Woodson v. City of Dallas et al

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Case 3:25-cv-01748-G-BT Document 24 _ Filed 02/12/26 Pagei1of54 PagelD <pagelD>

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION
RYAN WOODSON, §
Plaintiff,
Vv. : Case No. 3:25-cv-01748-G-BT
CITY OF DALLAS, et al., :
Defendants. :

FINDINGS, CONCLUSIONS, AND RECOMMENDATION
OF THE UNITED STATES MAGISTRATE JUDGE

Before the Court are separate dispositive motions filed by Defendant
Amazon Services LLC (ECF No. 6) (motion to dismiss), Marriott International, Inc.
(ECF No. 11) (motion for summary judgment), BDT Capital Partners LLC (ECF No.
14) (motion for judgment on the pleadings), and Jeffrey and Katherine Woodson
(ECF No. 19) (motion to dismiss) (collectively, the “Moving Defendants” and the
“Motions”). For the reasons stated, the District Judge should GRANT the Moving
Defendants’ Motions and DISMISS WITH PREJUDICE Plaintiffs claims
against the Moving Defendants. The District Judge should also sua sponte
DISMISS WITH PREJUDICE Plaintiffs claims against Defendants Gayle
Morris, Marielle and William Lemasters, Edgardo Garcia, Daryl Barclay, David

Lee, and SNL Associates. !

1 Woodson asserts a claim under 42 U.S.C. § 1983 against the City of Dallas and the
Dallas Police Department. Ex. A, Compl. at 21-22, {1 96-102. The City of Dallas
and Dallas Police Department did not file a dispositive motion, and therefore,

