Professional Documents
Culture Documents
Law Offices
Bernhardt, Rothermel & Siegel, P.C.
By: Frank A. Rothermel, Esquire
Attorney Identification No.: 54038
1515 Market Street, Suite 1540
Philadelphia, Pennsylvania 19102
(215) 568-0100
LEONARD N. HUBBARD, Individually, and on behalf
of GRAND NEGAZ, INC., a Pennsylvania Corporation
5555 Germantown Avenue, 3rd Floor
Philadelphia, PA 19119
Plaintiffs
SHAWN GEE
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and
AHMIR THOMPSON
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and
TARIK TROTTER
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and
SPORTS AND ENTERTAINMENT FINANCIAL
GROUP, a Pennsylvania Corporation
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and
GRAND NEGAZ, INC., a Pennsylvania Corporation
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and
OKAY TOURS, LLC, a Pennsylvania Limited
Liability Company
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and
GRAND WIZARDS, LLC, a Pennsylvania Limited
Liability Company
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and
THE ROOTS ON TOUR, INC., a Pennsylvania
Corporation
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V.
and
KENDALL A. MINTER
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Defendants
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NOTICE TO DEFEND
NOTICE
You have been sued in Court. If you wish to
defend against the claims set forth in the following
pages, you must take action within twenty (20) days
after the Complaint and notice are served, by
entering a written appearance personally or by
attorney and filing in writing with the court your
defenses or objections to the claims set forth against
you. You are warned that if you fail to do so the
case may proceed without you and a judgment may
be entered against you by the court without further
notice for any money claimed in the complaint or for
any other claim or relief requested by the plaintiff.
You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER,
THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
AVISO
Le han demandado a usted en la corte. Si
usted quiere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de
la demands y la notificacion. Hace falta asentar
una comparencia escrita sus defensas o sus
objeciones a las demandas en contra de su
persona.
Sea avisado que si usted no se
defiende, la corte tomara medidas y puede
continuar la demanda en contra suya sin previo
aviso o notificacion. Ademas, la corte puede
decidir a favor del demandante y requiere que
usted cumpla con todas las provisiones de esta
demanda. Usted puede perder dinero o sus
propiedades u ostos derechos importantes para
usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE
PAGAR TAL SERVICIO. VAYA EN PERSONA
O LLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Law Offices
Bernhardt, Rothermel & Siegel, P.C.
By: Frank A. Rothermel, Esquire
Attorney Identification No.: 54038
1515 Market Street, Suite 1540
Philadelphia, Pennsylvania 19102
(215) 568-0100
SHAWN GEE
:
:
:
:
:
:
and
AHMIR THOMPSON
:
:
:
and
TARIK TROTTER
:
:
:
and
SPORTS AND ENTERTAINMENT FINANCIAL
GROUP, a Pennsylvania Corporation
:
:
:
:
and
GRAND NEGAZ, INC., a Pennsylvania Corporation
:
:
:
and
OKAY TOURS, LLC, a Pennsylvania Limited
Liability Company
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and
GRAND WIZARDS, LLC, a Pennsylvania Limited
Liability Company
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and
THE ROOTS ON TOUR, INC., a Pennsylvania
Corporation
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Plaintiffs
V.
and
KENDALL A. MINTER
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:
Defendants
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COMPLAINT
I.
THE PARTIES
1.
3.
4.
5.
6.
8.
9.
practice law in the State of Georgia, New York and the District of Columbia with
offices located at
. Plaintiff
The entities GNI, Grand Wizards, LLC, Okay Tours, LLC, The Roots on
Tour, Inc., and The Roots Picnic, LLC, are all Pennsylvania entities which regularly
conduct business in Philadelphia County.
14.
GNI, Grand Wizards, LLC, and Okay Tours, LLC were all formed in
Philadelphia County and had their registered and regular place of business at
, Philadelphia until 2010.
3
15.
Philadelphia.
17.
18.
transactions or occurrences took place out of which these causes of action arose.
19.
