Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
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`ESTTA795535
`
`Filing date:
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`01/17/2017
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91231364
`
`Party
`
`Correspondence
`Address
`
`Submission
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`Filer's Name
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`Filer's e-mail
`
`Plaintiff
`Vale National Training Center, Inc.
`
`GEORGE R SCHULTZ
`SCHULTZ & ASSOCIATES P C
`5400 LBJ FREEWAY SUITE 1200
`DALLAS, TX 75240
`UNITED STATES
`rschultz@grspc.com, nmarsh@grspc.com, docket@grspc.com, kneed-
`ham@grspc.com
`
`Motion to Suspend for Civil Action
`
`George R. Schultz
`
`rschultz@grspc.com, nmarsh@grspc.com, docket@grspc.com, kneed-
`ham@grspc.com
`
`Signature
`
`Date
`
`/george r. schultz/
`
`01/17/2017
`
`Attachments
`
`Motion to Suspend TTAB 91231364 .0209.pdf(1289028 bytes )
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`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`OPPOSITION NO. 91231364
`
`
`
`In the matter of Trademark
`Application Serial No.: 86/923,011
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`For the mark: VALE INSURANCE PARTNERS
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`Published in the Official Gazette on: October 11, 2016
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`
`
`
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`VALE NATIONAL TRAINING CENTER, INC.,
`
`
`Opposer,
`
`
`v.
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`VALE INSURANCE PARTNERS LLC,
`
`
`Applicant.
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`
`
`JOINT MOTION FOR SUSPENSION
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`Vale National Training Center, Inc. (“Opposer”) and Vale Insurance Partners LLC
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`(“Applicant”) jointly move to suspend this proceeding pursuant to 37 C.F.R. § 2.117(a) and
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`would respectfully show the Board the following:
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`1.
`
`On August 23, 2016, Opposer filed suit against Applicant in the United States
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`District Court, Northern District of Texas, Dallas Division, Civil Action No. 3:16-cv-02449-D
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`(“Litigation”). Opposer alleges trademark infringement, false designation of origin, and unfair
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`competition by the use of Applicant’s mark. Pursuant to TBMP § 510.02(a), a copy of the
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`Original Complaint is attached as Exhibit A.
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`2.
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`The Board may suspend a proceeding when a party to the proceeding is engaged
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`in a civil action which may have a bearing on the proceeding. See, 37 C.F.R. § 2.117(a). The
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`civil action does not need to be dispositive of the proceeding to warrant suspension, it needs to
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`only have a bearing on the issues in the proceeding. See, New Orleans Louisiana Saints LLC v.
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`JOINT MOTION FOR SUSPENSION
`
`
`
`1
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`

`

`Who Dat?, Inc., Opp. No. 91198708, *6 (TTAB July 22, 2011). The suspension may last until
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`termination of the civil action. See, 37 C.F.R. § 2.117(a).
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`3.
`
`The Litigation may have a bearing on the proceeding because it involves some of
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`the same marks that are at issue in this proceeding, and requires a determination of whether or
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`not there is a likelihood of confusion relating to those marks. Further, in the Litigation, Opposer
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`has requested that Applicant be enjoined from continued use of the mark VALE INSURANCE
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`PARTNERS. See, Who Dat?, Opp. No. 91198708 at *7 (Suspension appropriate because
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`decision by the district court to enjoin use of mark would have a bearing on the proceeding.).
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`Therefore, the Parties respectfully request suspension of this proceeding until a final
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`determination of the Litigation, as well as any and all appeals.
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`
`
`Dated: January17, 2017.
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/paul c llewellyn/
`Paul C. Llewellyn
`
`ARNOLD & PORTER KAYE SCHOLER LLP
`250 W. 55th Street
`New York, New York 10019
`212-836-7828 telephone
`
`ATTORNEYS FOR APPLICANT
`VALE INSURANCE PARTNERS LLC
`
`
`
`
`
`
`
`
`
`
`/george r. schultz/
`George R. Schultz
`Texas Bar No. 17837500
`Nicole R. Marsh
`Texas Bar No. 24044653
`
`SCHULTZ & ASSOCIATES, P.C.
`5400 LBJ Freeway
`Suite 1200
`Dallas, Texas 75240
`214-210-5940 telephone
`214-210-5941 facsimile
`
`ATTORNEYS FOR OPPOSER
`VALE NATIONAL TRAINING CENTER,
`INC.
`
`
`
`JOINT MOTION FOR SUSPENSION
`
`
`
`
`
`2
`
`

