1
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
CHARLESTON DIVISION
NATALIE ARBOGAST,
Plaintiff, Civil Action No. No. 2:23-cv-00427
Senior Judge John T. Copenhaver, Jr.
v.
SKY ZONE, LLC;
CIRCUSTRIX HOLDINGS, LLC;
CIRCUSTRIX, LLC; and
JOHN DOE MANUFACTURERS 1–10,
Defendants.
CORPORATE DISCLOSURE STATEMENT
Pursuant to Federal Rule of Civil Procedure 7.1, Defendants Sky Zone, LLC, CircusTrix
Holdings, LLC, and CircusTrix, LLC hereby provide the following corporate disclosure statement:
1. Defendant Sky Zone, LLC is a private limited liability company, and its sole
member is CircusTrix Holdings, LLC.
2. Defendant CircusTrix, LLC is a private limited liability company, and its sole
member is also CircusTrix Holdings, LLC.
3. Defendant CircusTrix Holdings, LLC is a private limited liability company, and its
sole member is Trampoline Acquisition Holdings, LLC.
4. Trampoline Acquisition Holdings, LLC is a private limited liability company, and
its sole member is Trampoline Acquisition Parent Holdings, LLC.
5. Trampoline Acquisition Parent Holdings, LLC is a private limited liability
company whose members and sub-members are as follows:
Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 1 of 5 PageID #: 112
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1) Trampoline Acquisition Corp, a Delaware corporation with its
principal place of business in New York;
2) Tramp Dudez, LLC, a limited liability company whose members
are:
a. Peery Partners, a partnership whose partners are Jason Peery
and Ben Crocket, both of whom are citizens of California;
b. Pejman Nowzad, a citizen of California;
c. Dave Peery, a citizen of Washington; and
d. Richard Cook, a citizen of Washington;
3) Entrepology, LLC, a limited liability company whose members
are:
a. No Empty Chairs Trust whose trustee is Case Lawrence, a
citizen of Utah, and
b. Small Means Trust, whose trustee is Case Lawrence, a citizen
of Utah;
4) Entrepology 2, LLC, a limited liability company whose sole
member is Case Lawrence, a citizen of Utah;
5) Mike Carpenter, a citizen of North Carolina;
6) Vicky Carpenter, a citizen of North Carolina;
7) Edge Creations, Inc., a Utah corporation with its principal place of
business in Utah;
8) Richard Cook, a citizen of Washington;
9) The Launch Pad, Inc., a South Dakota corporation with its
principal place of business in South Dakota;
10) Mark McOmber, a citizen of California;
11) Expherience, LLC, a limited liability company whose sole member
is Erik Haugen, a citizen of Utah;
12) The McLain Revocable Trust, whose trustee is Scott McLain, a
citizen of Arkansas;
13) Eunjuhayne Charitable Remainder Unitrust, whose trustees are
Steven Larkin, a citizen of Virginia, and Henry Larkin, a citizen of
Virginia;
14) Stephanie Marcus, a citizen of Virginia;
15) Rocky Point, LLC, a limited liability company whose members
are:
a. Allan Asay, a citizen of Utah; and
b. Dana Asay, a citizen of Utah;
16) Jason Asay, a citizen of Utah;
17) Investors Freedom, LLC, a limited liability company whose sole
member is Floyd Hansen, a citizen of Utah;
18) Doug Lee, a citizen of Utah;
19) Logan Lawrence, a citizen of California;
20) Edward Hernandez, a citizen of Washington;
21) Delinda Hernandez, a citizen of North Carolina;
22) Chad Posthumus, a citizen of North Carolina;
23) Shanda Posthumus, a citizen of North Carolina;
Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 2 of 5 PageID #: 113
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24) Mile High Aces, LLC, a limited liability company whose members
are:
a. Allan Asay, a citizen of Utah;
b. Dana Asay, a citizen of Utah;
c. Camren Asay, a citizen of Utah; and
d. Amber Cottrell, a citizen of Utah;
25) David Mason, a citizen of California;
26) Tymber Lee, a citizen of Kansas;
27) Mclane Lawrence, a citizen of Arizona;
28) Jeremy Ware, a citizen of California;
29) Andrew Wilson, a citizen of Texas;
30) Susan Wilson, a citizen of Texas;
31) Marc Collopy, a citizen of California;
32) Lorraine Wilson, a citizen of California;
33) Michael Revak, a citizen of California;
34) Craig Smith, a citizen of California;
35) Brett Mortenson, a citizen of California;
36) Ken Easley, a citizen of California;
37) HJ Conyers, a citizen of California;
38) Mariana Easley, a citizen of California;
39) James “Scott” Carnathan, a citizen of California;
40) MCDRE, LLC; a limited liability company whose sole member is
Pete McDonough, a citizen of California;
41) Jeff Platt, a citizen of California;
42) David Matthew Lambeth, a citizen of California;
43) Glenn Lord, a citizen of California;
44) JUMP101, LLC, a limited liability company whose members are:
a. Mike Clark, a citizen of Idaho;
b. Spencer Nead, a citizen of Idaho;
c. Blue World Marketing, Inc., a Utah corporation with its
principal place of business in Utah;
d. Sunnyside Capital Group LLC, a limited liability company
whose members are:
i. Todd Rawle, a Utah citizen; and
ii. Tracy Rawle, a Utah citizen;
e. CS Equity Partners, LLC, a limited liability company whose
member is Sam Noel, a Utah citizen;
45) Clay Williams, a Utah citizen;
46) J2J Investments, LLC, a limited liability company whose sole
member Jennie Johnson, an Idaho citizen;
47) Reagan Hansen, a Washington citizen; and
48) Shereka Kelley, a Utah citizen.
