TULSA COUNTY • CJ-2025-785

Scott Bogie and Anne Bogie v. Julius Puma, LaBella Homes, Inc., JPDP, LLC, d/b/a LaBella Homes, DMG Master Builders, Larry Battaglia and Kent Construction, Inc.

Filed: Feb 25, 2025

Type: CJ

What's This Case About?

Let’s be real: if you’re going to build someone a $1.3 million custom home and then also build a whole labyrinth of shell companies just to dodge the bill when it all falls apart, you might as well call your business “Scooby-Doo Villain Enterprises.” Because that’s essentially what happened here in Tulsa County, Oklahoma, where two builders allegedly used a smoke-and-mirrors act involving fake LLCs, phantom ownership transfers, and financial shell games straight out of a mob movie—all to avoid paying a $126,337.94 judgment for a house that was so poorly built, it might as well have come with a free structural engineer.

Meet Scott and Anne Bogie, a married couple who, back in the day, thought they were investing in their dream home. What they didn’t realize? They weren’t just buying drywall and hardwood floors—they were stepping into a real-life Who’s the Actual Contractor, Anyway? episode. On the other side of this mess: Julius Puma and Larry Battaglia, two veteran homebuilders with enough side hustles, DBAs, and LLCs to make a tax attorney weep. Puma, the more publicly visible of the two, ran under the banner of “LaBella Homes,” a name so slick it sounds like a skincare line. Battaglia operated “Kent Construction,” slightly less glamorous but equally entrenched in the Tulsa custom home scene. Together, they formed Puma-Tag Enterprises, LLC—a company that, according to the Berties, was less of a real business and more of a legal sock puppet.

The story starts like any luxury home build: excitement, blueprints, promises of granite countertops and radiant heating. The Berties signed a contract with “Puma-Tag Construction”—a name that, by the way, doesn’t legally exist. The actual entity? Puma-Tag Enterprises, LLC. But don’t worry, because even the people who ran it couldn’t keep their story straight. Julius Puma signed the contract in his own name. No “by” clause, no corporate title—just “Julius Puma,” like he was autographing a baseball. The builder sign planted in the Berties’ yard? Not Puma-Tag. Nope. It proudly displayed “LaBella Homes.” The building permit? Filed under LaBella. The utility bills during construction? In Puma’s personal name. The mortgage paperwork? Signed by both Puma and Battaglia as managing members, but also personally guaranteed by them—because apparently, when it comes to getting loans, they’re happy to be real people. But when it’s time to pay up? Suddenly, they’re hiding behind an LLC thinner than the drywall in the Berties’ poorly constructed dream house.

Fast forward through years of litigation, a broken settlement agreement, and a final judgment in the Berties’ favor for $126,337.94—plus interest and attorney fees. You’d think that’s the end. But no. When the Berties went to collect, they discovered Puma-Tag Enterprises, LLC was a ghost. No assets. No bank balance. Just an empty shell, like a crab that had scuttled sideways into another company’s exoskeleton. Turns out, back in 2012—after the Berties’ house was built but before any judgment was entered—Puma and Battaglia transferred ownership of Puma-Tag to their other companies: LaBella and Kent. No money exchanged hands. No documentation. Just a quiet handoff, like passing a joint at a family barbecue. Then, in 2019—two months after the settlement agreement in the original case—they transferred the last of Puma-Tag’s real estate assets to yet another company: DMG Master Builders. Poof. No more assets. No way to collect.

But here’s the kicker: Puma and Battaglia didn’t retire. They didn’t close up shop. They’re still building homes. Still using the same crews, same offices, same vendors. Still advertising as LaBella Homes and Kent Construction. Still getting permits under those names. But Puma-Tag? That LLC? It’s a zombie—dead, but somehow still listed on contracts. Its website? Redirects to Kent Construction’s page. Its tax returns? Filed under the wrong name. Its bank account? A revolving door for cash flowing in and out with no records, no promissory notes, just “Hey Larry, can you cover this invoice?” and “Sure, I’ll pull it from Kent and call it a loan.”

The Berties aren’t suing for breach of contract this time. They’re not even asking for new damages. They’re asking the court to pierce the corporate veil—a legal term that sounds like something out of a medieval duel, but really just means: “These guys are using fake companies to hide their money, so treat them like the actual people they are.” They argue that Puma-Tag was never a real, independent business. It had no insurance of its own. No separate bank accounts. No corporate meetings. No minute books. It didn’t even have trade credit—it relied on LaBella’s vendor accounts. It was, in every practical sense, just Puma and Battaglia’s personal piggy bank, used to fund construction projects while keeping their “public brand” protected from complaints and accountability.