2
Background
Plaintiff Ryan Woodson initiated a lawsuit in Texas state court against
Defendants Jeffrey and Katherine Woodson (the “Woodson Defendants”); Gayle
Morris; William and Marielle Lemasters; David Lee; Edgardo Garcia; Daryl
Barclay; the City of Dallas; the Dallas Police Department; Amazon Services LLC
(Amazon); BDT Capital Partners LLC (Whataburger); Marriott International, Inc.
(Marriott); SNL Associates, Inc.; and Does 1–20. Ex. A, Compl. at 2–3, ¶¶ 2–16.2
In his pleading, Plaintiff asserts a litany of claims against the Defendants, including
(1) conspiracy, (2) fraud, (3) negligence, (4) negligent misrepresentation, (5)
assault, (6) stalking, (7) false imprisonment, (8) intentional infliction of emotional
distress, (9) violations of 42 U.S.C. § 1983, (10) breach of contract, and (11) breach
of the implied covenant of good faith and fair dealing. Id. at 9–25, ¶¶ 51–113. The
City of Dallas removed the case to federal court based on federal question
jurisdiction.3 See Not. of Removal at 2, ¶ 8 (ECF No. 1).
Woodson’s § 1983 claim remains. The Court will enter a Scheduling Order for
Plaintiff’s remaining claim.
2 The City of Dallas manually filed a USB containing the documents filed in the
state court action, including Plaintiff’s live pleading. See Not. of Removal at 3, ¶ 12
(ECF No. 1). For reference, a copy of Plaintiff’s original pleading is Exhibit A.
3 Upon review of the Notice of Removal, the City of Dallas timely removed the case
to federal court. But the Notice of Removal lacks evidence of consent to removal
from all the Defendants that appeared in state court, particularly the consent of
Defendant Gayle Morris. Although the City of Dallas states that “[a]ll defendants
who have been served and appeared and who are subject to suit join in the removal
of this action, as reflected by the signature of counsel on the notice,” the Court did
not locate evidence of the other defendants’ consent. Not. of Removal at 3, ¶ 11
(ECF No. 1). That said, this defect is procedural and does not deprive the Court of
jurisdiction to decide the Motions. Weekes v. Allstate Fire and Cas. Ins. Co., 690
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Stated succinctly, Plaintiff complains that various individuals and entities—
along with drug cartels, gangs, cults, and churches—conspired to harass, stalk,
frame, and kill him. Plaintiff contends this conspiracy began when he reported
“meth cooking” to police in California. Ex. A, Compl. at 3–4, ¶ 19. In retaliation of
his alleged police report, Plaintiff claims that various individuals connected to
“meth trafficking,” including his mother and father, repeatedly attempted “to
frame him for a crime and get him arrested.” Id. at 4, ¶¶ 20–22.
Plaintiff later moved from California to Dallas, Texas, where he contends the
stalking, assaults, and murder attempts continued. Id. at 5, ¶¶ 26–28. Plaintiff
claims that family members, neighbors, Whataburger fast-food workers, Amazon
delivery drivers, Marriott hotel employees, and individuals impersonating Dallas
police officers joined this conspiracy and were hired to aid in the criminal plots
against Plaintiff. Id. at 5, ¶¶ 25–28; 6–7, ¶¶ 30–34; 8–9, ¶¶ 40–50. As a result of
this purported criminal plot, Plaintiff claims that he has suffered “mental anguish,
fright, horror, nervousness, grief, anxiety, worry, shock, humiliation, and shame
that an ordinary, reasonable person would be unable to cope with[.]” Id. at 21, ¶ 95.
The Moving Defendants now seek to dismiss Plaintiff’s claims. Plaintiff filed
untimely responses to Amazon, the Woodson Defendants, and Whataburger’s
F. Supp. 3d 599, 608–09 (N.D. Tex. 2023) (Horan, J.) (explaining the difference
between subject matter and removal jurisdiction and stating that “the Court may
not remand an action to state court sua sponte ‘for purely procedural defects’ or
based on a lack of removal jurisdiction.”) (quoting In re Allstate, 8 F.3d 219, 223
(5th Cir. 1993)).
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dispositive motions using the Court’s emergency email. See Opp. to Amazon’s Mot.
to Dismiss (ECF No. 12) (deadline was 08/04/2025, filed on 08/24/2025); Opp.
to Woodson Defs.’ Mot. to Dismiss (ECF No. 20) (deadline was 10/06/2025, filed
on 11/11/2025); Opp. to Whataburger’s Mot. for J. on the Pleadings (ECF No. 21)
(deadline was 09/19/2025, filed on 01/08/2026). Thus, the Court struck Plaintiff’s
responses from the record. Order (ECF No. 22). The Court also ordered Plaintiff to
register as a CM/ECF user, but Plaintiff has yet to comply. Id. Although Plaintiff
provided an address upon filing, the documents the Court has tried to send to
Plaintiff have been returned as “undeliverable,” suggesting that Plaintiff moved
and failed to advise the Court of his new address. See Mail Returned (ECF Nos. 9
& 23). Despite Plaintiff’s lack of prosecution, the Motions are ripe for adjudication.
Legal Standards
Rule 56(a)
A court will grant summary judgment when the record shows that there is
no genuine dispute as to any material fact and that the moving party is entitled to
judgment as a matter of law. Fed. R. Civ. P. 56(a); Celotex Corp. v. Catrett, 477
U.S. 317, 323–25 (1986); Ragas v. Tenn. Gas Pipeline Co., 136 F.3d 455, 458 (5th
Cir. 1998). A dispute over a material fact is “genuine” if the evidence is such that a
reasonable jury could return a verdict for the nonmoving party. Anderson v.
Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). When ruling on a motion for
summary judgment, the court must view all facts and inferences in the light most
favorable to the nonmoving party and resolve all factual controversies in favor of
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the nonmoving party. Boudreaux v. Swift Transp. Co., 402 F.3d 536, 540 (5th Cir.
2005).
Further, a court “may not make credibility determinations or weigh the
evidence” in ruling on a motion for summary judgment. Reeves v. Sanderson
Plumbing Prods., Inc., 530 U.S. 133, 150 (2000); Anderson, 477 U.S. at 255. Once
the moving party has made an initial showing that no evidence supports the
nonmoving party’s case, the party opposing the motion must come forward with
competent summary judgment evidence of the existence of a genuine dispute of
material fact. Matsushita Elec. Indus. Co. v. Zenith Radio, 475 U.S. 574, 586–87
(1986). On the other hand, “if the movant bears the burden of proof on an issue,
either because he is the plaintiff or as a defendant he is asserting an affirmative
defense, he must establish beyond peradventure all of the essential elements of the
claim or defense to warrant judgment in his favor.” Fontenot v. Upjohn Co., 780
F.2d 1190, 1194 (5th Cir. 1986) (emphasis in original). “[When] the record taken as
a whole could not lead a rational trier of fact to find for the non-moving party, there
is no ‘genuine [dispute] for trial.’” Matsushita, 475 U.S. at 587 (citation omitted).
Mere 	conclusory 	allegations 	are 	not 	competent 	summary 	judgment
evidence, and thus cannot defeat a motion for summary judgment. Eason v.
Thaler, 	73 	F.3d 	1322, 	1325 	(5th 	Cir. 	1996) 	(per 	curiam). 	Unsubstantiated
assertions, 	improbable 	inferences, 	and 	unsupported 	speculation 	are 	not
competent summary judgment evidence. Forsyth v. Barr, 19 F.3d 1527, 1533 (5th
Cir. 1994). The party opposing summary judgment must identify specific evidence
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in the record and articulate the precise way that evidence supports his claim.
Ragas, 136 F.3d at 458. Rule 56 does not impose a duty on the court to “sift through
the record in search of evidence” to support the nonmovant’s opposition to the
motion for summary judgment. Id.; see also Skotak v. Tenneco Resins, Inc., 953
F.2d 909, 915–16 & n.7 (5th Cir. 1992). “Only disputes over facts that might affect
the outcome of the suit under the governing law will properly preclude the entry of
summary judgment.” Anderson, 477 U.S. at 248. If the nonmoving party fails to
make a showing sufficient to establish the existence of an element essential to its
case and on which it will bear the burden of proof at trial, summary judgment must
be granted. Celotex, 477 U.S. at 322–23.
Rules 12(c) and 12(b)(6)
A motion under Rule 12(c) “is designed to dispose of cases where the
material facts are not in dispute and a judgment on the merits can be rendered by
looking to the substance of the pleadings and any judicially noticed facts.” Hebert
Abstract v. Touchstone Props., Ltd., 914 F.2d 74, 76 (5th Cir. 1990) (per curiam).
The standard for deciding a motion under Rule 12(c) is the same as the one for
deciding a motion to dismiss under Rule 12(b)(6). Gentilello v. Rege, 627 F.3d 540,
543–44 (5th Cir. 2010).
Under Rule 12(b)(6), the court “accepts all well-pleaded facts as true,
viewing them in the light most favorable to the plaintiff.” In re Katrina Canal
Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007) (cleaned up). To survive a Rule
12(b)(6) motion, therefore, a plaintiff’s complaint must contain sufficient factual
