throbber
FILED
`1/26/2023 2:33 PM
`FELICIA PITRE
`DISTRICT CLERK
`DALLAS CO., TEXAS
`Debra Clark DEPUTY
`
`IN THE DISTRICT COURT
`
`134" JUDICIAL DISTRICT
`
`DALLAS COUNTY, TEXAS
`
`115 ManagementInc.,
`
`Plaintiff,
`
`VS.
`
`MedicalUSA Supply, LLC &
`Ryon Scott Kestler; Individually
`
`Defendants
`
`VS.
`
`Nexus Medical, LLC, Aaron Cain
`McKnight; Individually, David
`Schiller; Individually, Derrick
`“Smokey” Armstrong; individually, &
`Controlled Elements Sanitary
`Solutions, LLC
`
`Third-Party Defendants
`
`NO. DC-20-18383
`
`GCQPGLLILRLILILILILnGASILIG2LOLI?2LP?WONUNUrODIP
`
`DEFENDANT’S RESPONSE TO THIRD-PARTY DEFENDANTS MOTION FOR
`SUMMARY JUDGMENT
`
`TO HONORABLE JUDGE TILLERY & THE134";
`
`COMES NOW Defendants, MedicalUSA Supply, LLC and Ryon Scott Kestler in his
`
`individual capacity to quash the proposed “No Evidence Motion for Summary Judgment”. All
`
`evidence has already been provided and is now a matter of public record under Cause No. DC-20-
`
`Page 1 of 11 Defendanv’s Response To Third-Party Defendants Motion For Summary Judgment
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`

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`18383 in February 2021. All evidence points to what seems to be a criminal organization run by
`
`Aaron Cain McKnight, David Schiller, Derrick “Smokey” Armstrong, John Doe 1, John Doe 2, &
`
`John Doe 3. Nexus Medical, LLC list David Schiller as a partner, VP, and the companies registered
`
`agent (listed on Affidavit as Exhibit A). David Schiller has already demonstrated to be a dangerto
`
`the community of Dallas County. Schiller was Ordered by the Supreme Court of Texas from
`
`practicing law in the State of Texas. David Schiller, a disbarred attorney, was the main point of
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`contact for Defendants, MedicalUSA Supply, LLC to transact with Nexus Medical, LLC. Facts,
`
`documents, Evidence filed in the 134" in 2021 should be held as an unyielded action to abjure in
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`clear rejection to the Nexus Medical, LLC & David Schiller’s “No Evidence Motion for Summary
`
`Judgment”. Further documented(also listed on Affidavit as Exhibit A) displays order from Schiller
`
`to facilitate all transactions betweenall parties listed in this lawsuit.
`
`FACTUAL BACKGROUND
`
`1. This suit was originally filed by 115 Management, Inc. on December14, 2020. Original
`
`Plaintiff (115 Management) has settled with Defendants (MedicalUSA Supply, LLC,
`
`Ryon Scott Kestler) and has released all claims of such camouflaged & ludicrousfilings.
`
`115 Management, Inc. released its claims against Defendants (MedicalUSA Supply,
`
`LLC, Ryon Scott Kestler) after further trying to extort MedicalUSA Supply, LLC from
`
`the schemeorchestrated by Nexus Medical, LLC, Aaron Cain McKnight, David Schiller,
`
`Derrick “Smokey” Armstrong, Controlled Elements Sanitary Solutions, LLC, John Doe
`
`1, John Doe 2, & John Doe 3.
`
`Page 2 of 1] Defendant’s Response ‘To ‘Third-Party Defendants Motion For SummaryJudgment
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`

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`2. Original Plaintiff (115 Management, Inc.) wrote NSF checks post settlement agreement
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`to MedicalUSA Supply, LLC. Derrick “Smokey” Armstrong further caused even more
`
`financial harm to Defendants (MedicalUSA Supply, LLC, Ryon Scott Kestler) with hot
`
`checks. These NSF checks wrote to MedicalUSA Supply, LLC/Ryon Kestler caused the
`
`Defendants (Medical/Kestler) party to take further action with an outside debt collection
`
`agency.
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`3. Original Plaintiff (115 Management, Inc.) is no longer a party to this lawsuit. Plaintiff
`
`(115 Management) & Defendants (MedicalUSA Supply, LLC & Ryon Scott Kestler)
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`have severed, mutually released, ties. These two parties listed on this paragraph “3”are
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`no longer in dispute over the current matter at hands “pendingtrial in the 134" DC-20-
`
`1838”.
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`4, David Schiller, Cain McKnight, John Doe 1, John Doe 2, & John Doe 3 all wired funds
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`to their personal accounts from misrepresentation of goods from Nexus Medical, LLC
`
`transactions. David Schiller is no victim to the fraud orchestrated by this band of
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`criminals. Video Evidence can be displayedat trial, Trial scheduled in August of2023
`
`in the 134" Judicial District, of Schiller attempting to further defraud investors with
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`jewels, gems, and precious stones. Sending videos to McKnightto then re-forward to
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`Kestler as an act of desperation for further collateralized goods. Schiller, in addition,
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`on September 3", 2020 at 2:50PM wrote to MedicalUSA Supply, LLC & Kestler that
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`Nexus Medical, LLC would provide MedicalUSA Supply, LLC with collateral in form
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`of “title to the listed products” on a bill of sale. (Listed on affidavit as Exhibit B).
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`These products that Schiller/McKnight/Nexus/John Doe 1/John Doe 2/John Doe 3 used
`
`for collateral to offset debts owed to MedicalUSA Supply, LLC were the original cause
`
`Page 3 of 11 Defendant’s Response To Third-Party Defendants Motion For Summary Judgment
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`

