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Wonderland vs Rock Brook

Wonderland vs Rock Brook

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Published by Eric Nicholson

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Published by: Eric Nicholson on Jul 17, 2012
Copyright:Attribution Non-commercial

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07/19/2013

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MHDocs 3844503_1 980925.1
 Cause No. ____________ WONDERLAND MONTESSORIACADEMY, LLC,Plaintiff,v.TEXAS PATHSHALA, INC., d/b/aROCKBROOK MONTESSORIACADEMY, and RADHIKA SONI,Defendants.§§§§§§§§§§§IN THE DISTRICT COURT OFDALLAS COUNTY, TEXAS ______ JUDICIAL DISTRICT
ORIGINAL PETITION AND VERIFIED APPLICATION FOR TEMPORARY RESTRAINING ORDER, TEMPORARY INJUNCTION,AND PERMANENT INJUNCTION
 Wonderland Montessori Academy, LLC (“Wonderland”) by and through its counsel, brings this suit against Texas Pathshala, Inc., doing business as Rockbrook Montessori Academy(“Rockbrook”), and Radhika Soni (collectively “Defendants”) and respectfully shows the courtas follows:
I.DISCOVERY CONTROL PLAN
1.
 
Discovery is intended to be conducted pursuant to Discovery Level 2. T
EX
.
 
R.
 
C
IV
.
 
P
ROC
. 190.3.
II.PARTIES
2.
 
Plaintiff Wonderland Montessori Academy, LLC, a Texas Limited LiabilityCompany, is a resident of Denton County, Texas.3.
 
Defendant Texas Pathshala, Inc., doing business as Rockbrook MontessoriAcademy, a Texas For-Profit Corporation, is a resident of Dallas County, Texas. It can be
Filed12 July 16 A11:49Gary FitzsimmonsDistrict ClerkDallas District
DC- 2-07780I- 62ND
 
 
MHDocs 3844503_1 980925.1
 served through its registered address, Vineeta Bhargava, at 725 Penfolds Lane, Coppell, Texas75019, or wherever she may be found.4.
 
Defendant Radhika Soni is a resident of Denton County, Texas. She may beserved at her home, 195 E. Round Grove Rd. #1923, Lewisville, Texas 75067, or wherever shemay be found.
III.JURISDICTION AND VENUE
5.
 
This Court has subject matter jurisdiction pursuant to Texas Civil Practice andRemedies Code Section 65.021 of the Civil Practices and Remedies Code (granting districtcourts jurisdiction over injunctive proceedings). The amount in controversy is within the jurisdictional limits of the Court. Venue is proper in Dallas County under Texas Civil Practice &Remedies Code § 15.002 because Defendant Rockbrook is a resident of Dallas County.
IV.BACKGROUND FACTS
6.
 
Wonderland Montessori Academy, LLC, operates a private educational facility inFlower Mound, Texas, offering educational programs for children as young as infants throughchildren in elementary school. Mr. Sanjay Joshi is an owner of Wonderland. Ms. Heather Coleis the Director of Wonderland.7.
 
Parents with students enrolled at Wonderland enter into an ongoing contractualrelationship with Wonderland. To terminate this relationship, parents are required to providewritten notice of withdrawal thirty (30) days in advance of the last day of enrollment.8.
 
Rockbrook Montessori Academy has recently opened a private educationalfacility in Flower Mound, Texas, offering educational programs for children as young aseighteen (18) months through children in elementary school.
 
 
MHDocs 3844503_1 980925.1
 9.
 
For the past several months, Rockbrook has actively and aggressively recruitedteachers from Wonderland, often using underhanded methods of recruitment. On at least oneoccasion, a Rockbrook employee called Wonderland posing as a doctor’s office in order to speak with a Wonderland teacher. On another occasion, Rockbrook’s owner, Vineeta Bhargava,visited the home of a Wonderland teacher uninvited in order to try to convince the teacher to joinRockbrook.10.
 
In late-May 2012, Radhika Soni (“Ms. Soni”), who was employed withWonderland as an Assistant Teacher, notified Wonderland that she was leaving to take ateaching position at Castle Creek, a preschool in Flower Mound. Ms. Soni was asked explicitly by Ms. Cole whether she was going to work for Rockbrook, as another teacher from her classroom had already given her notice to resign and join Rockbrook. Ms. Soni denied that shewould be working for Rockbrook. Ms. Soni’s last scheduled day at Wonderland was Friday,June 8, 2012.11.
 
On Wednesday, June 6, 2012, Mr. Joshi learned from a parent of a student thatMs. Soni had approached her about immediately moving her child to Rockbrook Montessori. Inthe conversation with the parent, Ms. Soni encouraged the parent to leave Wonderland and not to pay any tuition to Wonderland that had not already been paid. She also told the parent that she believed that Rockbrook would be willing to provide financial incentives for the move.12.
 
Upon learning of this conversation, Ms. Cole immediately confronted Ms. Soniabout this conduct, at which time Ms. Soni strongly and repeatedly denied engaging in thisconduct. After that, Mr. Joshi spoke with Ms. Soni about this, and she again denied it.13.
 
That evening, Ms. Cole and Mr. Joshi both met with Ms. Soni in a conferenceroom at Wonderland. During this meeting, Ms. Soni admitted to approaching several parents

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