DC-24-04805
`CAUSE NO. _______________
`
`§
`§
`§
`§
`§
`§
`§
`§
`
`FILED
`4/1/2024 9:39 AM
`FELICIA PITRE
`DISTRICT CLERK
`DALLAS CO., TEXAS
`Fernando Soto DEPUTY
`
`IN THE DISTRICT COURT
`68th
`
`_____ JUDICIAL DISTRICT
`
`
`OF DALLAS COUNTY, TEXAS
`
`GUERIN WOODGATE AND
`ANTHONY GUTHRIE
`
`
`VS.
`
`
`FIX HOLD & FLIP
`CONSTRUCTION, LLC, ALAN
`GABRIEL ANTILLON, AND JAMES
`E. WILEY, JR and WILEY
`BROTHERS GENERAL
`CONTRACTORS, INC
`
`
`PLAINTIFFS' ORIGINAL PETITION
`Plaintiffs Guerin Woodgate and Anthony Guthrie, file this Plaintiffs’ Original
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`Petition complaining of Defendants Fix Hold & Flip Construction, LLC, Alan
`
`Gabriel Antillon, Wiley Brothers General Contractors, Inc. and James E. Wiley, Jr.,
`
`and for cause of action would show the Court the following:
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`Discovery Control Plan
`1. As provided in Rule 190, Texas Rules of Civil Procedure, Plaintiffs intend
`
`to conduct discovery under Level 2.
`
`Plaintiffs
`2. Plaintiff, Guerin Woodgate, is an individual whose address is 1312 Travis
`
`Circle S. Irving, TX 75038. The last three digits of Plaintiff's driver's license
`
`number are 106. The last three digits of Plaintiff's Social Security number are 603.
`
`Plaintiff Woodgate may be served through his counsel of record, Joseph LaFleur,
`
`Winborne LaFleur PC, 216 W. Franklin St. Waxahachie, TX 75165.
`
`Plaintiffs’ Original Petition
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`
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`Page 1
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`

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`3. Plaintiff, Anthony Guthrie, is an individual whose address is 1312 Travis
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`Circle S. Irving, TX 75038. The last three digits of Plaintiff's driver's license
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`number are 256. The last three digits of Plaintiff's Social Security number are 561.
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`Plaintiff Guthrie may be served through his counsel of record, Joseph LaFleur,
`
`Winborne LaFleur PC, 216 W. Franklin St. Waxahachie, TX 75165.
`
`Defendants
`4. Defendant, Fix Hold & Flip Construction, LLC, is a limited liability
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`company. It can be served with process by serving Gabriel Antillon, its registered
`
`agent, by personal delivery at the registered office located at 2231 Madera Street,
`
`Dallas, Texas 75206.
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`5. This Court has jurisdiction over Fix Hold & Flip Construction, LLC
`
`because said Defendant is a resident of Texas.
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`6. Defendant, Alan Gabriel Antillon, a.k.a. Gabriel Antillon is an individual
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`who may be served with process at Defendant's residence by personal delivery at
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`3039 Nowitzki Way #4002, Dallas, TX 75219. On information and belief, Gabriel
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`Antillon is also known as Alan Gabriel Antillon.
`
`7. This Court has jurisdiction over Alan Gabriel Antillon because said
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`Defendant is a resident of Texas.
`
`8. Defendant, James E. Wiley, Jr., is an individual who may be served with
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`process at Defendant's place of business by personal delivery at 2803 Virgo Lane,
`
`Dallas, Texas 75229.
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`Plaintiffs’ Original Petition
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`
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`Page 2
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`

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`9. This Court has jurisdiction over James E. Wiley, Jr. because said
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`Defendant is a resident of Texas.
`
`10. Defendant, Wiley Brothers General Contractors, Inc. is a Texas Domestic
`
`Corporation and may be served through its registered agent, James E. Wiley at the
`
`office of its registered agent 9990 Monroe Dr. Dallas, TX 75220.
`
`11. This Court has jurisdiction over Wiley Brothers General Contractors, Inc.
`
`because it is a Texas resident.
`
`Venue
`12. Venue is proper in this county in that the events giving rise to this cause
`
`of action occurred within Dallas County.
`
`Jurisdiction
`13. The damages sought in this suit are within the jurisdictional limits of the
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`Court. As required by Rule 47, Texas Rules of Civil Procedure, Plaintiffs state that
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`Plaintiffs seek monetary relief over $250,000 but not more than $1,000,000.
`
`Notice of Claim
`14. Plaintiffs delivered written notice of this claim to Fix Hold & Flip
`
`Construction, LLC on February 8, 2024, advising Fix Hold & Flip Construction,
`
`LLC in reasonable detail of the specific complaint made the subject of this action
`
`and the amount and nature of the damages and expenses sought.
`
`15. Plaintiffs delivered written notice of this claim to Alan Gabriel Antillon
`
`on February 8, 2024, advising Alan Gabriel Antillon in reasonable detail of the
`
`Plaintiffs’ Original Petition
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`
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`Page 3
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`