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matter to state a claim for relief that is plausible on its face. Bell Atl. Corp. v.
Twombly, 550 U.S. 544, 570 (2007). “To be plausible, the complaint’s ‘[f]actual
allegations must be enough to raise a right to relief above the speculative level.’” In
re Great Lakes Dredge & Dock Co. LLC, 624 F.3d 201, 210 (5th Cir. 2010) (quoting
Twombly, 550 U.S. at 555). This pleading standard does not require “‘detailed
factual allegations,’” but it does demand more than an unadorned accusation
devoid of factual support. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting
Twombly, 550 U.S. at 555). “A claim has facial plausibility when the plaintiff pleads
factual content that allows the court to draw the reasonable inference that the
defendant is liable for the misconduct alleged.” Id. at 678 (citing Twombly, 550
U.S. at 556). “[A] formulaic recitation of the elements of a cause of action will not
do.” Twombly, 550 U.S. at 555 (citing Papasan v. Allain, 478 U.S. 265, 286
(1986)). “While legal conclusions can provide the framework of a complaint, they
must be supported by factual allegations.” Iqbal, 556 U.S. at 679. Where the facts
do not permit the Court to infer more than the mere possibility of misconduct, the
complaint has stopped short of showing that the plaintiff is plausibly entitled to
relief. Id. at 678 (citing Twombly, 550 U.S. at 557).
Analysis
Plaintiff’s Claims Against Marriott (Causes of Action Nos. 1–5, 8 & 10–11)
Plaintiff’s claims against Marriott arise from his alleged stay at a Fairfield
Inn in Dallas, Texas. Ex. A, Compl. at 12, ¶ 61. During this stay, Plaintiff believes
that the Woodson Defendants and Defendant Morris conspired to “intentionally
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attempt to kill him, assault him, or frame him for a crime” at Marriott’s property.
Id. Plaintiff claims that Marriott’s employees “fraudulently misrepresented and
concealed” that he was placed “in a hotel room adjacent to the members of the
Morris family who had followed and stalked him there after his 911 call for
attempted murder in order . . . to cause Plaintiff substantial harm.” Id. at 13, ¶ 62.
Plaintiff also contends that Marriott negligently screened hotel guests, failed to
properly hire and supervise its employees and provide adequate security, and
interfered with his stay. Id. at 15–17, ¶¶ 69, 77. Plaintiff also characterizes
Marriott’s actions as “breaches of contract” and breaches of the implied covenant
of good faith and fair dealing. Id. at 23–24, ¶¶ 103–113.
In response, Marriott states that it “did not own the premises where Plaintiff
alleges an incident occurred,” “did not operate the subject premises,” “did not
manage the employees at the subject premises,” and “did not hire, train, or employ
the employees at the subject premises.” Marriott’s Mot. for Summary J. at 3, ¶ 5
(ECF No. 11). In support of these assertions, Marriott adduces the affidavit of Loren
Nalewanski, the Managing Vice President of U.S. Franchising for Marriott Select
Brands, who supports the above contentions. Id., Ex. A, Decl. of Loren Nalewanski,
at 1–4. Nalewanski explains that Marriott merely licensed its name to the owner of
the subject premises under a franchise agreement. Id. at 3, ¶ 8. Plaintiff did not
respond to Marriott’s Motion for Summary Judgment.
Plaintiff’s failure to respond to Marriott’s motion does not permit the Court
to enter a “default” summary judgment. See Settlement Cap. Corp., Inc. v. Pagan,
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649 F. Supp. 2d 545, 553 (N.D. Tex. 2009) (“Summary judgment may not be
awarded by default merely because the nonmoving party has failed to respond.”).
But when, as here, a party fails to address another party’s assertion of fact, the
Court may consider that facts as “undisputed for purposes of the motion and grant
summary judgment if the motion and supporting materials show that the movant
is entitled to it.” Pogue v. Sw. Credit Sys., L.P., 2019 WL 6312267, at *2 (N.D. Tex.
Oct. 30, 2019) (Rutherford, J.) (citing Fed. R. Civ. P. 56(e)(2)–(3)), adopted by
2019 WL 6311143 (N.D. Tex. Nov. 22, 2019) (Fish, J.). That a litigant is proceeding
pro se in a particular case does not alter these principles. See Davis v. Fernandez,
798 F.3d 290, 293 (5th Cir. 2015) (“[T]his is not to say that pro se plaintiffs don’t
have to submit competent evidence to avoid summary judgment, because they
do.”).
Here, the record shows that Plaintiff cannot prevail against Marriott. The
record contains undisputed evidence that Marriott does not own or operate the
premises at which Plaintiff’s alleged “stalking” and “attempted assault or murder”
occurred. As Plaintiff did not respond to Marriott’s motion, he has “not designated
specific facts showing that there is a genuine issue for trial.” Taplin v. Wells Fargo
Bank, N.A., 2018 WL 6933153, at *3 (N.D. Tex. Nov. 28, 2018) (Horan, J.),
adopted by 2019 WL 112103 (N.D. Tex. Jan. 4, 2019) (Lynn, J.). “A summary
judgment nonmovant who does not respond to the motion is relegated to [his]
unsworn pleadings, which do not constitute summary judgment evidence.” Id.
(quoting Bookman v. Shubzda, 945 F. Supp. 999, 1002 (N.D. Tex. 1996)).
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Accordingly, the District Judge should GRANT Marriott’s Motion for
Summary 	Judgment 	and 	DISMISS 	all 	claims 	asserted 	by 	Plaintiff 	against
Marriott (Causes of Action Nos. 1–5, 8 & 10–11).
Plaintiff’s Tort Claims
1. 	Fraud (Cause of Action No. 2)
In 	Plaintiff’s 	second 	cause 	of 	action, 	he 	alleges 	that 	the 	Woodson
Defendants, Gayle Morris, Edgardo Garcia, Daryl Barclay, Marriott, Amazon, and
Whataburger “fraudulently misrepresented and concealed” to Plaintiff that they
were allegedly conspiring “to frame him for a crime or kill him”; covertly surveilled
Plaintiff and hacked into his phone and computer; conspired with the Dallas Police
Department and the City of Dallas to ignore Plaintiff’s police reports; and many
other fantastical allegations involving criminal gangs, impersonation of police
officers, and an alleged murder plot. Ex. A, Compl. at 10, ¶¶ 55–63.
The Moving Defendants interpret Plaintiff’s fraud claim as one of fraudulent
nondisclosure. See Amazon’s Mot. to Dismiss at 6 (ECF No. 6) (“Although the
Complaint purports to assert a fraud claim, Plaintiff’s allegations more accurately
reflect a cause of action for fraudulent nondisclosure.”); Whataburger’s Mot. for J.
on the Pleadings at 4 (ECF No. 15) (“Woodson’s allegations . . . are more suited as
being analyzed under a claim for fraud by nondisclosure.”); Woodson Defs.’ Mot.
to Dismiss at 5 (ECF No. 19) (“Although the Complaint purports to assert a fraud
claim, Plaintiff’s allegations more accurately reflect a cause of action for fraudulent
nondisclosure.”). The Court also construes Woodson’s fraud claim as one for
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fraudulent nondisclosure. See Ex. A, Compl. at 12–13, ¶¶ 61–62 (stating that
Defendants “fraudulently misrepresented and concealed” certain facts to Plaintiff).
“Fraud by nondisclosure is a subcategory of fraud.” Wise v. SR Dall., LLC,
436 S.W.3d 402, 409 (Tex. App.—Dallas 2014, no pet.) (citing Schlumberger Tech.
Corp. v. Swanson, 959 S.W.2d 171, 181 (Tex. 1997)).4 Fraud by nondisclosure
requires a plaintiff to show:
(1) the defendant deliberately failed to disclose material facts; (2) the
defendant had a duty to disclose such facts to the plaintiff; (3) the
plaintiff 	was 	ignorant 	of 	the 	facts 	and 	did 	not 	have 	an 	equal
opportunity to discover them; (4) the defendant intended the plaintiff
to act or refrain from acting based on the nondisclosure; and (5) the
plaintiff relied on the non-disclosure, which resulted in injury.
Matter of Clem, 124 F. 4th 341, 349 (5th Cir. 2024) (citing Bombardier Aerospace
Corp. v. SPEP Aircraft Holdings, LLC, 572 S.W.3d 213, 219–20 (Tex. 2019)). The
Moving Defendants assert that Plaintiff failed to establish fraud by nondisclosure
because he alleged no duty to disclose, no reliance, and no injury. See Amazon’s
Mot. to Dismiss at 6 (ECF No. 6); Whataburger’s Mot. for J. on the Pleadings at 5
(ECF No. 15); Woodson Defs.’ Mot. to Dismiss at 5–7 (ECF No. 19). And the Moving
Defendants 	argue 	that 	Woodson 	cannot 	overcome 	the 	heightened 	pleading
standard under Rule 9(b) for fraud claims. Plaintiff did not timely reply to the
Motions.
4 As Plaintiff originally filed his Complaint in Texas state court, and given the
parties apparently agree that Texas law applies to this action, the Court applies to
Texas law to Plaintiff’s claims.
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A heightened level of pleading applies to fraud claims—plaintiffs alleging
fraud must plead with particularity. Fed. R. Civ. P. 9(b). This requires “the
complaint to set forth ‘the who, what, when, where, and how’ of the events at issue.”
Dorsey v. Portfolio Equities, Inc., 540 F.3d 333, 339 (5th Cir. 2008). The Fifth