Pennsylvania and in Philadelphia County. Defendant Minter had and has clients in
Pennsylvania, including Plaintiff Hubbard in Philadelphia. Defendant Minter holds
himself out as capable of handling matters on a worldwide basis. Defendant Minter
has been the Chairman of the Rhythm and Blues Foundation which is headquartered
here in Philadelphia, PA and is believed to have been a member of its Board since at
least 2000.
III.
FACTS
20.
22.
as Malik Smart formed GNI and were performing and known as "The Roots."
23.
24.
Plaintiff Hubbard for many years contributed to The Roots his unique
In 2007 plaintiff Hubbard became ill and was diagnosed with multiple
myeloma. Since that time Mr. Hubbard has been unable to continue performing with
The Roots.
26.
Defendants Shawn Gee has been the business manager of The Roots
LLC, Okay Tours, LLC, The Roots on Tour, Inc., and The Roots Picnic, LLC. Mr. Gee
controls all details of those entities' day-to-day financial, personnel and business
operations and assumes actual, participatory, total control of those entities business
activities.
28.
Mr. Gee has acted individually and as the agent of defendant Sports and
29.
Richard Nichols was the band manager of The Roots from on or about
Since the death of Mr. Nichols, defendant Shawn Gee has also taken on
34.
president.
35.
Patent and Trademark office the mark "The Roots" at Registration Number 1966181.
The owner of the mark "The Roots" is GNI.
37.
persons of GNI, a close corporation, defendants Thompson, Trotter and Gee owe a
fiduciary duty and duty of loyalty to GNI and to plaintiff Hubbard.
38.
39.
received by GNI.
40.
GNI owns and controls use of the registered mark "The Roots."
42.
Defendants Thompson, Trotter and Gee have permitted the use of the
mark "The Roots" by other entities without compensation for such use. Such use
includes, but is not limited to, use of the mark The Roots by The Roots on Tour, Inc.
and The Roots Picnic, LLC, two entities in which plaintiff has no ownership interest;
as well as use of the mark by Passyunk Productions LLC, a Pennsylvania entity in
which plaintiff has no ownership interest.
43.
Defendants Thompson, Trotter and Gee have never noticed and/or held
of GNI to plaintiff.
48.
year until 2011 when, without explanation, payments were reduced to approximately
$7,000 per year.
GRAND WIZARDS, LLC
49.
defendant Thompson 25%, defendant Trotter 25%, plaintiff Hubbard 25%, and Richard
Nichols 25%.
51.
recordings, outside production and distribution. To that end, since 2003 Grand
Wizards, LLC has contracted with SoundExchange, an independent digital
performance rights organization.
52.
Grand Wizards, LLC, defendants Thompson, Trotter and Gee owe a fiduciary duty
and duty of loyalty to Grand Wizards, LLC and to plaintiff Hubbard.
53.
Plaintiff Hubbard has never been consulted about, voted for, or agreed
Plaintiff Hubbard has never been consulted about, voted for, agreed to
Company and hold as trustee for it any profits derived from its business. 15 Pa.C.S.A.
8943.
8
56.
collects royalties under contract with Grand Wizards, LLC, has distributed all digital
works consisting of The Roots catalog of music.
58.
product.
60.
Plaintiff Hubbard has received only one check from Grand Wizards, LLC
Plaintiff Hubbard has had and continues to have his health insurance
On or about March 28, 2014 plaintiff Hubbard received from Mr. Nichols,
the Band Manager, an email on behalf of defendants, threatening plaintiff with being
cut off from any and all payments including health insurance.
65.
66.
On August 28, 2000 The Roots formed Okay Tours, LLC a Pennsylvania
The purpose of Okay Tours, LLC, was to contract for and collect revenue
Okay Tours, LLC handled all touring productions for The Roots until late
71.
2011.
Okay Tours, LLC, defendants Thompson, Trotter and Gee owe a fiduciary duty and
duty of loyalty to Okay Tours, LLC and to Plaintiff Hubbard.
72.
Plaintiff Hubbard has never been consulted about, voted for, or agreed
Plaintiff Hubbard has never been consulted about, voted for, agreed to
and hold as trustee for it any profits derived from its business. 15 Pa.C.S.A. 8943 (a).
10
75.
Okay Tours, LLC, handled all touring productions, contracted for and
collected revenue from touring productions of The Roots from Okay Tours, LLCs
formation in 2000.
