STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS CIVIL ACTION DOCKET NOK B17 PERRY WILLIAMS Plaintiff v. MAJELLA DEVELOPMENTS SEVEN, LLC And MAJELLA GLOBAL TECHNOLOGY DEVELOPMENTS LLC COMPLAINT And MAJELLA REALTY DEVELOPMENT, LLC And MAJELLA GLOBAL TECHNOLOGIES (AMERICAS) LLC Defendants NOW COMES the plaintiff Perry Williams, by and through his undersigned counsel, Frank K. N. Chowdry of F.K.N. Chowdry Chartered, LLC, and COMPLAINS against the Defendants as follows: PARTIES 1 The Plaintiff is a resident of the Town of Rangeley, County of Franklin and State of Maine.2. The Defendant, Majella Developments Seven, LLC is a Maine Corporation with a principal place of business in Portland, Maine. 3. The Defendant, Majella Global Technologies (Americas) LLC is a Maine Corporation with a principal place of business in Portland, Maine. 4. The Defendant, Majella Global Technology Developments LLC is a Maine Corporation with a principal place of business in Portland, Maine. 5. The Defendant, Majella Realty Development, LLC is a Maine Corporation with a principal place of business in Portland, Maine. FACTS AND ALLEGATIONS 6. Onor around January 1, 2017, the Defendant, Majella Developments Seven, LLC, entered into a consulting agreement with the Plaintiff. 7. The terms of the consulting agreement included a $5,000 fee per month. 8. Defendant Majella Developments Seven, LLC, made timely payments until February 17, 2017. 9. Defendant Majella Developments Seven, LLC, failed to pay consulting fees from February 17, 2017 until July 8, 2017. 10. The Defendant Majella Developments Seven, LLC has breached the consulting agreement by failing to pay for services performed by Plaintiff. 11. The total amount of unpaid consulting fees amounts to $21,250.00. 12. On July 8, 2017, Defendant Majella Developments Seven, LLC entered into an employment agreement with Plaintiff. 13. The Defendant Majella Developments Seven, LLC agreed to pay the Plaintiff a $110,000 annual salary including benefits.14, The Defendant Majella Developments Seven, LLC began paying a weekly paycheck in the amount of $2,115.39 on July 14, 2017. 15. Payments continued until October 27, 2017. 16. Defendant Majella Developments Seven, LLC terminated the employment of Plaintiff on November 9, 2017. 17. Defendant Majella Developments Seven, LLC failed to pay Plaintiff for the time period of October 27, 2017 to November 23, 2017 inclusive of two weeks severance pay. 18. The total amount of unpaid wages amounts to $4,230.78. 19. Defendant Majella Developments Seven, LLC failed to pay wages due ina timely fashion. 20. A Demand for wages was made on November 9, 2017 to Majella Developments Seven, LLC and Majella Group, et al. Exhibit A. 21. Majella Developments Seven, LLC, by and through its Chief Executive Officer, Fred LaMontagne, duly authorized and an agent of Majella Developments Seven, LLC, guaranteed payment of the outstanding unpaid consulting fees and wages. 22. Majella Group, doing business in Maine as Majella Developments Seven, LLC, by and through its Chief Executive Officer, Sebastian Monsour, duly authorized and an agent of Majella Group including the following corporate forms, Majella Global Technologies (Americas) LLC, Majella Global Technology Developments LLC, Majella Realty Development, LLC guaranteed payment of the outstanding unpaid consulting fees and wages.23. The Defendants, Majella Group, et al, failed to pay wages owed as of the date of this complaint. COUNT I (Breach of Contract) 24. The Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 23 above as if set out fully herein. 25. Onor about January 1, 2017, the Defendant Majella Developments Seven, LLC offered to the Plaintiff a contract to perform consultation services. 26. The Plaintiff accepted the terms of that contract. 27. The Plaintiff has fully performed all duties as required by said contract. 