Filed Filed 15-Cl-?1125?woal16l2018 Amy Feldman, Circuit Clerk COMMONWEALTH OF KENTUCKY PIKE CIRCUIT COURT DIVISION NO. ACTION NO. 13-01- (0 JONES, WALTERS. TURNER 8; SHELTUN. PLLC PLAINTIFF vs. 9.9m Fl KENTUCKY FUEL CORPORATION: ANNA G?ws a. A 8: COAL CORPORATION: VIRGINIA FUEL CORPORATION: ENERGY. INCA SEQUOIA ENERGY. FOUR STAR RESOURCES, LLC and JAMES C. JUSTICE COMPANIES, INC. Comes the Plaintiff, Janee, Walters, Turner a Shelton. PLLC, by and through counsel. and for its Complaint herein. states as follows: INT RDDU 1. Thle is a cellacllon action allegan that lhe above-named Defendants have failed to pay the Plaintiff for legal work performed on their behalf. JLIRISDICTION AND 2. This Court has Ju?edicilen and venue IS prepares the amount In controversy BXceads the of the Court and lhe alleged agreement to retain the as legal counsel was dlscussed. negotiated andlor consummated in Pikaville, Pike County. Kentucky. 3. The Jones. Waller. Turner 8: Shelton, PLLC is a Kentu cky profesalanal [Imith company legal services to the publlc. JWTS's EXHIB 08:1612018 Amy Feldman, Franklin Circuit CI EXH :000001 of 000028 Filed Filed 15-01-011st 03i16i2013 Amy Feidman, Frehorin Circuit Clerk main of?ce is located at 203 Second Street, Pikeyiile, Kentucky 41501. 4. The Defendant, Kentucky Fuel Corporation is a foreign corporation authorized to conduct business within the Commonweetth of Kentucky. registered agent {or service of process is CT CORPORATION SYSTEM. 306 West Main Street, Suite 512. Frankfort. KY 40601. 5. The Defendant. A 8? Coal Corporation is a foreign corporation authorized to conduct business within the Commonwealth of Kentucky. A it G'sregistered agent for service of process Is CT CORPORATION SYSTEM. 306 West Main Street, Suite 512. Frankfort. KY 40601 . 5. The Defendant, Virginia Fuei Corporation Is a foreign corporation authorized to conduct business within the Commonweaith of Kentucky. registered agent for service of process is CT CORPORATION SYSTEM, 306 West Main Street, Suite 512, Frankfort, KY 40601. 7. - ?re Defendant, James C. Justine Companies, Inc. is a foreign corporation authorized to conduct business within the Commonwealth of Kentucky. .JJC's tegistered agent for service of process is CT CORPORATION SYSTEM. 305 West Main Street. Suite 512. Frankfort. KY 40001. I B. The Defendant. In?nity Energy, Inc. (?In?nity?) is a Kentucky corporation authorized to oonduot business within the CommonWeaith of Kentucky. In?nity?s registered agent for service of process is CT CORPORATION SYSTEM, 305 West Main Street. Suite 512. Frankfort, KY 40601. 9. The Deiendent. Sequoia Energy. LLC (?Sequoie?) is a Kentucky limited liability company authorized to conduct business within the Commonwealth of Kentucky. Sequel-3?s registered agent for service of process is CT CORPORATION SYSTEM. 306 15-CI-01125 08i16i2018 Amy Feidman, Franklin Circuit Clerk EXH 000002 of 000028 Filed Filed 15-Ci~01125 wasrrerzma Amy Feldman, Circuit Clerk West Main Street. Suite 512. Frankfurt, KY 40601. 10. The Defendant, Four Star Resources. LLC is a Kentucky limited liability company authorized to conduct business within the Commonwealth of Kentucky. FS R's registered agent for service of process is CT CORPORATION SYSTEM. 305 West Main Street. Suite 512, Frankfort, KY 40501. 11. Upon information and belief. MO is the ultimate parent corporation andlor ultimate managing member of KFC. A 8. G. VFC, FSR. In?nity and Sequoia (collectively. "The Justice Operating Companies?). 12. The Justice Operating Companies are all involved in the coal mining industry in the Commonwealth of Kentucky and have in the past andior are currently mining. processing and selling coal is at least the following counties in Kentucky: Pike. Floyd. Knoll, Megoflln. Letoher. Harlan. Breathitt and Leslie. 13. Since April 1, 2013. JWTS has provided legal services to The Justice Operating Companies on Various civii and administrative legal matters relating to their involvement in the coal mining business within the Commonwealth of Kentucky. 14. The legal services were provided by MTS after discussions with JJC represenlailves who assured JWTS. that It would be paid for providing legal services to The Justice Operating Companies and after receiving purchase order numbers from JJC representatives. in reliance Upon the representations of the JJC representatives, JWTS provided the subject legal services. 15. As of the date of the ?ling of this Complaint, has provided legal services to the Defendants, which remain unpaid. in the total amountof 385220.23. True and accurate copies of legal bills previously submitted to the Defendants reflecting-the 1543431125 08i16i2018 Amy Feldrnan, Franklin Circuit Clerk EXH UDOGUS of 000028 Filed Filed Amy Feldman, Frartwn Circuit Clerk above-referenced balance are attached hereto and made a part hereof as. A. 15. Members of JWTS have discussed this outstandan balance forte-gal services provided to the Defendants with representatives of the Defendants on numerous occasions: however. the Defendants have refused to pay the outstanding balanceowed to JWTS. 17. The actions of the Defendants in felilngio pay forthe legal services provided by JWTS are unlawful end are in breach of the agreement of the parties. 18. The Defendants obtained a valuable bene?t from the actions and efforts of JWTS in providing valuable and necessanr legal services such that the failure of the Defendants to pay JWTS for those legal services is unlawful. WHEREFORE. JWTS prays as follows: 1. That the Court enter a judgment against the Defendants in the amount of 585220.23 plus interest. both ore?judgment and poetiudgment, at the memmum legal rate. 2. For its costs herein expended. including a reasonable attorney fee. 3. For all other proper relief. Respectfully submitted, 97%, U3 UH WHITNEY L. LUCAS, ESQ. Jones. it?deltereI Turner 8. Shelton PLLC 151. N. Eagle Creek Drive. Suite 310 Lexington, Kentucky 40509 (859) 294?6868 (859) 29445866 Facsimile W?tr? (- 08? $2018 Amy Feldman, Franklin Circuit Clerk EXH 300004 of 000023