Pursuant to Rule 7.1(b)(2), the Defendants will promptly supplement this disclosure if
any of the above information changes.
Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 3 of 5 PageID #: 114
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Dated: June 12, 2023
SKY ZONE, LLC;
CIRCUSTRIX HOLDINGS, LLC; and
CIRCUSTRIX, LLC
By Counsel:
/s/ James E. Simon
James E. Simon (WV State Bar # 13265)
Victoria L. Creta (WV State Bar # 13869)
SPILMAN THOMAS & BATTLE, PLLC
300 Kanawha Blvd., East (25301)
P.O. Box 273
Charleston, WV 25321
(304) 340-3800
(304) 240-3801 fax
JSimon@spilmanlaw.com
VCreta@spilmanlaw.com
and
110 Oakwood Drive, Suite 500
Winston-Salem, NC 27103
(336) 725-4710
(336) 725-4476 fax
Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 4 of 5 PageID #: 115
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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
CHARLESTON DIVISION
NATALIE ARBOGAST,
Plaintiff, Civil Action No. No. 2:23-cv-00427
Senior Judge John T. Copenhaver, Jr.
v.
SKY ZONE, LLC;
CIRCUSTRIX HOLDINGS, LLC;
CIRCUSTRIX, LLC; and
JOHN DOE MANUFACTURERS 1–10,
Defendants.
CERTIFICATE OF SERVICE
I, James E. Simon, hereby certify that on the 12th day of June, 2023, the foregoing
CORPORATE DISCLOSURE STATEMENT was served upon the following counsel of record
through the Court’s CM/ECF system:
Scott S. Segal, Esq.
Jason P. Foster, Esq.
C. Edward Amos, II, Esq.
THE SEGAL LAW FIRM
A Legal Corporation
810 Kanawha Boulevard, East
Charleston, WV 25301
Counsel for Plaintiff
/s/ James E. Simon
James E. Simon (WV State Bar # 13265)
Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 5 of 5 PageID #: 116

Records for Sunnyside and Rawles Brothers.pdf

  • 1.
    1 IN THE UNITEDSTATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA CHARLESTON DIVISION NATALIE ARBOGAST, Plaintiff, Civil Action No. No. 2:23-cv-00427 Senior Judge John T. Copenhaver, Jr. v. SKY ZONE, LLC; CIRCUSTRIX HOLDINGS, LLC; CIRCUSTRIX, LLC; and JOHN DOE MANUFACTURERS 1–10, Defendants. CORPORATE DISCLOSURE STATEMENT Pursuant to Federal Rule of Civil Procedure 7.1, Defendants Sky Zone, LLC, CircusTrix Holdings, LLC, and CircusTrix, LLC hereby provide the following corporate disclosure statement: 1. Defendant Sky Zone, LLC is a private limited liability company, and its sole member is CircusTrix Holdings, LLC. 2. Defendant CircusTrix, LLC is a private limited liability company, and its sole member is also CircusTrix Holdings, LLC. 3. Defendant CircusTrix Holdings, LLC is a private limited liability company, and its sole member is Trampoline Acquisition Holdings, LLC. 4. Trampoline Acquisition Holdings, LLC is a private limited liability company, and its sole member is Trampoline Acquisition Parent Holdings, LLC. 5. Trampoline Acquisition Parent Holdings, LLC is a private limited liability company whose members and sub-members are as follows: Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 1 of 5 PageID #: 112
  • 2.
    2 1) Trampoline AcquisitionCorp, a Delaware corporation with its principal place of business in New York; 2) Tramp Dudez, LLC, a limited liability company whose members are: a. Peery Partners, a partnership whose partners are Jason Peery and Ben Crocket, both of whom are citizens of California; b. Pejman Nowzad, a citizen of California; c. Dave Peery, a citizen of Washington; and d. Richard Cook, a citizen of Washington; 3) Entrepology, LLC, a limited liability company whose members are: a. No Empty Chairs Trust whose trustee is Case Lawrence, a citizen of Utah, and b. Small Means Trust, whose trustee is Case Lawrence, a citizen of Utah; 4) Entrepology 2, LLC, a limited liability company whose sole member is Case Lawrence, a citizen of Utah; 5) Mike Carpenter, a citizen of North Carolina; 6) Vicky Carpenter, a citizen of North Carolina; 7) Edge Creations, Inc., a Utah corporation with its principal place of business in Utah; 8) Richard Cook, a citizen of Washington; 9) The Launch Pad, Inc., a South Dakota corporation with its principal place of business in South Dakota; 10) Mark McOmber, a citizen of California; 11) Expherience, LLC, a limited liability company whose sole member is Erik Haugen, a citizen of Utah; 12) The McLain Revocable Trust, whose trustee is Scott McLain, a citizen of Arkansas; 13) Eunjuhayne Charitable Remainder Unitrust, whose trustees are Steven Larkin, a citizen of Virginia, and Henry Larkin, a citizen of Virginia; 14) Stephanie Marcus, a citizen of Virginia; 15) Rocky Point, LLC, a limited liability company whose members are: a. Allan Asay, a citizen of Utah; and b. Dana Asay, a citizen of Utah; 16) Jason Asay, a citizen of Utah; 17) Investors Freedom, LLC, a limited liability company whose sole member is Floyd Hansen, a citizen of Utah; 18) Doug Lee, a citizen of Utah; 19) Logan Lawrence, a citizen of California; 20) Edward Hernandez, a citizen of Washington; 21) Delinda Hernandez, a citizen of North Carolina; 22) Chad Posthumus, a citizen of North Carolina; 23) Shanda Posthumus, a citizen of North Carolina; Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 2 of 5 PageID #: 113
  • 3.