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`specific complaint made the subject of this action and the amount and nature of the
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`damages and expenses sought. The letter also warned Defendants Antillon and
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`FHFC that Plaintiffs would sue under the Texas Deceptive Trade Practices Act.
`
`16. Plaintiffs contacted Defendant, James E. Wiley, Jr. on March 11, 2024,
`
`demanding that property Defendant James E. Wiley possessed which belonged to
`
`plaintiffs be returned. Wiley refused to cooperate in the return of Plaintiffs’
`
`property.
`
`Facts-As to Defendants FHFC and Antillon
`17. On 10/11/2023, Guerin Woodgate, Anthony Guthrie, Fix Hold & Flip
`
`Construction, LLC (“FHFC”), and Gabriel Antillon, FHFC’s sole member and agent,
`
`agreed that FHFC would perform a comprehensive renovation of a rental home
`
`which included such items as replacing the roof, leveling the foundation, replacing
`
`the supply and sewer plumbing, replacing the electrical system, installing a new
`
`kitchen, installing new flooring, and many other cosmetic items to prepare the home
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`for rent. The agreement is memorialized in an invoice prepared by FHFC’s principal
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`and formed the basis of a contract. A copy of said agreement is marked P-1 and
`
`incorporated herein for all purposes.
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`18. The heart of the agreement was a detailed document which detailed the
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`work to be done. The price set was $156,828.75. Plaintiffs paid $116,004.06 down
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`with a balance of $40,824.69 to be paid as progress payments. Defendants proposed
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`additional work to Plaintiffs and Plaintiffs agreed to some of the additional work,
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`however, discussed below, Defendants fraudulently induced Plaintiffs to agree to
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`Plaintiffs’ Original Petition
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`Page 4
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`additional work to repair problems that Defendants themselves intentionally
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`caused.
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`19. Defendants Fix Hold & Flip, LLC and Alan Gabriel Antillon, abandoned
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`the work and failed to complete the work for which they were paid. This
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`abandonment damaged the Plaintiffs who lost the benefit of the bargain and had to
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`pay to repair damages intentionally caused by Plaintiffs.
`
`20. Additionally, Antillon removed valuable building materials, including
`
`drywall, lighting, air conditioning units etc. from the rental property and stored
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`them at 2970 Blystone Lane, #108, Dallas Texas. This address is an address for a
`
`building owned or leased by James Wiley and/or Wiley Brothers General
`
`Contractors, Inc. Despite requests from Plaintiff Woodgate to both Antillon and
`
`Wiley, Wiley refused to return the building materials and equipment from the
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`Blystone Lane location to Plaintiffs. Discussed below, Wiley first said the building
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`was empty and that Antillon had opportunity to remove the materials. Antillon
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`stated he was locked out of the building.
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`21. Antillon and FHFC promoted themselves as “a Dallas Fort Worth
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`Roofing, restauration & Construction company that has provided DFW with quality
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`residential and commercial repairs and replacements since 2008.”
`
` See
`
`www.fixholdflip.com. According to the filings at the Texas Secretary of State’s
`
`office, the reality is that FHFC did not come into existence until 2020, and Antillon
`
`formed the LLC on May 7, 2020, while the Covid-19 pandemic ravaged the globe.
`
`Plaintiffs’ Original Petition
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`
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`Page 5
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`

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`22. The website further warranted, “At Fix, Hold & Flip Construction, LLC,
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`our mission is to serve our clients with the highest level of customer service through
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`great communication, best materials in the industry, best installation & warranty
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`available, and to build a relationship for many years to come.” Not only did Antillon
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`lack experience and resources to provide the renovations Woodgate and Guthrie
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`hired Antillon and FHFC to do in a good and workmanlike manner, but the
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`Defendants also failed to provide the promised “best warranty available.”
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`23. The business reviews of FHFC are fake.
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`24. Instead of the “highly trained construction project managers” Defendants
`
`promised, Defendants used a twenty-something year old habitual drunkard, Adil
`
`Awwai, who had no training and no qualifications to manage a total home
`
`renovation. Having knowingly hired this habitual drunkard, Antillon, who knew
`
`about Awaii’s problems blamed Awaii for the failures at the project.
`
`25. Despite numerous requests, Defendants either would not or could not
`
`provide a project plan to Woodgate and Guthrie, despite repeated requests for one.
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`Instead of the promised work, Defendants delivered defect after defect.
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`26. Some of the defective work Defendants did included (1) installing
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`improperly sized windows and attempting to conceal the improper sizing by using
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`spray foam to fill in gaps; (2) brick masonry with bricks placed in uneven patterns
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`and mismatched mortar lines; (3) installing a sliding glass door with no base, so to
`
`open and close it, required dragging it along the slab; (4) installing a new roof on top
`
`Plaintiffs’ Original Petition
`
`
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`Page 6
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`