76.
Plaintiff Hubbard believes, and therefore avers, that Okay Tours, LLC
Plaintiff Hubbard has never received a payment from Okay Tours, LLC
as a one-third owner.
80.
Defendants Thompson, Trotter and Gee have never noticed and/or held
Internal Revenue Service a notice of tax deficiency for the year 2009. Upon receipt of
that notice, Plaintiff Hubbard began making inquiries about income and benefits from
his ownership in the above referenced entities and The Roots generally.
83.
84.
intentionally transferred all assets of Okay Tours, LLC (of which Plaintiff Hubbard
was a one-third (1/3rd) owner), and diverted all touring business, business
knowledge, and contracts for touring business from Okay Tours, LLC to the
defendants newly formed The Roots on Tour, Inc. for the purpose of denying Plaintiff
Hubbard any interest in such business.
86.
All revenue from Okay Tours, LLC was likewise diverted to The Roots on
Tour, Inc. for the purpose of denying Plaintiff Hubbard any benefit from or interest in
such business.
87.
The transfer of all business from Okay Tours, LLC to The Roots on Tour,
Philadelphia.
91.
12
COUNT I
PLAINTIFF V. AHMIR THOMPSON, TARIK TROTTER, SHAWN GEE, THE ROOTS
ON TOUR, INC. AND SPORTS AND ENTERTAINMENT FINANCIAL GROUP, INC.
(Fraudulent Transfer)
92.
LLC, its members and its business manager; that plaintiff Hubbard had been illegally
and improperly denied any income or inclusion in the operations of Okay Tours, LLC;
that defendants illegally and improperly paid to themselves disproportionately high
compensation to the detriment of Plaintiff Hubbard; defendants embarked upon a
scheme and artifice to fraudulently convey all the business and assets of Okay Tours,
LLC (of which Plaintiff Hubbard was a one-third (1/3rd) owner) to The Roots on Tour,
Inc. an entity in which Plaintiff Hubbard has no interest, intending thereby to deny
Plaintiff Hubbard the fruits of his ownership interest and any benefit from the touring
business conducted by Okay Tours, LLC.
94.
knowledge, and contracts for touring business, from Okay Tours, LLC to The Roots on
Tour, Inc.
95.
Okay Tours, LLC has no remaining assets or business from which to pay
13
96.
The transfer from Okay Tours, LLC to The Roots on Tour, Inc. was
without fair consideration and was intended to hinder, delay or defraud Plaintiff
Hubbard.
97.
and Trotter to commit the acts companied of herein which were unlawful or
otherwise lawful by unlawful means.
WHEREFORE, Plaintiff Leonard N. Hubbard requests relief as follows:
a)
The Roots from Okay Tours, LLC to The Roots on Tour, Inc.;
b)
for maintaining this action, including reasonable attorneys' fees and costs;
d)
e)
100.
defendants Thompson and Trotter owe a fiduciary duty and duty of loyalty to GNI and
to Plaintiff Hubbard.
101.
defendants Thompson and Trotter and that they were beaching their duties and
defendant Gee aided and abetted those breaches. Defendant Gee substantially
assisted or encouraged defendants Thompson and Trotter in their scheme and their
breaches of fiduciary duties.
102.
and Trotter to commit the acts complained of herein which were unlawful or
otherwise lawful by unlawful means.
103.
Defendants have a fiduciary duty to act fairly and not to act in favor of
one group to the detriment of others, and are required to account to the Companies
and hold as trustee for them any profits derived from their business.
104.
fiduciary duties.
105.
b)
compensation;
c)
15
d)
e)
f)
g)
Self-dealing;
h)
i)
j)
companies;
activities;
106.
k)
l)
defendants Thompson, Trotter and Gee, Plaintiff Hubbard has suffered damages in
the form of lost income, unpaid dividends, undistributed profits, consequential
damages in the form of lost interest and investment opportunity, loss of right as a
shareholder, and expenses and legal fees.
107.
Plaintiff Hubbard has been excluded from his proper share of benefits
accruing from the enterprises as a result of the defendants' bad faith and breaches of
fiduciary duties.
