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PITTSBURG COUNTY • CJ-2025-00339

The Royal Mushroom Company LLC v. Pollen Nation Cultivation LLC

Filed: Nov 7, 2025
Type: CJ
View Official Docket ↗

What's This Case About?

Let’s be real: you don’t expect to walk into a medical marijuana grow operation and find yourself knee-deep in a legal dumpster fire involving autoclaves, DNA analyzers, and a $1.6 million inventory of lab equipment that no one can agree belongs to whom. But welcome to Pollen Nation Cultivation LLC v. The Royal Mushroom Company LLC, where a partnership built on weed, whispers, and handshake deals has exploded into a 16-count civil war that reads like a stoner’s fever dream after one too many edibles.

Here’s how we got here: Nevada King, a man with a name that sounds like a rejected Dungeons & Dragons character, walked into a budding Oklahoma cannabis venture in mid-2023 with a proposition. He’d provide services — think cultivation expertise, operational support, maybe some vibes — in exchange for a cut of the profits once the business, Pollen Nation Cultivation (PNC), started turning a dime. No written contract. Just a verbal agreement. Because when you’re dealing in six-figure lab equipment and federally illegal plants, why bother with paperwork?

King wasn’t alone. He brought along The Royal Mushroom Company LLC (RMC), a Louisiana-based entity that, despite the name, doesn’t seem to sell psychedelic fungi at farmers markets. Instead, RMC owned a small fortune in high-tech lab gear — autoclaves, dehumidifiers, DNA extractors, environmental chambers, freezers, pH meters, and enough sterile lab coats to outfit a microbiology convention. This equipment, valued at a jaw-dropping $1.6 million, was shipped to PNC’s facility in Hartshorne, Oklahoma, where it was supposed to be used to help grow premium medical marijuana. King, as managing member of RMC, oversaw the whole operation. He also brought in Natalie Beavers, another employee who, like King, started working for PNC around the same time. Spoiler: neither of them ever got a paycheck.

Now, let’s talk about the other players. Jason Adams and James Tschiersch ran PNC, the Oklahoma-based grow operation. They also formed a second entity, Hydranetix LLP, a limited liability partnership that King claims he never agreed to join — yet somehow found his name on the paperwork. That’s not a typo. Adams allegedly created a partnership in King’s name without his consent. Which, legally speaking, is like signing your roommate’s name to a lease for a timeshare in Belize. Not cool. Not legal. And definitely not the kind of thing you want to explain to a judge.

For a while, the arrangement limped along. King and Beavers worked without pay. RMC’s equipment hummed away in the grow facility. And everyone pretended the verbal agreement was as binding as the Constitution. But by August 2025, the illusion cracked. PNC locked King out of the facility. Literally. Changed the locks. Blocked access. Said, “You’re not welcome here anymore.” And worse — they kept all of RMC’s $1.6 million worth of equipment. Not just borrowed it. Not just “temporarily using it.” They held onto it, allegedly used it to run their own competing operations, and refused to give it back. Meanwhile, King and Beavers? Still no wages. Still no explanation. Just a cold shoulder and a growing stack of legal grievances.

So why are we in court? Because this isn’t just a “you stole my stuff” case. It’s a full-blown corporate exorcism. The plaintiffs aren’t just asking for their equipment back — though that’s a big part of it. They’ve filed sixteen causes of action, which is like bringing a flamethrower to a water gun fight. Let’s break it down: they’re claiming breach of contract (the oral partnership agreement was violated), conversion (you can’t just take someone’s million-dollar lab gear and call it yours), fraud (false promises were made), unjust enrichment (PNC got rich off King’s labor and RMC’s equipment without paying a dime), and a whole suite of partnership law violations — including breach of the duty of loyalty, competing with the partnership, and acting with reckless negligence. Oh, and they want an accounting. Because when trust evaporates, you demand spreadsheets.

Then come the nuclear options: they’re asking the court to dissolve both the original partnership and Hydranetix, appoint receivers to take control of the business (basically a court-appointed babysitter with legal authority), issue a restraining order to stop PNC from selling or destroying the equipment, and grant prejudgment delivery — a legal Hail Mary that lets RMC reclaim its gear before the trial even happens. If the court agrees, the sheriff could show up at the facility, pack up $1.6 million worth of lab toys, and hand them over like a reverse Santa Claus.

And the money? The plaintiffs are seeking at least $1 million in compensatory damages and another $1 million in punitive damages. Is that a lot? For a medical marijuana grow in rural Oklahoma, yes. For equipment valued at $1.6 million and two years of unpaid labor? Maybe not. Punitive damages are meant to punish bad behavior, and if the allegations are true — secret partnerships, stolen equipment, unpaid wages, lockouts — then the court might agree that someone needs to feel the financial burn.

So what’s our take? Look, business partnerships are messy. Verbal agreements are risky. But the real absurdity here isn’t the lack of a contract — it’s the sheer scale of the betrayal. You don’t accidentally form a partnership with someone. You don’t accidentally lock them out of a facility. You don’t accidentally keep $1.6 million worth of equipment and pretend it’s yours. And you definitely don’t create a legal entity in someone’s name without their consent and act surprised when they sue you.

We’re rooting for King and RMC, not because they’re saints — though being stiffed for two years of work is rough — but because this case is a cautionary tale about what happens when greed overpowers basic decency. It’s also a reminder: in the wild west of legal cannabis, where federal ambiguity meets state-level entrepreneurship, the real crop isn’t weed — it’s litigation. And this field? It’s harvest-ready.