And let’s talk about that brand protection. The Berties tried to file a complaint with the Home Builders Association (HBA). You know what they were told? “Puma-Tag isn’t a member.” But LaBella and Kent are. So if something goes wrong, homeowners can’t use the HBA’s dispute resolution process unless they sue the real names behind the operation—which is exactly the point. It’s a built-in immunity system: contract under the invisible LLC, get the work done under the real brand, and when things go south, vanish into the corporate fog.

Now, $126,337.94 might sound like a lot—and for most people, it is. But for builders constructing multi-million-dollar homes, it’s less than the cost of the landscaping on one of their properties. It’s not a bankruptcy-level sum. It’s not even a “we had a bad quarter” kind of loss. It’s a rounding error in the world of high-end custom homes. And yet, these guys would rather shuffle money between shell companies, redirect websites, and write undocumented “loans” than just pay what they owe.

So what’s the most absurd part? Is it that Puma-Tag had negative capital before building the Berties’ home? Is it that they used LaBella’s insurance but claimed it was a separate entity? Is it that Puma and Battaglia kept taking distributions from Puma-Tag after they allegedly transferred ownership? Or is it that the entire operation runs like a shell game at a county fair, where the ball is always under the cup labeled “Not My Problem”?

Honestly, it’s all of it. This isn’t just negligence. This isn’t just poor bookkeeping. This is a system—a well-oiled machine designed to let builders profit from high-end construction while insulating themselves from accountability. They used the legal system like a costume, putting on the “LLC” disguise when it suited them and shedding it the moment a judge said, “You owe money.”

We’re entertainers, not lawyers, but if this case teaches us anything, it’s this: when your contractor’s corporate structure looks like a flowchart drawn by a conspiracy theorist, maybe don’t let them build your house. And if they do—and it falls apart—don’t be surprised when they’ve already packed up the LLC and moved on to the next one. The Berties aren’t just fighting for their money. They’re fighting to prove that in a world where builders can vanish behind a maze of fake companies, someone still has to answer for the cracked foundation, the missing warranties, and the dream home that turned into a legal nightmare. And honestly? We’re rooting for the Berties. Because if this isn’t justice, it should at least be televised.

Case Overview

$126,338 Demand Petition

Jurisdiction

Tulsa County District Court, Oklahoma

Filing Attorney

David R. Cordell

Conner & Winters, LLP

Relief Sought

$126,338 Monetary

Plaintiffs

Scott Bogie and Anne Bogie individual

Defendants

Julius Puma, LaBella Homes, Inc., JPDP, LLC, d/b/a LaBella Homes, DMG Master Builders, Larry Battaglia and Kent Construction, Inc. business|individual|business

Claims

#	Cause of Action	Description
1	Piercing Corporate Veil and Alter Ego	Plaintiffs seek to hold defendants liable for debts and actions of Puma-Tag Enterprises, LLC

