged and continue to damage the Plaintiff in 

amounts which are not readily susceptible of calculation or proof. 

28. Defendant has no adequate remedy at last. 

WHEREFORE, Plaintiff requests this court to enjoin Defendants Cassi Layne, 

Tony Layne and Senior Dental Care from contacting or soliciting business from any 

of the nursing homes which Defendant Cassi Layne contacted while employed by 

Plaintiff. 

 IV. Violation of Copyright 

29. Plaintiff incorporate paragraph 1 through 30 as though fully set forth 

herein. 

30. Defendant Cassi Layne’s copying Plaintiffs’ manuals, procedures and 

from and Defendant Tony Layne and Senior Dental Care use of these 

materials constitutes an infringement of copyright. 

31. Such actions have damaged and continue to damage the Plaintiff in 

amounts which are not readily susceptible of calculation or proof. 

32. Plaintiff has no adequate remedy of law. 

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WHEREFORE, Plaintiff requests this Court to enjoin Defendants Cassi Layne, 

Tony Layne and Senior Dental Care from using such materials or copies thereof 

and to return all such materials and copies to Plaintiff. 

V. Misappropriation of Trade Secrets. 

33. Plaintiff incorporate paragraph 1 through 34 as though fully set forth 

herein. 

34. Defendants Senior Dental Care and Tony Lane misappropriated trade 

secrets of OHCS by obtaining them from Cassi Lane in violation of her 

duty to keep them secret. 

35. Such actions have damaged Plaintiff in an amount in excess of $75,000. 

WHEREFORE, Plaintiff demands the following against Defendants Tony Layne 

and Senior Dental Care, jointly and severally on this count: 

a. Compensatory damages in excess of $75,000 

b. Punitive Damages 

c. Court Costs 

 VI. Conspiracy 

36. Plaintiff incorporates paragraphs 1 through 37 as though fully set forth 

herein 

37. All of the Defendants have conspired together to commit the torts 

described in this complaint. 

WHEREFORE, Plaintiff demands the following against all Defendants, jointly and 

severally, on this count: 

a. Compensatory damages in excess of $75,000 

b. Punitive Damages 

c. Court Costs 

Respectfully submitted 

/s/ Michael Stone 

Michael Stone 

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Florida Bar No.: 0256791 

STONE & SUTTON, P.A. 

116 East Fourth Street 

Panama City, Florida 32401 

(850) 785-7272 

(850) 785-7094 fax 

mlstone@stonesuttonlaw.com

Attorney for the Plaintiff 

Of Counsel 

James T. Carney 

PA I.D. No. 00232 

845 Northridge Dr. 

Pittsburgh, Pa. 15216 

(412) 657-002 

(412) 561-1613 fax 

jtcarney10@comcast.net 

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