CAUSE NO.____________________ SEEDX, INC. ,and Jacqueline BASULTO § IN THE DIST. COURT/CCL and Justin RASHIDI , as managing partners § in their of fi cial capacity; § § Plaintiffs; § v. § __________COURT § KANYE 2020, the Presidential Campaign § as a public good non-pro fi t; and LINCOLN § STRATEGY GROUP, LLC , and § FORTIFIED CONSULTING , and § Nathan SPROUL , in his of fi cial and § personal capacity. § § Defendants § TRAVIS COUNTY, TEXAS P LAINTIFFS ’ O RIGINAL P ETITION C OME N OW , Plaintiffs SEEDX INC. (hereinafter “SeedX”), a Texas domestic corporation, by and through its agents Jacqueline BASULTO (hereinafter “Ms. Basulto”) and Justin RASHIDI (hereinafter “Mr. Rashidi”), and fi le this Plaintiffs’ Original Petition by and through their Counsel of Record, and would hereby humbly show this Court as follows: Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 1 56 I. I NTRODUCTION Now, the Plaintiffs come complaining of the Defendants and their breach, and various torts, and pray for relief from this Court. With this, Plaintiffs’ Original Petition, Plaintiffs allege breach of contract, promissory estoppel, quantum meruit, negligent misrepresentation, fraud in the inducement, fraud, conversion, unjust enrichment and disgorgement, civil conspiracy, and application for accounting. II. D ISCOVERY C ONTROL P LAN 1. Plaintiffs intend to conduct discovery under level 2 of the Texas Rules of Civil Procedure Rule 190.3. 2. Plaintiffs af fi rmatively plead that its suit is not governed by the expedited actions process in the Texas Rules of Civil Procedure under Rule 169 because Plaintiffs seek non-monetary relief, as well as monetary. III. P ARTIES 3. SeedX Inc. is a Delaware for-pro fi t corporation, with the right to transact 1 business in Texas. Its principal place of business located at 14400 Weldon 2 Lane, Austin, Texas 78728. They may be served by and through their counsel Pls. App. at 000012. 1 Pls. App. at 000021. 2 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 2 56 of record, Guest & Gray, P.C. c/o Elizabeth Alvarez or Scott Gray, 315 S. Bois D’Arc, Forney, Texas 75126. 4. Jacqueline Basulto is an of fi cer of SeedX Inc. and is its representative in this matter. She is not participating in her individual capacity. She is a Plaintiff in this matter and may be served by and through her counsel of record, Guest & Gray, P.C. c/o Elizabeth Alvarez or Scott Gray, 315 S. Bois D’Arc, Forney, Texas 75126. 5. The Defendant Kanye 2020 is a mutual bene fi t non-pro fi t corporation incorporated in Wyoming. Its incorporator is Andre Bodiford. Its principal 3 4 place of business is located at 3202 Big Horn Ave., Cody, Wyoming, 82414. It 5 may be served with service of process through its registered Agent, Cogency Global Inc., 1920 Thomas Ave., Ste. 610, Cheyenne, Wyoming, 82001. 6 6. Lincoln Strategy Group, LLC (hereinafter “Lincoln”) is an Arizona Corporation, with both its registered of fi ce and its principal place of business at 740 S. Mill Ave, #200, Tempe, Arizona 85281. Lincoln is a consulting fi rm that specializes in campaign management. It may be served with service of process Pls. App. at 000028. 3 Id. 4 Id. 5 Id. 6 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 3 56 through its registered Agent, Nathan Sproul, 740 S. Mill Ave, #200, Tempe, Arizona 85281. 7 7. Forti fi ed Consulting (hereinafter “Forti fi ed”) is a Virginia Corporation, with its registered of fi ce at 4701 Cox Road, Suite 285, Glen Allen, Virginia 23060 and its principal place of business at 740 S. Mill Ave, #200, Tempe, Arizona 85281. Forti fi ed is a consulting group that specializes in independent campaigns. It may be served with service of process through its registered Agent, CT Corporation, 4701 Cox Road, Suite 285, Glen Allen, Virginia 23060. 8 8. Defendant Nathan Sproul (hereinafter “Mr. Sproul”) is an individual who resides in Tempe, Arizona. He conducts business in Mariscopa County, Arizona, in his role as CEO of both Lincoln and Forti fi ed. He may be served with service of process at his work address, 740 S. Mill Ave, #200, Tempe, Arizona 85281. Arizona Corporation Commission, Entity Search, https://ecorp.azcc.gov/BusinessSearch/ 7 BusinessInfo?entityNumber=L14191676 (last accessed May 3, 2021). Virginia State Corporation Commission, Clerk’s Information System, https:// 8 c i s . s c c . v i r g i n i a . g o v / E n t i t y S e a r c h / B u s i n e s s I n f o r m a t i o n ? businessId=11063321&source=FromEntityResult&isSeries=False (last accessed May 3, 2021). Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 4 56 IV. P ETITION J URISDICTION & V ENUE 9. This Court has jurisdiction over this lawsuit and is jurisdictionally competent to render judgment in this matter. 10. This Court likewise has jurisdiction because it has subject-matter jurisdiction over the declaratory relief sought, pursuant to Tex. Civ. Prac. and Rem. Code § 37.003. 11. This Court has speci fi c personal jurisdiction over the Defendants for their breach of contract and other related claims under Texas’ long arm statute, and 9 an exercise of that jurisdiction would not violate the due process clause of the Constitution. And since “[t]he Texas long-arm statute extends to the limits of 10 the Constitution,” only the second prong of the test is at issue. 11 12. The Defendants have more than minimum contact with Texas as a forum state, and have purposefully directed their business activities toward Texas, and purposefully availed themselves of conducting their business activities here, including political consulting activities and campaign activities regarding the Tex. Civ. Prac. & Rem. Code Ann. § 17.021. 9 In re Chinese–Manufactured Drywall Prods. Liab. Litig ., 753 F.3d 521, 535 (5th Cir. 2014) (noting that 10 a Court has personal jurisdiction over a Defendant if “(1) the long-arm statute of the forum state confers personal jurisdiction over that defendant; and (2) exercise of such jurisdiction by the forum state is consistent with due process under the United States Constitution.”(quoting Ainsworth v. Moffett Eng’g, Ltd ., 716 F.3d 174, 177 (5th Cir. 2013)). Stroman Realty, Inc. v. Antt , 528 F.3d 382, 385 (5th Cir. 2008). 11 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 5 56 Kanye West 2020 campaign, and Plaintiffs’ causes of action arise from these forum related contacts. 12 13. Venue in Travis County is proper in this cause under § 15.002 of the Texas Civil Practice and Remedies Code as a substantial part of the events giving rise to the claim occurred in Travis County. V. F ACTS A. S EED X B EGAN AS A S MALL B USINESS , AND H AS Q UICKLY B ECOME A T HRIVING PR B RAND 14. SeedX is a marketing and web development company incorporated in the state of Delaware and authorized to do business in Texas. 13 15. Started in 2016 as the brain child of Plaintiff Jacqueline Basulto and her partner, Justin Rashidi, SeedX exploded into the tech and PR world, and has already made a name for itself. 16. SeedX provides marketing and digital consulting services to companies and organizations growing their online presences, ranging from small businesses to nonpro fi ts to campaigns. They pride themselves in providing omni-channel marketing which creates an easy and ef fi cient process for customers. Monkton Ins. Servs., Ltd. v. Ritter , 768 F.3d 429, 433 (5th Cir. 2014). 12 Pls. App. at 000012, Pls. App. at 000021. 13 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 6 56 17. There are three shareholders, Ms. Basulto with 49%, Mr. Rashidi with 49%, and Heidi Riedeman with 2%. SeedX also has a team of 25-30 employees. 18. Ms. Basulto serves as its CEO and the majority of her day to to day activity is focused on business development, fi nding new clients, working on contracts, billing, and more. 19. Meanwhile, cofounder Mr. Rashidi focuses on strategy and operations of the company. 20. Under their leadership, the company has continued to grow and earned over $1,000,000 in revenue in 2020, and Ms. Basulto and Mr. Rashidi have obtained a spot on Forbes 30 Under 30 for their work in marketing and advertising for their fi rm. SeedX’s cutting edge approach has garnered them recognition and 14 awards, including: being named the top women owned digital marketing company in 2021 by Clutch.co , being ranked number 2 in Los Angeles for 15 Pls. App. at 000024 14 Top Women Owned Digital Marketing Agencies, Clutch.co, https://clutch.co/agencies/ 15 digital-marketing/women-owned (last accessed on May 3, 2021). Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 7 56 marketing agencies in 2020 by Improvado , and being ranked number 10 for 16 digital marketing agencies in 2021 by The Manifest. 