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`of action filed by Plaintiff (115 Management) against Defendants (MedicalUSA
`
`Supply, LLC, Ryon Scott Kestler) as a form of“theft”, “fraud”, and “conversion”
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`among other disrelishing acts. David Schiller and his band of criminal associates are
`
`proven con artist. David Schiller’s associate, Cain McKnight, is being prosecuted by
`
`the U.S. Securities and Exchange Commission;
`
`
`HTTPS://WWW.SEC.GOV/LITIGATION/COMPLAINTS/2023/COMP25677.PDF. Further the
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`Original Plaintiff (115 Management) aka Derrick “Smokey” Armstrong has already
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`been arrested for extorting Sam Nazarian HTTPS://WWW.LATIMES.COM/BUSINESS/LA-FI-
`
`
`MAN-ACCUSED-OF-EXTORTING-NAZARIAN-ARRESTED-IN-LAS-VEGAS-20141218-
`
`STORY.HTML.
`
`5. Between 7/24/2020 — 09/15/2020 Defendant
`
`(MedicalUSA Supply, LLC) wired
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`$766,800 to the Third-Party Defendants (Nexus Medical, LLC, McKnight, Schiller, John
`
`Doe 1, John Doe 2, John Doe 3) for two separate orders of PPP goods. All Third-Party
`
`Defendants /isted as individuals wired fundsto their personal accounts. This band of
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`fraudsters wired funds directly to themselves for their own self gain with zero intention
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`of providing a true and fulfilled order to Defendants (MedicalUSA Supply, LLC, Ryon
`
`Scott Kestler).
`
`6. Third-Party Defendants, and their attorney of representation, are not un-common to such
`
`claims made by Defendants (MedicalUSA Supply, Ryon Scott Kestler). Third-Party
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`Defendants listed as individuals are shown sending wires to their personal banks
`
`accountspriorto delivering any PPP goodsin another case in the 134" Judicial District
`
`Page 4 of 11 Defendant’s Response ‘To Third-Party Defendants Motion For SummaryJudgment
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`

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`Court. Please locate Cause Number DC-20-07453 for filed evidence of fraud, breach
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`of contract, unjust enrichment, money had and received, statutory fraud, negligence,
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`misrepresentation, and conspiracy. You will
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`find David Schiller, amongst other
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`fraudsters, wiring themselves thousands of thousands of dollars to their personal
`
`accounts for self-gain. Exhibit C on the Affidavit (Listed on the Affidavit as Exhibit
`
`C) shows wires sent to David Schiller in Case Number DC-20-07453, McKnight, and
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`other, John Does“the band of con artist”.
`
`7. On December 9", 2021 Zephyr Collections, LLC filed its petition in intervention in this
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`case wherein it asserted claims against Defendants (MedicalUSA Supply, LLC, Ryon
`
`Scott Kestler). These claims were from Defendants (MedicalUSA Supply, LLC, Ryon
`
`Scott Kestler) being a middleman in between Third-Party Defendants (Nexus Medical,
`
`LLC, McKnight, Schiller, John Doe 1, John Doe 2, John Doe3) for facilitation of goods
`
`for goods promised by “Nexus Medical”. On 08/04/2020 MedicalUSA Supply, LLC
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`received payment from Intervenor“Zephyr” for $372,000 for PPP goods. The very same
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`day MedicalUSA Supply, LLC sent paymentto “Nexus” for $358,500 to fulfill the order.
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`This same order was already negotiated between Defendants (MedicalUSA Supply,
`
`LLC, Ryon Scott Kestler) & Third-Party Defendants (Nexus Medical, LLC, McKnight,
`
`Schiller, John Doe 1, John Doe 2, John Doe 3). This purchase order was signed by
`
`“Schiller” and already submitted into evidence on 02/02/2021.
`
`e
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`“Nexus” did not deliver product. “Nexus”, “Schiller”, “McKnight”, “John Doe 1”, “John
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`Doe 2”, “John Doe 3” misrepresented and breached contract. The band ofthief’s strike again.
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`Page 5 of 11 Defendant’s Response ‘To ‘Third-Party Defendants Motion For SummaryJudgment
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`