Petition Text

2,567 words

IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA SCOTT BOGIE and ANNE BOGIE, Plaintiffs, vs. JULIUS PUMA, LABELLA HOMES, INC., JPDP, LLC, d/b/a Labella Homes, DMG Master Builders, LARRY BATTAGLIA and KENT CONSTRUCTION, INC. Defendants. ORIGINAL PETITION Scott Bogie and Anne Bogie ("Plaintiffs") for their claims against Defendants Julius Puma ("Puma"), LaBella Homes, Inc. ("LaBella"), JPDP, LLC, d/b/a LaBella Homes ("JPDP"), DMG Master Builders, Larry Battaglia ("Battaglia") and Kent Construction, Inc.(“Kent”) allege and state as follows: This is an action in equity to collect the judgment described below from the shareholder/unit holders of Puma-Tag Enterprises, LLC., Julius Puma, Larry Battaglia and their controlled operating companies LaBella Homes, JPDP and Kent Construction. Puma and Battaglia are attempting to hide behind the corporate shield of the woefully and intentionally undercapitalized and now defunct Puma-Tag Enterprises, LLC to avoid paying the judgment all the while continuing in the home building business in Tulsa County under various other names. Equity and justice demand that they pay the lawful judgment owing to the Plaintiffs. Parties, Jurisdiction and Venue 1. Plaintiffs are judgement creditors in the sum of $126,337.94 together with post judgment interest and accruing attorney fees (the ‘judgment’) in the case of Scott Bogie and Anne Bogie vs. Puma Tag Enterprises, LLC, Tulsa County District Court, State of Oklahoma; Case No. CJ-2014-04061 (the “underlying case”) 2. Defendant Battaglia and/or business entities owned or controlled by him such as Kent were at all relevant times the owners of judgment debtor Puma-Tag Enterprises, LLC ("Puma-Tag"). 3. Defendant Puma and/or business entities owned or controlled by him such as LaBella DMG Master Builders, and JPDP, were at all relevant times, the owners of judgment debtor Puma-Tag. 4. Defendants LaBella, DMG Master Builders and JPDP were, at all relevant times, owned and/or controlled by Puma. 5. Defendant Kent and DMG Master Builders were, at all relevant times, owned and/or controlled by Battaglia. 6. Puma, LaBella, JPDP, DMG Master Builders, Battaglia and Kent at all relevant times conducted business in Tulsa County in the State of Oklahoma therefore jurisdiction and venue are proper in this judicial district. Facts Common to All Claims 7. Plaintiffs entered into an agreement for the construction of their custom home all as alleged and the petition in the underlying case. The home was negligently constructed, suffered from poor workmanship, did not meet contract specifications, was defective and incomplete. The lot and home were offered for sale by Puma and LaBella and a local real estate brokerage firm. At the time the Plaintiffs had no knowledge that they were allegedly not dealing with Puma and LaBella much less know the capitalization value of Puma-Tag and justifiably relied on the assumption that they were dealing with a legitimate entity with the capital to build high-end residences and stand good for their work and warranties. Puma was and is a well-known builder in Tulsa who has and continues to operate under the advertised trade name of LaBella Homes. Although not as well-known, Battaglia was and is a builder in Tulsa who has and continues to operate under the advertised trade name of Kent Construction. 8. After years of litigation, including a breached settlement agreement, Plaintiffs recovered the judgment against Puma-Tag and began to try to collect it. 9. In connection with attempting to recover on the judgment it was discovered that the judgement debtor defendant Puma-Tag was merely a sham LLC set up to attempt to personally shield Puma and Battaglia and their respective publicly known operating companies from judgment. It is unclear to customers like the Plaintiffs as to the legal structure surrounding the publicly advertised trade name of “LaBella Homes”. This ambiguity arises because “Labella Homes, Inc.” is registered with the Oklahoma Secretary of State as a for-profit corporation. However, legal documents, like mortgages, have been signed by defendant Puma as the Manager of “JPDP LLC DBA LaBella Homes.” Although “LaBella Homes, Inc.” is the legal entity name, the defendant Puma uses it interchangeably as DBA of one of his LLC’s. 10. Defendants and each of them are the alter egos and mere instrumentalities of the judgment debtor Puma-Tag. Puma- Tag was and is undercapitalized to the extreme that even at the time of its founding its liabilities exceeded its assets. That remains true to date. 11. Puma-Tag did not keep adequate books and records, separate accounts or finances and was treated as the personal Piggy Bank of Puma and Battaglia. Puma-Tag was so inadequately capitalized that it repeatedly wrote hot checks which were dishonored requiring Puma and Battaglia to make arrangements to cover the checks. Battaglia and Puma depleted any assets available to creditors by distributing any funds in the Puma-Tag account to themselves personally. 12. Puma-Tag was set up by Larry Battaglia and Julius Puma “to start a home building business”. 13. At the time Plaintiffs contracted for the construction of their house, Puma-Tag was owned by Battaglia and Puma personally, but on or about October 24, 2012, after the construction of the Plaintiffs’ house, and unbeknownst to Plaintiffs, they subsequently transferred ownership of those shares/units to LaBella and to Kent, their closely held and controlled companies. 