28. — Despite repeated demand, the Defendants have failed to pay the monies owed to the Plaintiff as a result of that contract, 29. The Defendants’ failure to pay monies owed as a result of the contract and for services rendered constitutes a breach of said contract. WHEREFORE, the Plaintiff respectfully requests this Honorable Court enter a judgment against the Defendants for damages plus costs and fees; and for such other further relief as this Court deems just and appropriate. COUNT IL (Unfair Employment Practices) 30. The Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 29 above as if set out fully herein.31. The Plaintiff and Defendant Majella Developments Seven, LLC entered in an employment agreement whereby the Plaintiff was to provide services from the period of July 8, 2017 onward. 32. The Plaintiff's position was eliminated and he was laid off on November 9, 2017. 33. The Plaintiff received last payments on that employment agreement on October 27, 2017. 34. By letter dated November 9, 2017, the Plaintiff demanded that all remaining amounts owed under the employment be paid immediately. 35. Despite that demand, the Defendants have failed to pay monies owed to the Plaintiff. 36. This failure to timely pay monies owed at the cessation of Plaintiff's employment violates Title 26 M.R.S.A. § 626. WHEREFORE, the Plaintiff respectfully requests this Honorable Court enter a judgment against the Defendants in an amount twice the amount of the wages owed under the contract as liquidated damages; plus costs and fees; and for such other further relief as this Court deems just and appropriate. COUNT LI Unjust Enrichment/Quantum Meruit 37. The Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 36 above as if set out fully herein. 38. This Count is brought in the alternative to Counts I and II.39. The Plaintiff provided services for the Defendants. 40. The Defendants agreed to pay for those services. 41. The Defendants have failed to pay for those services, despite repeated demand. 42. Asa result of not paying for services rendered, the Defendants has been unjustly enriched. 43. It would be unfair for the Defendants to retain said benefit without paying for its reasonable value. WHEREFORE, the Plaintiff respectfully requests this Honorable Court enter a judgment against the Defendants for damages plus costs and fees; and for such other further relief as this Court deems just and appropriate. DATED at Portland, Maine this 29" day of January, 2018. CN. Chowdry ine Bar No. 3708 ‘Attomey for Perry Williams F. K.N. CHOWDRY CHARTERED, LLC 120 Exchange St, Fourth Floor Portland, Maine 04101 (207) 805-1041EXHIBIT A.“Tota Nak Dfect Bdpocs) lg i rere uti 32 PUTOTHES PO BOX 1317 agtesiggo.23"t | 3B onDeRoF RANGELEY ME 04970 are Bis, r VOID THIS IS NOT A CHECK .. + DOLLARS hy i : **NON-NEGOTIABLE** L AaTRORTD aS ~ 1 “PERSONAL: AND CHECK IWFORMATION: “Faoaowae ery Wome Po gon 337 Satay Rangeley, ME 04970 Total Hours Soe'See# wxss-u0% Employee ID: 7 Shea tartngs ‘otal Hs Worked Home Department: 109 Stat Phone Alowaneo Pay Peciod: OTO8/17 to 071411 Rome 4 OWNER PAYMENTS {Ghock Date: 01720117 Check: 50004 WHTRROLDINGS DESCRIPTION LING STATOS WET PAY ALLOCATIONS Social Secuty escRPnioN THIS PERIOD S) Medicare (heck Amount 20 Fedincime Tex $2 hig 8800 23 Me locome Tex 82 NET PAY yaa023 TOTAL Que Ero we® “Payroll by Bayona, ino. (0069 1107-6108 Meola Deer | | \ \ events SevonLLC 978 Sacco Moutsin Re + Rangsey ME O4570=(207) 648832 FOLDAND REMOVE BP EARNINGS no DESCIHP TON —-HRIUNT—— RA TETHISPERIOD 9PYFD HOURS AOI 215s 2118.30 Paced 1500 1500 IDs) sas 2087 4onas sar00 we oa 140.23DEMAND FOR WAGES Effective immediately, I Perry D. Williams of P.0. Box 1317 Rangeley, Maine do hereby demand payment of past due earned wages from Majella Developments Seven, LIC. Consulti Past due g fees total $21,250. ‘gross wages through 11/10/17 total $8,461.54. Total al $29,711.54 Dated, N Seen an Fred Lal vember 9, 2017. Agreed, jontagne CEO Western Region Majella Group Majella 32 Tho! evelopments Seven, LLC jas Street Portland, Maine 04102DEMAND FOR WAGES Bifive smmediately, I Perry D. Williams of P.0. Box 1317 Rangeley, Maine do hereby demand payment of past due earned wages from Majella Developments Sevan, LLC. Consulting fees total $21,250. Pastidue gross wages through 11/10/17 total $8,461.54. Total due: $29,711.54 Dated, November 9, 2017. Majella Grou DBA Majella Developments Seven, LLC 32 Thomas Street Portland, Maine 04102SUMMARY SHEET This summary sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by the Maine Rules of Court or by aw. This form is required for the use of the Clerk of Court forthe purpose of initiating or updating the civil docket, (SEE INSTRUCTIONS ON REVERSE) 1. County of Fiting or District Court Jurisdiction: Maine Superior Court, Cumberland County TL CAUSE OF ACTION. (Cite the primary civil statutes under which you are filing, rany.) Prose plaintiffs: Ifunsure, leave blank. 