One last thing: the filing demands a jury trial. So at some point, a group of ordinary Oklahomans will sit in a courtroom, listening to arguments about Percival environmental chambers and Gellan Gum culture media, trying to decide who owns a fogger worth $20. And honestly? That might be the most entertaining civil trial since the great avocado toast dispute of 2022.

We’re entertainers, not lawyers. But if this goes to trial? We’re bringing popcorn. And maybe a pH meter, just for vibes.

Case Overview

Jury Trial Petition
Jurisdiction
District Court of the Eighteenth Judicial District, Oklahoma
Filing Attorney
Brian Ted Jones
Relief Sought
$1,000,000 Monetary
$1,000,000 Punitive
Injunctive Relief
Declaratory Relief
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Breach of Contract (Partnership Agreement) Defendants breached the express terms of the Partnership Agreement
2 Conversion/Misappropriation/Chose in Action Defendants used Plaintiffs' Equipment for their own benefit
3 Fraud, Deceit, and/or Constructive Fraud Defendants made false representations to Plaintiffs
4 Unjust Enrichment Defendants were unjustly enriched by the retention of Plaintiffs' Equipment
5 Accounting King is entitled to an accounting of PNC
6 Violation of Duty of Loyalty as Trustee Defendants violated their duties of loyalty to King as a trustee
7 Violation of Duty of Loyalty: Adverse Interest Defendants dealt with King on behalf of a party having an adverse interest to the Partnership
8 Violation of Duty of Loyalty: Non-Competition Defendants competed with the Partnership
9 Violation of Duty of Care: Grossly Negligent or Reckless Conduct Defendants engaged in grossly negligent or reckless conduct
10 Action for Unpaid Wages and Liquidated Damages PNC employed King and Beavers without paying them wages
11 Application for Prejudgment Delivery RMC requests prejudgment delivery of the Equipment
12 Application for Restraining Order RMC requests a restraining order against Defendants
13 Judicial Dissolution of the Partnership King and RMC request judicial dissolution of the Partnership
14 Judicial Dissolution of Hydranetix King requests judicial dissolution of Hydranetix
15 Petition for Appointment of Receiver Over PNC King requests appointment of a receiver over PNC
16 Petition for Appointment of Receiver Over the Partnership King requests appointment of a receiver over the Partnership