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`of rotten decking and then using spray insulation to cover it up; (5) missing
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`insulation in parts of the home; (5) improperly installing fencing; and (6) extensive
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`damage to the garage door.
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`27. Additionally, in a blatant act of fraud, Defendant FHFC and Antillon
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`pulled down portions of the brick veneer and exposed the interior sheetrock. After
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`exposing the sheetrock, Defendants left it uncovered and the interior sheetrock,
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`which otherwise was in good repair was destroyed, and Plaintiffs had to replace it
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`unnecessarily. Defendants lied to Plaintiffs and stated that the brown coloring on
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`the drywall meant it had to be replaced, when it was merely the color of the paper
`
`attached to the drywall in the 1970s.
`
`28. Despite numerous promises to return the money to Plaintiffs, Antillon
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`has returned none of the money.
`
`29. Upon investigation, Antillon has a pattern of forming companies,
`
`defrauding, and stealing from consumers, and then allowing the companies to go
`
`into forfeiture. For an example of how Defendants Antillon and FHFC repeatedly
`
`defraud consumers, see generally DC-23-02531, currently pending in the 298th
`
`Judicial District Court, which is a case with remarkably similar facts.
`
`Facts-As to Defendants Jim Wiley / Wiley Brothers General Contractors,
`Inc.
`30. Defendant Antillon stored valuable materials and equipment, including
`
`parts to the home’s HVAC system, that Plaintiffs own, and that Plaintiffs intended
`
`to use for the renovations at a warehouse owned by Jim Wiley and/or Wiley
`
`Plaintiffs’ Original Petition
`
`
`
`Page 7
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`

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`Brothers General Contractors, Inc. at 2970 Blystone Lane, #108, Dallas, Dallas
`
`County, Texas. This is the address Antillon used as his business address, and it
`
`appears on the agreement.
`
`31. Because Antillon’s spree of destruction abounds in the metroplex,
`
`Plaintiff Woodgate was able to communicate with another of Antillon’s victims and
`
`learned that Antillon was held in a warehouse owned by Jim Wiley and/or Wiley
`
`Brother’s Construction. Court records demonstrate that Antillon engages in this
`
`same pattern of behavior, and that Antillon habitually abuses the corporate
`
`structure for his own benefit and hides behind the shield of an LLC.
`
`32. Plaintiff Woodgate contacted Jim Wiley about retrieving the materials
`
`and HVAC equipment from the Warehouse. At first Wiley stated that the
`
`warehouse was empty, the later admitted that he had not been to the warehouse in
`
`months.
`
`33. On information and belief, Jim Wiley
`
`/ Wiley Brothers General
`
`Contractors, Inc. unlawfully disposed of or utilized the property or is holding it
`
`unlawfully with the knowledge that the equipment belongs to Plaintiffs.
`
`
`
`
`
`Plaintiffs’ Original Petition
`
`
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`Page 8
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`

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`Conditions Precedent
`34. Plaintiffs state that Guerin Woodgate and Anthony Guthrie have fully
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`performed all obligations under the contract.
`
`35. All conditions precedent to the performance by Defendants have been
`
`met.
`
`Breach of Contract
`36. Fix Hold & Flip Construction, LLC ("FHFC") is a sham company formed
`
`for the purpose of committing fraud against unwitting customers for the benefit of
`
`its member, Alan Gabriel Antillon. Antillon used FHFC to lure Plaintiffs to pay
`
`him $116,004.06 as consideration for an extensive renovation project to occur at
`
`2205 Avenue C in Grand Prairie, Texas. FHFC and Antillon completed only part of
`
`the paid for work, and the work that was done was defective, and a substantial
`
`portion had to be redone or must be redone. FHFC and Antillon failed to render the
`
`services they were paid to do and failed to perform home repairs in a good and
`
`workmanlike manner.
`
`Breach of Implied Warranty Of Good and Workmanlike Manner
`37. Defendants Antillon and FHFC breached the implied warranty that the
`
`work would be performed in a good and workmanlike manner. Defendants used
`
`materials that were of the wrong size and for the wrong purposes such as wrong
`
`sized windows and spray foam as filler. Defendants installed new roofing materials
`
`over rotten wood and failed to professionally install the sliding doors among other
`
`issues.
`
`Plaintiffs’ Original Petition
`
`
`
`Page 9
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`