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`e
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`“Nexus” and the bandits were misappropriating funds paid for PPP to disposeofselfish lude
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`acts. Purchasing bottle service at fancy nightclubs, driving luxury cars (such as Porsche 911,
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`Mercedes S Class, and other high-end cars), renting out million-dollar mansions in Park
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`Cities & Highland Park. David Schiller is no victim in these acts of criminal activity.
`
`e While “Nexus”fails to deliver products and live the high life. “MedicalUSA Supply, LLC
`
`& Ryon Scott Kestler are scrambling to make good on their commitments to good business
`
`with Intervenor “Zephyr’’.
`
`1.
`
`MedicalUSA Supply, LLC honored the agreements with their referral partner Caleb
`
`Reynolds by wiring him his fee of $4,600 on the same day of order 08/04/2020.
`
`il.
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`MedicalUSA Supply, LLC paid out of pocket expenses exceeding $6,000 on
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`shipping and handling for what PPP goods MedicalUSA Supply, LLC could locate
`
`for Intervenor “Zephyr”. These delivery expenses were promised to be executed by
`
`the “Nexus Medical”parties, as they were to have the order ready as bulk pick up
`
`for the “Zephyr” parties.
`
`iil.
`
`MedicalUSA Supply, LLC, in addition,still delivered nearly 50% of the order placed
`
`by Intervenor (Zephyr).
`
`iv.
`
`MedicalUSA Supply, LLC,in addition, delivered reimbursementsat its own expense
`
`paid back to Intervenor (Zephyr) in the following amounts:
`
`(a) $25,000 on 09/17/2020
`
`(b) $9,9000 on 09/11/2020
`
`(c) $65,000 on 09/16/2020
`
`(d) $21,200 on 08/03/2022
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`Page 6 of 11 Defendant’s Response ‘To Third-Party Defendants Motion For SummaryJudgment
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`

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`= $121,100 out of pocket in addition to products delivered, shipping cost, referral fees, and more.
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`MedicalUSA Supply, LLC & Ryon Scott Kestler have suffered extreme financial harm on the order
`
`in which “Zephyr” Intervened. Negative delta on this order as “middleman” between the “Nexus”
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`criminal organization & Intervenor “Zephyr” exceed losses of $503,700 to MedicalUSA Supply,
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`LLC and Ryon Scott Kestler.
`
`8. Outside of the order between Intervenor “Zephyr” and Defendant “MedicalUSA” Ryon
`
`Scott Kestler invested personal funds on outside orders between Third-Party Defendants
`
`(Nexus Medical, LLC, McKnight, Schiller, John Doe 1, John Doe 2, John Doe 3). Per
`
`State Law of Texasin the 134" Judicial District Court “Kestler’” has every & all right to
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`represent “Kestler” in his individual capacity for these orders funded by “Kestler’.
`
`9. Fraudster, Con-Artist, and Deceiving Schiller also presented himself as the President
`
`of Assets and Projects for THE CGE GROUP(Listed on the Affidavit as Exhibit
`
`D). The CGE Group (“CGE”) is the home basis for “The HYIP Scheme” filed be the
`
`U.S. Securities and Exchange Commission for defrauding investors out of millions of
`
`dollars. Reference;
`
`HTTPS://WWW.SEC.GOV/LITIGATION/COMPLAINTS/2023/COMP25677.PDE.
`
`e These acts of fraud by Third-Party Defendants (Nexus Medical, LLC, McKnight, Schiller,
`
`John Doe 1, John Doe 2, John Doe 3) lured further losses in the amounts:
`
`i.
`
`$75,000 wired to CGE, GROUP LLC on 09/15/2020
`
`Page 7 of 11 Defendant’s Response ‘To ‘Third-Party Defendants Motion For SummaryJudgment
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`