108.
disregard of the rights of Plaintiff Hubbard, and are so shocking, outrageous and in
bad faith that punitive damages are warranted.
16
Okay Tours, LLC, defendants Thompson and Trotter owe a fiduciary duty and duty of
loyalty to Grand Wizards, LLC, and Okay Tours, LLC and to Plaintiff Hubbard who is
a 25% owner of Grand Wizards, LLC and one-third owner of Okay Tours, LLC.
111.
defendants Thompson and Trotter and that they were beaching their duties and
defendant Gee aided and abetted those breaches. Defendant Gee substantially
assisted or encouraged defendants Thompson and Trotter in their scheme and their
breaches of fiduciary duties.
17
112.
and Trotter to commit the acts complained of herein which were unlawful or
otherwise lawful by unlawful means.
113.
Defendants have a fiduciary duty to act fairly and not to act in favor of
one group to the detriment of others, and are required to account to the Companies
and hold as trustee for them any profits derived from their business.
114.
fiduciary duties.
115.
b)
compensation;
c)
d)
e)
f)
g)
Self-dealing;
h)
i)
companies;
activities;
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j)
116.
k)
l)
defendants Thompson, Trotter and Gee, Plaintiff Hubbard has suffered damages in
the form of lost income, unpaid dividends, undistributed profits, consequential
damages in the form of lost interest and investment opportunity, loss of right as a
member, and expenses and legal fees.
117.
Plaintiff Hubbard has been excluded from his proper share of benefits
accruing from the enterprises as a result of the defendants' bad faith and breaches of
fiduciary duties.
118.
disregard of the rights of Plaintiff Hubbard, and are so shocking, outrageous and in
bad faith that punitive damages are warranted.
WHEREFORE, Plaintiff Leonard N. Hubbard demands judgment in his favor
and against the defendants Ahmir Thompson, Tarik Trotter and Shawn Gee,
enjoining breaches of their fiduciary duties; an award to Plaintiff of such monetary
damages as he may establish at trial which are in excess of $50,000; punitive
damages; an award to Plaintiff of the costs and expenses incurred in bringing this
action, including reasonable attorneys' fees; and such relief as this Court may deem
just and proper under the circumstances.
19
COUNT IV
PLAINTIFF V. AHMIR THOMPSON AND TARIK TROTTER AND GNI
(Appointment of Custodian/Receiver)
119.
control of GNI, in defeating the rights and expectations of Plaintiff Hubbard were
oppressive conduct.
121.
operate 100% control of the shares, profits and other benefits of GNI thereby
substantially diminishing the power and compensation of Plaintiff Hubbard and
further, substantially diminishing the fair value of Plaintiff Hubbards shares in GNI.
122.
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COUNT V
PLAINTIFF V. AHMIR THOMPSON AND TARIK TROTTER,
GRAND WIZARDS, LLC AND OKAY TOURS, LLC
(Appointment of Trustee)
123.
control of Grand Wizards, LLC and Okay Tours, LLC in defeating the rights and
expectations of Plaintiff Hubbard were oppressive conduct.
125.
diminished in an effort to operate 100% control of the profits and other benefits that
go along with the interest of a member for less than fair value.
126.
Liability Company Law, including, without limitation, 15 Pa.C.S.A. 8972 & 8973.
WHEREFORE, Plaintiff Leonard N. Hubbard requests that this Court grant
judgment in his favor and against defendants Ahmir Thompson, Tarik Trotter, Grand
Wizards, LLC and Okay Tours, LLC, and appoint a Trustee to manage the affairs of
Grand Wizards, LLC and Okay Tours, LLC, and authorize the Trustee to act to the full
extent of the authority provide for under the Pennsylvania Limited Liability Company
Law, and award Plaintiff the costs and expenses incurred in bringing this action,
including reasonable attorneys' fees, together with such relief as this Court may
deem just and proper under the circumstances.
21
COUNT VI
PLAINTIFF V. GNI, AHMIR THOMPSON, TARIK TROTTER AND SHAWN GEE
(Shareholder derivative action)
127.
129.