Petition Text

5,418 words
IN THE DISTRICT COURT OF THE EIGHTEENTH JUDICIAL DISTRICT SITTING WITHIN AND FOR PITTSBURG COUNTY STATE OF OKLAHOMA (1) THE ROYAL MUSHROOM COMPANY LLC, a Louisiana limited liability company; (2) NEVADA KING, a natural person; and (3) NATALIE BEAVERS, a natural person, PLAINTIFFS, v. (1) POLLEN NATION CULTIVATION LLC, an Oklahoma limited liability company; (2) HYDRANETIX LLP, an Oklahoma limited liability partnership; (3) JASON ADAMS, a natural person; and (4) JAMES TSCHIERSCH, a natural person, DEFENDANTS Case No. CJ-2025-339 ATTORNEY LIEN CLAIMED JURY TRIAL DEMANDED PETITION COMES NOW Plaintiffs, The Royal Mushroom Company LLC ("RMC"), Nevada King ("King"), and Natalie Beavers ("Beavers") through their attorneys of record, Brian Ted Jones and Max Federman, of the firm Brian Ted Jones, PC, to present this petition ("the Petition") against the Defendants Pollen Nation Cultivation LLC ("PNC"), Hydranetix LLP ("Hydranetix"), Jason Adams ("Adams"), and James Tschiersch ("Tschiersch"). In support, Plaintiffs assert: I. PARTIES, JURISDICTION, AND VENUE 1. RMC is, and at all relevant times was, a Louisiana limited liability company doing business in the State of Oklahoma. 2. King is, and at all relevant times was, a natural person residing in the State of Oklahoma. 3. Beavers is, and at all relevant times was, a natural person residing in the State of Oklahoma. 4. PNC is, and at all relevant times was, an Oklahoma limited liability company residing in the State of Oklahoma. 5. Hydranetix is, and at all relevant times was, an Oklahoma limited liability partnership residing in the State of Oklahoma. 6. Adams is, and at all relevant times was, a natural person residing in the State of Oklahoma. 7. Tschiersch is, and at all relevant times was, a natural person residing in the State of Oklahoma. 8. The Court has personal jurisdiction over the parties, subject-matter jurisdiction over the action, and venue is proper in this Court. II. STATEMENT OF GENERAL FACTS 9. The allegations set forth in paragraphs 1 through 8 of this Petition are incorporated as if repeated in this paragraph. 10. In mid-2023, King entered into an express oral contract ("the Partnership Agreement") with Defendants. Pursuant to the Partnership Agreement, King would provide services to PNC's medical marijuana grow business ("the Services") in exchange for a share of profits when PNC reached profitability. 11. The Partnership Agreement created a partnership between King, PNC, Adams, and Tschiersch ("the Partnership"). Pursuant to the Partnership Agreement and in furtherance of the Partnership, King's Services included Services related to certain items of equipment ("the Equipment") owned by RMC. 12. The Equipment includes: A. A conveyor system consisting of approximately twenty-nine (29) pieces, valued at approximately $241.88; B. Five (5) LS-150LD Autoclaves, valued at approximately $12,750.00; C. Selmi Chocolate Machinery loader model 175 with sensor, valued at approximately $15,340.00; D. Assorted kitchen pans, valued at approximately $708.00; E. Ideal air dehumidifier model 701600, valued at approximately $590.00; F. Innovative Solutions Proguard air and surface purifiers model DXB-100, valued at approximately $15,340.00; G. Approximately nine hundred forty-nine (949) Uline stackable shelf bins, valued at approximately $653.00; H. One (1) Sage Science DNA analyser, valued at approximately $1,400.00; I. One (1) 140 Gallon High Performance Commercial Seafood Boiler, valued at approximately $3,899.00; J. One (1) 1,400-lb heavy duty utility cart, valued at approximately $248.96; K. Five (5) Med-Bio Cabinets with six foot flowhoads with stands, valued at approximately $503.00; L. Two (2) FireKing Fire Proof Cabinets model CF4436-MD, valued at approximately $384.81; M. One (1) ULINE Flammable Storage Cabinet model H-2218S-Y, valued at approximately $64.13; N. Three (3) VWR Standard Heatblocks model 13259-030, valued at approximately $57.72; O. One (1) Megamag Genie Stirrer model SI2236, valued at approximately $22.44; P. One (1) Eppendorf Thermo Mixer model 5382, valued at approximately $962.00; Q. One (1) Eppendorf Thermoblock for PCR plates 96 model 5306HQ405354, valued at approximately $128.27; R. One (1) InterteK Ice Machine model LK190802-11, valued at approximately $80.17; S. One (1) IGLOO Ice Crusher serial number 110v, valued at approximately $3.21; T. Eight (8) ULINE Metal Racks, valued at approximately $1,282.66; U. Seven (7) Lab Tables, valued at approximately $256.53; V. Nine (9) Lab Tables, valued at approximately $224.47; W. Three (3) Abatement Technologies portable air scrubbers model PAS2400, valued at approximately $1,600.00; X. One (1) Binder Portable 2 door drying and heating chamber model FED720-UL, valued at approximately $15.00; Y. One (1) Fisher Scientific digital vortex mixer model 945415, valued at approximately $60.00; Z. One (1) Waring Commercial Blender CB-6 model 91-215 with two (2) stainless steel pitchers with choppers, valued at approximately $200.00; AA. Four (4) Waring Commercial Blender stainless steel pitchers with choppers, valued at approximately $200.00; AB. One (1) Schott glass reaction bulb, valued at approximately $100.00; AC. One (1) Flanders PrecisionAIRE HEPA/ULPA Fan/Filter Module model EFFPM4932448STD, valued at approximately $25.00; AD. One (1) Stainless steel utility sink and table, valued at approximately $125.00; AE. Pallet of Plastic Buckets with lids, valued at approximately $50.00; AF. Approximately thirty-four (34) Stainless Steel Portable Carts, valued at approximately $50.00; AG. Two (2) Bohn walk-in cooler chiller units model ADT208AK, valued at approximately $100.00; AH. One (1) Lab bench on casters, valued at approximately $60.00; AI. Two (2) Pelton and Crane Autoclaves, valued at approximately $500.32; AJ. One (1) Fisher Scientific Mini Heat Block model 3327, valued at approximately $50.00; AK. One (1) gray racking, valued at approximately $12.09; AL. One (1) Credenza and Shelf; one (1) Two Drawer File Cabinet; one (1) Whiteboard; two (2) Table Lamps; four (4) Chairs; one (1) 4 Drawer File Cabinet, valued at approximately $25.00; AM. Cisco Video Conference Equipment model EX60, valued at approximately $25.00; AN. One (1) Cisco Controller model 4402, valued at approximately $25.00; AO. One (1) Labonco Waterpro PS System Model 