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`i.
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`Directed and Orchestrated by McKnight, Schiller, John Doe 1, John Doe 2, John Doe
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`3 to further falsify money needed to complete order. McKnight, Schiller, John Doe
`
`1, John Doe 2, John Doe 3 expressed desperation that orders would finally be
`
`fulfilled with this wire being sent by Defendants (MedicalUSA Supply, LLC, Ryon
`
`Scott Kestler). These parties “McKnight, Schiller, John Doe 1, John Doe 2, John Doe
`
`3” demonstrated that CGE GROUP was a holdings company and backed with
`
`insurance bondsto coverall funds received. Claimingthat the dollars received were
`
`protected and CGE GROUPwasin the process of securing millions of dollars to
`
`make all orders on “back-end” to be fulfilled. CGE Group also claimed their Nexus
`
`Medical account had been frozen due to such high level of volumes in business.
`
`Claiming that the orders were delayed due to banking errors. MedicalUSA Supply,
`
`LLC believes in integrity, commitment, and good business for the communities it
`
`serves. MedicalUSA Supply, LLC was overly committed to find ways to
`
`accommodate its customers by doing everything & anythingto fulfill their customers
`
`request for goods. This wasa timein history for horror, economical meltdown, death,
`
`and desperation. MedicalUSA Supply, LLC wasalso indeed of desperationto satisfy
`
`its customers. The shortages of much needed PPP goods during the pandemic
`
`allowed predators like McKnight, Schiller, John Doe 1, John Doe 2, John Doe 3 to
`
`take advantage of those in need. Many victimsfall like fallen soldiers from these
`
`predators, MedicalUSA Supply, LLC is of no different other than another victim to
`
`these monsters.
`
`Page 8 of 11 Defendant’s Response ‘To Third-Party Defendants Motion For Summary Judgment
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`

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`PRAYER
`
`WHEREFORE, PREMISES CONSIDERED,Defendants MedicalUSA Supply, LLC and Ryon
`
`Scott Kestler pray that Third-Party Defendants Nexus Medical, LLC, Aaron Cain McKnight, David
`
`Schiller, Solutions, LLC, John Doe 1, John Doe 2, & John Doe3. take nothing from Nexus
`
`Medical, LLC and David Schiller’s request for a “No Evidence Motion For Summary Judgment”
`
`and that MedicalUSA Supply, LLC and RyonScott Kestler recoverall losses suffered from these
`
`criminals as follows:
`
`1. The Third-Party Defendants Nexus Medical, LLC, Aaron Cain McKnight, David Schiller,
`
`John Doe 1, John Doe 2, & John Doe 3 take nothingin its suit against MedicalUSA Supply,
`
`LLC or RyonScott Kestler.
`
`2. Third-Party Defendants Nexus Medical, LLC, and David Schiller take nothing their request
`
`for a No Evidence Summary Judgment.
`
`3. That judgment be rendered in favor of Defendants MedicalUSA Supply, LLC and Ryon
`
`Scott Kestler against Nexus Medical, LLC, Aaron Cain McKnight, David Schiller, John Doe
`
`1, John Doe 2, & John Doe 3 for
`
`(a) Actual damages;
`
`(b) Exemplary damages in an amount assessed by the jury at the timeoftrial;
`
`(c) Pre-and post judgmentinterest at the maximum rates allowed by law;
`
`(d) Attorneys’ fees; and
`
`(e) All cost of court
`
`4. That defendants have such other and furtherrelief, general and special, at law and in
`
`equity, to which it may show itselfjustly entitled, or which the Court deems proper.
`
`5. Amendment Seven is property accounted for upon ratification to the Constitution on
`
`Page 9 of 11 Defendant’s Response To ‘Third-Party Defendants Motion For SummaryJudgment
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`

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`December 15", 1791, per Joseph Story.
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`6. That the courts quash Second Amended Original Answer of Third-Party Defendants Nexus
`
`Medical, LLC and David Schiller.
`
`7. MedicalUSA Supply, LLC demandsand further prays the court allowsitself to have
`
`represent itself for trial whentrial is warranted. Quash Second Amended Original Answer
`
`of Third-Party Defendants Nexus Medical, LLC and David Schiller that MedicalUSA
`
`Supply, LLC wasin goodstanding at the time of suit, it can continue the lawsuit:
`
`from filin
`Courts have interpreted Section 171.252 and its predecessor to preclude an entity only
`
`suit after forfeiting from continuing an action filed before its right to do business, not to prohibit it
`
`its privileges were forfeited. See Waterway Ranch, LLC v. City of Annetta, 411 S.W.3d 667 (Tex.
`
`
`
`.—Fort Worth 2013, no pet.); Texas Clinical Labs,
`Inc. v. Leavitt, 535 F.3d 397 (5th Cir. 2008);
`Scogin v. Texas Eagle Ford Shale Magazine, Civil No. 2:14CV-478, 2016 WL 632031 (S.D. Tex. Feb.
`17, 2016)
`
`Respectfully Submitted,
`
`
`By:
`/s/ Ryon Scott Kestler
`Ryon Scott Kestler
`309 Crescent Dr
`Seguin, Texas 78155-78156
`512-998-0917 (telephone)
`ryon@depgco.com
`
`CERTIFICATE OF SERVICE
`
`I certify that on July 21%, 2023 a true and correct copy of the above and foregoing document
`wasserved to all counsel of record electronically through the electronic filing manager.
`
`Page 10 of 11 Defendant’s Response ‘To ‘Third-Party Defendants Motion For Summary Judgment
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`