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`Fraudulent Inducement / Common Law Fraud
`38. Defendants Antillon and FHFC fraudulently induced Plaintiffs into
`
`entering into this agreement by falsifying facts in its marketing material such as
`
`the age of the company, the experience of the staff and the training of the staff.
`
`Additionally, prior to abandoning the job, Defendants lied to Plaintiffs about the
`
`necessity of replacing some materials. Defendants then purposefully damaged the
`
`home which would require Plaintiffs to spend more money to repair parts of the
`
`home that Defendants intentionally damaged.
`
`39. The above-described statements and representations were material and
`
`were made knowing that they were false when made, or they were made recklessly
`
`without regard for their truth.
`
`40. The above-described statements and representations were made with the
`
`intent that Plaintiffs rely on them, and Plaintiffs did rely on them when entering
`
`the contract.
`
`41. As a result of Defendants' fraud, Plaintiffs have been damaged, for which
`
`Plaintiffs request judgment.
`
`Restitution
`42. Plaintiffs delivered valuable goods or services to Defendants which
`
`resulted in an unconscionable unjust enrichment to Defendants. Plaintiffs therefore
`
`ask for a judgment of restitution in equity against Defendants.
`
`Plaintiffs’ Original Petition
`
`
`
`
`
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`Page 10
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`

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`Negligent Hiring and Negligent Retention
`43. The evidence will show that Antillon and FHFC knew about Awaii’s
`
`drinking habits and lack of experience. Antillon complained to Plaintiffs about
`
`Awaii but never terminated him nor hired anyone competent to complete the job as
`
`promised.
`
`Exemplary Damages
`44. The conduct of Defendants as described above constituted fraud.
`
`45. Defendants Antillon and FHFC have a pattern of defrauding others.
`
`46. Given the knowledge Antillon had about Awaii, the negligent hiring and
`
`retention of Awaii constituted gross negligence.
`
`47. Plaintiffs seek exemplary damages as provided in Section 41.003, Texas
`
`Civil Practice and Remedies Code, for which Plaintiffs request judgment.
`
`Declaratory Judgment
`48. Plaintiffs seek declaratory judgment that there was a contract between
`
`Plaintiffs and Defendants Antillon and / FHFC and that the attached P-1 provides
`
`evidence of the terms and conditions of the contract.
`
`Unjust Enrichment
`49. Should the Court find that there was no written contract between
`
`Plaintiffs and Defendants Antillon and FHFC, Plaintiffs ask for a judgment for the
`
`unjust enrichment from which Defendants benefitted by the payments from
`
`Plaintiffs.
`
`Plaintiffs’ Original Petition
`
`
`
`Page 11
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`

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`50. As to Defendants Jim Wiley and Wiley Brother’s Construction, Plaintiffs
`
`seek the value of the materials and equipment the Wiley defendants either used in
`
`their own business or disposed of unlawfully.
`
`Damages
`51. Plaintiffs seek damages for paid for but incomplete work, consequential
`
`damages, attorney’s fees, loss of benefit of the bargain, reliance damages and all
`
`other damages which the evidence may support.
`
`Economic Damages
`52. As a result of Defendants' conduct, Plaintiffs suffered economic damages
`
`as defined in Section 41.001, Texas Civil Practice and Remedies Code, for which
`
`Plaintiffs request judgment.
`
`Attorney's Fees and Costs
`53. Plaintiffs request judgment for reasonable attorney’s fees and costs
`
`under Sections 37.009 and Chapter 38, Texas Civil Practice and Remedies Code.
`
`Conversion
`54. Plaintiffs sue Defendants Jim Wiley / Wiley Brothers General
`
`Contractors, Inc. for conversion. Defendants are either wrongfully retaining
`
`materials and equipment they know belong to Plaintiffs or they utilized the
`
`materials in their own business.
`
`55. Plaintiffs sue Defendants Alan Gabriel Antillon and FHFC for conversion
`
`of their property.
`
`Plaintiffs’ Original Petition
`
`
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`Page 12
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`

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`Alternative Pleadings
`56. As provided in Rule 48, Texas Rules of Civil Procedure, claims for relief
`
`made in this petition are presented in the alternative when necessary to preserve
`
`such claim.
`
`Required Initial Disclosures
`57. As provided in Rule 194, Texas Rules of Civil Procedure, required Initial
`
`Disclosures of all items listed in Rule 194.2 must be made at or within 30 days after
`
`the filing of the first answer unless a different time is set by the parties’ agreement
`
`or court order.
`
`58. Plaintiffs ask the Court to keep the requirement of Initial Disclosures to
`
`be made within 30 days.
`
`Writ of Sequestration
`59. Plaintiffs will seek a writ of sequestration for all of the materials and
`
`equipment taken from Plaintiffs by Antillon and stored at the facility
`
`controlled/owned by the Wiley defendants.
`
`
`
`Plaintiffs’ Original Petition
`
`
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`Page 13
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`