`

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`
`
`CERTIFICATE OF SERVICE
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`A true and correct copy of the foregoing Joint Motion for Suspension was served upon
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`the persons listed below in the manner indicated on January 17, 2017:
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`Via Email paul.llewellyn@apks.com
`
`
`
`Mr. Paul C. Llewellyn
`Arnold & Porter Kaye Scholer LLP
`250 West 55th Street
`New York, NY 10019
`
`/george r. schultz/
`George R. Schultz
`
`
`
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`CERTIFICATE OF SERVICE – SOLO PAGE
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`

`

`
`
`Exhibit A
`Exhibit A
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`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 1 of 12 PageID 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
`
`
`VALE NATIONAL TRAINING CENTER, §
`INC.,
`§
`
`§
`
`§ CIVIL ACTION NO.
`
`§
`v.
`§
`
`§
`VALE INSURANCE PARTNERS LLC,
`§
`
`
`§
`
`§ JURY TRIAL DEMANDED
`
`§
`
`§
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT
`
`Plaintiff, Vale National Training Center, Inc. (“Vale”), files its Original Complaint
`
`against Defendant, Vale Insurance Partners LLC (“Defendant”), and would respectfully show the
`
`Court the following:
`
`Parties
`
`1.
`
`Vale is a Texas corporation with a principal place of business at 2424 E. Randol
`
`Mill Road, Arlington, Texas 76011.
`
`2.
`
`Vale Insurance Partners LLC is a limited liability company organized and existing
`
`under the laws of the State of Illinois with a principal place of business at 40 West 57th Street,
`
`Suite 1610, New York, New York 10019. Vale Insurance Partners LLC has listed its registered
`
`agent for service of process as VCorp Agent Services, Inc., 2920 W. Coyle Avenue, Chicago,
`
`Illinois 60645.
`
`
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`1
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 2 of 12 PageID 2
`
`Jurisdiction and Venue
`
`4.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331, 1338(a) and
`
`15 U.S.C. § 1121 because this case arises under the Trademark Act of 1946, as amended, 15
`
`U.S.C. § 1051 et seq.
`
`5.
`
`This Court has jurisdiction over the unfair competition claim under the provisions
`
`of 28 U.S.C. § 1338(b), because this claim is joined with substantial and related claims under the
`
`trademark laws of the United States, 15 U.S.C. § 1051 et seq.
`
`6.
`
`This Court has supplemental jurisdiction over the claims which arise under the laws
`
`of the State of Texas pursuant to 28 U.S.C. § 1367(a), as the claims are so related to the Federal
`
`Claims that they form part of the same case or controversy and derive from a common nucleus of
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`operative fact.
`
`7.
`
`Venue lies properly in this judicial district and division under the provisions of 28
`
`U.S.C. § 1391(b) and (c) because Defendant is subject to personal jurisdiction in this district and,
`
`thus, is deemed to reside in this district and because the claims and causes of action arose
`
`through acts Defendant committed in this District and Division.
`
`Factual Allegations
`
`8.
`
`For many years and since long prior to the acts of Defendant which are the subject
`
`of this Complaint, Vale has offered and continues to offer the services of insurance adjustor
`
`training for all forms of property damage, casualty, OSHA claims, and worker’s compensation
`
`across the United States, including in this District and Division. The services of Vale are provided
`
`in association with one or more of the trademarks, including “VALE TRAINING SOLUTIONS®”,
`
`and “VALE NATIONAL®” (collectively, the “VALE Marks”), among others.
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`2
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 3 of 12 PageID 3
`
`9.
`
`Vale is the owner of Federal Trademark Registration No. 3,782,029 on the
`
`Principal Register for the trademark “VALE TRAINING SOLUTIONS®” for “education
`
`services, namely, training and courses in the fields of appraising damage to automobiles, trucks,
`
`heavy equipment, mobile homes, recreational vehicles and all forms of property, casualty,
`
`workers compensation, legal liability, adjuster and agent licensing, professional development,
`
`professional designations, OSHA and healthcare” in Class 41. A copy of the registration is
`
`attached as Exhibit A. The Mark has been used continuously since its date of first use, which was
`
`at least as early as September 2008. The registration is valid and subsisting, uncancelled and
`
`unrevoked. The registration has become incontestable under 15 U.S.C. § 1065.
`
`10.
`
`Vale is the owner of Federal Trademark Registration No. 2,255,689 on the
`
`Principal Register for the trademark “VALE NATIONAL®” and design for “education services,
`
`namely, training in the field of appraising damage to automobiles, trucks, heavy equipment,