`

`
`By:
`/s/ Ryon Scott Kestler
`Ryon Scott Kestler
`
`Page 11 of 11 Defendant’s Response To ‘Third-Party Defendants Motion For Summary Judgment
`
`

`

`IN THE DISTRICT COURT
`
`134'* JUDICIAL DISTRICT
`
`DALLAS COUNTY, TEXAS
`
`115 ManagementInc.,
`
`Plaintiff,
`
`VS.
`
`MedicalUSA Supply, LLC &
`RyonScott Kestler; Individually
`
`Defendants
`
`VS.
`
`Nexus Medical, LLC, Aaron Cain
`McKnight; Individually, David
`Schiller; Individually, Derrick
`“Smokey” Armstrong; individually, &
`Controlled Elements Sanitary
`Solutions, LLC
`
`Third-Party Defendants
`
`NO. DC-20-18383
`
`COPCO?OPWO?(>WOUG?WOR602UGUDODUO?UPG2WO?WO?8WDUO6?2(>OP
`
`Affidavit of Exhibits by Ryon Scott Kestler
`
`Before me, the undersigned notary public on this day personally appeared Ryon Scott Kestler, an
`
`authorized officer of MedicalUSA Supply, LLC knownto be the person whose nameis subscribed
`
`to this instrument, and who acknowledged to me that he executed same and further stated the
`
`following:
`
`

`

`1.
`
`“My nameis Ryon Scott Kestler. | am more than eighteen (18) years of age, suffer no
`
`legal or mental disabilities, and am fully competent to makethis affidavit.
`
`2.
`
`|am an officer of MedicalUSA Supply, LLC (“Defendants”) and have been authorized to
`
`act on its behalf as this matter.
`
`In such capacity, | have personal knowledge of these
`
`facts stated herein. In addition, I’m within my rights of the 7 Amendmentand signing
`
`on behalf of myself in my personal capacity as Ryon Scott Kestler (Defendants).
`
`3. Attachedto this Affidavit list the following Exhibits in the following order:
`
`Exhibit A
`1.
`Exhibit B
`2.
`3. Exhibit C
`4. Exhibit D
`
`Exhibit A
`
`This Purchase Order shall be effective onlyafter it has been signed bythe
`DocuSign or other similar software, and delivered to the Seller. Neither pari
`any additional termsstated in this Purchase Order, unless and only if both Bu
`such additional termsa part of and sign this Purchase Order.
`
`Agreed to bySeller:
`
`D&e.
`Neats Medical, LLC
`David Schiller, VP Products
`meses
`eas
`Date 07.10.20
`
`Agreed to by Buyer:
`
`4
`MédicalUSA Supply, LLC
`RyonKestler; Partner
`
`Date of Execution: 07.17.2
`
`wiatow
`
`ie
`
`setwopemenr
`
`seaveys
`
`wiewes
`
`wy wrewerdaw ites)
`
`ieneet
`
`tx ereme
`
`eEmarwngy
`
`est
`
`eg
`
`sie acy
`
`DocuSignor other similar soltware, and deliveredto the Seller. Neither party sh
`any additional terms stated in this Purchase Order, unless and onlyif both Buyer .
`such additional terms a part of andsign this Purchase Order.
`
`Agreed to bySeller:
`
`Nexus Medical, LLC
`David Schilfer, VP Products
`
`Date 7/23/20
`
`Agreed to by Buyer:
`/
`i
`/
`l
`¢Le
`
`MedicalUSA
`
`Ryon Kestler
`
`7
`
`5
`ae
`
`108 €. Trailmoor, Suite 6
`Fredericksburg, Texas 78624
`800-470-6850
`info@nexusmedicalproducts.com
`
`108 E. Trailmoor, Suite 6
`Fredericksburg, Texas 78624
`800-470-6850
`info@nexusmedicalproducts.com
`
`