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`Prayer
`
`Plaintiffs pray that citation be issued commanding Defendants to appear and
`
`answer herein and that Plaintiffs be awarded judgment against Defendants, jointly
`
`and severally, for the relief requested herein and for all other relief to which
`
`Plaintiffs are entitled both in equity and at law.
`
`Respectfully submitted,
`
`/s/ Joseph LaFleur
`Joseph LaFleur
`Bar No: 24103410
`WINBORNE LAFLEUR PC
`216 W. Franklin Street
`Waxahachie, Texas 75165
`Attorney Plaintiffs
`Office Phone: (972) 330-2171
`Email: JLAFLEUR@WINLAF.COM
`
`
`Plaintiffs’ Original Petition
`
`
`
`Page 14
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`

`

`‘
`
`INVOICE
`
`P-1
`P-]
`
`Fix Hold & Flip Construction LLC gabriel@fixholdflip.com
`2970 Blystone Lane, 108
`+1 (214) 892-1910
`Dallas, TX 75220
`https://www.fixhoidflip.com
`
`FIX HOLD
`& FE L| p
`
`Guerin Woodgate Jr
`
`Bill to
`Guerin Woodgate Jr
`2205 Aveenue C
`Grand Prairie, Tx 75051 USA
`
`Invoice details
`
`Invoice no.: 1049
`Terms: Net 30
`Invoice date: 10/11/2023
`Due date: 11/10/2023
`
`Ship to
`Guerin Woodgate Jr
`2205 Aveenue C
`Grand Prairie, Tx 75051 USA
`
`#
`
`1,
`
`2:
`
`3.
`
`4.
`
`5.
`
`6.
`
`Product or service
`
`Qty
`
`Rate
`
`Amount
`
`$16,870.00
`$16,870.00
`Foundation
`Professionally repair foundation of property. Includes adjusting 11 exterior piers. If piers need to be driven down additional
`cost will be at $100 perpier. If a new pier is requiredit will be at a cost of $300 perpier.
`Professionally install 11 new piers outside of home.
`Professionally install 12 piers inside the hore,if additional piers are needed, it will be at a costof $400 perpier.
`Includes permits, engineering report, andlifetime warranty.
`
`$4,900.00
`$4,900.00
`Concrete
`Professionally excavate area for new 12x20 concrete pad. Include properly setting up forms and rebar. Concrete pad will be
`doweled into home foundation. Brush finish. Includesall materials and labor.
`
`$4,200.00
`$4,200.00
`1
`Mud Pumping
`Professionally pump 10 yards below foundation to eliminate hollow areas underneath foundation.This will be doneafter
`tunneling to best seal off cavities. Includes all materials and labor.
`
`$5,950.00
`Mortar and brick repair
`Sate removal and haul off of damaged brick on right side of wall were -brick was not properly braced with framing.
`Professionally lay new brick along wall where previous brick was removed. Includes sanding, mortar along seams. Includes
`all materials and labor.
`
`$5,950.00
`
`$12,560.00
`$12,560.00
`HVAC
`Professionally install new 2.5 ton Carrier system with heat pump in new area to the right of home behind electrical panel. New
`unit will be placed on new concrete pad for unit. Includes disconnect, néw ductwork, vent covers and smart thermostat.
`Includes all materials and labor.
`
`$9,100.00
`$9,100.00
`Exterior Roofing
`Removeand repiaceexisting roofing. Remove and replacerotten decking on roofline. Remove and replaceall ventilation
`and jack pipe flashing
`
`rr
`
`

