Re: The Trump Network: You're hired! (for a fee, of course)
IN THE FOURTH JUDICIAL DISTRICT COURT IN AND FOR UTAH COUNTY, STATE OF UTAH THOMAS E. MOWER Plaintiff, vs. IDEAL HEALTH, INC., a Nevada corporation; TTN, LCC dba THE TRUMP NETWORK, a Massachusetts limited liability company;
TODD STANWOOD; SCOTT STANWOOD; and LOUIS DeCAPRIO, Defendants.
Plaintiff THOMAS E. MOWER alleges and complains of Defendants IDEAL HEALTH, INC., TTN, LLC dba THE TRUMP NETWORK, TODD STANWOOD, SCOTT STANWOOD and LOUIS DeCAPRIO (collectively “Defendants”) as follows:
PARTIES AND JURISDICTION
1. Plaintiff THOMAS E. MOWER (“Plaintiff”) is, and at all times relevant hereto was, an individual residing in Utah County, Utah.
2. Defendant IDEAL HEALTH, INC. (“Ideal Health”) is, and at all times relevant hereto was, a Nevada corporation, doing business throughout the United States and has held itself out as an owner of THE TRUMP NETWORK.
3. Defendant TTN, LLC (“TTN”) is, and at all times relevant hereto was, a Massachusetts limited liability company, doing business as THE TRUMP NETWORK throughout the United States. Plaintiff is informed and believes, and on that basis alleges, that at all times alleged herein TTN and Ideal Health were the alter ego of the other.
4. Defendant TODD STANWOOD (“T. Stanwood”) is, and at all times relevant hereto was, an individual residing in the State of Massachusetts.
5. Defendant SCOTT STANWOOD (“S. Stanwood”) is, and at all times relevant hereto was, an individual residing in the State of Massachusetts.
6. Defendant LOUIS DeCAPRIO (“DeCaprio”) is, and at all times relevant hereto was, an individual residing in the State of Massachusetts.
7. Plaintiff is informed and believes, and on that basis alleges, that at all times herein mentioned each of the Defendants was the agent, representative and/or employee of each of the other defendants, and, in doing the acts hereinafter alleged, was acting within the course and scope of such relationship and with the permission and consent of their co-defendants and, further, that the Defendants, and each of them, have authorized, ratified, and approved the acts of each of the other Defendants with full knowledge of those acts.
8. This Court has jurisdiction over the present matter pursuant to UTAH CODE ANN. § 78A-5-102(1) because this is a civil matter arising out of the parties’ transaction of business within the State of Utah. Defendants and each of them through the transaction hereinafter alleged have established sufficient minimum contacts with the State of Utah justifying this Court’s assertion of jurisdiction over them.
9. This Court is the proper venue for the present matter under UTAH CODE ANN. § 78B-3-304(2) and/or § 78B-3-307.
Read the full complaint HERE
The only thing necessary for the triumph of evil is for good men to do nothing
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