9000704, valued at approximately $200.00; AP. Thirty-eight (38) Logiquip Metal Racks, valued at approximately $800.00; AQ. Nine hundred forty-nine (949) Uline Stackable Shelf Bins, valued at approximately $653.00; AR. One (1) Roche Magna Pure Nucleic Acid Extractor, thirteen (13) Rainin 1000 1200UL Precision Pipettes, one (1) VWR Scientific Heat Block, one (1) National Labnet Adjustable Tilt Rocker, and one (1) Fischer Scientific Sonic Dismembrator, valued at approximately $402.00; AS. One (1) Thermo Scientific REC-500 Refrigerator, valued at approximately $102.00; AT. One (1) Thermo Forma Freezer, valued at approximately $122.00; AU. Two (2) Thermo Freezers model 8604, five (5) Allentown Blower Exhausts, one (1) Sterilizer model SS-325E, one (1) Freezone Freeze Dryer model 7740021, one (1) Welch Pump Vacuum model 8912Z-02, one (1) Bechman Coulter Centrifuge model Allegra-6R, one (1) Eppendorf Microcentrifuge model 5426 5415R, one (1) Sentry Cleaner Ultrasonic model CD-4860, valued at approximately $344.00; AV. One (1) Lab Line Incubator Imperial, one (1) Aqua Solutions Water Purification Systems, valued at approximately $50.00; AW. One (1) Misonix fume hood with wheeled cart, valued at $367.00; AX. Two (2) NCL 150 Fiber Optic Illuminators, valued at approximately $6.54; AY. One (1) Li-Cor Inc. LI-1600 steady state porometer, valued at approximately $6.54; AZ. One (1) Taylor 9" Sling Psychrometer/Hygrometer, valued at approximately $6.54; BA. One (1) Sigma Aldrich H3770 hotplate/stirrer, valued at approximately $6.54; BB. One (1) Mettler AE 100 analytical balance & scale, valued at approximately $6.54; BC. One (1) Fisher Scientific AP63 Accumet Portable Laboratory PH Meter w/ Case, valued at approximately $32.70; BD. One (1) Tyler Industrial Portable Sieve Shaker Model 24, valued at approximately $5.45; BE. One (1) Orbit Shaker, valued at approximately $16.35; BF. One (1) Precision Water Bath, valued at approximately $16.35; BG. One (1) Hecon G0124184 Counter, valued at approximately $12.72; BH. Two (2) Titan fiber optic light, valued at approximately $25.44; BI. One (1) Southern Micro Instruments EKE Light, valued at approximately $12.72; BJ. One (1) Kendro Labs Sorvall Biofuge Pico, valued at approximately $12.72; BK. One (1) Heraeus Biofuge Pico, valued at approximately $12.70; BL. Three (3) Southern Micro Instruments, valued at approximately $40.88; BM. One (1) Precision water bath, valued at approximately $40.88; BN. One (1) APC Backup Unit, valued at approximately $8.18; BO. Four (4) extension cords, valued at approximately $8.18; BP. One (1) Lab Table, valued at approximately $8.18; BQ. One (1) APC Backup Unit CS350, valued at approximately $8.18; BR. Two (2) PH Meters, valued at approximately $76.30; BS. Glassware, valued at approximately $174.40; BT. Glassware & Petri Dishes, valued at approximately $87.20; BU. Miscellaneous Graduated Cylinders, valued at approximately $24.53; BV. Sample Bottles, valued at approximately $24.53; BW. 9x9 Bio Dishes, valued at approximately $7.27; BX. NIB Lab Coats, Absorbent Liner, Bouffant Lab Caps, valued at approximately $7.27; BY. NIB Chem Wipes, valued at approximately $7.27; BZ. Filtration Apparatus & Filter Paper, valued at approximately $7.27; CA. NIB Inoculation Loops, valued at approximately $7.27; CB. NIB Cell Speaders, valued at approximately $7.25; CC. Four (4) Wrapping Tables, valued at approximately $43.60; CD. Miscellaneous Lab Box, Versi Dry, Clam Shells, Etc, valued at approximately $43.60; CE. One (1) Image Analytics Inc. Model AF1, valued at approximately $32.70; CF. Miscellaneous Reusable pipettes & Storage & Petri Dishes, valued at approximately $463.25; CG. Three (3) Zymo Research Zymoclean Gel DNA Recovery Kits, three (3) Plasmid Miniprep Kits, valued at approximately $72.67; CH. Three (3) Omega DNA Kits, one (1) Magnetic Separation Device, valued at approximately $72.67; CI. Ninety-six (96) Qiagen QIAVAC Plates, two (2) Plasmid Plus Mini Kits, valued at approximately $72.66; CJ. Morter & Pestals, valued at approximately $54.50; CK. Cart with Tissue Culture Dishes, valued at approximately $21.80; CL. Assorted storage Racks, valued at approximately $27.25; CM. Ten (10) Space Saver Tip Rack Refills, valued at approximately $10.90; CN. Caps and Storage Boxes, valued at approximately $10.90; CO. Miscellaneous lot Wash plates, Strip Caps, Filters, Etc, valued at approximately $10.90; CP. One (1) five gallon Shop Vacuum, valued at approximately $16.35; CQ. One (1) 1.5 gallon Shop Vacuum, valued at approximately $16.35; CR. Lab Coats, Gloves, and Bouffant Caps, valued at approximately $27.25; CS. Light, coat racks, Sanitaire Vacuum with extra bags, valued at approximately $43.60; CT. Seven (7) boxes of NIB Lab Coats, valued at approximately $10.90; CU. Clam shells, valued at approximately $10.90; CV. Three (3) palets of Square Containers, valued at approximately $32.70; CW. One (1) box of assorted tools, valued at approximately $10.90; CX. Rolling Cart with Glassware, valued at approximately $38.15; CY. Three (3) sets of Bio Dishes, valued at approximately $43.60; CZ. Agitator Shafts and Blades, valued at approximately $50.00; DA. One (1) Dristeem Vapormist Humidifier, valued at approximately $50.00; DB. One (1) Dristeem XT Steam Blower, valued at approximately $50.00; DC. One (1) Air Science LF Series Pure Air Laminaire Flow Safety Cabinet with Bench, valued at approximately $198.34; DD. Nestable Stackable Bins with Contents including Consumables, valued at approximately $264.45; DE. One (1) Thermo Scientific Orion AQ3010 Turbidity Meter with Case, valued at approximately $661.13; DF. One (1) Stereozoom Microscope with 10X Eye Pieces, valued at approximately $125.61; DG. One (1) Fisher Scientific Accumet Model AE150 pH Meter, valued at approximately $330.56; DH. One (1) VWR Model VWR-64B2 Digital Flass Enclosed Lab Balance, valued at approximately $793.35; DI. Pallet Shelving, Medium Duty Shelving, Clip Together Shelving, Metro Style Wire Shelving with Contents, valued at approximately $2,380.05; DJ. Contents of Consumable Supply Closet including 5L Flasks, Millipore Centrifugal Filters, Syringes, and Trays, valued at approximately $528.90; DK. Four (4) Interion Lab Chairs, valued at approximately $105.78; DL. Cell Culture Consumables including Cell Culture Flasks, Cell Culture Plates, Reagent Reservoirs, and