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PLAINTIFF’S ORIGINAL PETITION
Plaintiff Integrity Aviation Financing, LLC d/b/a IA&L Aircraft Engine, Leasing, LLC (“Integrity Aviation”) files this Original Petition against Defendants Odyssey Engines, LLC (“Odyssey”) and Xtreme Aviation LLC (“Xtreme”), and in support thereof would respectfully show the Court as follows:
I. SUMMARY
1. This case involves breach of contract, fraud, conversion, and theft by Odyssey. Odyssey has failed to abide by its agreements to repair and/or lease jet engines owned by Integrity. For over a year, Odyssey has made false statements and broken promises concerning the status and return of these engines, as well as monies owed to Integrity Aviation. Recently, Odyssey’s excuse for some of its failures was that Odyssey is “fraudulent document central.” Alan Boyer, Odyssey’s Chief Executive Office, made this admission. It is time for Odyssey’s fraud and wrongful conduct to end.
II. DISCOVERY CONTROL PLAN
2. Discovery will be conducted under Level 2. Tex. R. Civ. P. 190.
. PARTIES
3. Plaintiff Integrity Leasing, LLC d/b/a IA&L Aircraft Engine, Leasing, LLC (“Integrity Aviation”) is a Nevada limited liability company doing business in Texas with its principal place of business in Texas.
4. Defendant Odyssey Engines, LLC (“Odyssey”) is a Florida limited liability company with its principal place of business at 8050 NW 90th Street, Medley, Florida 33166. Pursuant to Section 5.251 of the Texas Business Organizations Code, Defendant Odyssey may be served with process by serving the Texas Secretary of State because Odyssey has failed to appoint or maintain a registered agent in Texas. Pursuant to Section 5.255 of the Texas Business Organizations Code, Defendant Odyssey may also be served with process by serving its registered agent for service in Florida, David Alan Boyer at 8050 NW 90th Street, Medley, Florida 33166.
5. Defendant Xtreme Aviation LLC (“Xtreme”) is a Florida limited liability company with its principal place of business at 1801 NW 79th Avenue, Doral, Florida 33126. Pursuant to Section 5.251 of the Texas Business Organizations Code, Defendant Xtreme may be served with process by serving the Texas Secretary of State because Xtreme has failed to appoint or maintain a registered agent in Texas. Pursuant to Section 5.255 of the Texas Business Organizations Code, Defendant Xtreme may be served with process by serving its registered agent for service, Jose Rodriguez, at 801 NW 79th Avenue, Doral, Florida 33126.
IV. JURISDICTION AND VENUE
6. Jurisdiction is proper in this Court pursuant to art. 5 §§ 1 and 8 of the Texas Constitution and Texas Government Code §§ 24.007 and 24.008.
7. Venue is appropriate in Travis County under § 15.002 of the Texas Civil Practice and Remedies Code because all or a substantial part of the events giving rise to the claim occurred in Travis County.