Circuit “interprets Rule 9(b) strictly, requiring a plaintiff pleading fraud to specify
the statements contended to be fraudulent, identify the speaker, state when and
where 	the 	statements 	were 	made, 	and 	explain 	why 	the 	statements 	were
fraudulent.” Id. (cleaned up).
“The existence of a duty to disclose is an essential element of a fraudulent-
nondisclosure claim.” City of Clinton v. Pilgrim’s Pride Corp., 653 F. Supp. 2d 669,
676 (N.D. Tex. 2009), aff’d by 632 F.3d 148 (5th Cir. 2010). Plaintiff makes no
effort to establish that any of the Defendants owed him a duty to disclose under
any legal theory. He points to no fiduciary or special relationship that would give
rise to a duty to disclose between the Defendants and Plaintiff. See Jang Won Cho
v. Kun Sik Kim, 572 S.W.3d 783, 794 (Tex. App.—Houston [14th Dist.] 2019, no
pet.) (explaining that a duty to disclose can arise in certain formal relationships
where a fiduciary duty arises as a matter of law, or in an informal fiduciary
relationship 	predicated 	or 	“a 	moral, 	social, 	domestic 	or 	purely 	personal
relationship of trust and confidence”). Plaintiff has thus failed to sufficiently plead
the first element of his fraudulent nondisclosure claim.
Further, Plaintiff’s complaint is silent about his reliance on, and injury
resulting from, the Defendants’ purported nondisclosure. Rather, Plaintiff sets
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forth 	a 	formulaic 	recitation 	of 	the 	elements 	for 	fraud—not 	fraudulent
nondisclosure—without further explanation. Ex. A, Compl. at 13, ¶ 63. Plaintiff’s
threadbare allegations do not meet the pleading standard in Rule 8(a), let alone
Rule 	9(b)’s 	heightened 	pleading 	standard. 	Thus, 	the 	Court 	should 	dismiss
Plaintiff’s fraudulent nondisclosure claim (Cause of Action No. 2).
2. Assault (Cause of Action No. 5)
Plaintiff claims that the Woodson Defendants, the Lemasters, Morris, and
Lee committed assault by allegedly conspiring to stalk, surveil, frame, and kill him.
Ex. A, Compl. at 17–19, ¶¶ 80–83. Plaintiff states that these “intentional actions
caused Plaintiff to reasonably apprehend imminent, harmful, or offensive contacts
by Defendants and their co-conspirators.” Id. at 19, ¶ 82. The Woodson Defendants
respond that Plaintiff does not allege “a bodily injury, no threats of imminent
bodily injury and no physical contact that would be considered offensive or
provocative.” Woodson Defs.’ Mot. to Dismiss at 10 (ECF No. 19).
“The elements of civil assault mirror those of a criminal assault.” Loaisiga v.
Cerda, 379 S.W.3d 248, 256 (Tex. 2012). Under the Texas Penal Code, an assault
occurs when a person:
(1) 	intentionally, knowingly, or recklessly causes bodily injury to
another . . . ;
(2) 	intentionally or knowingly threatens another with imminent
bodily injury . . . ; or
(3) 	intentionally or knowingly causes physical contact with another
when the person knows or should reasonably believe that the
other will regard the contact as offensive or provocative.
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Id. (citing Tex. Penal Code § 22.01(a)). As to the first type of contact, Plaintiff does
not allege that Defendants ever caused him bodily injury. Second, Plaintiff does
not allege that Defendants threatened him with imminent bodily injury. See Jones
v. Shipley, 508 S.W.3d 766, 769 (Tex. App.—Houston [1st Dist.] 2016, no pet.)
(“The focus in an assault by threat case is on the defendant’s words and conduct,
and the critical inquiry is whether a reasonable person under the circumstances
would consider the words and conduct to be an objective threat of imminent bodily
injury.”) (emphasis added). Finally, Plaintiff does not allege that Defendants made
any offensive or provocative contact. Plaintiff therefore fails to state a plausible
claim for assault.
3. Stalking (Cause of Action No. 6)
Plaintiff also alleges that Defendants “engaged in harassing behavior toward
Plaintiff that was reasonably likely to harass, annoy, alarm, abuse, torment, or
embarrass him” on “numerous occasions.” Ex. A, Compl. at 19, ¶ 85. As a result,
Plaintiff claims he “reasonably feared for his safety.” Id.
To 	establish 	a stalking 	claim 	under Texas 	law 	without evidence 	that
Defendants violated a restraining order prohibiting harassing behavior, Plaintiff
must prove:
(A) 	the defendant, while engaged in harassing behavior, by
acts or words threatened to inflict bodily injury on the
claimant 	or 	to 	commit 	an 	offense 	against 	the
claimant . . . ;
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(B) 	the defendant had the apparent ability to carry out the
threat;
(C) 	the defendant’s apparent ability to carry out the threat
caused the claimant to reasonably fear for the claimant’s
safety . . . ;
(D) 	the claimant at least once clearly demanded that the
defendant stop the defendant’s harassing behavior;
(E) 	after the demand to stop by the claimant, the defendant
continued the harassing behavior; and
(F) 	the harassing behavior has been reported to the police as
a stalking offense.
Tex. Civ. Prac. & Rem. Code Ann. § 85.003(a). Plaintiff vaguely states that he “was
forced to file for a temporary restraining order,” but he does not explain whether
the restraining order ever went into effect, who the alleged restraining order was
against, or whether there was any violation of the same. Ex. A, Compl. at 4, ¶ 22.
Nor did Plaintiff allege that he reported his concerns to the police as a stalking
offense. Rather, Woodson makes vague references to “police reports” about his
“attempted murder” that the Dallas Police Department failed to investigate. Ex. A,
Compl. at 6, ¶¶ 33 (alleging that he made “multiple police reports” about “frame
attempts” that the Dallas Police Department failed to investigate); 7, ¶ 37 (alleging
that he reported an attempted murder, which Defendant Barclay failed to respond
to); 8, ¶¶ 40–41 (alleging that individuals impersonating police officers conducted
a welfare check on him); 8, ¶ 43 (allegedly reporting to police of an attempted
“murder or assault and battery”); 9, ¶¶ 49–50 (alleging that he was stalked on his
way to the Dallas Police Department to report his attempted murder). Due to
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Plaintiff’s pleading deficiencies, the District Judge should conclude that Woodson
has failed to plausibly allege a stalking claim.
4. False Imprisonment (Cause of Action No. 7)
Plaintiff next claims that due to “Defendants continuously and illegally
monitoring 	Plaintiff’s 	movements 	on 	hidden 	cameras 	and 	either 	following,
stalking, assaulting, and attempting to frame Plaintiff for a crime, or directing
others to follow, stalk, assault, and try to frame him for a crime, Defendants
intentionally 	restricted 	Plaintiff’s 	freedom 	of 	movement 	by 	making 	him
apprehensive and forcing him to not leave his residence[.]” Ex. A, Compl. at 20,
¶ 90.
“False imprisonment in Texas is the direct restraint by one person of the
physical liberty of another, without adequate legal justification.” McLaurin v.
Waffle House, Inc., 178 F. Supp. 3d 536, 554 (S.D. Tex. 2016) (quoting Reicheneder
v. Skaggs Drug Center, 421 F.2d 307, 310 (5th Cir. 1970)). “Under Texas law, the
elements of a false imprisonment claim are: (1) willful detention; (2) without
consent; and (3) without authority of law.” Jeanty v. Big Bubba’s Bail Bonds, 72
F. 4th 116, 119 (5th Cir. 2023) (citing Wal-Mart Stores, Inc. v. Rodriguez, 92
S.W.3d 502, 506 (Tex. 2002)). “[A] detention may be accomplished by violence,
threats, or any other means that restrains or wrongfully interferes with a person’s
freedom.” Wray v. Home Depot USA, Inc., 2020 WL 4043053, at *2 (N.D. Tex.
July 16, 2020) (Scholer, J.) (quoting Broadnax v. Kroger Tex., L.P., 2005 WL
2031783, at *8 (Tex. App.—Dallas Aug. 24, 2005, no pet.)).
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Nowhere in Plaintiff’s complaint is there any plausible claim that the
Defendants restrained Plaintiff’s physical liberty by threat or otherwise. Indeed,
Plaintiff was free to leave his residence, but he chose not to go anywhere because
of his own apprehension. Therefore, Plaintiff’s false imprisonment claim should be
dismissed.
5. 	Intentional Infliction of Emotional Distress (Cause of Action No. 8)
Finally, Woodson seeks damages for intentional infliction of emotional
distress (IIED). Ex. A, Compl. at 21, ¶ 94. In sum, Plaintiff states:
Defendants’ 	intentional 	conduct 	was 	outrageous; 	Defendants
intended to cause Plaintiff emotional distress or Defendants acted
with reckless disregard of the probability that Plaintiff would suffer
emotional distress; Defendants knew that Plaintiff was present when
the conduct occurred; Plaintiff suffered severe emotional distress; and
Defendants’ conduct was a substantial factor in causing Plaintiff’s
severe emotional distress.
Id.
To state a claim for intentional emotional distress, Plaintiff must allege that
“(1) the defendant acted intentionally or recklessly; (2) the defendant’s conduct
was extreme and outrageous; (3) the defendant’s conduct caused the plaintiff