14. LaBella now appears to be a d/b/a of JPDP LLC which in turn is owned by Julius Puma and his wife and/or trusts controlled by them 15. LaBella and JPDP LLC are alter egos of Puma, and Puma-Tag. 16. Kent is an S-corp owned by Larry Battaglia. 17. Puma and Battaglia also started a company called DMG Master Builders which is an alter ego of Puma and Battaglia as well. 18. Puma-Tag has not held any assets since 2019 when they transferred their remaining real estate to DMG Master Builders. This transfer of assets to their other company occurred two months after the settlement agreement was made in the underlying case and Puma-Tag has held no assets since. These transfers or additional companies were established or had the effect of attempting to shield Puma, Battaglia and their other companies from collection of the Plaintiffs’ judgment. 19. LaBella and Kent are the only brands that are advertised, that belong to the Home Builders Association (“HBA”), with web sites, yard signs, or with established trade vendor accounts. They also prevent any complaints against their public brands by contracting through the LLC’s which have no standing with the HBA. Julius Puma and Larry Battaglia move personal funds in and out of their LLC’s as necessary, they comingle funds, and do not meet the necessary corporate formalities to show that the LLC’s are anything but alter egos of themselves. 20. Puma and Battaglia co-mingled assets and personally funded Puma-Tag when necessary to fund debts and to “protect credit” up until the point of having a judgement against the company, yet both of them continue in the exact same business of building custom homes. Under Capitalization 21. Battaglia has testified Puma-Tag was always “minimally” capitalized - just “enough money to get the LLC put together”. 22. Even though Puma-Tag was building multiple million-dollar homes, it never had in excess of $50,000 in capital. 23. Puma-Tag never carried its own builders risk insurance. It was carried through LaBella. 24. Puma-Tag never carried workers compensation insurance. 25. It was a “general practice” that they would use a rider to attach to a LaBella insurance policy, even though they claim that LaBella was an unrelated entity until after the construction of Plaintiffs’ house. 26. The Puma-Tag 2013 tax return shows a beginning of year cash balance was only $4,041, they had $60,000 in loans to partners and had negative capital of $57,380. This shows they were not appropriately capitalized when building the Plaintiffs’ house. Separate Books and Records 27. Puma-Tag did not maintain a minute book, meeting minutes, bank resolutions, etc. The only corporate governance documents produced were the original management agreement and the transfer of ownership. No Separate Individual Finances 28. Battaglia and Puma would pay bills for subcontractors and materials personally. 29. Kent would loan Puma-Tag money to pay bills, but did not have written evidence of debt, loan agreements or promissory notes between the two entities. 30. Battaglia would loan money personally to Puma-Tag when they “exceeded their loan capability”, but with no promissory note or anything formal to document the personal loan. 31. Loan repayment would come through “distributions” to Puma and Battaglia personally. For “ease of billing”, suppliers and contractors would bill LaBella, Puma or Battaglia because Puma-Tag did not have any trade accounts under its name. Aggregated materials and/or subcontractor invoices for projects across multiple entities would be billed to LaBella and they would “pull out what belonged to Puma-Tag”. Battaglia and Puma would pay bills out of their personal accounts as opposed to Puma-Tag’s. If it was necessary to protect credit and to “do it quickly”, one of them would have paid it out of their own personal account. 33. The companies all shared common employees, accountants, office space and business equipment such as phone lines, computers, etc. 34. The construction loan/mortgage obtained by Puma-Tag to build the Plaintiffs’ home was with First National Bank of Muskogee. It was signed by both Puma and Battaglia as Managing Members of Puma-Tag, but the loan was also personally guaranteed by Battaglia and Puma which is the “standard practice”. 35. The lien against the Plaintiffs’ house, that was granted by the City of Tulsa, was filed under La Bella Homes. This is “Because LaBella would require – request merchandise to be purchased on behalf of Puma-Tag to make it simpler and easier to transact.” 36. "Personal money" had been loaned to Puma-Tag for "operations" and money has flowed from Puma-Tag to Kent, LaBella, Puma and Battaglia, but those parties have refused to pay the judgement. 37. Puma and Battaglia used money from the mortgage on one Puma-Tag property to fund another Puma-Tag property construction through "short-term loans", but those loans were never documented. 38. The tax returns for Puma-Tag do not list the correct entity name. They show Puma-Tag LLC not Puma-Tag Enterprises, LLC. 39. On March 15, 2015 (after ownership of Puma-Tag transferred to LaBella and Kent) a "membership distribution of $10,000 was made to "Larry Battaglia" personally. 40. On 8/19/2015, there was a deposit from an unidentified source in the amount of $14,000 made to the Puma-Tag Master account. On that same day, Puma-Tag invested in another LLC (PTBEV) that was used to build homes in a Tulsa home development named Tradition. 