Complaint — SRB Capital, LLC v. A R Central 2, LLC et al. (Southern District of Ohio)
Summary
A complaint filed April 7, 2023 by SRB Capital, LLC against A R Central 2, LLC, Kalra Hospitality, LLC, Kalra Management Services, Inc. and other hospitality companies it calls the "Dairy Queen Entities", in the U.S. District Court for the Southern District of Ohio, Case No. 2:23-cv-1243. SRB states that on or about May 17, 2022 the parties entered a written Consulting Agreement for financial consulting services, and that the defendants failed to make the required payments. Count One pleads breach of contract, Count Two an account and Count Three quantum meruit, each for an amount in excess of $135,376.00. The complaint cites a monthly interest rate of 1.25% on unpaid invoices and seeks attorney's fees and costs; the Consulting Agreement and invoices are attached as Exhibits A and B.
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“Complaint — SRB Capital, LLC v. A R Central 2, LLC et al. (Southern District of Ohio).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/1-complaint-srb-v-ar-central-with-consulting-agreement-invoices-8a74bb1941/
, SHA-256 2178ed2788bdc86e3fb93f70873b0456f10f836c800f693b6b27d2d2cf4bf35f.Full text
Case: 2:23-cv-01243-SDM-CMV Doc #: 1 Filed: 04/07/23 Page: 1 of 6 PAGEID #: 1
IN THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISIOIN
SRB Capital, LLC :
8868 Columbus Road :
Mount Vernon, Ohio 43050 :
:
Plaintiff, :
:
v. : Case No. 2:23-cv-1243
:
:
A R Central 2, LLC :
c/o Ramandeep Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
Kalra Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
2602 E Beautiful Ln. :
Phoenix, AZ 85042 :
:
and :
:
Kalra Management Services, Inc. :
c/o Ramandeep Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
Mira Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
MMPR Bullhead City Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
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12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
MMPR Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
:
MMPR Kingman Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
MMPR Rainbow Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
4010 S Rainbow Blvd, :
Las Vegas, NV 89103 :
:
and :
:
MMPR Union Hills Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
MMPR Yuma Hospitality, LLC :
c/o Ramandeep Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
:
and :
:
Puram Hospitality, LLC :
c/o Puja Kalra, Statutory Agent :
12456 N 28th Dr. :
Phoenix, AZ 85029 :
Defendants. :
2
Case: 2:23-cv-01243-SDM-CMV Doc #: 1 Filed: 04/07/23 Page: 3 of 6 PAGEID #: 3
COMPLAINT
Now comes Plaintiff, SRB Capital, LLC (“Plaintiff”), by and through its undersigned
counsel, and for its Complaint against Defendants, A R Central 2, LLC (“A R”), Kalra Hospitality,
LLC (“Kalra Hospitality”), Kalra Management Services, Inc. (“Kalra Management”), Mira
Hospitality, LLC (“Mira Hospitality”), MMPR Bullhead City Hospitality, LLC (“MMPR
Bullhead”), MMPR Hospitality, LLC (“MMPR Hospitality”), MMPR Kingman Hospitality, LLC
(“MMPR Kingman”), MMPR Rainbow Hospitality, LLC (“MMPR Rainbow”), MMPR Union
Hills Hospitality, LLC (“MMPR Union”), MMPR Yuma Hospitality, LLC (“MMPR Yuma”), and
Puram Hospitality, LLC (“Puram”) (collectively, “Defendants” or “Dairy Queen Entities”), hereby
states as follows:
Parties, Jurisdiction, and Venue
1. Plaintiff is a domestic limited liability company registered with the Secretary of
State of Ohio. Plaintiff’s principal place of business is located at 8868 Columbus Road, Mount
Vernon, Ohio 43050 (Knox County). Plaintiff engages in interstate commerce by providing
financial and other consulting services.
2. Defendant A R Central 2, LLC is a limited liability company registered with the
Secretary of State of Arizona, having a principal place of business in Phoenix, Arizona.
3. Defendant Kalra Hospitality, LLC is a limited liability company registered with the
Secretary of State of Arizona, having a principal place of business in Phoenix, Arizona.