emotional distress; and (4) the resulting emotional distress was severe.” Hoffman-
La Roche Inc. v. Zeltwanger, 144 S.W.3d 438, 445 (Tex. 2004). “Extreme and
outrageous conduct is conduct ‘so outrageous in character, and so extreme in
degree, as to go beyond all possible bounds of decency, and to be regarded as
atrocious, and utterly intolerable in a civilized community.’” Id. (quoting Twyman
v. Twyman, 855 S.W.2d 619, 621 (Tex. 1993)).
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A claim for IIED is “a ‘gap-filler’ tort, judicially created for the limited
purpose of allowing recovery in those rare instances in which a defendant
intentionally inflicts severe emotional distress in a manner so unusual that the
victim has no other recognized theory of redress.” Id. at 447 (discussing Standard
Fruit and Vegetable Co. v. Johnson, 985 S.W.2d 62, 68 (Tex. 1998)). Therefore, a
claim for IIED “cannot be maintained when the risk that emotional distress will
result is merely incidental to the commission of some other tort.” Standard Fruit
and Vegetable Co., 985 S.W.2d at 68.
Plaintiff’s IIED claim merely recites the essential elements of an IIED claim
and labels the Defendants’ purported conduct as “outrageous.” Further, Plaintiff’s
emotional 	distress 	is 	merely 	incidental 	to 	Defendants’ 	alleged 	stalking 	and
criminal plots. Because the “gravamen” of Woodson’s complaint is really his other
various tort claims, his IIED claim is not viable. Hoffman-La Roche Inc., 144
S.W.3d at 447.
For the reasons stated above, the District Judge should DISMISS Plaintiff’s
tort claims for failure to state a claim upon which relief may be granted (Causes of
Action Nos. 2, 5–9).
Plaintiff’s Conspiracy Claim (Cause of Action No. 1)
Plaintiff also alleges that “Defendants conspired with each other and other
individuals to follow, harass, stalk, frame, falsely imprison, cause severe emotional
distress, assault, and attempt to kill [him] in retaliation for his police reports, 911
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calls, and other communications and acts regarding [Defendants’] drug dealing
organizations.” Ex. A, Compl. at 9–10, ¶ 52.
Under Texas law, civil conspiracy is not an independent tort, but a derivative
tort that depends on participation in some underlying tort for which the plaintiff
seeks to hold the defendant liable. Tilton v. Marshall, 925 S.W.2d 672, 681 (Tex.
1996); see also Agar Corp., Inc. v. Electro Circuits Int’l, LLC, 580 S.W.3d 136, 142
(Tex. 2019) (“[C]ivil conspiracy is a theory of vicarious liability and not an
independent tort.”). So civil conspiracy “survives or fails alongside” the underlying
tort alleged. Agar, 580 S.W.3d at 141. Accordingly, for Plaintiff’s conspiracy claim
to prevail, he must plausibly allege the underlying torts. See, e.g., AFE Oil & Gas,
L.L.C. v. Hess, 2009 WL 294828, at *4 (Tex. App.—Dallas Feb. 9, 2009, no pet.)
(“[I]f no defendant is liable for fraud, then no defendant can be liable for
conspiracy to commit fraud.”).
For the reasons explained above, Plaintiff’s complaint does not adequately
allege any claim of fraud, assault, stalking, false imprisonment, or intentional
infliction of emotional distress against any of the Defendants.5 And no reasonable
person could believe Plaintiff’s allegations that the Woodson Defendants, Morris,
5 The Court notes that Plaintiff cannot base his civil conspiracy claim on his
negligence claims, which are discussed below. See Tri v. J.T.T., 162 S.W.3d 552,
557 (Tex. 2005) (“We have consistently held that there cannot be a civil conspiracy
to be negligent.”); McKinney/Pearl Rest. Partners, L.P. v. Metropolitan Life Ins.
Co., 241 F. Supp. 3d 737, 772 (N.D. Tex. 2017) (“In Texas, because conspiracy
requires specific intent, one cannot agree or conspire to be negligent. Therefore,
Plaintiff’s claim for conspiracy could be derivative only of its underlying claim for
fraud, not negligent misrepresentation.”) (internal citation omitted).
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the Lemasters, Lee, Marriott, Whataburger, and Amazon conspired “to follow,
harass, stalk, frame, falsely imprison, cause severe emotional distress, assault, and
attempt to kill Plaintiff[.]” Ex. A, Compl. at 9–10, ¶ 52. Thus, Plaintiff’s conspiracy
claim fails alongside his tort claims, and the District Judge should DISMISS
Plaintiff’s conspiracy claim (Cause of Action No. 1). See Adams v. Alcolac, Inc., 974
F.3d 540, 545 (5th Cir. 2020) (per curiam) (“Because the plaintiffs have identified
no tortious conduct . . . the plaintiffs have failed to establish the elements of civil
conspiracy.”).
Plaintiff’s Negligence Claims
1. 	Negligence (Cause of Action No. 3)
Plaintiff’s assertions supporting his claims of negligence mirror his tort
allegations and retell the same fantastical story that the Defendants conspired and
attempted to frame or kill Plaintiff, secretly surveilled and monitored his activity
and movements, and recruited the help of criminal organizations to help stalk and
kill him. Ex. A, Compl. at 13–17, ¶¶ 64–79. Plaintiff alleges that the Woodson
Defendants, 	Morris, 	the 	Lemasters, 	Lee, 	Amazon, 	Whataburger, 	and 	SNL
Associates acted negligently by “acting and conspiring” to the do the above actions.
Id. at 13, ¶ 65.
Under Texas law, “[t]he common law doctrine of negligence consists of three
elements: 1) a legal duty owed by one person to another; 2) a breach of that duty;
and 3) damages proximately resulting from the breach.” Allen v. Walmart Stores,
L.L.C., 907 F.3d 170, 178 (5th Cir. 2018) (quoting Greater Hous. Transp. Co. v.
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Phillips, 801 S.W.2d 523, 525 (Tex. 1990)). Whether a duty exists “is a question of
law for the court to decide from the facts surrounding the occurrence in question.”
Id. (quoting Greater Hous. Transp. Co., 801 S.W.2d at 525). Duty “is the threshold
inquiry, and a plaintiff must prove the existence and violation of a duty owed by
the defendant to establish liability in tort.” Est. of Newton v. Grandstaff, 2011 WL
2678933, at *3 (N.D. Tex. July 8, 2011) (Lindsay, J.) (citing Abalos v. Oil Dev. Co.
of Tex., 544 S.W.2d 627, 631 (Tex. 1976)).
In conclusory fashion, Plaintiff states that the Defendants “owed Plaintiff a
legal duty to exercise reasonable care in connection with their dealings with
Plaintiff. The Negligent Defendants breached their legal duty to Plaintiff by
negligently acting and conspiring . . . .” Ex. A, Compl. at 13, ¶ 65. Plaintiff does not
elaborate on this purported “legal duty,” and he presents no facts establishing that
any of the Moving Defendants owed him a “legally enforceable obligation to
conform to a particular standard of conduct.” Fugett v. DCP Midstream, L.P., 2015
WL 510965, at *3 (N.D. Tex. Feb. 6, 2015) (Robinson, J.) (quoting Way v. Boy
Scouts of Am., 856 S.W.2d 230, 233 (Tex. App.—Dallas 1993, writ denied)).
Plaintiff’s general recitation of the elements of a negligence claim fails to plausibly
allege a claim for relief.
2. Negligent Misrepresentation (Cause of Action No. 4)
Plaintiff next claims that the Woodson Defendants, Morris, the Lemasters,
and Lee “negligently misrepresented or negligently concealed to [him] all of the
preceding material information” in his negligence cause of action discussed above.
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Ex. A, Compl. at 16, ¶ 75. In response, the Woodson Defendants argue that Plaintiff
meets none of the elements of a negligent misrepresentation claim. Woodson Defs.’
Mot. to Dismiss at 9–10 (ECF No. 19).
To state a claim for negligent misrepresentation under Texas law, a plaintiff
must allege: (1) the defendant made a representation in the course of his business,
or in a transaction where he has a pecuniary interest; (2) the defendant provided
false information for the guidance of others in their business; (3) the defendant did
not exercise reasonable care or competence when obtaining or communicating this
information; and (4) the plaintiff sustained a pecuniary loss by justifiably relying
on the defendant’s representation. See Gen. Elec. Cap. Corp. v. Posey, 415 F.3d
391, 395–96 (5th Cir. 2005) (cleaned up) (quoting Clardy Mfg. Co. v. Marine
Midland Bus. Loans, Inc., 88 F.3d 347, 357 (5th Cir. 1996)).
Plaintiff wholly fails to allege facts to support the elements of negligent
misrepresentation. He did not allege that the Woodson Defendants—or any of the
Defendants—made a representation in the course of a business or transaction in
which he has a pecuniary interest, how the Woodson Defendants failed to exercise
reasonable care in communicating the alleged misrepresentation to him, how
Plaintiff justifiably relied on the misrepresentation to his detriment, or what
pecuniary loss he suffered as a result of his reliance on the misrepresentation.
Plaintiff’s complaint lacks 	well-pleaded 	facts 	to 	plausibly 	allege 	a negligent
misrepresentation claim.
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3. Negligent Hiring, Training, and Supervision