17 21. Their clients include many prominent blue chip and large national corporations such as the AARP, and Kaiser Permanente. 22. Their innovative solutions and modern cutting-edge approach to marketing and PR constantly attracts large businesses and other new clients. B. M EANWHILE , L INCOLN S TRATEGY G ROUP WAS C REATED BY D EFENDANT N ATHAN S PROUL AS O NE IN A L ONG L INE OF C ONSULTING F IRMS WITH T IES TO THE R EPUBLICAN P ARTY 23. Defendant Nathan Sproul has been a consultant in Republican politics since the early to mid-1990s. He also began his career as an intern for the Republican National Committee. He served as the fi eld director for the Arizona Christian Coalition in 1997, Executive Director for the Arizona Republican Party from 1999-2002 and founder of Sproul & Associates in 2003. However, his wife indicated in 2003 that Mr. Sproul’s main job at that time was “...for a company called Voyager Expanded Learning as Regional President in charge of sales for Hailey Friedman, The Best Marketing Agencies in Los Angeles: Top-53 LA Agencies , Improvado, (Feb. 16 26, 2020), https://improvado.io/blog/best-marketing-agencies-los-angeles (last accessed May 3, 2021). Top 70 Digital Marketing Companies In Austin, The Manifest, https://themanifest.com/ 17 digital-marketing/agencies/austin (last accessed May 3, 2021). Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 8 56 the Western territory.” He also worked for Grassroots Mobilization LLC in 18 2005. He renamed Sproul & Associates to Lincoln Strategy Group in 2008. In 2008, He created Grassroots Outreach LLC which was registered at 80 E. Salado Parkway, Tempe, Arizona which has 27 other companies registered to this address. In 2012, Mr. Sproul created Issue Advocacy Partners and Strategic Allied Consulting which shares an address with Karl Rove’s PAC, American Cross Roads and Holtzman Vogel Jose fi ak Torchinsky PLLC. 19 24. He has been at the helm of a variety of different consulting companies: Sproul & Associates, Strategic Allied Consulting, Lincoln Strategy Group, and Forti fi ed Consulting. 25. Unbeknownst to Plaintiffs, Mr. Sproul has a history of fraud and campaign enforcement issues. He has been investigated in Arizona, Nevada, Florida, and Oregon regarding allegations that Democratic registration forms were Pillsbury Baptist Bible College Alumni Directory (June 23, 2007), https://web.archive.org/ 18 web/20040619141215/http://pillsbury.edu/nav.php?link=direct/dir_pbbc.htm (last accessed April 30, 2021). Brad Friedman, Rove’s American Crossroads Shares Address, Legal Firm with GOP Operative Sproul’s 19 Firm , T RUTH O UT (October 18, 2012), https://truthout.org/articles/roves-american-crossroads- shares-address-legal- fi rm-with-shady-gop-operatives- fi rm/ (last accessed May 3, 2021). Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 9 56 destroyed or discarded, and by the Federal Election Commission. He was 20 21 once a consultant for the Republican National Committee in 2004, but that relationship ended when Mr. Sproul and his fi rm were investigated by the Florida Department of Law Enforcement for election fraud. 22 26. Mr. Sproul founded Lincoln Strategy Group in 2008 and Forti fi ed Consulting. 27. It has since grown into a consulting company with and international presence, but is still heavily involved in consulting for Republican politics. 28. Lincoln has an of fi ce in Arizona, but does work all over the continental United States. It has consulted on several high-pro fi le campaigns and won many awards. 29. In fact, in the 2020 Election, it did work for the Republican Party of Texas 23 and for Chip Roy for Congress. 24 Sara Murray and Scott Glover, Kanye West’s campaign has hired GOP operative with history of 20 controversial work , KTBS (Sept. 22, 2020), https://www.ktbs.com/news/national_politics/kanye- w e s t s - c a m p a i g n - h a s - h i r e d - g o p - o p e r a t i ve - w i t h - h i s t o r y - o f - c o n t rove r s i a l - w o rk / article_25c9c939-8fee-59c2-ae36-0a19796d2350.html (last accessed May 3, 2021). Id. 21 Id. 22 Vendor/Recipient Pro fi le: Lincoln Strategy Group, OpenSecrets: Center for Responsive 23 P o l i t i c s , h t t p s : / / w w w. o p e n s e c r e t s . o r g / c a m p a i g n - e x p e n d i t u r e s / v e n d o r ? vendor=Lincoln+Strategy+Group&year=2014 (last accessed May 3, 2021). Id. 24 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 10 56 30. Among other entities Lincoln has formed a relationship with, is the Preserve America’s Future PAC. 31. The most current statement of organization for this PAC was fi led with the Federal Election Commission on October 15, 2014. 