other Cell Culture related consumables, valued at approximately $1,289.19; DM. Bi-directional drying fans, valued at approximately $80.00; DN. Miscellaneous cleaned tools, valued at approximately $25.00; DO. One (1) Fogger, valued at approximately $20.00; DP. Assorted air hoses, valued at approximately $5.00; DQ. Five (5) Percival I36VL environmental chamber, valued at approximately $7,611.00; DR. One (1) Percival I-66NLX environmental chamber with Innovative Air IAT-75RE desiccant dehumidifier, valued at approximately $1,548.00; DS. One (1) Fitotron SGC120-SS environmental chamber, valued at approximately $741.75; DT. One (1) Stephan Vertical Cutter Mixer Model VCM-40, valued at approximately $800.00; DU. One (1) Gantry Lift System, valued at approximately $2,100.00; DV. One hundred (100) grams of 6-Benzylaminopurine (BA), valued at approximately $99.65; DW. Four (4) units 100ML GIB Acid Solution, valued at approximately $107.64; DX. Three (3) units 100L M&S Macronutrient Salt Base, valued at approximately $157.41; DY. One (1) unit 100L M&S Modified Basal Medium, valued at approximately $73.62; DZ. Two (2) units 50L Murashige & Skoog Modified Salt Mix, valued at approximately $54.90; EA. Two (2) units 100L MS Micronutrient Salt Base, valued at approximately $99.81; EB. Three (3) units 100L MS Cannabis Mix with T841 & S391, valued at approximately $266.89; EC. One (1) unit 100ML 2, 4-D Acid Solution (10mg/mL), valued at approximately $24.34; ED. One (1) unit 1KG myo-INOSITOL, valued at approximately $191.92; EE. Two (2) units 100ML Gamborg Vit. Powder (1000x), valued at approximately $30.87; EF. One (1) unit 1KG Casein Hydrolysate, valued at approximately $144.90; EG. One (1) unit 500G Nicotinic Acid, valued at approximately $41.04; EH. One (1) unit 500G a-Naphthaleneacetic Acid, valued at approximately $163.30; EI. One (1) unit 100G Indole-3-Acetic Acid, valued at approximately $133.92; EJ. One (1) unit 100G Indole-3-Butyric Acid, valued at approximately $139.90; EK. One (1) unit 100G Pyridoxine Hydrochloride, valued at approximately $45.76; EL. One (1) unit 500G L-Glutamine, valued at approximately $127.44; EM. One (1) unit 1KG L-Asparagine, valued at approximately $167.06; EN. One (1) unit 50L MES Buffer Mix, valued at approximately $51.48; EO. One (1) unit 250G Alginic Acid, valued at approximately $115.33; EP. One (1) unit 1KG Gellan Gum, Culturegel, valued at approximately $169.06; EQ. One (1) pair of Autoclave Gloves, valued at approximately $37.53; ER. One (1) unit 1KG Calcium Nitrate, valued at approximately $57.28; ES. One (1) unit 1KG Polyethyleneglycol, valued at approximately $48.24; ET. One (1) unit 1KG Ammonium Nitrate, valued at approximately $55.84; EU. One (1) unit 100G Thiamine Hydrochloride, valued at approximately $57.06; EV. One (1) unit 25ML Phytoax, valued at approximately $122.98; EW. One (1) unit 50L DKW B. Med. with 10 grams per liter Sucrose, valued at approximately $44.95; EX. One (1) unit 25G Indole-3-Butyric Acid, valued at approximately $53.46. 13. King, as managing member for RMC and pursuant to the Partnership Agreement, housed the Equipment at PNC's medical marijuana grow facility located at 300 Jupiter St., Ste B., Hartshorne, OK 74547 ("the Facility"). 14. Beginning in mid-2023 and continuing through August 2025, PNC employed King and Beavers. 15. PNC never paid any wages to King or Beavers. 16. Although RMC purchased the Equipment, holds title to the Equipment, is the rightful owner of the Equipment, and is entitled by law to immediate possession of the Equipment, Defendants have wrongfully detained the Equipment, and have not taken the Equipment in execution on any order or judgment against RMC or King, or for the payment of any tax, fine, or amercement assessed against RMC or King, or by virtue of an order of delivery issued pursuant to 12 O.S. § 1571, or any other mesne or final process issued against RMC or King. 17. Without King's consent, Adams organized Hydranetix as a limited liability partnership between Adams and King. 18. Recently, PNC, Adams, and Tschiersch have locked King out of the Facility, wrongfully detained the Equipment, and repudiated the Partnership Agreement. 19. On information and belief, Defendants have used the Equipment to further their own independent business interests, exercising dominion and control over the Equipment to the exclusion of King and RMC, in furtherance of their own use and benefit, and without King and RMC's consent. 20. On information and belief, Defendants have withheld the Equipment and the value created by the Equipment and maintained the Equipment and the value created by the Equipment for their own personal, independent, and/or competitive use. 21. On information and belief, PNC has violated its duties to the Partnership. 22. On information and belief, Adams has violated his duties to the Partnership. 23. On information and belief, Tschiersch has violated his duties to the Partnership. 24. RMC and King hold an interest in PNC pursuant to the Partnership Agreement, their interests in PNC are probable, and those interests are in danger of being lost, removed, or materially injured III. SPECIFIC CAUSES OF ACTION 25. The allegations set forth in paragraphs 1 through 24 of this Petition are incorporated as if repeated in this paragraph. 26. Without waiving their right to assert further causes of action in the pretrial conference order pursuant to Rule 5 of the Rules for District Courts of Oklahoma, the Plaintiffs asserts the following specific causes of action: First Cause of Action Breach of Contract (Partnership Agreement) by King Against All Defendants 27. The allegations set forth in paragraphs 1 through 26 of this Petition are incorporated as if repeated in this paragraph. 28. King entered into the Partnership Agreement, an express, valid, and enforceable contractual agreement governing the relationship between King and Defendants. 29. Defendants breached the express terms of the Partnership Agreement by, among other things, locking King out of the Facility, wrongfully detaining the Equipment, and repudiating the Partnership Agreement. 30. As a result of Defendants' breaches, King has suffered damages, and continue to suffer damages, in an amount to be proven at trial. 