At all times mentioned, Plaintiff was and is the owner and holder of
Trotter, in conspiracy with defendant Gee, have engaged in an artifice and scheme,
all to the detriment of GNI and the minority shareholder, Plaintiff herein, to do the
following:
a)
b)
c)
compensation;
d)
e)
Self-dealing;
f)
companies; and
g)
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131.
fraudulent.
132.
defendants comport themselves to their duties, and, among other things, has
requested an accounting of funds of GNI. Despite such request, defendants have
consistently failed and refused to comport to their duties and have consistently failed
and refused to deal fairly and equitably with the claims and interests of Plaintiff
minority shareholder.
WHEREFORE, Plaintiff Leonard N. Hubbard requests relief as follows:
a)
defendant Grand Negaz, Inc. by reason of the acts of defendants Ahmir Thompson,
Tarik Trotter and Shawn Gee;
b)
directed to pay to defendant Grand Negaz, Inc. the sum found to be due and
judgment be entered against said defendants, jointly and severally, in the amount
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found to be due in favor of defendant corporation, together with interest on that amount;
c)
for maintaining this action, including reasonable attorneys' fees and costs; and
d)
damaged as aforesaid.
139.
rights of Plaintiff Hubbard, and are so shocking, outrageous and in bad faith that
punitive damages are warranted.
WHEREFORE, Plaintiff Leonard N. Hubbard demands judgment in his favor
and against the defendants Ahmir Thompson, Tarik Trotter and Shawn Gee, for such
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As a result of their positions with GNI, Grand Wizards, LLC and Okay
Tours, LLC, defendants Thompson, Trotter and Gee had a fiduciary and/or special
relationship with and duties to Plaintiff Hubbard.
142.
Plaintiff and have withheld information from and otherwise deceived Plaintiff
Hubbard in regard to his financial and legal rights.
143.
Plaintiff has been deprived of his rights and has suffered damages as aforesaid.
144.
rights of Plaintiff Hubbard, and are so shocking, outrageous and in bad faith that
punitive damages are warranted.
WHEREFORE, Plaintiff Leonard N. Hubbard demands judgment in his favor
and against the defendants Ahmir Thompson, Tarik Trotter and Shawn Gee, for such
25
corporate records, including, without limitation, the share register, books, and
records of account; and the records of the proceedings of the incorporators,
shareholders and directors.
147.
corporation permit him to inspect, either personally or through his duly authorized
representatives, the books and records of the corporation. A copy of his request,
which was made pursuant to the Pennsylvania Business Corporation Law, as
amended, 15 P.S. 1508 (inadvertently identified as 1308), is attached hereto as
Exhibit "B."
148.
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149.
examine the books and records of the corporation, Plaintiff has suffered great
damage, for which he has no other adequate remedy at law.
WHEREFORE, Plaintiff Leonard N. Hubbard requests relief as follows:
a)
corporate books and records of Grand Negaz, Inc. pursuant to 15 Pa.C.S.A. 1508;
b)
for maintaining this action, including reasonable attorneys' fees and costs; and
c)
153.
LLC.
Hubbard is entitled to access for inspection and copying, to the books and records of
Grand Wizards, LLC and Okay Tours, LLC, including without limitation, financial
27
records, copies of income tax returns (not limited to K-1s), and all other information as
is just and reasonable.
154.
21, 2015, Plaintiff has been denied access to Company records of Grand Wizards, LLC
and Okay Tours, LLC. A true and correct copy of Plaintiffs request and demand is
attached here to as Exhibit C.
WHEREFORE, Plaintiff Leonard N. Hubbard requests relief as follows:
a)
for maintaining this action, including reasonable attorneys' fees and costs; and
c)
Service of a notice of deficiency for the year 2009 and making inquiries about income
and benefits from his ownership in The Roots entities and The Roots generally;
Plaintiff Hubbard was not satisfied with the responses he was receiving.
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157.
services of defendant Minter to advise Plaintiff and represent Plaintiff in regard to his
relationships with defendants and his legal rights arising from such relationships.
158.
159.
Defendant Minter holds himself out to the public and held himself out to
Defendant Minter holds himself out to the public and held himself out to
but was not successful in obtaining all records necessary to appraise the financial
and/or legal position of Plaintiff with The Roots entities as they withheld and/or
refused to produce documents.