32. The mailing address for the PAC is listed as P.O. Box 26141, Alexandria, Virginia 22313. The head of the PAC is Chris LaCivita. 33. According to the fi nance reports on fi le with the Federal Election Commission, since 2014, both Lincoln and the law fi rm, Holtzman Vogel Jose fi ak Torchinsky PLLC, made small loans to the PAC. Later, the PAC hired Lincoln and Holtzman Vogel Jose fi ak Torchinsky to do consulting and compliance work and subsequently made expenditures to both. C. S EED X H AD A P REVIOUS R ELATIONSHIP WITH D EFENDANTS L INCOLN S TRATEGY G ROUP AND N ATHAN S PROUL 34. Lincoln has worked on a variety of matters which occasioned them to be in need of the services SeedX provides. 35. On June 30, 2020, someone from Lincoln reached out to SeedX via SeedX’s contact form to discuss potential work opportunities. Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 11 56 36. In July 2020, Lincoln and SeedX entered into a Non-Disclosure Agreement that would purport to cover work done for Lincoln 25 37. In August 2020, Lincoln and SeedX made an oral agreement for SeedX to provide consulting services in the marketing and web development areas for three months for Lincoln for work with a company for $34,000. 26 38. This agreement was later put into writing that became effective August 1, 2020 and was signed by SeedX and a Lincoln employee on August 10, 2020 (Mr. Sproul signed on October 27, 2020). This agreement made SeedX a vendor/ service provider to Lincoln. At no time were either Ms. Basulto or Mr. Rashidi employees of Lincoln. 39. Both Ms. Basulto and Mr. Rashidi were added to the Lincoln website. They 27 were added in July/August 2020 and were removed around January 15, 2021. 40. The course of the work was performed over a three month period. During this three month period, SeedX satis fi ed its duties per the agreement, which included: engaging a community for the company that spanned across the world, identifying trends and issues in the industry the company was in, communicating on all relevant channels and media, creating and manageing Pls. App. at 001715. 25 Pls. App. at 001711. 26 Pls. App. at 001377-79. 27 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 12 56 shareable content, developing target advertising campaigns, increasing engagement, etc... Additionally, SeedX provided extra consulting to Lincoln beyond the three month time period, but to date has not compensated for this work. The global contract continued month to month and the last of fi cial date of work was December 15, 2020. A website project was added in writing in December 2020 and fi nalized mid-January 2021. D. K ANYE 2020, L INCOLN S TRATEGY G ROUP , AND F ORTIFIED C ONSULTING 41. On July 4, 2020, via Twitter, hip-hop artist and entrepreneur Kanye West announced he would campaign and run for U.S. President in the November 2020 Election as part of the Kanye West 2020 Presidential Campaign (hereinafter “Campaign”). 42. On July 15, 2020, Mr. West fi led a Statement of Organization with the Federal Election Commission. 28 43. The Campaign listed 3202 Big Horn Ave, Cody, Wyoming 82414, as its address. 29 44. The Statement of Organization lists an Andre Bodiford as its treasurer. Pls. App. at 000033-36. 28 Pls. App. at 000033. 29 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 13 56 45. On July 23, 2020, the Campaign was incorporated as a mutual bene fi t nonpro fi t corporation in Wyoming. 30 46. It listed Cogency Global Inc, a registered agent company, as its registered agent, with an address of 1920 Thomas Ave. Ste. 610, Cheyenne, Wyoming, 82001. 47. The principal of fi ce address and the mailing address for the campaign were both listed as 3202 Big Horn Avenue, Cody, Wyoming 82414. 48. The corporation has no members. 49. The Campaign was placed on the ballot in twelve states. 50. The only listed incorporator is Andre Bodiford. The Articles list a Wyoming phone numbers for Mr. Bodiford, and as his email, info@kanye2020.org. 51. The fi rst consultant the Campaign hired to assist it was Mercury Public Affairs, LLC, a public relations fi rm that it represents it consults for corporations, NGOs, governments, political parties, and politicians. 