Although Plaintiff does not bring a separate cause of action for negligent
hiring, 	training, 	and 	supervision, 	he 	alleges 	that 	Defendants 	Amazon 	and
Whataburger negligently hired, trained, and supervised its employees. Ex. A,
Compl. at 15, ¶¶ 67–68. Amazon and Whataburger highlight that Plaintiff has not
alleged a legal duty or flaws with Amazon and Whataburger’s hiring, training, and
supervision processes. Whataburger’s Mot. for J. on the Pleadings, at 8–9 (ECF
No. 15); Amazon’s Mot. to Dismiss at 10–12 (ECF No. 6).
“To recover under a theory of negligent hiring, a plaintiff must prove that (1)
the employer owed a legal duty to protect third parties from the employee’s actions
and (2) the third party’s sustained damages were proximately caused by the
employer’s breach of that duty.” Gordon v. Bank of Am. Corp. & Green Tree
Servicing, LLC, 2015 WL 5872659, at *7 (N.D. Tex. Oct. 5, 2015) (Lindsay, J.)
(quoting TXI Transp. Co. v. Hughes, 224 S.W.3d 870, 901 (Tex. App.—Fort Worth
2007), rev’d on other grounds by 306 S.W.3d 230 (Tex. 2010)). To properly plead
a claim of negligent supervision, a plaintiff must allege that the defendant owed
him a legal duty to supervise its employees, that it breached that duty, and that the
breach proximately caused the plaintiff’s injuries. People’s Choice Home Loan, Inc.
v. Mora, 2007 WL 708872, at *7 (N.D. Tex. Mar. 7, 2007) (Fish, J.) (citing Knight
v. City Streets, L.L.C., 167 S.W.3d 580, 584 (Tex. App.—Houston [14th Dist.] 2005,
no pet.)). “In addition to proving negligence on the part of the employer in hiring,
supervising, or training the employee, the plaintiff also must prove that the
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employee committed an actionable tort.” Id. (citing Brown v. Swett & Crawford of
Texas, Inc., 178 S.W.3d 373, 384 (Tex. App.—Houston [1st Dist.] 2005, no pet.)).
Plaintiff makes no allegations that Defendants Amazon and Whataburger
failed to investigate, screen, or supervise its employees. See Walker v. Everhart
Transp., Inc., 2024 WL 1517221, at *1 (N.D. Tex. Apr. 5, 2024) (Toliver, J.) (“A
negligent hiring claim requires a plaintiff to allege enough facts to establish that
the employer was negligent because it ‘fail[ed] to investigate, screen, or supervise
its hirees[.]’”). And Plaintiff asserted no factual information about Defendants
Amazon and Whataburger’s allegedly deficient training. See Johnson v. Cox, 2024
WL 331631, at *7 (N.D. Tex. 2024) (Brown, J.) (“To support a claim for negligent
training 	and 	supervision, 	a plaintiff 	must prove 	that 	a reasonably 	prudent
employer would have provided training and supervision beyond that which was
given and the failure to do so caused his injuries.”) (quoting Lermon v. Minyard
Food Stores, Inc., 2014 WL 6466840, at *8 (Tex. App.—Dallas 2014, no pet.)).
Plaintiff’s mere legal conclusion that Defendants Amazon and Whataburger failed
to “properly hire, train, and supervise, its employees,” devoid of factual support,
dooms his claim.
For the above reasons, the District Judge should DISMISS Plaintiff’s various
negligence claims for failure to state a claim upon which relief may be granted.
Woodson’s Claims Against the Nonmoving Defendants
Defendant Gayle Morris, proceeding pro se, has been served with legal
process and filed an answer in state court, but she has not filed a dispositive motion
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in this case. And Defendants Marielle and Williams Lemasters, Edgardo Garcia,
Daryl Barclay, and SNL Associates have not appeared in this lawsuit (collectively
with Morris, the “Nonmoving Defendants”). Nonetheless, the claims against the
Nonmoving Defendants should be dismissed.
“The Fifth Circuit has held that where ‘a defending party establishes that a
plaintiff has no cause of action . . . this defense generally inures also to the benefit
of a defaulting defendant,’” and district courts have extended this holding to
unserved defendants. Armendariz v. Chowaiki, 2016 WL 8856919, *19 (W.D. Tex.
Mar. 31, 2016) (citing Lewis v. Lynn, 236 F.3d 766, 768 (5th Cir. 2001)); see also
Roa v. City of Denison, 2017 WL 9287012, at *18 (E.D. Tex. Aug. 29, 2017)
(dismissing claims against unserved defendants upon finding that plaintiff had
failed to state a claim against the appearing defendants, “as defaulting and/or
unserved defendants may generally derive the benefit of a defendant party’s
demonstration that the plaintiff has no cause of action”), adopted by 2017 WL
4675062 (E.D. Tex. Oct. 18, 2017)). Here, Plaintiff asserts the same claims against
the Nonmoving Defendants as the Moving Defendants, and the Rule 12(b)(6)
analysis is not unique to any Defendant. Therefore, the District Judge should
DISMISS 	Plaintiff’s 	claims 	against 	Defendants 	Gayle 	Morris, 	Marielle 	and
Williams Lemasters, Edgardo Garcia, Daryl Barclay, and SNL Associates. See
Liccardi v. Schorr, 2023 WL 9102232, at *5 (N.D. Tex. Dec. 11, 2023) (Rutherford,
J.), adopted by 2024 WL 57319 (N.D. Tex. Jan. 3, 2024) (Kinkeade, J.).
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Opportunity to Amend
Ordinarily, a pro se plaintiff should be granted leave to amend his complaint
before dismissal, but leave is not required when he has already pleaded his “best
case.” Brewster v. Dretke, 587 F.3d 764, 767–68 (5th Cir. 2009). Further, “an
opportunity to replead is unnecessary where the facts alleged are fantastic or
delusional scenarios or where the legal theory upon which a complaint relies is
indisputable meritless.’” Starrett v. U.S. Dep’t of Def., 2018 WL 6069969, at *3
(N.D. Tex. Oct. 30, 2018) (Ramirez, J.) (internal quotations omitted) (quoting
Gregory v. McKennon, 430 F. App’x 306, at *1 (5th Cir. 2011)), aff’d by 763 F.
App’x 383 (5th Cir. 2019).
Even based on the most deferential review of Plaintiff’s fantastic allegations,
it is unlikely that, given the opportunity, he could allege viable legal claims.
Further, Plaintiff did not timely respond to the Moving Defendants’ Motions and
did not request an opportunity to amend his pleading. Plaintiff also failed to
comply with the Court’s Order to register as a CM/ECF user, and documents the
Court has tried to send Plaintiff at his provided address have been returned as
“undeliverable.” Not only do these actions suggest “a failure to prosecute but also
indicates that Plaintiff is unable to set forth allegations to support his claims[.]”
Del Rio Trejo v. Bank of Am., N.A., 2020 WL 980951, at *1 (N.D. Tex. Feb. 28,
2020) (Lindsay, J.).
Thus, the District Judge should conclude that granting leave to amend under
these circumstances would be futile and cause needless delay. See Starrett, 2018
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WL 6069969, at *3 (denying leave to amend because the plaintiff’s “fantastical and
delusional scenario” could not “be remedied by an opportunity to amend or further
factual development”); Korn v. Tex., 2022 WL 494377, at *3 (N.D. Tex. Jan. 31,
2022) (Toliver, J.) (denying leave to amend because the plaintiff’s claims were
“fatally infirm”), adopted by 2022 WL 487929 (N.D. Tex. Feb. 17, 2022) (Scholer,
J.). 	The 	District 	Judge 	should 	therefore 	DISMISS 	WITH 	PREJUDICE
Plaintiff’s claims.
Recommendation
For the reasons stated above, the District Court should GRANT the Motions
(ECF Nos. 6, 11, 14 & 19) and DISMISS WITH PREJUDICE Plaintiff’s claims
against Defendants Amazon Services LLC, Marriott International, Inc., BDT
Capital Partners LLC, and Jeffrey and Katherine Woodson. The District Judge
should also sua sponte DISMISS WITH PREJUDICE Plaintiff’s claims against
Defendants Gayle Morris, Marielle and Williams Lemasters, Edgardo Garcia, Daryl
Barclay, and SNL Associates.
SO RECOMMENDED.
February 12, 2026.
REBECCA RUTHERFORD
UNITED STATES MAGISTRATE JUDGE
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INSTRUCTIONS FOR SERVICE AND
NOTICE OF RIGHT TO APPEAL/OBJECT
A copy of this report and recommendation will be served on all parties in the
manner provided by law. Any party who objects to any part of this report and
recommendation must file specific written objections within 14 days after being
served with a copy. See 28 U.S.C. § 636(b)(1); Fed. R. Civ. P. 72(b). To be specific,
an objection must identify the specific finding or recommendation to which
objection is made, state the basis for the objection, and specify the place in the
magistrate judge’s report and recommendation where the disputed determination
is found. An objection that merely incorporates by reference or refers to the
briefing before the magistrate judge is not specific. Failure to file specific written
objections will bar the aggrieved party from appealing the factual findings and legal
conclusions of the magistrate judge that are accepted or adopted by the district
judge, except upon grounds of plain error. See Douglass v. United Servs. Auto.
Ass’n, 79 F.3d 1415, 1417 (5th Cir. 1996).
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Case 3:25-cv-01748-G-BT Document 24 Filed 02/12/26 Page29o0f54 PagelD <pagelD>

