1. CAUSE NO. 2013-68459
STEVEN COE WILSON, individually § IN CIVIL DISTRICT COURT
and derivatively on behalf of CTLI, LLC, §
PLAINTIFFS §
§
VS. § 151st JUDICIAL DISTRICT
§
JEREMY ALCEDE and §
SARAH ALCEDE §
DEFENDANT. § HARRIS COUNTY, TEXAS
PLAINTIFFS’ SUPPLEMENTAL REQUEST FOR TEMPORARY INJUNCTION AND
MOTION FOR APPOINTMENT OF RECEIVER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Plaintiffs, STEVEN COE WILSON, individually and derivatively on
behalf of CTLI, LLC, d/b/a Tactical Firearms (herein “Movants”) and pray for an order granting
Plaintiffs’ Motion for Appointment of Receiver (the “Motion”) to take charge and possession of
the business known as Tactical Firearms, located at 1200 S. Mason Rd., Katy, Texas 77450 and
for good cause would show unto the Court the following:
I. INTRODUCTION
Plaintiff Steven Coe Wilson ("Wilson") and Defendants Sarah Alcede and Jeremy Alcede
are partners and managing members of CTLI, LLC d/b/a Tactical Firearms ("Tactical"). Attached
to this Motion as Exhibit “1” is a true and correct copy CTLI, LLC d/b/a Tactical Firearm's LLC
Agreement.
The litigants formed Tactical during the end of 2011. Tactical operates an indoor gun
range, an ammunition store, and other products and services associated with firearms. Tactical is
located at 1200 S. Mason Rd., Katy, Teas 77450. Wilson contributed over $3 million dollars in
Filed 13 November 25 A11:11
Chris Daniel - District Clerk
Harris County
ED101J017833983
By: Wanda Chambers
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purchasing the real estate and improvements where Tactical is located today. On the other hand,
the Defendants contributed "sweat equity."
II. PROPERTY AND FUNDS OF TACTICAL FIREARMS ARE IN IMMEDIATE
DANGER OF BEING LOST, REMOVED OR MATERIALLY INJURED
Wilson recently discovered that Defendants have been pocketing funds intended for
Tactical relating to the recycling of the lead and brass shells that are left behind from customers
discharging their firearms in the gun range. Specifically, Freedom Munitions would periodically
come to Tactical to collect all of the lead and brass casings. Freedom Munitions would pay for
the lead and brass casings based on the amount collected at Tactical. Freedom Munitions pays on
average $8,000.00 to $12,000.00 per month for this brass. Instead of making the checks payable
to tactical, Defendants request Freedom Munitions to either pay the Defendants individually in
cash and/or issue checks to their names individually. Defendants pocketed this money rather than
depositing the funds into Tactical's business account(s). Plaintiff recently confirmed Defendants'
tortious conduct through a conversation through a representative of Freedom Munitions.
Consequently, Defendants are stealing from Tactical. Defendants are diverting and hiding
revenue that artificially lowers profits thereby causing Tactical to underreport revenue and incur
potential civil and criminal liability with the Internal Revenue Service. In effect, Defendants are
under reporting Tactical's revenue to the company's detriment.
III. CO-DEFENDANT JEREMY ALCEDE’S ACTIONS ARE PUTTING TACTICAL
FIREARMS IN IMMEDIATE DANGER OF INSOLVENCY
On November 12, 2013, the Honorable Judge Brent Gamble signed a temporary restraining
order ("TRO") against the Defendants enjoining them from spending partnership funds on
themselves and from destroying evidence in this case. (Ex. 2).
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After the TRO was signed, it was discovered that Defendant Jeremy Alcede has also
wrongfully (and potentially criminally) diverted at least $100,000.00 in partnership revenue to his
own personal accounts. Specifically, Defendant Jeremy Alcede stole the cash and checks paid to
the partnership for recycling its brass casings and lead from the gun range. Likewise, Defendant
Jeremy Alcede has also used partnership funds to pay for a friend's surgery. (Ex. 3). It is painfully
evident that Defendant Jeremy Alcede cannot help himself from raiding partnership venue.