4. Defendant Kalra Management Services, Inc is a for-profit corporation registered
with the Secretary of State of Arizona, having a principal place of business in Phoenix, Arizona.
5. Mira Hospitality, LLC is a limited liability company registered with the Secretary
of State of Arizona, having a principal place of business in Phoenix, Arizona.
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6. Defendant MMPR Bullhead City Hospitality, LLC is a limited liability company
registered with the Secretary of State of Arizona, having a principal place of business in Phoenix,
Arizona.
7. Defendant MMPR Hospitality, LLC is a limited liability company registered with
the Secretary of State of Arizona, having a principal place of business in Phoenix, Arizona.
8. Defendant MMPR Kingman Hospitality, LLC is a limited liability company
registered with the Secretary of State of Arizona, having a principal place of business in Phoenix,
Arizona.
9. Defendant MMPR Rainbow Hospitality, LLC is a limited liability company
registered with the Secretary of State of Nevada, having a principal place of business in Las Vegas,
Nevada.
10. Defendant MMPR Union Hills Hospitality, LLC is a limited liability company
registered with the Secretary of State of Arizona, having a principal place of business in Phoenix,
Arizona.
11. Defendant MMPR Yuma Hospitality, LLC is a limited liability company registered
with the Secretary of State of Arizona, having a principal place of business in Phoenix, Arizona.
12. Defendant Puram Hospitality, LLC is a limited liability company registered with
the Secretary of State of Arizona, having a principal place of business in Phoenix, Arizona.
13. Upon information and belief, all of the members of the Defendant LLCs are
residents of either Arizona or Nevada.
14. This Court has both subject matter jurisdiction to hear this matter and personal
jurisdiction over the Defendants.
15. Venue is proper in this Court Pursuant to 28 U.S.C. § 1391.
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Count One - Breach of Contract
16. Plaintiff incorporates by reference the previous paragraphs as if fully written herein.
17. On or about May 17, 2022, Plaintiff and Defendants entered into a written
Consulting Agreement (the “Agreement”), whereby Plaintiff agreed to provide certain consulting
services to Defendants, and Defendants agreed to pay for said consulting services. (The
Agreement is attached hereto as Exhibit A.)
18. Plaintiff substantially performed its obligations under the Agreement by providing
Defendants with financial consulting services for an agreed-upon fee. (See Invoices attached
hereto as Exhibit B.)
19. Defendants breached the Agreement and is in default thereof for failure to make
payments to Plaintiff, as required by the Agreement.
20. Pursuant to the Agreement, if any invoice is not paid within 15 days from its billing
date, the unpaid balance shall accrue compounding interest at the monthly rate of one and one-
quarter percent (1.25%). (See Exhibit A.)
21. Pursuant to the Agreement, in the event that any collection action is required to
collect unpaid balances due and owing to SRBC, reasonable attorney’s fees and collection costs
shall be recoverable. (See Exhibit A.)
22. As a direct and proximate result of Defendants’ breach, Plaintiff has been damaged
in an amount in excess of $135,376.00, plus attorney’s fees and costs.
Count Two - Account
23. Plaintiff incorporates by reference the previous paragraphs as if fully written herein.
24. Defendants owe Plaintiff an account stated in excess of $135,376.00 for financial
consulting services rendered to Defendants.
5
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Count Three - Quantum Meruit
25. Plaintiff incorporates by reference the previous paragraphs as if fully written herein.
26. Defendants owe Plaintiff an amount in excess of $135,376.00 pursuant to the
equitable doctrines of quantum meruit/quantum valebant.
WHEREFORE, Plaintiff demands judgment against Defendants, The Dairy Queen
entities, in an amount in excess of $135,376.00, plus attorney’s fees and costs, plus any other relief
that this Court may deem appropriate either at law or in equity.
LUPER NEIDENTHAL & LOGAN
A Legal Professional Association
/s/ Kyle T. Anderson
Kyle T. Anderson (0097806)
1160 Dublin Road, Suite 400
Columbus, Ohio 43215-1052
Telephone: (614) 221-7663
Facsimile: (866) 345-4948
E-mail: kanderson@LNLattorneys.com
Attorney for Plaintiff
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