41. On 12/30/2015, the Puma-Tag Master account made "membership distributions" to Larry Battaglia in the amount of $6,500 even though he was not an owner of the LLC at the time. 42. On 1/20/2016, a check was written to PTBEV in the amount of $10,000 for "Cal Call Julius", even though Puma claims to have no ownership in Puma Tag. 43. On 4/27/16 the Master Account made "Membership Distributions" of $5,000 and $1,000 to unnamed members. 44. On 5/26/16, the Master Account recorded a deposit as a "Member Contribution" and noted it as a "loan from Larry" even though Battaglia claims that his shares were owned by Kent. 45. On 7/13/16, a deposit was made into the Master Account in the amount of $15,000 and on the same day, a check was written to JPDP in the same amount. It simply passed through the Master Account. The LLCs are Merely Shams of their Members 46. Puma-Tag was formed to “start a home building business”. They stopped building homes through Puma-Tag, because they “couldn’t make any money” yet both Battaglia and Puma are still in business together, are building homes and have set up other companies like DMG Master Builders, LaBella Homes and Kent Construction among others. 47. Ownership of Puma-Tag was allegedly transferred in 2012 to LaBella and Kent, but no consideration was paid by either entity. 48. The contract with Plaintiffs listed “Puma-Tag Construction” as the contracting party, yet no such company exists. 49. Julius Puma signed the contract as Julius Puma, not “Puma-Tag Enterprises LLC by Julius Puma”. Battaglia signed the purchase price modification as Larry Battaglia with no mention of Puma-Tag Enterprises LLC. 50. The marketing material for the comparator Wing house referenced in the Plaintiffs’ contract references being “built by Julius Puma”, although it was advertised by LaBella Homes, with no reference to Puma-Tag Construction. 51. As of the date of this filing, the URL puma-tag.com points to Kent Construction’s website. 52. Puma-Tag had no outside building experience other than Julius Puma. 53 is missing 54. The builder’s sign placed in front of the Plaintiffs’ house during its construction was that of LaBella Homes, not Puma-Tag Enterprises. 55. The building permit for the Plaintiffs’ home was pulled under LaBella “for ease of getting it pulled”. The application for the building permit lists LaBella Homes as both the contractor and the property owner, it lists Julius Puma as the contact using his personal email address, and his personal home address as the contractor and owner address. Puma-Tag is not mentioned on the permit application. 56. It was “not a general practice” to inform buyers that they were working with an LLC instead of Larry Battaglia and Julius Puma. 57. Utility bills for the construction of the Plaintiffs’ home were under Julius Puma personally. 58. Puma-Tag is not a member of the Home Builders Association, but both Kent and LaBella are. The Plaintiffs attempted to file a complaint against Puma-Tag through the HBA and tried to utilize the HBA’s dispute resolution process but were informed by the HBA that Puma-Tag was not a member, and that they had no standing against its registered members, LaBella, and Kent. This practice of using sham LLC’s to contract for construction while only having the public brand of LaBella and Kent as a member of the HBA prevents customers from filing complaints or using the HBA/BBB dispute resolution process and allows the builder to hide behind and protect the reputation of their “public brand”. 59. “Most of the time” LaBella work was being done out of the Puma-Tag offices even though LaBella lists its office location as Julius Puma’s home which in turn is owned by JPDP. 60. Julius Puma did not maintain an email through puma-tag.com. His personal email ([email protected]) was used for all communications. Count I - Piercing Corporate Veil and Alter Ego 61. Plaintiffs incorporate by reference the allegations of paragraphs 1-60 above as if set forth herein. Puma, JPDP, DMG Master Builders and LaBella are alter egos of one another and of Puma -Tag and should be disregarded and Julius Puma, La Bella, DMG Master Builders and JPDP should be held liable for the debts and actions of Puma-Tag and specifically the judgment. 62. Battaglia and Kent are alter egos of one another and of Puma-Tag and Battaglia and Kent should be disregarded and considered liable for the debts and actions of Puma-Tag and specifically the judgment. 63. Puma and Battaglia acted in concert and treated Puma-Tag as a mere pass-through entity in order to borrow money from banks to build and sell residential homes all to the end that all profits were theirs individually. 64. Puma and Battaglia and their controlled companies should be held liable jointly and severally for the debts of Puma-Tag and for the judgment in favor of Plaintiffs and against Puma. WHEREFORE, premises considered Plaintiffs pray for judgment against Puma, La Bella, DMG Master Builders, JPDP, Battaglia and Kent, jointly and severally, in the amount of the underlying judgment, for costs and their attorneys fees, and all other relief as may be justified under the circumstances. Respectfully submitted, David R. Cordell, OBA#11272 CONNER & WINTERS, LLP 4100 First Place Tower 15 East Fifth Street Tulsa, Oklahoma 74103 Tel: (918) 586-8995 Fax: (918) 586-8675 [email protected] Attorneys for Scott Bogie and Anne Bogie

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