`
`mobile homes, recreational vehicles and all forms of property” in Class 41. A copy of the
`
`registration is attached as Exhibit B. The Mark has been used continuously since its date of first
`
`use, which was at least as early as 1979. The registration is valid and subsisting, uncancelled and
`
`unrevoked. The registration has become incontestable under 15 U.S.C. § 1065.
`
`11.
`
`Prior to the acts of Defendant complained of herein, Vale has expended a
`
`substantial amount of money, energy, time and effort in continuously advertising and promoting
`
`the VALE Marks in connection with its services. Vale continues to advertise and promote its
`
`services to the trade and the public.
`
`12.
`
`As a result of the care and skill exercised by Vale in the conduct of its business,
`
`by extensive advertising, and through the continuous marketing of services under the VALE
`
`Marks, Vale has acquired a reputation for high quality.
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`3
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 4 of 12 PageID 4
`
`13.
`
`Vale is now known in the marketplace as the exclusive source of services bearing
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`the VALE Marks. The VALE Marks have acquired wide notoriety and symbolize the goodwill
`
`which Vale has created. Consequently, the VALE Marks constitute valuable assets of Vale.
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`Growth and continuation of Vale’s business depends in part upon the unique and distinctive
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`nature of the VALE Marks and on the reputation and goodwill symbolized thereby.
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`14.
`
`Upon information and belief, Defendant has adopted and used the mark “VALE
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`INSURANCE PARTNERS” (the “Infringing Mark”) in association with insurance services
`
`including brokering, underwriting and issuing insurance policies and advising customers how to
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`mitigate damage and casualty claims, as recently as January 2016, throughout the United States
`
`and Texas including in this District and Division. An example of advertising bearing the
`
`Infringing Mark is attached as Exhibit C.
`
`15.
`
`At no time has Vale authorized or approved Defendant’s sale, offer for sale,
`
`distribution, or advertising of services under the Infringing Mark. Vale has notified Defendant
`
`that its actions constitute trademark infringement and unfair competition. Yet, Defendant has
`
`continued to sell its services under the Infringing Mark.
`
`Count I
`Federal Trademark Infringement
`(15 U.S.C. § 1114(1))
`
`16.
`
`Vale repeats and realleges the allegations of Paragraphs 1 through 15 as if fully
`
`set forth herein.
`
`17.
`
`Defendant has infringed the VALE Marks in violation of 15 U.S.C. § 1114(1)(a),
`
`by conducting various acts without the consent of Vale, including use in commerce of a
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`reproduction, counterfeit, copy or colorable imitation of the VALE Marks and selling, and
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`4
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 5 of 12 PageID 5
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`offering for sale, services under the Infringing Mark which are likely to cause confusion, or to
`
`cause mistake or to deceive consumers.
`
`18.
`
`Defendant has also infringed the VALE Marks in violation of 15 U.S.C. §
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`1114(1)(b), by conducting various acts without the consent of Vale, including using a
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`reproduction, copy or colorable imitation of the VALE Marks on webpages, signs, prints,
`
`receptacles or advertisements intended to be used in commerce upon or in connection with the
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`sale, offering for sale, distribution, or advertising of services in a manner likely to cause
`
`confusion, to cause mistake, or to deceive consumers.
`
`19.
`
`On information and belief, Defendant’s acts of trademark infringement are
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`fraudulent, deliberate, willful and malicious, and have been committed with the intent to cause
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`injury to Vale and its property rights in the VALE Marks, and to cause confusion, mistake and
`
`deception.
`
`Count II
`False Designation of Origin
`(15 U.S.C. § 1125(a))
`
`20.
`
`Vale repeats and realleges the allegations of Paragraphs 1 through 19 as if fully
`
`set forth herein.
`
`21.
`
`For many years, and since long prior to the acts of Defendant, Vale has
`
`continuously marketed and sold services under the VALE Marks.
`
`22.
`
`Since long prior to the acts of Defendant, Vale has expended a substantial amount
`