`

`]
`
`PTY\N EK US
`f
`\
`+YMEDICAL
`|
`Purchase Orderfram
`to Nexus Medical, LLC
`| No:
`20072101
`[|
`This Purchase Order from MedicalUSA Supply to Nexus Medical, LLC ("Purchase
`Order” hereinafter) is by and between the Parties (the “Agreement”).
`In accord therewiththe
`Bayer herebyorders from the Seller the following Goods, subject to the following tenns:
`
`Product
`
`
`
`a
`Nitrile Gloves
`Blue SuperiorMedicalExamGrade
`30,000 Boxes of Blue Superior Gloves3-4nim
`
`SLL9S
`ee
`$358,500
`
`ILLSShiloh RdGarlandTx75052
`TRB .
`
`Bank Name: Plains Capital Bank
`
`ABA Number: 111322994
`Account Number: 7447321200
`
`ACCT NAME: Nexus Medical
`
`This Purchase Order shall be effective onlyafter it has been signed by the Buyer, including
`by DocuSiga or other similar software, and delivered to the Seller. Neither party shall be bound
`by any additional terms statedin this Purchase Order, unless and onlyif both Buyer and Seller
`makesuchadditional terms a part of andsign this Porchase Order.
`
`15,000 Med & 15,000 Large
`
`Agreedto by Seller:
`Nexus Medical, LLC
`David Schiller, VP Contracts
`
`pre
`
`Date of Execution os 03/2020
`
`Agreed to by Buyer:
`fof Ly
`lL)
`af
`
` ition: 8.3.20
`
`wih
`
`108 E. Trailmoor, Suite 6
`Fredricksburg, Texas 78624
`
`Texas Secretaryof State »
`
`Jane Nelson
`
`ucc
`
`Business Organizations
`
`Trademarks
`
`Notary
`
`Logout
`Briefcase
`Help/Fees
`Account
`BUSINESS ORGANIZATIONSINQUIRY- VIEW ENTITY
`
`Fillng Number;
`Original Date of Filing:
`Formation Date:
`Tax 10:
`Name:
`Address:
`
`803593613
`April 15, 2020
`NIA
`32073981063
`Nexus Medical, LLC
`108 E. Trailmoor Or., Suite 6,
`Fredericksburg, TX 78624-78624 USA
`NA
`Fictitious Name:
`OE, USA
`Jurisdiction:
`Forelgn Formation Date: March 30, 2020
`
`Entity Type:
`Enlity Status:
`FEIN:
`
`Foreign Limited Liability Company (LLC)
`Forfeited existence
`850594266
`
`|
`
`Name
`David Schiter
`
`Address
`4108 Kirk Meadow Drive
`Datias, TX 75287 USA
`
`Inactive Date
`
`|
`
`|
`
` |AdditionalTerms:
`
`Quantity
`| Unit Price
`Total Price
`Acceptance Address:
`Delivery Date Request:
`Wiring Instructions
`
`_
`
`
`
`

`

`Texas Secretary of State
`4
`Jane Nelson
`
`UCC
`Business Organizations
`Trademarks
`Notary
`Account
`Help/Fees
`Briefcase
`Logout
`BUSINESS ORGANIZATIONSINQUIRY- VIEW ENTITY
`
`Filing Number: Entity Type:—Foreign Limited Liability Company (LLC)803593613
`
`
`Original Date of Filling:
`April 15, 2020
`Entity Status: Forfeited existence
`Formation Date:
`NWA
`Tax ID:
`32073981063
`FEIN:
`850594266
`Name:
`Nexus Medical, LLC
`Address:
`108 E. Traitmoor Dr., Suite 6,
`Fredericksburg, TX 78624-78624 USA
`NA
`Fictitious Namo:
`DE, USA
`Jurisdiction:
`Forelgn Formation Date: March 30, 2020
`
`
`UPILINGHISTORY90000) (ore 0 OleNAMES) D>
`"ASSUMEDNAMES— |! ASSOCIATED ENTITIES}!
`INITIALADDRESS
`if
`>
`|
`{REGISTEREDAGENT
`Name
`Title
`Address
`Last Update
`George Burl Outlaw
`Manager
`PO Box 949
`Apel 15, 2020
`Fredericksburg, TX 78624-78624 USA
`
`e Exhibit B
`
`Bill of Sale
`
`David Schiller <david@nexusmedicalproducts.com>
`To:
`ryonkestler
`sy
`Bil of Sale .pdf
`= 368.9 KB
`Download All + Preview All
`
`©) You replied to this message on 9/6/20, 9:68 AM.
`Ryon:
`
`Thursday, September 3, 2020 at 2:50 f
`
`;
`
`Show Rep
`
`Attached Is the executed Bill of Sale. This documentwill provide you collateralin the form oftitle to thelisted product currently In the warehouse. Please sign and return. Also please find the attached wiring instructions
`from Cain.
`
`Chase Bank Wire
`
`Account Name: CGE GROUP LLC
`
`Address:
`25 Highland Park Village
`Dallas, Tx 75205
`
`Checking 581102255
`Routing: 021000021
`Swift: CHASUS33
`
`JAMES KiM | Business Banking | JPMorgan Chase & Co.
`| 15625 EWhittierBlvd, Floor 02.Whittier, CA, 90603.
`| Direct: 714.987.2177 | eFAX: 844.359.7589| james.kim@jomorgan.com
`David Schiller
`VP Products
`108 E. TrailmoorSuite 6
`Fredricksburg, Texas 78624
`david@nexusmedicaloroducts.com
`
`