31. Accordingly, Plaintiff King respectfully requests that judgment be entered in his favor, and against Defendants, awarding Plaintiff King compensatory damages in an amount in excess of $10,000.00 with respect to the Partnership Agreement, together with pre- and post-judgment interest, costs, and attorney's fees incurred in the prosecution of this action, and such other and further relief to which they may be entitled. [THIS AREA INTENTIONALLY LEFT BLANK.] Second Cause of Action: Conversion/Misappropriation/Chose in Action by RMC Against All Defendants 32. The allegations set forth in paragraphs 1 through 31 of this Petition are incorporated as if repeated in this paragraph. 33. Defendants have used RMC's Equipment to further their own independent business interests, exercising dominion and control over the Equipment to the exclusion of RMC, in furtherance of their own use and benefit, and without the RMC's consent. 34. RMC has therefore been wrongfully denied the benefit and use of its property due to Defendants' conversion or misappropriation of the Equipment. 35. Defendants' conduct was malicious, deliberate, and made with the specific purpose to injure and impair RMC, and in reckless disregard of its rights. As such, an award of punitive damages is appropriate. 36. Accordingly, RMC respectfully requests that judgment be entered in its favor, and against Defendants, such that RMC is awarded compensatory and punitive damages in an amount in excess of $10,000.00, together with pre- and post-judgment interest, costs, and attorney's fees incurred in the prosecution of this action, and such other and further relief to which they may be entitled. Third Cause of Action: Fraud, Deceit, and/or Constructive Fraud by King and RMC Against All Defendants 37. The allegations set forth in paragraphs 1 through 36 of this Petition are incorporated as if repeated in this paragraph. 38. Defendants intentionally and falsely represented material facts, including their intentions to honor the Partnership Agreement. 39. These representations materially affected King's decision to enter into the Partnership Agreement and provide the Services, and RMC's decision to provide the Equipment to Defendants and store the Equipment at the Facility. 40. King and RMC reasonably relied upon these false representations to their detriment. 41. Defendants' actions constitute fraud, deceit, and/or constructive fraud, and were the direct cause of damages to Plaintiffs in an amount to be proven at trial. 42. Furthermore, Defendants committed these actions intentionally and with malice, or in reckless disregard of King and RMC's rights, such that King and RMC are entitled to recover punitive damages against Defendants. 43. Accordingly, King and RMC respectfully request that judgment be entered in their favor, and against Defendants, such that King and RMC are awarded compensatory and punitive damages in an amount in excess of $10,000.00, together with pre- and post-judgment interest, costs, and attorney's fees incurred in the prosecution of this action, and such other and further relief to which they may be entitled. Fourth Cause of Action: Unjust Enrichment by All Plaintiffs Against All Defendants 44. The allegations set forth in paragraphs 1 through 43 of this Petition are incorporated as if repeated in this paragraph. 45. Defendants has withheld the value of King's Services, King and Beavers's labor, and RMC's Equipment for their own personal, independent, and/or competitive use ("the Enrichment"). 46. Defendants were unjustly enriched through the retention of the Enrichment and the benefits obtained from Plaintiffs. 47. Defendants' Enrichment was obtained at the financial expense, and to the unjust detriment, of Plaintiffs. 48. Accordingly, Plaintiffs respectfully request that judgment be entered in their favor, and against Defendants, such that Plaintiffs are awarded compensatory damages in an amount in excess of $10,000.00, together with pre- and post-judgment interest, costs, and attorney’s fees incurred in the prosecution of this action, and such other and further relief to which they may be entitled. Fifth Cause of Action: Accounting by King Against PNC 49. The allegations set forth in paragraphs 1 through 48 of this Petition are incorporated as if repeated in this paragraph. 50. King, as a partner of PNC, is entitled to an accounting of PNC. 51. Accordingly, King respectfully requests that this Court order an accounting of PNC. and that King be awarded his costs and attorney’s fees incurred in obtaining this accounting, along with such other and further relief to which his may be entitled. Sixth Cause of Action: Accounting by the Partnership 52. The allegations set forth in paragraphs 1 through 51 of this Petition are incorporated as if repeated in this paragraph. 53. King, as a partner in the Partnership with Defendants, is entitled to an accounting of the Partnership. 54. Accordingly, King respectfully request that this Court order an accounting of the Partnership and that King be awarded his costs and attorney’s fees incurred in obtaining this accounting, along with such other and further relief to which he may be entitled. Seventh Cause of Action: Violation of Duty of Loyalty as Trustee by King Against All Defendants 55. The allegations set forth in paragraphs 1 through 54 of this Petition are incorporated as if repeated in this paragraph. 56. Defendants' actions constitute a violation of their duties of loyalty to King as a trustee under 54 O.S. § 1-404 (b)(1). Specifically: A. Defendants' Partnership with King imposed on them a duty of loyalty to account to the Partnership and hold as trustee for it any property, profit, or benefit derived by the Partnership in the conduct of the Partnership's business or derived from a use by any partner of Partnership property under 54 O.S. § 1-404 (b)(1); B. Defendants actions, including locking King out of the Facility, wrongfully detaining the Equipment, and repudiating the Partnership Agreement, in furtherance of their own use and benefit, and without the King's consent, violated their duties of loyalty to King as a trustee and caused harm to King under 54 O.S. § 1-405 (a). C. Furthermore, Defendants committed these actions intentionally and with malice, or in reckless disregard of King's rights, such that King is entitled to recover punitive damages against Defendants. 