Exhibit A

FILED
10/29/2024 11:50 AM

Case 3125-cP-BP735G-BT Document 24 Filed 02/12/26 Page 300f54 PagelD <pagefAsr clerk

DALLAS CO., TEXAS
Shunta Jackson DEPUTY

Ryan Woodson
10749 Sandpiper Ln.
Dallas, Texas 75230

tO

3 || Tel.: 214-502-1121
Email: rwcalif@gmail.com

4

5 || Plaintiff in pro per

6

7

8 IN THE DISTRICT COURT OF THE STATE OF TEXAS

? FOR THE COUNTY OF DALLAS
10
11 RYAN WOODSON, an individual,
12 Plaintiff. PLAINTIFF RYAN WOODSON’S

. COMPLAINT AGAINST DEFENDANTS

13 || v. JEFF WOODSON, KATHERINE

WOODSON, GAYLE MORRIS, CITY OF
DALLAS, DALLAS POLICE DEPARTMENT,
MARIELLE LEMASTERS, WILLIAM
LEMASTERS, DAVID LEE, EDGARDO
GARCIA, DARYL BARCLAY, AMAZON
SERVICES LLC, BDT CAPITAL PARTNERS
LLC, MARRIOTT INTERNATIONAL, INC.,
AND SNL ASSOCIATES, INC.

14 || JEFFREY WOODSON, an individual;

15 || KATHERINE WOODSON, an individual;
GAYLE MORRIS, an individual; CITY

16 || OF DALLAS; DALLAS POLICE
DEPARTMENT: MARIELLE

17 || LEMASTERS, an individual; WILLIAM
1g || LEMASTERS, an individual; DAVID
LEE, an individual; EDGARDO GARCIA;

Nm ee eee ee eee OOS AOS OS O_O O_O O_O Oa

19 || DARYL BARCLAY; AMAZON 1. CONSPIRACY
SERVICES LLC; BDT CAPITAL 2. FRAUD
20 || PARTNERS LLC: MARRIOTT 3. NEGLIGENCE
51 || INTERNATIONAL, INC.; SNL 4. NEGLIGENT MISREPRESENTATION
ASSOCIATES, INC.; and DOES 1 5. ASSAULT
22 || through 20, inclusive, 6. STALKING
3 7. FALSE IMPRISONMENT
Defendants. 8. INTENTIONAL INFLICTION OF
24 MOTIONAL DISTRESS
9. VIOLATION OF 42 U.S.C § 1983
25 10. BREACH OF CONTRACT
26 11. BREACH OF THE IMPLIED
COVENANT OF GOOD FAITH AND FAIR
27 DEALING
28 DEMAND FOR JURY TRIAL

-|-

PLAINTIFF RYAN WOODSON’S COMPLAINT

Case 3:

Lo

Co He N Don

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

4

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PARTIES

1. Plaintiff RYAN WOODSON, an individual (“PLAINTIFF”), is and at all times relevant to this
action was a resident of Dallas, Texas.

2. Defendant JEFFREY WOODSON. an individual, is and at all times relevant to this action was
a resident of Dallas, Texas.

3. Defendant KATHERINE WOODSON, an individual, is and at all times relevant to this action
was a resident of Dallas, Texas.

4. Defendant GAYLE MORRIS, an individual (“MORRIS”), is and at all times relevant to this
action was a resident of Dallas, Texas..

5. Defendant MARIELLE LEMASTERS, an individual (*“LEMASTERS”), is and at all times
relevant to this action was a resident of Dallas, Texas.

6. Defendant WILLIAM LEMASTERS, an individual, is and at all times relevant to this action
was a resident of Dallas, Texas.

7. Defendant DAVID LEE, an individual (“LEE”), is and at all times relevant to this action

was a resident of Dallas, Texas.

8. Defendant CITY OF DALLAS is and at all times relevant to this action was a

municipality in Dallas County, Texas.

9, Defendant DALLAS POLICE DEPARTMENT (“DPD”) is and 1.at all times relevant to this
action was an entity in Dallas County, Texas.

10. Defendant EDGARDO GARCIA, an individual (“GARCIA”), is and at all times

relevant to this action was a resident of Dallas, Texas.

11. Defendant DARYL BARCLAY, an individual (“BARCLAY”), is and at all times

relevant to this action was a resident of Dallas, Texas.

12. Defendant AMAZON SERVICES LLC (“AMAZON) is and at all times relevant to this action
was a corporation doing business in Dallas, Texas.

13. Defendant BDT CAPITAL PARTNERS LLC (“WHATABURGER’”) is and at all times

relevant to this action was a corporation doing business as Whataburger in Dallas, Texas.

-2-

PLAINTIFF RYAN WOODSON’S COMPLAINT

Case 3

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14. Defendant MARRIOTT INTERNATIONAL, INC. (“MARRIOTT”) is and at all times relevant
to this action was a corporation doing business as Fairfield Inn & Suites (’Fairfield”) in Dallas, Texas.
15. Defendant SNL ASSOCIATES, INC. (“SNL”) is and at all times relevant to this action was a
California corporation doing business as Pagewood Townhomes ("Pagewood”) in Dallas, Texas.

16. | PLAINTIFF is presently unaware of the true identities and capacities of the Defendants sued
herein by the fictitious names DOES 1 through 20, inclusive. PLAINTIFF is informed and

believes and based thereon alleges that each such fictitiously named DOE Defendant is legally

liable to him for their acts, omissions, and for their involvement in the events and transactions

on which this action is based. PLAINTIFF will amend this Complaint when he ascertains the true

names and capacities of the fictitiously named DOE Defendants.

JURISDICTION
17. Dallas County District Court is the proper jurisdiction because the events that form the basis
of PLAINTIFF’s Complaint occurred in Dallas County, Texas and PLAINTIFF and DEFENDANTS
are residents of, located in, or doing business in Dallas County, Texas.

FACTUAL ALLEGATIONS

Meth Cooking Police Calls Against Organized Crime Relatives of Defendants

18. In April 2019, PLAINTIFF leased a house from Isaac Laufer (“Laufer”) in Redondo Beach,
California. Laufer fraudulently concealed to PLAINTIFF that he was close relatives of the founders of
Whitey Bulger’s Winter Hill Gang, the McLeans. In 2021, the Department of Justice sued Laufer for
embezzling over $100 billion from Medicare through several nursing homes he operated in New York
and Laufer’s brother was indicted for a $20 million fraudulent car wreck insurance scheme. Laufer also
fraudulently concealed that he was related to his tenants next door at 1007 S. Prospect Avenue who
began cooking meth daily.

