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Toad Lick lawsuit filed in Houston County

Toad Lick lawsuit filed in Houston County

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Published by John S Keppy
Lawsuit by advertising agency filed against TOADLICK
Lawsuit by advertising agency filed against TOADLICK

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Published by: John S Keppy on Apr 09, 2014
Copyright:Traditional Copyright: All rights reserved

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03/12/2015

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IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA WALKER360, INC. Plaintiff, v. TOADLICK ENTERTAINMENT, LLC, ROBERT “CHRIS” GILBERT, Individually; and, RONNIE MCGLOTHLIN, Individually, Defendant. )))))))))) CASE NO. CV-2014-____________________
COMPLAINT
Comes now Plaintiff, Walker360, Inc., by and through their attorneys, William B. Matthews, Jr. and William B. Sellers, and asserts the following Complaint against Defendant, Toadlick Entertainment, LLC, hereinafter referred to as (“Toadlick”): 1. Plaintiff is an Alabama corporation with its principle place of business in Montgomery County, Alabama. 2. Defendant Toadlick Entertainment, LLC (“Toadlick”) is an Alabama corporation located at 2000 Ross Clark Circle, Dothan, Alabama 36301 in Houston County, Alabama. At all times pertinent to the allegations of this Complaint, Toadlick acted by and through its duly authorized and appointed officials and agents. 3. Defendant Robert “Chris” Gilbert is the Registered Agent of Toadlick Entertainment, LLC, Registered Office Mailing Address is 117 Eastridge Drive, Dothan, Alabama 36301 in Houston County, Alabama.
234683.1
 
 
ELECTRONICALLY FILED4/7/2014 2:23 PM38-CV-2014-900233.00CIRCUIT COURT OFHOUSTON COUNTY, ALABAMACARLA H. WOODALL, CLERK
 
4. Ronnie McGlothlin is a principal of Toadlick Entertainment, LLC located at 2000 Ross Clark Circle, Dothan, Alabama 36301 in Houston County, Alabama. 5. This Court has jurisdiction over this matter and venue is proper.
STATEMENT OF FACTS
1. On or about November 20, 2012, Defendant Toadlick by and through principal Ronnie McGlothlin entered into in to an Agreement, Walker30 Agency of Record Authorization Letter with the effective date of November 21, 2012, hereinafter referred to as (“Contract”). A copy of the Contract is attached hereto as
Exhibit “A”
 and is incorporated by reference as if fully set forth herein. Payment has not been received. The Agreement specifically states, “I/we will remain responsible for payment of account balances, collection costs, attorney fees and court costs incurred in the event of non-payment by said agency, regardless of whether judicial action is taken or otherwise” and Defendants agreed by execution of the Agreement. 2. A Personal Credit Guarantee was executed by Robert “Chris” Gilbert, individually guaranteeing payment of Toadlick Entertainment, LLC for all credit extended and monies owed to Walker360. A copy of said Personal Credit Guarantee is attached hereto as
Exhibit “B”
 and is incorporated herein by reference as if fully set forth herein. 3. Defendants owe the Plaintiff $33,603.36 in advertising expenses, unpaid invoices,  plus interest of $14,232.88, and attorney’s fees. A copy of said Estimation is attached hereto as
Exhibit “C”
 and is incorporated herein by reference as if fully set forth herein. 2
 
COUNT I BREACH OF CONTRACT
4. Plaintiff Walker360, Inc. adopts and reasserts all of the foregoing paragraphs of this Complaint and, in addition thereto, alleges that Defendants breached the contract attached hereto as Exhibit “A” by, among other things, failing to pay Plaintiff the amounts set forth in the invoices. WHEREFORE, the premises considered, Plaintiff demands judgment against the Defendants in the sum of $33,603.36 in advertising expenses, unpaid invoices, plus interest of $14,232.88, and attorney’s fees, costs, and such other relief to which it is entitled.
COUNT II UNJUST ENRICHMENT
 5. Plaintiff Walker360, Inc. adopts and reasserts all of the foregoing paragraphs of this Complaint and, in addition thereto, alleges that Plaintiff performed advertising services for the Defendants at their request. The Defendants have failed to make payment for such advertising expenses, and collections costs, and therefore had been unjustly enriched. 6. The terms of the Agreement allow for an award of account balances, collection costs, attorney fees and court costs incurred in the event of non-payment and collection. The Plaintiff asserts that a fee up to $7,175.44 is a reasonable and customary fee for collection of this account. 3

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