57. Defendants should be ordered to pay King his actual damages resulting from the Defendants' violations of their duties of loyalty as a trustee, along with punitive damages, attorney's fees and costs, and any other relief to which King might be entitled. Eighth Cause of Action: Violation of Duty of Loyalty: Adverse Interest by King Against All Defendants 58. The allegations set forth in paragraphs 1 through 57 of this Petition are incorporated as if repeated in this paragraph. 59. Defendants' actions constitute a violation of their duties of loyalty against dealing with King in the conduct of the Partnership’s business on behalf of a party having an adverse interest to the Partnership under 54 O.S. § 1-404 (b)(2). Specifically: A. Defendants’ Partnership with King imposed on them a duty of loyalty not to deal with the Partnership in the conduct of the Partnership’s business on behalf of a party having an adverse interest to the Partnership under 54 O.S. § 1-404 (b)(2); B. Defendants' actions, including including locking King out of the Facility, wrongfully detaining the Equipment, and repudiating the Partnership Agreement, constitute a violation of their duty of loyalty not to deal with the Partnership in the conduct of the Partnership’s business on behalf of a party, specifically, Defendants, having an adverse interest to the Partnership under 54 O.S. § 1-404 (b)(2), constituting a violation of his duty of loyalty to Plaintiffs and causing harm to King under 54 O.S. § 1-405 (a). C. Furthermore, Defendants committed these actions intentionally and with malice, or in reckless disregard of King's rights, such that King is entitled to recover punitive damages against Illingworth. 60. Defendants should be ordered to pay King his actual damages resulting from the Defendants' violations of their duties of loyalty against dealing with the Partnership in the conduct of the Partnership's business on behalf of a party having an adverse interest to the Partnership, along with punitive damages, attorney’s fees and costs, and any other relief to which Plaintiff might be entitled. Ninth Cause of Action: Violation of Duty of Loyalty: Non-Competition by King Against All Defendants 61. The allegations set forth in paragraphs 1 through 60 of this Petition are incorporated as if repeated in this paragraph. 62. In the alternative, Defendants' actions constitute a violation of their duties of loyalty against competing with the Partnership under 54 O.S. § 1-404 (b)(3). Specifically: A. Defendants' Partnership with King imposed on them duties of loyalty not to compete with the Partnership under 54 O.S. § 1-404 (b)(3); B. Defendants' actions, including locking King out of the Facility, wrongfully detaining the Equipment, and repudiating the Partnership Agreement, constitute a violation of their duties of loyalty not to compete with the Partnership under 54 O.S. § 1-404 (b)(3) by placing Defendants in competition with the Partnership, constituting a violation of their duties of loyalty to King and causing harm to King. C. Furthermore, Defendants committed these actions intentionally and with malice, or in reckless disregard of King's rights, such that King is entitled to recover punitive damages against Illingworth. 63. Defendants should be ordered to pay King his actual damages resulting from the Defendants' violations of their duty of loyalty against competing with the Partnership, along with punitive damages, attorney’s fees and costs, and any other relief to which Plaintiff might be entitled. Tenth Cause of Action: Violation of Duty of Care: Grossly Negligent or Reckless Conduct, Intentional Misconduct, or Knowing Violation of the Law by King Against All Defendants 64. The allegations set forth in paragraphs 1 through 63 of this Petition are incorporated as if repeated in this paragraph. 65. In the alternative, Defendants' actions constitute a violation of their duties of care to refrain from engaging in grossly negligent or reckless conduct, intentional misconduct, or a knowing violation of the law in the conduct or winding up of the Partnership’s business under 54 O.S. § 1-404 (c). Specifically: A. Defendants' Partnership with King imposed on them duties of care to refrain from engaging in grossly negligent or reckless conduct, intentional misconduct, or a knowing violation of the law in the conduct or winding up of the Partnership’s Business under 54 O.S. § 1-404 (c); B. Defendants' actions, including locking King out of the Facility, wrongfully detaining the Equipment, and repudiating the Partnership Agreement, constitute a violation of their duties of care to King, causing harm to King. C. Furthermore, Defendants committed these actions intentionally and with malice, or in reckless disregard of King's rights, such that King is entitled to recover punitive damages against Illingworth. 66. Defendants should be ordered to pay King his actual damages resulting from the Defendants' violations of their duties of care to refrain from engaging in grossly negligent or reckless conduct in the conduct or winding up of the Partnership’s business, along with punitive damages, attorney’s fees and costs, and any other relief to which Plaintiffs might be entitled. Eleventh Cause of Action Action for Unpaid Wages and Liquidated Damages by King and Beavers Against PNC 67. The allegations set forth in paragraphs 1 through 66 of this Petition are incorporated as if repeated in this paragraph. 68. In the alternative, PNC employed King and Beavers for approximately two (2) years and paid King and Beavers no wages whatsoever. 69. In addition, PNC terminated King and Beavers on or about August, 2025, and failed to pay King and Beavers their wages in full. 70. Accordingly, and pursuant to 40 O.S. § 165.9, PNC is liable to King and Beavers for their unpaid wages. In addition, and pursuant to 40 O.S. § 165.3, PNC is also liable to King and Beavers for liquidated damages in the amount of two percent (2%) of the total unpaid wages for each day of PNC's continuing failure to pay King and Beaver their unpaid wages after those wages became earned and due. 71. Defendants should be ordered to pay King and Beaver their unpaid wages and liquidated damages in the amount of two percent (2%) of the total unpaid wages for each day of PNC's continuing failure to pay King and Beaver their unpaid wages after those wages became earned and due. Twelfth Cause of Action: Application for Prejudgment Delivery 72. The allegations set forth in paragraphs 1 through 71 of this Petition are incorporated as if repeated in this paragraph. 