`

`Install new synthetic felt. Install ice and water shield. install starterstrip. Install new 30 year shingies in black. Install ridge cap.
`Includes ali materials and labor. Material and labor included
`
`$4,923.00
`$4,923.00
`Flooring
`Professionallyinstall approximately 1,094 sqft of hybri¢ restient flooring and moisture barrier throughout property. Furnace in
`closet will be removed with floor to be level with the rest of home. Furnace closet will include shelving. Labor only.
`
`$6,560.00
`$6,560.00
`Flooring
`Materials cast for 1,094 sqft of flooring and underlayment/moisture barrier. Includes materials cost for shelving. Includes the
`cost of materials after tax.
`htips://wwwJiflooring.com/p/d uravana-7mm-and-pad-foggy-bottom-oak-waterproof-hybrid-resilient-flooring-7.56-in.-wide-x-
`50.63-in.-long-10082741 .htmi
`
`https://wwwliflooring.com/p/underlayment%C2%A0--quietwalk-versa-1 00sft-10056873.htm!
`
`Toilet installation
`
`$248.75
`
`$248.75
`
`Professionally install new toilet and existing toilet previously removed for both bathrooms. Includestoilet flange replacement,
`new flapper, and new wax ring. Silicone wil be properly applied undertoilet. Water and leak test will be conducted after
`installation to ensure proper flow. Labor only.
`
`Toilet
`
`$475.00
`
`$475.00
`
`Materials cost for toilet installation includ ing new toilet, flappers, wax rings, silicone, and flanges for both bathrooms. incudes
`proper associated plumbing work. This is price of materials after tax.
`
`Shower Wall Tile
`
`$2,073.00
`
`$2,073.00
`
`Professionally install shower wall tile (Includes thin-set and grout), Approximately 176 sqft in area. Includes shampco nook.
`Includes Labor Only.
`
`Shower Wali Tile
`
`$650.00
`
`$650.00
`
`Materials costfor installing shower wall tile for both bathrooms, This is the cost of materials after tax.
`htips.//www.secondsandsurpius.com/flooring/floor-tie/harbor-gray-porcelain-tile-12-x-24
`
`httos://www.flooranddecor.com/schiuter-instalation-materials/schluter-jolly -ed ge- 1 -2in.-matte-biack-10100931 4 html
`
`https ://www.flooranddecor.com/tile-grout-installation-materials/mapei-kerapoxy-cq-M1070.html?dwvar_M1070_color=Black
`
`Bathtub
`
`$1,333.00
`
`$1,333.00
`
`Professionallyinstall bathtubs and curtain rods in both bathrooms of property. Incudes proper associated plumbing work.
`Laborony.
`
`Bathtub
`
`$505.00
`
`$505.00
`
`Materials cost for both bathtubs in restrooms. This is the cost of materials after tax.
`httos.//www.homedepot.com/p/Bootz-Industries-Aloha-60-in-x-30-in-Soaking-Bathtub -with -Left-Drain-in-White-0 41-3365-
`00/314614191
`
`ntips.//www.homedepot.com/p/Bootz-Industries-Aloha-60-in-x-30-in-Soaking-Bathtub -with -Right-Drain-in-White-01 1 -3364-
`00/314614199
`
`htips://www.amazon.com/Tension-Drilling-Anti-Slip-Waterproof-Bathroom/dp/BOC8NSJSPK/ref=sr_1_3_sspa?
`keywords=curved %2Bshower%2Bcurtain%2Brod %2BECin&gid= 18945719388sr=8-3-
`spons&sp_csd=d2ikZ2VOTMFtZT1zcF9hcGY&th=1t
`
`$270.00
`$270.00
`Bathroom Vanity
`Professionally install new vanities in both bathrooms of the property. Includes installation of mirrors in both bathrooms. Labor
`only.
`
`Bathroom Vanity
`
`$433.00
`
`$433.00
`
`Materials cost to instail 2 new vanities and bathroom mirrors. This is the price of maierials after tax.
`
`
`10.
`
`11.
`
`12.
`
`13.
`
`14,
`
`45,
`
`16.
`
`