`of money in continuously advertising and promoting the VALE Marks in connection with its
`
`services. Vale continues to advertise and promote its services to the trade and to the public under
`
`the VALE Marks.
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`5
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 6 of 12 PageID 6
`
`23.
`
`Since long prior to the acts of Defendant, Vale has acquired a fine reputation
`
`because of its uniformly high quality of services sold under the VALE Marks and because of its
`
`extensive advertising and sales. As a result, services associated with the VALE Marks have been
`
`and are now recognized by the public and the trade as originating from a single source, namely,
`
`Vale.
`
`24.
`
`Because of the inherent distinctiveness of the VALE Marks and/or because the
`
`marks have acquired a secondary significance in the industry, the VALE Marks have come to
`
`indicate a single source, namely Vale, for its services.
`
`25.
`
`Defendant’s acts are in violation of 15 U.S.C. § 1125(a)(1)(A) because Defendant
`
`has used the Infringing Mark in commerce, in association with its services, which constitutes a
`
`false and misleading description of fact and a false or misleading representation of fact and
`
`which is likely to cause confusion, or cause mistake, or to deceive as to the affiliation,
`
`connection or association of Defendant with Vale, or as to the origin, sponsorship or approval of
`
`Defendant’s services.
`
`26.
`
`Defendant’s acts are in violation of 15 U.S.C. § 1125(a)(1)(B) because Defendant
`
`has used, in connection with services, in commerce, words, terms, names, symbols and devices
`
`and combinations thereof and false, misleading descriptions of fact in commercial advertising
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`and promotions which misrepresent the nature, characteristics, and qualities of Defendant’s
`
`services and/or commercial activities.
`
`27.
`
`On information and belief, Defendant’s acts of false designation of origin are
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`fraudulent, deliberate, willful and malicious, and have been committed with the intent to cause
`
`injury to Vale and its property rights in the VALE Marks, and to cause confusion, mistake and
`
`deception.
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`6
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 7 of 12 PageID 7
`
`Count III
`Injury to Business Reputation and Dilution
`(Tex. Bus. & Com. Code Ann. § 16.103)
`
`28.
`
`Vale repeats and realleges the allegations in Paragraphs 1 through 27 as if fully
`
`set forth herein.
`
`29.
`
`Beginning at least as early as 1979, Vale adopted and used at least one of the
`
`VALE Marks in association with its services. The VALE Marks have been used by Vale or
`
`those under its supervision and authority continuously since the respective first use date of each
`
`trademark.
`
`30.
`
`The VALE Marks are each famous and inherently distinctive and/or have
`
`acquired distinctiveness. The VALE Marks have been registered on the Principal Register of the
`
`United States Patent and Trademark Office and have been used extensively throughout the State
`
`of Texas.
`
`31.
`
`Defendant has adopted and used a trademark in commerce that is likely to cause
`
`dilution of the distinctive quality of one or more of the VALE Marks. Specifically, the use of the
`
`Infringing Mark is likely to create confusion and induce consumers to believe that the services
`
`offered by Defendant are actually those of Vale or connected or associated with Vale. Moreover,
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`the distinctive quality of the VALE Marks will be blurred and tarnished through the actions of
`
`Defendant. Accordingly, Defendant’s conduct violates the Texas Trademark Act.
`
`32.
`
`On information and belief, Defendant’s violations of the Texas Trademark Act are
`
`fraudulent, deliberate, willful and malicious, and have been committed with the intent to cause
`
`injury to Vale and its property rights in the VALE Marks, and to cause confusion, mistake and
`
`deception.
`
`
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`7
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 8 of 12 PageID 8
`
`Count IV
`Unfair Competition
`(Texas Common Law)
`
`Vale repeats and realleges the allegations in Paragraphs 1 through 32 as if fully
`
`33.
`
`set forth herein.
`
`34.
`
`Vale has adopted and used one or more of the VALE Marks for use on and in
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`connection with its services since at least as early as 1979 and has used the marks continuously
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`since their respective dates of first use. The VALE Marks identify Vale as a sole source of
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`services offered by Vale and distinguishes those services from many others.
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`35.
`
`As a result of the care and skill exercised by Vale in the conduct of its business