73. In the alternative, pursuant to 12 O.S. § 1571 (A), RMC requests this Court enter an Order for Prejudgment Delivery of the Equipment, directing the Sheriff of Pittsburg County to take the Equipment and deliver the Equipment to RMC. 74. RMC's application for prejudgment delivery seeks an Order for Prejudgment Delivery concerning assets (the Equipment) which is fully described in paragraph 12 of this Petition, and which has an estimated value of $1,600,000.00. 75. RMC is the rightful owner of the Equipment, and entitled by law to immediate possession of the Equipment. 76. RMC's Equipment has been wrongfully detained by Defendants. 77. RMC's Equipment was not taken in execution on any order or judgment against RMC, or for the payment of any tax, fine, or amercement assessed against it, or by virtue of an order of delivery issued pursuant to 12 O.S. § 1571, or any other mesne or final process issued against RMC. 78. On premises considered, RMC respectfully requests this Court enter an Order for Prejudgment Delivery of the Equipment, directing the Sheriff of Pittsburg County to take the Equipment and deliver the Equipment to RMC, together with an award to RMC of its attorney fees and costs and any further relief the Court deems just. Thirteenth Cause of Action: Application for Restraining Order 79. The allegations set forth in paragraphs 1 through 78 of this Petition are incorporated as if repeated in this paragraph. 80. In the alternative, pursuant to 12 O.S. § 1571 (C), RMC requests this Court enter a restraining order against Defendants, prohibiting them from concealing, damaging, or destroying the Equipment, or any part thereof, or removing the Equipment or any part thereof from Pittsburg County, pending hearing on RMC's Application for Prejudgment Delivery. 81. RMC is entitled to prejudgment delivery pursuant to 12 O.S. § 1571 (A). 82. The Court has statutory authority under 12 O.S. § 1571 (C) to order Defendants not to conceal, damage, or destroy the Equipment, any part thereof, or remove the Equipment, or any part thereof from Pittsburg County, pending hearing on RMC's Application for Prejudgment Delivery. 83. On premises considered, RMC respectfully requests this Court enter a restraining order against Defendants, prohibiting them from concealing, damaging, or destroying the Equipment, or any part thereof, or removing the Equipment or any part thereof from Pittsburg County, pending hearing on RMC's Application for Prejudgment Delivery, together with an award to PMC of its attorney fees and costs and any further relief the Court deems just. Fourteenth Cause of Action: Judicial Dissolution of the Partnership 84. The allegations set forth in paragraphs 1 through 83 of this Petition are incorporated as if repeated in this paragraph. 85. It is not reasonably practicable to carry on the Partnership's business in conformity with the Partnership Agreement. 86. Accordingly, King and RMC respectfully request this Court enter an order decreeing the Partnership be dissolved, its operations wound down, and its assets distributed to the Partners. Fifteenth Cause of Action: Judicial Dissolution of Hydranetix 87. The allegations set forth in paragraphs 1 through 86 of this Petition are incorporated as if repeated in this paragraph. 88. King did not consent to be named as a partner in Hydranetix, no separate partnership agreement exists for Hydranetix, and it is not reasonably practicable to carry on Hydranetix as a business. 89. Accordingly, King respectfully requests this Court enter an order decreeing that Hydranetix be dissolved, its operations wound down, and its assets distributed equitably.. Sixteenth Cause of Action Petition for Appointment of Receiver Over PNC 90. The allegations set forth in paragraphs 1 through 89 of this Petition are incorporated as if repeated in this paragraph. 91. In the alternative, pursuant to 12 O.S. § 1551, King requests this Court appoint a receiver over the PNC, authorizing the receiver to exercise all powers over PNC authorized by 12 O.S. § 1554. In support of this petition, King asserts: A. King holds an interest in PNC pursuant to the Partnership. B. King's rights to or interests in PNC are probable. C. King's rights to or interests in PNC are in danger of being lost, removed, or materially injured. 92. On premises considered, King request this Court appoint a receiver over PNC authorizing the receiver to exercise all powers over the Grow Facility authorized by 12 O.S. § 1554. Seventeenth Cause of Action Petition for Appointment of Receiver Over the Partnership 93. The allegations set forth in paragraphs 1 through 92 of this Petition are incorporated as if repeated in this paragraph. 94. In the alternative, pursuant to 12 O.S. § 1551, King requests this Court appoint a receiver over the Partnership, authorizing the receiver to exercise all powers over the Partnership authorized by 12 O.S. § 1554. In support of this petition, King asserts: A. King holds an interest in the Partnership. B. King's rights to or interests in the Partnership are probable. C. King's rights to or interests in the Partnership are in danger of being lost, removed, or materially injured. 95. On premises considered, King request this Court appoint a receiver over the Partnership authorizing the receiver to exercise all powers over the Grow Facility authorized by 12 O.S. § 1554. IV. PRAYER FOR RELIEF WHEREFORE, on premises considered, Plaintiffs pray that this Court grant them judgment in an amount in excess of $10,000.00, together with punitive damages in an amount in excess of $10,000.00, an accounting of PNC and the Partnership, prejudgment delivery of the Equipment, a restraining order related to the Equipment, judicial dissolution of the Partnership and Hydranetix, the appointment of receivers over PNC and the Partnership, along with Plaintiffs' attorney fees, pre-judgment and post judgment interest, and any such other relief the Court may deem just and proper. Respectfully submitted, [Signature] Brian Ted Jones, OBA No. 22611 Max Federman, OBA No. 36383 Brian Ted Jones, PC 528 NW 12th Street Oklahoma City, OK 73103 Phone: 405-843-9909 Fax: 405-842-2913 Email: [email protected] Counsel for Plaintiffs
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