`

`Exhibit C
`
`CHASE o
`
`Apri01,2020throughApril30,2020
`Atcoun Nwrber
`2255
`
`COE
`
`
`ELECTRONIC WITHDRAWALS] {coun
`AMOUNT
`CATE
`DESCRIPTION
`20,000.00
`Up
`04/14
`04/14 Online Domestic Wire Transier Via: faredasane NP. Thompson
`JOLTA Trust Dokas TX 75201 US Imad 04148
`0004882 Tm: BOFSGOVOSEe
`
`04/14=04/14OnlinoDaomosticWiro TransiceVia en Amesica, N.A/0959A/C: Bank of Amorica 40,000.00
`NA Dafas TX 75283-1973 US Ban: Bud Oullaw Dallas TX 7205 US Sen: 0008348 Tr
`
`A08SIZ0IOSES
`O4/15
`04/15 Online Domestic Wire Transtor Vix Bank of America, N.A/0959 AVC: Bank of America
`10,000.00
`BApeesUirents-1979 US Ban Burl OutlawCallasTX 76205 US Sen: 0389743 Tm:
`&
`
`O415
`04/15 Online Domestic Wee Transior Via Wolls Fargo NV/121000248 A/C. Aba/ 111900659
`1,000 00
`Fon Worth TX 76101 US Ben. Darla Laird Dale 1X 75205 US Rot /Timo/1§:43 Imad.
`0415810
`15216 Tra 61B3220106E
`04716 Onling Transtor To Chk. 2198a 6461690124
`OV16
`2.000.00
`
`
`OMIT OAT Online Transfer To Chk. 2198 Transaction# 9471052018
`$.000.00
`04/20 Calne Domestic Wire Trantter Via: TO Bank, NA026013679 AIC: Raw Consuting Now
`180,000.00
`Yoru NY 10013 US Imad 042061
`m: 41719201 11Es
`04/20 Onino Domostic WveTranster Via’ Cabbenh113183592 AC Roman bate
`75,00000
`fOLTA Trust Datas TX 75201 US Imad 042081
`0003503 Tn 4848-42011 1s
`04/20 Ontine Domestic Wro Transfer Via, Cabank
`
`1000089 A/G. AarongoneTevinrgre Datas
`20,000.00
`TX 75205 US Rof ‘Tene/13 24 Imad 0420B1
`7332 Tm: 59960201 11Es
`0420
`04/20 Onino Domestic Were Transfer Via: Bank of America, N.A0989 A/C: Bank of
`108,600 00
`AmericaNationa) Holywood CA 90028:7364 U5 Bon: Alanis Intornational Corporation Bovorly
`
`
`easiestrsAGNDORENGDEB04/20 04/20 Online Domestic Wire Transler Via; TD Bank, NA026019673 AIC: Raw Consulting New 149,000.00
`
`
`YorkNY s0013USImactSeogee m; Mpaeoentike
`04/722
`04/22 Onlno Domestic Wire Transler Via
`Bk Amer
`AG: Donald Klein DoRas
`3,800.00
`TX 75206 US Imad 04228109¢04C0007 11 Ten: 36
`1iSEs
`
`04/22
`04/22 Online Transfer To Chk ...2188 Transoolion#t: 9492414676
`10,000.00
`04/22
`04/22 Online Domestic Wire Translor WC Bauer Advisors LLC Now York NY 10021-4258 US
`22,780.00
`
`Rel: Invoice 00162 Tin 60597201 12Es
`0423 04/23 Onine Domesilc Wire Transfer AC Bauer Advisore LLC New York NY 10021-3256 US
`2,720 00
`TmTesto I3Es
`—-.
`Dometic WireTranstorVi:Pianecasia BanwTiiaeenes AVG: David Schisor
`$,000.00
`Dane1a78205USRe!‘Time/13.26Imad_ 04238
`0006779Tm:$975920119Es
`04/23 Online Domosiic Wire Transfer Via: TO Bank, NA026013679 A/C: Raw Consulting New
`35,080.00
`04/23
`York NY net US Imad 04228109006C009185 Tm: $136420114Es
`04724
`04/24 Online Domestic Wire Transtar Vix Prosperity Bk Ele’ 13122655 AC: D
`13,000.00
`perieweepIneDallasTX75230USRielTume/14:22Imad. QeasBIOgoICOOTTeeTm
`
`Ee
`04727
`04/27 Online Domestic Wre Transtar Via: Bank al Amonca, N A/0959 A‘C: Bank of America
`$0,000 00
`HtrastjeaeesveeUSBen BurlOutlawDallas1K75205USSs0437401 Tm,
`127420116Es
`
`04/29 Onlina Domostic Wee Tranasfor Vix: Plinecaptal Bani11322994 A/C: David Schiller
`10,000 00
`Dallas 1K78208 US Ral /Time’08 00 Imad 042685
`1608 Tm: 3751420120Es
`04/29 Ontno Domostic Wao Transioe Vix_ Bank of Amorica, N A/0959 A/C: Bank of Amoiica
`11,000.00
`bsee75283-1973 US Ben Gurl Oullaw Dallas TX 75205 US Sen: 0987245 Tm
`6
`9,000 00
`04730 Online Domostic Wee Transter Vin. Bank of Amorica, NA 0959 AIC: Bank of America
`NADaas1X75783-1979 US Bon Burl Oulaw Datos1X 75205 US Ssnv 6501093 Tm:
`&a
`Toto} Efoolronto Withdrawale
`$880,200.00
`
`0429
`
`