52. However, Mercury Public Affairs was dismissed from the campaign, ending its involvement. It does not appear anywhere on the campaign’s reports. 31 53. The Campaign searched for an alternate consulting fi rm. Pls. App. at 000032. 30 Pls. App. at 000073-120, Pls. App. at 000131-55, Pls. App. at 000165-67, Pls. App. at 768-85, 31 Pls. App. at 001184-227, Pls. App. at 001229-55, Pls. App. at 001303-14, Pls. App. at 001357-76. Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 14 56 54. The Campaign approached Lincoln, well-known for working with Republicans in late summer 2020. 55. Lincoln agreed to work with the Campaign, and in meetings af fi rmatively shopped Ms. Basulto’s work. In fact, with Ms. Basulto and Mr. Rashidi’s names and images on their website, they were able to bill themselves as innovative and attract a campaign with a candidate whose personal brand would identify with SeedX’s approach. 56. Mr. Sproul created Forti fi ed speci fi cally to work on this campaign to not be on the report as Lincoln, presumably because of his history as a Republican campaign consultant, and Lincoln’s work for the Republican Party of Texas in 32 the 2020 Election. 33 57. Forti fi ed gives its address as 740 S. Mill Ave, #200, Tempe, Arizona 85281. However, that address is the same address as 740 S. Mill Ave, #200, Tempe, Arizona 85281, which is the address for Lincoln. Sara Murray and Scott Glover, Kanye West’s campaign has hired GOP operative with history of 32 controversial work , KTBS (Sept. 22, 2020), https://www.ktbs.com/news/national_politics/kanye- w e s t s - c a m p a i g n - h a s - h i r e d - g o p - o p e r a t i ve - w i t h - h i s t o r y - o f - c o n t rove r s i a l - w o rk / article_25c9c939-8fee-59c2-ae36-0a19796d2350.html (last accessed May 3, 2021). Vendor/Recipient Pro fi le: Lincoln Strategy Group, OpenSecrets: Center for Responsive 33 P o l i t i c s , h t t p s : / / w w w. o p e n s e c r e t s . o r g / c a m p a i g n - e x p e n d i t u r e s / v e n d o r ? vendor=Lincoln+Strategy+Group&year=2014 (last accessed May 3, 2021). Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 15 56 58. In fact, if you go to the of fi ce address, there is not a separate location for Forti fi ed, just doors with the name “Lincoln Strategy Group” on them. 34 E. L INCOLN S TRATEGY G ROUP I NVITED S EED X TO W ORK WITH T HEM ON THE K ANYE 2020 C AMPAIGN 59. In August 2020, Mr. Sproul approached Ms. Basulto’s and indicated that he would like SeedX to provide consulting services in the marketing and web development areas for the Campaign for possible compensation ranging from $200,000 to $4,000,000 in proportion to the performance of the services provided. 60. SeedX was intrigued and excited by the opportunity to work for the Campaign. Ms. Basulto indicated the terms were agreeable to her, and asked for a written contract to memorialize it. 61. Mr. Sproul told Ms. Basulto they could fi gure out details later and reduce the agreement to writing at a later time. The oral discussions ranged from revenue share being 50/50 split to a multi-million dollar project for the services. 62. No agreement was forthcoming. Sara Murray and Scott Glover, Kanye West’s campaign has hired GOP operative with history of 34 controversial work , KTBS (Sept. 22, 2020), https://www.ktbs.com/news/national_politics/kanye- w e s t s - c a m p a i g n - h a s - h i r e d - g o p - o p e r a t i ve - w i t h - h i s t o r y - o f - c o n t rove r s i a l - w o rk / article_25c9c939-8fee-59c2-ae36-0a19796d2350.html (last accessed May 3, 2021). Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 16 56 63. In October 2020, Mr. Sproul again approached SeedX about the Campaign, this time with more urgency. Mr. Sproul indicated that the Campaign was ready to go and had completed necessary paperwork and was getting on various state ballots. He indicated that a website was needed immediately due to the Campaign being ready to go. SeedX was able to create the website within ten days under the belief that payment would be made much like the prior arrangement Lincoln had made with SeedX which was paid out in monthly amounts. Ms. Basulto again asked for a written agreement. Mr. Sproul did not provide a written agreement. F. A FTER P ROVIDING S ERVICES AND D ELIVERING ALL C ONTRACTED FOR R ECEIVABLES , S EED X H AS Y ET TO B E C OMPENSATED U NDER THE C ONTRACT 64. SeedX’s fi rst and immediate job was to create a website for the Campaign with a deadline of two weeks from then ,and it was informed her that compensation would be worked out later. Mr. Sproul still never provided a written agreement for SeedX and its work on the Campaign through either Lincoln or Forti fi ed, even though SeedX believed it was working for Forti fi ed on the Campaign. Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 17 56 65. SeedX was in direct contact with the Campaign and Forti fi ed and was always available to the Campaign and Forti fi ed. 35 66. Besides creating the website in ten days, SeedX made sure the website with compliant with the Federal Election Commission’s rules. SeedX also created 36 an advertisement to go in the New York Times, as well as creating merchandise for the Campaign ranging from hats to sweatshirts. They also handled the 37 sales of the merchandise and gathering the donor data. 38 67. The Campaign paid out $13,210,013.12 in 2020 for services provided to it. 39 Over 1/3 of that was paid to Forti fi ed ($4,769,529.86). 40 68. SeedX also was told that no reimbursements would be provided for travel; however, Forti fi ed was paid $7,808.28 and $58,200.00 on August 26, 2020 for travel reimbursements. Other companies that provided services to the 41 Campaign were also paid for travel reimbursements. Pls. App. at 001381-706. 35 Pls. App. at 001391-1427. 36 Pls. App. at 001444-81. 37 Pls. App. at 001444-85. 38 Pls. App. at 000073-120, Pls. App. at 000131-55, Pls. App. at 000165-67, Pls. App. at 768-85, 39 Pls. App. at 001184-227, Pls. App. at 001229-55, Pls. App. at 001303-14, Pls. App. at 001357-76. Id. 40 Pls. App. at 000092, Pls. App. at 000093. 41 Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 18 56 69. Millennial Strategies LLC began work on the website before SeedX and was paid $205,968.75 for its work on one page of the Campaign website. It was also reimbursed for travel. 70. Neither SeedX nor any of their work is to be found on any of the fi nance reports, despite being contacted by Jill Vogel from Holtzman Vogel Jose fi ak Torchinsky PLLC to get SeedX’s help in creating the fi nance reports. 42 71. Holtzman Vogel Jose fi ak Torchinsky PLLC was not included on the fi nance reports by the Campaign. 72. Further, the Campaign reported paying $83,509.33 on the 2020 fi nance reports to Shopify and $918,130.00 too Los Angeles Apparel for work provided to the Campaign, but SeedX worked with those companies and created the website and was left off the reports. 43 73. The Campaign also paid $270,000.00 to MVD, Inc. and $105,000.00 to We Think LLC for communications consulting which are similar to the services provided by SeedX. 44 Pls. App. at 001531. 42 Pls. App. at 000771, Pls. App. at 001365. 43 Pls. App. at 000155, Pls. App. at 001192, Pls. App at 001255, Pls. App. at 001314, Pls. App. at 44 001366, Pls. App. at 001376. Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 19 56 G. R EQUESTS TO BE P AID U NDER THE T ERMS OF THE C ONTRACT WITH F ORTIFIED C ONSULTING H AVE B EEN M ET WITH S TONEWALLING , C ONFUSING R EBUTTALS , A TTEMPTS AT E XTORTION , AND D OWNRIGHT R EFUSAL 74. SeedX made multiple requests to be paid for the services provided to the Campaign. However, Lincoln, Forti fi ed, and Mr. Sproul often ignored these requests or refused to pay. They also asked that the website be transferred to Lincoln in order to be paid. 75. SeedX was able to develop and maintain a website for the Campaign. The website was not only compliant with the Federal Election Commission’s rules but also raised $2,500,000 for the Campaign in just one week. 76. Further, as part of SeedX’s consulting services, SeedX created an advertisement for the New York Times and engaged in other work to aid Forti fi ed in the Campaign. 77. However, SeedX and Ms. Basulto received no written agreements from Mr. Sproul, Forti fi ed, or Lincoln nor did SeedX receive any compensation for the work done for the Campaign. 78. For the next two months (December 2020 and January 2021), Ms. Basulto informed Mr. Sproul that SeedX still had not been compensated for its work Cause No. SeedX, et al v. Kanye 2020, et al Plaintiffs’ Original Petition and Application for Injunctive Relief Page of 20 56