`

`17.
`
`18,
`
`19.
`
`20,
`
`21.
`
`https://www.secondsandsurplus.com/nome-decor/white-framed-mirror-24-x -30-30-23105
`
`$1,283.00
`Bathroom Hardware set
`Professionally instali new shower/tub faucet combo set, sink faucet, and hardware for both bathrooms. Laberonly.
`
`$1,283.00
`
`$860.00
`$860.00
`Bathroom Hardware set
`Materials cost for shower/tub faucet combo, sink faucet, and harcware set for both bathrooms. This is the cost of materia's
`after tax.
`nttps://www.boelon.com/products/boelon-shower-system-with-four-functions
`
`htips://www.amazon.com/14-Pieces-Bathroom-Accessories-Stainiess -Hard ware/dp/BOBLT47G9B/ref=sr_1_5?
`crid=2JGP7FLDTRTJG&keywords=biack%2Bbathroom%2Baccessories %2Bset&q id= 1694622 7488sp refix=black%2Bbath
`%2Caps %2C205&sr=8-58th=1
`
`https v/www.amazon,.com/SHACO-Matte-Black -Bathroom-Faucet/dp/BOC2VK9OZVZ/reissr_1_14_sspa?
`crid=1DW3SFCAPCEFY&keywords=biack+ssik+faucet+bathroom-+ 3+ hole&qid=16946228584s prefix=biack+sink+faucet+b
`athroom+3+%2Caps % 2C4598sr=8-14-spons&sp_csd=d2ikZ2VOTmPtz11zcFatdGy&psc=1
`
`Insulation
`
`$2,167.00
`
`$2,167.00
`
`Professionally instail R-19 insulation on all exterior walls throughout property and install R-30 insulation in attic. Laboronly.
`
`Insulation
`
`$6,906.00
`
`$6,906.00
`
`Materiais cost for wall and attic insulation. This is the cost of materiais after tax.
`
`$4,000.00
`$4,000.00
`Rough Plumbing
`Professionally change out previous rough plumbing of property and install new pvc/pex plumbing system. Includes allnew
`valves, fittings, piping runs, and new electrical tankless water heater. Includes ali materials and labor. Includes all materials
`and labor.
`https.//www.homedepot.com/p/Rheem-Performance-27-kw-Seit-Modulating-5-27-GPM-Tankless-Electric-Water-Heater-
`RETEX-27/300800755
`
`22.
`
`Kitchen Cabinets
`
`$4,074.60
`
`$4,071.00
`
`Professionally mount and install new kitchen cabinetry in kitchen, Inciudesinstallation of butcher block countertops whichwill
`be sealed andfinished. includes painting of kitchen cabinetry. New standard sink and garbage disposalwill be installed with
`proper plumbing connections. Includes all materials and labor.
`https://homeoutiet.com/product/unfinished-oak-cabinets
`
`https ://homeoutiet.com/product/acacia-butcher-block~countertop -25-x-122-hk
`
`httos://www.boelon.conyproducts/boeion-kitchen-faucet-with-waterfa!-design
`
`https://www.homedepot.com/p/InSinkErator-B adger-100-1-3-HP-Continuous-Feed -Kitchen-Garbage-Disposal-Standard-
`Series-BADGER-100/321511603
`
`https ://www.amazon.com/Westablize-12-Knuried-Aluminum-Charcuterie/dp/BOBY4V2327/ref=sr_1_357
`crid=1EIKZ7XQHSBOt &keywords=cabinet%2Bpulls %2Bcontemporary&qid= 1694741 9864sprefix=cabinet% 2Bpulis ™2Be
`ontemporary %2Caps%2C1 10&sr=8-358th=1
`
`23.
`
`24.
`
`Kitchen Backsplash
`
`Professionaiy install kitchen backsplash throughout kitchen. Labor only.
`
`Kitchen Backsplash
`
`Maierials cost for kitchen backsplash. This is the cost of materials after tax.
`httos://www.flooranddecer.com/shower-decoratives/ocean-honed -marble-tile- 10024601 6.htm|
`
`$700.00
`
`$700.06
`
`$300.00
`
`$300.00
`
`https://www.fiooranddecor.com/schluter-installation-materials/schiuter-jolly-ed ge-1 -2in.-matte-black-101009314 html
`
`nttps://www.flooranddecor.com/tile-grout-instaltation-materiais/mapei-kerap oxy -cq-M1070.htmi?dwvar_M1070_color=Black
`
`
`

`

`25.
`
`26.
`
`27.
`
`2B.
`
`29.
`
`30.
`
`31.
`
`32,
`
`33.
`
`34,
`
`35.
`
`36.
`
`av.
`
`$11,469.00
`$11,469.00
`Drywall, Texture, and Paint
`Professionally hang new gypsum board throughout walls and ceilings in home. Includes tape and bed. Once drywall has
`been installed, orange peel/knockdown texture will be applied on all newly installed drywall. includes prime ang paint. Walls
`to be agreeable grey in satin finish, Ceiling wil be flat in white. Labor only.
`
`Drywall, Texture, and Paint
`Materiais cost for drywall, texture, paint throughout property. This the price of materials after tax.
`
`$5,515.00
`
`$5,515.00
`
`Trim Instailation
`
`$2,103.00
`
`$2,103.00
`
`Professionally install approximately 350 jin ft of baseboard anc coortrim throughout home.labor only.
`
`Trim
`
`$1,184.00
`
`$4,184.06
`
`Materials cost for block-style baseboard and doortrim. This is the price of materials after tax.
`
`$809.50
`$809.50
`Interior Painting
`Prep, seal, caulk all areas to prepare for painting. Professionally paint all baseboards, doortrim, and window sills, Labor only.
`
`Interior Painting
`Materials cost painting baseboards, wincowsills, and doortrim. This is the cost of materials after tax.
`
`$224.50
`
`$224.50
`
`$3,200.60
`$3,200.00
`Rough Electrical
`Professionaily install new updated electrica! service panel, meter base, and disconnect to updateelectrical. includes ali
`materials and iabor.
`
`Amazon Exteriorlights
`Professionally install 2 exterior light fixtures, one locatedin front and one in back. Labor only.
`
`$114.56
`
`$114.50
`
`Amazon Exterior lights
`
`$70.00
`
`$70.00
`
`Materials cost for 2 exterior light fixtures. This is the cost of materials after tax.
`ntips://www.amazon.convBIRITALO-Fixture-Waterproof-Aluminum-Outdoor/cp/BOB2ZKNS2T/ret=sr_1_42?
`crid=3VOMB2EEXENQB &key words =exterior %2B light%2Bfixtures&qid=1695077542&sprefix=exterior2B light 2Bfixtures
`%MeCaps %2C265&sr=8-428th= 1
`
`Recessed Lights
`
`$3.284.50
`
`$3,284.50
`
`Professionally instal 19 recessed ceiling lights. Includes proper wiring. Labor only.
`
`$165.00
`Recessed Lights
`Materials cost for installing 19 new recessed lights throughout property. This is the cost of materials after tax.
`htips://www.amazon.com/Amico-Ultra-Thin-Seiectable-Brightness-Downiight/dp/BOQRZLZN71/refesr_1_8?
`crid=88PODRABHN163&keywords=6in %2Bled %2Brecessed % 2Blight%2B20% 2Bpack&qid= 1694628409Asprefix=6in%2
`Bled %2Brecessed % 2Blight% 2B 20% 2Bpck%2Caps %2C1 128sr=B8-8&th= 1
`
`$165.00
`
`$1,329.00
`$1,329.00
`Ceiling Fan
`Professionaily install new celling fan. Includes proper mounting to brackets, connecting power to electrical, fitment of trim
`plates, and ensuing fan andits remote are functioning properly. Labor only.
`
`Ceiling Fan
`
`$400.00
`
`$400.00
`
`Materials cost for 4 ceiling fans. This is the cost of ceiling fans after tax.
`htips://www.amazon.com/Honeywell-Barcadera-Contemporary-Mounting-Reversibie/dp/BO8LQW893H/ref=sr_1_41?
`crid=28CPIY21276Z7&keywords =modern%2Bbiack%2Bceiling% 2Bfan&qid=169473951 4&sprefix=modern% 2Bblack %2Be
`eiling%2Bfan%2Caps % 26 138a8sr=8-41 &th=1
`
`38.
`
`$4,404.50
`$4,404.50
`Electrical Outlet(s)
`Professionally install 23 electrical outlets throughout property including 4 GFC| outlets for wet areas. includes new wiring.
`Labor only.
`
`
`
`