29
163.
Defendant Minter did not assert a right to the records of The Roots
entities under the Pennsylvania Business Corporation Law, 15 Pa. C.S.A. 1508.
164.
Defendant Minter did not assert a right to the records of The Roots
entities under the Pennsylvania Limited Liability Company Law, 15 Pa. C.S.A. 8901
et seq.
165.
Statute of Limitations relating to any claims he may have concerning his legal rights
relating to The Roots entities.
167.
Defendant Minter did not refer Plaintiff Hubbard to any of his network of
colleagues in an effort to protect any rights which may be lost by passage of the
Statute of Limitations.
168.
protect any rights which may be lost by passage of the Statute of Limitations.
169.
during Minter's representation of Plaintiff Hubbard, and if an action had been brought
30
within the Statute of Limitations, they would have gone to a trial and resulted in a
substantial recovery and relief for the Plaintiff.
172.
173.
part in that he failed to advise Plaintiff to bring suit, refer the matter for suit, advise
Plaintiff of the Statute of Limitations, or institute and prosecute certain causes of
action for the Plaintiff against defendants within the Statute of Limitations.
174. Plaintiff is now barred from bringing some or all of Plaintiff's actions
against the defendants because there was no action brought within the applicable
Statute of Limitations.
175. As a result of defendant's failure to comply with the conditions of the
contract between the parties, the Plaintiff has not recovered and is prevented from
recovering from the defendants some or all of Plaintiff's legitimate claims.
WHEREFORE, Plaintiff Leonard N. Hubbard, in the alternative to those claims
asserted against the other defendants in this action which may be barred by the
actions of defendant Kendall A. Minter, demands judgment in his favor and against
the defendant Kendall A. Minter, for such monetary damages as he may establish at
trial which are in excess of $50,000, award to Plaintiff of the costs incurred in bringing
this action, interest, and such relief as this Court may deem just and proper under the
circumstances.
31
COUNT XII
PLAINTIFF V. KENDALL A. MINTER
(Professional Negligence)
176.
of an attorney;
b)
c)
178.
e)
f)
his right to seek relief and compensation for the deprivation of his legal rights and
injuries from the other defendants as set forth above.
WHEREFORE, Plaintiff Leonard N. Hubbard, in the alternative to those claims
asserted against the other defendants in this action which may be barred by the
actions of defendant Kendall A. Minter, demands judgment in his favor and against
the defendant Kendall A. Minter, for such monetary damages as he may establish at
32
trial which are in excess of $50,000, award to Plaintiff of the costs incurred in bringing
this action, interest, and such relief as this Court may deem just and proper under the
circumstances.
COUNT XIII
PLAINTIFF V. KENDALL A. MINTER
(Constructive Fraud)
179.
that he had no past or present business or financial dealings with any of the parties
involved, including defendant Gee, that would in any way compromise his zealous
advocacy on behalf of Plaintiff Hubbard.
182.
In about December 2014, defendant Minter disclosed for the first time
that he had two clients who were also represented by defendant Gee, and that he
(defendant Minter) had been actively working with defendant Gee to maximize
business opportunities for these clients with defendant Gee and Gee-controlled
entities.
33
183.
has been deprived of his right to seek relief and compensation for the deprivation of
his legal rights and injuries from the other defendants as set forth above.
186.
rights of Plaintiff Hubbard, and are so shocking, outrageous and in bad faith that
punitive damages are warranted.
WHEREFORE, Plaintiff Leonard N. Hubbard, demands judgment in his favor
and against defendant Kendall A. Minter, for such monetary damages as he may
establish at trial which are in excess of $50,000, award to Plaintiff of the costs
incurred in bringing this action, interest, punitive damages, and such relief as this
Court may deem just and proper under the circumstances.
BERNHARDT, ROTHERMEL & SIEGEL, P.C.
BY:
Frank A. Rothermel
/s/
Frank A. Rothermel (#54038)
Attorney for Plaintiff
34
Of counsel:
Michael J. McCaney, Jr.
Attorney ID No.: 28013
1515 Market Street
Suite 1505
Philadelphia PA 19102
(215) 496-0177
Email: mjm@mccaneylaw.com
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10/1/15