`
`and particularly in the maintenance of high quality services, by its extensive advertising, and by
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`the extensive and continuous marketing of services throughout the industry over many years, the
`
`services offered under the VALE Marks have acquired a reputation for high quality. As a result
`
`of these efforts by Vale, consumers and the industry recognize the VALE Marks to identify Vale
`
`exclusively as a source of high quality services. The VALE Marks have acquired wide notoriety
`
`and symbolize the goodwill which Vale has created by the sale of dependable and high quality
`
`services. Consequently, the VALE Marks constitute a valuable asset of Vale.
`
`36.
`
`Subsequent to the adoption and use of the VALE Marks by Vale, Defendant
`
`began infringing the VALE Marks by advertising and selling services under a trademark that is
`
`confusingly similar to and creates the same commercial impression as one or more of the VALE
`
`Marks in Texas. Such conduct represents unfair competition and misappropriation and is
`
`designed to cause confusion and mistake and to deceive consumers into believing that
`
`Defendant’s services are somehow sponsored by, or associated with Vale.
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`8
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 9 of 12 PageID 9
`
`37.
`
`On information and belief, Defendant has attempted to and has passed off on the
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`public services of Defendant as those of Vale.
`
`38.
`
`On information and belief, Defendant’s acts of false designation of origin and
`
`misappropriation are fraudulent, deliberate, willful and malicious, and have been committed with
`
`the intent to cause injury to Vale and its property rights in the VALE Marks, and to cause
`
`confusion, mistake and deception.
`
`Allegations Of Damage
`
`39.
`
`Vale repeats and realleges the allegations in Paragraphs 1 through 38 as if fully
`
`set forth herein.
`
`40.
`
`Because of Defendant’s actions, Vale has suffered and will continue to suffer
`
`damage to its business, reputation and goodwill and to endure a loss of sales and profits in an
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`amount yet to be determined.
`
`41.
`
`Because of Defendant’s actions, Defendant will be unjustly enriched by profits it
`
`has made through the sale of services utilizing the Infringing Mark.
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`42.
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`Unless Defendant is enjoined from its actions, Vale will suffer irreparable harm,
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`for which there is no adequate remedy at law.
`
`Demand For Jury Trial
`
`43.
`
`Pursuant to Federal Rule of Civil Procedure 38(b), Vale hereby demands a jury
`
`trial.
`
`WHEREFORE, Vale respectfully requests:
`
`Prayer
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`9
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 10 of 12 PageID 10
`
`44.
`
`That Defendant, its officers, agents, servants, employees, attorneys, confederates
`
`and all persons in active concert or participation with it, be enjoined immediately and
`
`preliminarily during the pendency of this action, and thereafter perpetually from:
`
`A.
`
`Using the Infringing Mark, and any reproduction, counterfeit, copy or
`
`colorable imitation of any of the VALE Marks in connection with the advertising, selling or
`
`offering for sale, services that are the same, similar, or related to those offered by Vale;
`
`B.
`
`Using the Infringing Mark, and any reproduction, counterfeit, copy or
`
`colorable imitation of the VALE Marks in any manner likely to cause confusion, to cause
`
`mistake or to deceive;
`
`C.
`
`Selling or passing off, inducing, or enabling others to sell or pass off any
`
`services similar to, associated with, or connected with those offered by Vale;
`
`D.
`
`Committing any acts, including, but not limited to marketing and
`
`advertising, which are likely to cause injury to Vale’s business reputation and/or blur or tarnish
`
`the distinctiveness of any of the VALE Marks;
`
`E.
`
`Committing any acts, including, but not limited to marketing and
`
`advertising, which are calculated to cause consumers to believe that Defendant’s services are
`
`Vale’s services in whole or in part, unless they are entirely such;
`
`F.
`
`Otherwise competing unfairly with Vale in any manner, including, but not
`
`limited to, usage of the Infringing Mark or any other mark which is confusingly similar to the
`
`VALE Marks;
`
`G.
`
`Destroying, altering, disposing of, concealing, tampering with or in any
`
`manner secreting any and all business records, invoices, correspondence, books of account,
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`receipts or other documentation relating or referring in any manner to the providing, advertising,
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`10
`
`