    3 24) Mile HighAces, LLC, a limited liability company whose members are: a. Allan Asay, a citizen of Utah; b. Dana Asay, a citizen of Utah; c. Camren Asay, a citizen of Utah; and d. Amber Cottrell, a citizen of Utah; 25) David Mason, a citizen of California; 26) Tymber Lee, a citizen of Kansas; 27) Mclane Lawrence, a citizen of Arizona; 28) Jeremy Ware, a citizen of California; 29) Andrew Wilson, a citizen of Texas; 30) Susan Wilson, a citizen of Texas; 31) Marc Collopy, a citizen of California; 32) Lorraine Wilson, a citizen of California; 33) Michael Revak, a citizen of California; 34) Craig Smith, a citizen of California; 35) Brett Mortenson, a citizen of California; 36) Ken Easley, a citizen of California; 37) HJ Conyers, a citizen of California; 38) Mariana Easley, a citizen of California; 39) James “Scott” Carnathan, a citizen of California; 40) MCDRE, LLC; a limited liability company whose sole member is Pete McDonough, a citizen of California; 41) Jeff Platt, a citizen of California; 42) David Matthew Lambeth, a citizen of California; 43) Glenn Lord, a citizen of California; 44) JUMP101, LLC, a limited liability company whose members are: a. Mike Clark, a citizen of Idaho; b. Spencer Nead, a citizen of Idaho; c. Blue World Marketing, Inc., a Utah corporation with its principal place of business in Utah; d. Sunnyside Capital Group LLC, a limited liability company whose members are: i. Todd Rawle, a Utah citizen; and ii. Tracy Rawle, a Utah citizen; e. CS Equity Partners, LLC, a limited liability company whose member is Sam Noel, a Utah citizen; 45) Clay Williams, a Utah citizen; 46) J2J Investments, LLC, a limited liability company whose sole member Jennie Johnson, an Idaho citizen; 47) Reagan Hansen, a Washington citizen; and 48) Shereka Kelley, a Utah citizen. Pursuant to Rule 7.1(b)(2), the Defendants will promptly supplement this disclosure if any of the above information changes. Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 3 of 5 PageID #: 114
  • 4.
    4 Dated: June 12,2023 SKY ZONE, LLC; CIRCUSTRIX HOLDINGS, LLC; and CIRCUSTRIX, LLC By Counsel: /s/ James E. Simon James E. Simon (WV State Bar # 13265) Victoria L. Creta (WV State Bar # 13869) SPILMAN THOMAS & BATTLE, PLLC 300 Kanawha Blvd., East (25301) P.O. Box 273 Charleston, WV 25321 (304) 340-3800 (304) 240-3801 fax JSimon@spilmanlaw.com VCreta@spilmanlaw.com and 110 Oakwood Drive, Suite 500 Winston-Salem, NC 27103 (336) 725-4710 (336) 725-4476 fax Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 4 of 5 PageID #: 115
  • 5.
    5 IN THE UNITEDSTATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA CHARLESTON DIVISION NATALIE ARBOGAST, Plaintiff, Civil Action No. No. 2:23-cv-00427 Senior Judge John T. Copenhaver, Jr. v. SKY ZONE, LLC; CIRCUSTRIX HOLDINGS, LLC; CIRCUSTRIX, LLC; and JOHN DOE MANUFACTURERS 1–10, Defendants. CERTIFICATE OF SERVICE I, James E. Simon, hereby certify that on the 12th day of June, 2023, the foregoing CORPORATE DISCLOSURE STATEMENT was served upon the following counsel of record through the Court’s CM/ECF system: Scott S. Segal, Esq. Jason P. Foster, Esq. C. Edward Amos, II, Esq. THE SEGAL LAW FIRM A Legal Corporation 810 Kanawha Boulevard, East Charleston, WV 25301 Counsel for Plaintiff /s/ James E. Simon James E. Simon (WV State Bar # 13265) Case 2:23-cv-00427 Document 3 Filed 06/12/23 Page 5 of 5 PageID #: 116