`

`e Exhibit D
`
`Bill of Sale Word Doc
`
`DavidSchiller <david@thecgegroup.com>
`To:
`ryonkestler; Cain McKnight
`
`Saturday, September 5, 2020 at 10:56 AM
`
`30.1KB
`= Bill of Sale .docx
`Download All
`« Preview All
`

`
`DavidSchiller
`President ofAssets and Projects
`The CGE Group
`777 Third Avenue, 36th Floor
`New York, NY 10017
`¢: 310.704.2733
`{: 917.780.3089
`
`Disclaimer: Seader is aot a United States Securities Dealer, Agead of Kocased Broker, nor US lavestmeat Adviser. This E-mail letter aed the attached related
`documents are ecver to be considered a solicitation fos any purpose in any form or content. This is mot an offer to buy of sel securities. Sender is only acting
`in the manner of introduction. All parties must conduct their own Dur Diligcace accordingly.
`
`the Electronic
`CONFIDENTIALITY: E-mail is sot a secere mode of commusication aad may be accessed byunauthorized persons. This cocmemnication is protected mackes
`the addressce(s) identified shove and may coniaia iaformation which is kegally privileged aadfor otherwise confidential. If yos are wot an addressec and/or
`have received this email ia error, aremries eh milpasredinabecca cackimmediatelydelete this email [rom yourcomputerand destroy all
`physical copies ofcame. Any unauthorized review,disclosure,reproduction, re-tranamizsins or othe: dissemination or use of this email (or any portion
`thereof) is urictly prohibited.
`NO SIGNATURE:Unless stated otherwise in the body of this email, neither the typed same of the sender nor anything else in this message is intended to
`coastinelc an electronic signatur:.
`
`
`
`
`* Officer of
`
`Medi
`
`IUSA Supply, LLC
`
`Scott Kestler; In his individual Capacity
`
`, 2023.
`July
`Subscribed and sworn to before me onthis the a\st dayof
`GLORIA CHAVEZ
`(Nou Chay
`ie, Notary Public, State of Texas
`wos Comm.Expires 05-07-2027
`
`* Notary ID 12543431-4
`
`Notary Public In and For the
`State of Texas, County of
`Printed Nameof Notary:
`Gievia Clhavev
`
`My Commission Expires: Sh } 3)
`
`

`

`Automated Certificate of eService
`This automated certificate of service was created by the efiling system.
`The filer served this document via email generated by the efiling system
`on the date and to the personslisted below. The rules governing
`certificates of service have not changed. Filers muststill provide a
`certificate of service that complies with all applicable rules.
`
`Envelope ID: 77910188
`Filing Code Description: Response
`Filing Description: AMENDED RESPONSE TO MTN FOR SUMMARY
`JUDGMENT
`Status as of 7/27/2023 9:47 AM CST
`
`Associated Case Party: LOYSTPFLETCHER
`
` Loyst Fletcher P| loyst@Ipfletcherlaw.com|7/26/2023 2:33:19 PM|SENT
`
`GcSc
`
`ap
`
`asetetenovis|[sonar|TANTO[SET
`BcScaa
`
`[Fearem|[marten_|WARDa9|SET
`roves|[penisocon|TRSRDETRSTO|SET
`[saiseetsar|Tavaa0|ROR
`[eatin|eeaaerercon|TaanDaTESTO|SENT
`PeeohTans|[sonra|TOTO|SENT
`
`Case Contacts
`
`ner[EnaFesti
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`

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