`

`
` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 11 of 12 PageID 11
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`sale or offer for sale of any services bearing the Infringing Mark or any other mark which is
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`confusingly similar to the VALE Marks;
`
`45.
`
`That after final hearing Defendant be required to deliver up for destruction or,
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`alternatively, to obliterate all infringing marks on their entire inventory of infringing items,
`
`including but not limited to signs, labels, packaging, advertisements, video and audio recordings,
`
`literature, correspondence, invoices, catalogs, and electronic advertising of any kind and any
`
`other material in its possession bearing the Infringing Mark or any other mark which is
`
`confusingly similar to the VALE Marks;
`
`46.
`
`That for the next five (5) years, upon ten (10) days notice, Vale be permitted to
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`inspect and audit Defendant’s inventory and all business records to determine compliance with
`
`the Order issued by the Court;
`
`47.
`
`That Defendant be ordered to account and pay over to Vale all damages sustained
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`by Vale and profits realized by Defendant by reason of Defendant’s unlawful acts as alleged
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`herein, that such profits be fully trebled as provided by law because of the willfulness of
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`Defendant’s acts;
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`48.
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`49.
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`50.
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`That Vale be awarded prejudgment and post-judgment interest;
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`That Vale be awarded its costs and reasonable attorney’s fees; and
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`That Vale have such other and further relief as the Court deems just and proper.
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`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`11
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`

`

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` Case 3:16-cv-02449-D Document 1 Filed 08/23/16 Page 12 of 12 PageID 12
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`Dated: August 23, 2016.
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`Respectfully submitted,
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`
`
`s/George R. Schultz
`George R. Schultz
`Texas State Bar No. 17837500
`rschultz@grspc.com
`Nicole R. Marsh
`Texas State Bar No. 24044653
`nmarsh@grspc.com
`
`SCHULTZ & ASSOCIATES, P.C.
`5400 LBJ Freeway
`Suite 1200
`Dallas, Texas 75240
`(214) 210-5940 telephone
`(214) 210-5941 facsimile
`
`ATTORNEYS FOR PLAINTIFF
`VALE NATIONAL TRAINING CENTER,
`INC.
`
`
`
`ORIGINAL COMPLAINT
`27831.0187.081516.5
`
`12
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`

`

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` Case 3:16-cv-02449-D Document 1-1 Filed 08/23/16 Page 1 of 7 PageID 13
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`
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`Exhibit A
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` Case 3:16-cv-02449-D Document 1-1 Filed 08/23/16 Page 2 of 7 PageID 14
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`

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` Case 3:16-cv-02449-D Document 1-1 Filed 08/23/16 Page 3 of 7 PageID 15
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`Exhibit B
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`

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` Case 3:16-cv-02449-D Document 1-1 Filed 08/23/16 Page 4 of 7 PageID 16
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`

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` Case 3:16-cv-02449-D Document 1-1 Filed 08/23/16 Page 5 of 7 PageID 17
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`Exhibit C
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`

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`About Us - VALE Insurance Partners
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`http://valeinsurancepartners.com/about-us/
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` Case 3:16-cv-02449-D Document 1-1 Filed 08/23/16 Page 6 of 7 PageID 18
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`8/10/2016 4:40 PM
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`1
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`About Us - VALE Insurance Partners
`
`http://valeinsurancepartners.com/about-us/
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` Case 3:16-cv-02449-D Document 1-1 Filed 08/23/16 Page 7 of 7 PageID 19
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`VALE Insurance Partners
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`8/10/2016 4:40 PM
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`2
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