`

`Electrical Outtet(s}
`Materials cost for electrical outlets. This is the cost of materials after tax.
`htips.//www.amazon.com/ELEGRP-Decorator-Electrical-Receptacle-Self-Grounding/d p/BOB6FGHB8X/ref=sr_1_2sspa?
`crid=39F42IPMU201 R&keywords=outlets %2B20%2Bpack&gid=1694557 7578s prefix=outlets %2B20%2Bpack%2Cans%
`2C254asr=8-2-spons&sp_csd=C2ikZ2VOTMFIZTtzcF9hdGYath=1
`
`$85.00
`
`$85.00
`
`https.//www.amazon.com/Ind icator-Tamper-Resistant-Weather-Resistant-Receptacle/dp/BOBSNS5K7XTY/ref=sr_1_5?
`crid=1I8SRZWB412CS&keywords=gici+outlets+4+pack&gid= 169455765745 prefix=gfci-outlets +4%2Caps %2C 149&s1=8-
`
`5 S
`
`$3,809.00
`$3,809.00
`witch Installation
`Professionally install 17 newlight switches with new wiring. Additional 6 light switches which will be installed which are to be
`dimmer switches. Labor only.
`
`$115.00
`Switch Installation
`Materia's cost for new paddile-style switches throughout property. This is the cost of materials after tax.
`https://www.amazon.com/ELEGR P-Digital-Dimmab‘e-Incandescent-Inciuded/dp/BOS9RJ2HRN/ref=sr_1_1 _sspa?
`crid= 1GNBWST7K9W7 D&kaywords=light% 2Bswitches %2B paddie%2Bdimmer&q id= 1694566541 &sprefix=light%2Bswitch
`%2 Bpaddie% 2Bdimmer%2Caps % 2C 160&sr=8-1-spons&sp_csd=d2ikZ2VOTMFtZT1 zcF9nd GY&th=1
`
`$115.00
`
`nttps://www.amazon.com/20-Pack-ELECTECK-included-Certified/d p/BOOTBWNLHG/ref=sr_1_7?
`crid=15XISHENBWYLA&keywords =light%2Bswitches % 2B paddie%2B20%2Bpack&qid=1 6945673438sprefix=light%2Bswi
`tches %2Bpaddle%2B20%2Bpack%2Caps %2023938sr=8-7&th=1
`
`$487.00
`Vanity Light{s)
`Professionally install vanity lights in both bathrooms of property. includes associated wiring. Labor only.
`
`$487.00
`
`Vanity Light(s)
`Materials cost for vanity lights in both bathrooms. This is the cost of materials after tax.
`httos://www.amazon.com/SOLFAR T-Rotatable-Fixtures-Aluminum-Bathroorycd p/BO881NVNLD/ref=sr_1_1_sspa?
`crid=2EVTYMJ3BW3D7&keywords= vanity %2Blights % 2B solfart&qid= 1694566808&sprefix=vanity@2Bights %2Bsolfart%2
`Caps%2C148&sr=8-1-spons&sp_csd=d