Consequently, Plaintiff would respectfully request this Court to appoint a receiver to
operate the partnership business during the litigation of this matter. Section 64.01(a)(3) and (6) of
the Tex. Civ. Prac. Rem. Code specifically authorizes this Court to appoint a receiver "in an action
between partners" or "in any other case in which a receiver may be appointed under the rules of
equity." In fact, a court may appoint a receiver on its own motion and without application of a
party where the facts justify the appointment to preserve and protect property in litigation. Cross
v. Cross, 738 S.W.2d 86, 87 (Tex.App.-Corpus Christi 1987, writ dism'd w.o.j.).
In this case, the litigants are partners in CTLI, LLC, d/b/a Tactical Firearms whereby the
Defendants have put their own personal self-interest above the partnership business to its
detriment. Defendant Jeremy Alcede has embezzled at least $100,000.00 in revenue that was
meant for Tactical Firearms, transferred partnership funds from its operating account directly into
his personal savings account, and wasted partnership funds on personal items such as jewelry for
his girlfriend, Prada shoes, surgery for a friend, Caribbean vacations with his girlfriend, and a
litany of other financial shenanigans.
Along with embezzlement and since the TRO was signed, Jeremy Alcede has terminated
or cause at least four employees to quit because he believed that they were speaking with the
Plaintiff about his potentially illegal conduct. Jeremy Alcede's greed has overshadowed what
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business acumen he has regarding the successful operation of the partnership business. Defendant
Jeremy Alcede currently operates the business to hide his fraudulent conduct and to retaliate
against the employees that he suspects may have helped expose his theft. Consequently, a receiver
is necessary to prevent Jeremy Alcede from running the business into the ground.
Defendants' actions, as set forth above, could put Tactical in jeopardy with applicable laws,
regulations, and statutes and put Tactical Firearms in imminent danger of insolvency as it would
make it impracticable to carry forth with Tactical's business.
An appointment of a receiver is necessary for the protection of Tactical's assets and
Plaintiffs’ interests in the business until the dissolution of the corporation or a “buy-out” of one
party’s shares is effectuated. Thus, Plaintiff respectfully requests this Court to appoint a receiver,
award Plaintiff reasonable and necessary attorney fees associated with same, and other just and
equitable relief the Court deems proper.
IV. JURISDICTION
This Court has jurisdiction because Movants have requested specific relief under TEX. CIV.
PRAC. & REM. CODE ANN. § 64.001(a)(3), § 64.001(a)(5), and § 64.001(a)(6). Specifically,
Movants request the appointment of a receiver in an action between partners or others jointly
owning or interested in any property or fund. Movants have a probable interest in or right to the
property and funds, and the property and funds are in immediate danger of being lost, removed, or
materially injured. Furthermore, Movants are entitled to their requested relief because of the
immediate danger of insolvency of the subject business made the basis of this Motion.
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V. PRAYER
For these reasons set forth above, unless a receiver is appointed to take charge and
possession of the business known as Tactical Firearms, located at 1200 S. Mason Rd., Katy, Texas
77450, Tactical is in imminent danger of insolvency and the property or funds of Tactical will be
in danger of being lost, stolen, removed, or materially injured. Therefore, Movants asks that the
Court:
1. Issue and Order Granting Plaintiffs’ Motion for Appointment of Receiver to take
charge and possession of the business known as Tactical Firearms, located at 1200
S. Mason Rd., Katy, Texas 77450.
2. Such further relief at law or in equity, to which Movants may by this pleading or
proper amendment, thereto, show themselves justly entitled.
Respectfully submitted,
MICHAEL P. FLEMING &
ASSOCIATES, P.C.
By:_____________________________
MICHAEL P. FLEMING
State Bar No. 07130600
DAVID TANG
State Bar No. 24014483
RICHARD NGUYEN
State Bar No. 24085981
440 Louisiana, Suite 1920
Houston, Texas 77002
Telephone: (713) 221-6800
Telecopier: (713) 221-6806
COUNSEL FOR PLAINTIFFS
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CERTIFICATE OF SERVICE
I hereby certify that the above and foregoing instrument has been duly served upon the
following counsel of record in accordance with Texas Rule of Civil Procedure 21 and 21a on
November 25, 2013.
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DAVID TANG
UnofficialCopyOffice
ofChrisDanielDistrictClerk