26MRSA§ 626, Ti, NATURE OF FILING Initial Complaint CD Third-pary Complaint 1) Cross-Claim or Counterclaim G1 fReinstated or Reopened, give original Docket Number (fling a second or subsequent Money Judgment Disclosure, By docket numberof first disclosure) IV. O] TITLE TOREAL ESTATE IS INVOLVED MOST DEFINITIVE NATURE OF ACTION (Place an X in one box only) ___Prosse plaintiffs: If unsure, leave blank. Personal Injury Tort G1 Property Negligence Cy Auto Negligence Medical Malpractice 1 Product Liability OO AssaulvBattery © Domestic Tons 1 Otter Negligence Other Personal Injury Tort — Non-Personal Injury Tort OD LibevDefamation 1 Auto Negligence 1) Otter Negligence 1 Other Non-Personal Injury Tort ‘GENERAL CIVIL (CY) Contract Contract Declaratory/Equitable Relief Cy Genera injunctive Reliet Declaratory Judgment CF Other Equitable Reliet Constitutional/Civil Rights i Consiutional’Civil Rights Statutory Actions 1 Unfair Trade practices © Freedom of Access C1 Other Statutory Actions Miscellaneous Civil 1 Drug Forfeitures 1 Other Forfeitures/Property Libels GF Land Use Enforcement (80K) © Administrative Warrant DD HV Testing Arbitration Awards 1 Appointment of Receiver Shareholders’ Derivative Actions 1 Foreign Deposition © Pre-action Discovery 1 Common Law Habeas Corpus 1 Prisoner Transfers 1D Foreign iudgments LD Minor Settlements O Other civil {iD PROTECTIVE CUSTODY (PO) "SPECIAL ACTIONS (S54 Money Judgments 1 Noo-DHs Protective Custody ‘Money Judgment Request Disclosure REALESTATE (RE) Title Actions Foreclosure ‘Mise. Real Estate 1 Quiet Title 1 Foreclosure -(ADR exempt) Equitable Remedies Dy Nuisance 7 Eminent Domain Gy Foreciosure (Diversion eligible) [] Mechanics Liens Fy Abandoned Roads Gy Easements 1 Foreclosure - Other D Panttion Trespass Bi Boundaries 1D Adverse Possession i other Real Estate ‘APPEALS (AP) (To be fil Court) ADR Exempt Governmental Body (808) Ci Administrative Agency (800) 1 other Appeats VL MA .Civ.P. 168 Alternative Dispute Resolution (ADR) C1 Loemify that pursuant to M.Civ.P. 16B(b), this case is exempt from a required ADR process because: Cy Ie falls within an exemption listed above (.e, an appeal or an action for non-payment of a note ina secured transaction). CG The plaintiff or defendant is incarcerated in a local, state or federal facility. C The parties have participated in a statutory prelitigation screening process with 1B The parties have patipte informal ADR process with on. Di this isa Persona exemption from ADR. (Gate). ny action in which the plaintf?’s likely damages will not exceed $30,000, andthe plaintiff requests an ‘Goan of neutral‘VEL (a) PLAINTIFFS (Name & Address including county) or C Third-Party, (] Counterclaim or Cross-Claim Plaintiffs Di The plainttts a prisoner in a local, state or federal facility Peny Williams 59 Spring Valley Road, Raymond, Maine 04071 (b) Attomeys (Name, Bar number, Firm name, Address, Telephone Number) fall counsel listed do NOT represent al pi (Uf Pro se plaintiff, leave blank) specify who the listed attorney(s) represent. Frank K. N. Chowdry, Esq. Bar No. 3706 F.K.N. Chowdry Chartered, LLC 120 Exchange Street, 4* Floor Portland, Maine 04101 (207) 805-1041 ‘VID. (3) DEFENDANTS (Name & Address including county) andor [] Third-Party, C] Counterclaim or — (]_Cross-Claim Defendants D7 The defendant isa prisoner in a local, state or federal facility. ‘Majella Developments Seven, LLC 32 Thomas Street, Portland, ME Majella Global Technology Developments, LLC 32 Thomas Street, Portland, ME ‘Majella Realty Development, LLC 32 Thomas Street, Portland, ME ‘Majella Global Technologies (Americas) LLC 32 Thomas Street, Portland, ME (®) Attomeys (Name, Bar number, Firm name, Address, Telephone Number) _Ifall counsel listed do NOT represent all defendants, (fknown) specify who the listed attorney(s) represent, Unknown IX, RELATED CASE(S) IF ANY. Judge/Tustice Docket Number Date: January 29, 2018, CV-001, Rev. 08°09,