19. JEFF WOODSON is related to the tenants, the Wells, who are close relatives of Beau

Hershberger (“Hershberger”) who was indicted in a $10 million drug bust several years before. JEFF

-3-

PLAINTIFF RYAN WOODSON’S COMPLAINT

Case 3

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WOODSON fraudulently concealed to PLAINTIFF that he was related to these individuals. In
September 2020, PLAINTIFF called 911 to report the neighbors’ meth cooking to the

RBPD and called the RBPD on the neighbors several more times through 2020. JEFF WOODSON
conspired with Laufer to lease the property to PLAINTIFF in order to get PLAINTIFF arrested.

20. ‘In retaliation against PLAINTIFF for calling the police on their meth cooking and dealing,
Laufer conspired with Simeon Hixson (“Hixson”), a close relative of Hershberger, to lease a property
to PLAINTIFF in May 2021 to frame him for a crime and get him arrested. Furthermore, Hixson is a
relative of KATHERINE WOODSON who conspired with Hixson to lease the property to PLAINTIFF
in order to get PLAINTIFF arrested on a criminal frame job.

21. After moving into the Hixson property, PLAINTIFF noticed meth cooking immediately by his
co-tenant. Subsequently, Hixson’s tenants and others attempted to frame PLAINTIFF for a crime by
staging an attempted break-in and unlawfully and fraudulently blaming PLAINTIFF, but the unlawful
attempt was thwarted by a person witnessing the incident.

22. Subsequently, JEFF WOODSON, KATHERINE WOODSON, Laufer, and Hixson conspired
with others to lease a property to PLAINTIFF in Manhattan Beach, California to retaliate against
PLAINTIFF by again trying to frame him for a crime and get him arrested. PLAINTIFF was forced to
file for a temporary restraining order and was later illegally detained by a MBPD officer who was a
relative of Hershberger, Laufer, and Hixson.

23. PLAINTIFF believes that JEFF WOODSON, KATHERINE WOODSON, MORRIS,
LEMASTERS, Laufer, Hixson, and others are involved in meth trafficking through the federally
indicted The Order cult aka The Kingston Clan, the Mormon church, and/or the Church of Scientology
and are associated with the drug cartels the Knights Templar, Gomez Martinez cartel, Martin-Story
gang, Sinaloa cartel, and other drug cartels. PLAINTIFF has sued Laufer, Hixson, RBPD, HBPD,
MBPD, and other defendants in related cases in California.

24. | PLAINTIFF was immediately stalked by multiple individuals on the street of KATHERINE
WOODSON and MORRIS including but not limited to multiple members of MORRIS’S family. This
even forced PLAINTIFF to cease walking his dog on the street and hire a dog walker.

-4.

PLAINTIFF RYAN WOODSON’S COMPLAINT

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JANUARY 2023 MURDER ATTEMPTS

25. Prior to returning to Dallas, PLAINTIFF discovered that Defendant DAVID LEE (“LEE”),
who was the private investigator of a California law firm from which PLAINTIFF obtained a monetary
settlement, had married KATHERINE WOODSON’s next door neighbor on the other side from
MORRIS named MARIELLE LEMASTERS. WILLIAM LEMASTERS owns the townhouse. All
three adjacent townhomes are located in Pagewood Townhomes.

26. On December 31, 2022, PLAINTIFF returned to Dallas from Manhattan Beach and arrived late
in the evening. The first and second times he left KATHERINE WOODSON's townhouse, he was
followed, stalked, and assaulted by multiple family members of MORRIS. The second time, a family
member of MORRIS made a false police report on PLAINTIFF in an attempt to frame him for a crime.
27. On January 5, 2023, JEFF WOODSON invited PLAINTIFF to lunch at private Royal Oaks
Country Club, which he later changed to public Backyard Barbeque on Greenville Avenue. In the
parking lot after lunch, PLAINTIFF was intentionally blocked in his parking space by three cars who
PLAINTIFF believes intended on shooting or assaulting him. PLAINTIFF later identified some of the
individuals to be relatives of MORRIS, neighbor Elizabeth Murray, and other neighbors including one
related to the KATHERINE WOODSON’s Martin family, Jason Martin Caswell ("Martin Caswell").
Later in the afternoon of January 5, 2023, Martin Caswell made another attempt to kill or assault
PLAINTIFF on or near the Northhaven Trail.

28. On January 6, 2023, PLAINTIFF took his dog to Churchill Park on Forest Lane south of LBJ
freeway. PLAINTIFF was followed to a nearby office parking lot where three cars again attempted to
block him in a parking space by individuals who PLAINTIFF believes are related to MORRIS,
Murray, and included Martin Caswell. PLAINTIFF believes that they intended on shooting or
assaulting him.

29. On January 7, 2023, PLAINTIFF took his dog to the vet on Preston and LBJ to treat injuries he
sustained from the driving PLAINTIFF had to do to escape these individuals. When returning.
KATHERINE WOODSON suggested they go to WHATABURGER drive through on Forest and

Central. When arriving, the only car in the drive through was an African American individual who

5.

PLAINTIFF RYAN WOODSON’S COMPLAINT

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PLAINTIFF later learned was Marcus Morris, another relative of MORRIS and a police officer for
DISD and possibly also DPD.

30. | When WHATABURGER unusually instructed both cars to move forward to wait for their food,
a large white pickup that PLAINTIFF believes was driven by another relative of MORRIS pinned
them in from behind while a car driven by Martin Caswell parked off the rear, right bumper of
KATHERINE WOODSON’s car with PLAINTIFF in the front passenger seat. Again, PLAINTIFF
believes that they intended on shooting or assaulting him. PLAINTIFF believes that the
WHATABURGER drive through employee was a Morris and this location employed other Morris’s.
31. | Subsequently over the next several days, PLAINTIFF continued to be stalked, followed, and
assaulted by neighbors of KATHERINE WOODSON and MORRIS and others. PLAINTIFF observed
many individuals on or around the street with earpieces or monitoring their cell phones for direction.
PLAINTIFF later discovered that KATHERINE WOODSON had numerous hidden cameras and audio
devices placed in her townhouse in order for she, MORRIS, LEMASTERS, LEE, Murray, and others
to monitor and direct others to follow, stalk, and assault.

32. | PLAINTIFF also discovered that MORRIS had illegally arranged for every one of the
approximate ten deliverymen on the street to be Morris’s including but not limited to United States
postal, AMAZON, Fed Ex, and UPS employees. MORRIS illegally conspired with employees of these
companies to make these arrangements. On numerous occasions from January 2023 through the
present, MORRIS, LEMASTERS, LEE, Murray, and others directed these people to drive up near
KATHERINE WOODSON’s townhouse when they observed on the hidden cameras that PLAINTIFF
was leaving to illegally attempt to frame him for a crime.

33. They or other neighbors intended on claiming PLAINTIFF did something illegal with the other
deliverymen or neighbors to be lying witnesses to a fabricated crime. MORRIS, LEMASTERS, LEE,
Murray, and others also used other companies for frame attempts such as DART and Waste
Management, which are controlled or managed by Morris’s. PLAINTIFF made multiple police reports
on these individuals and companies, which DPD also failed to investigate at all.

34. | AMAZON, these deliverymen and other workers, and these companies fraudulently concealed

to PLAINTIFF that they were conspiring with Defendants to frame him for a crime, or at a minimum

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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1 || acted negligently. AMAZON also failed to exercise reasonable care in, inter alia, hiring these workers,

2 || training them, and supervising them.

3 |{35. Therefore, PLAINTIFF left the house of KATHERINE WOODSON. PLAINTIFF was then

4 || followed and stalked by their neighbors and members of their criminal group to multiple other cities in

5 || Texas where PLAINTIFF believes several other attempted murders and assaults occurred at motels and

6 || other locations.

7 |{36. Then, PLAINTIFF returned to KATHERINE WOODSON’s townhouse because it would be

8 || relatively safer than a motel and PLAINTIFF did not have the financial resources or employment to

9 || purchase or lease a stand alone house. PLAINTIFF continued to be followed and stalked by neighbors
10 |}of KATHERINE WOODSON, MORRIS, and LEMASTERS and the deliverymen.
11 |}37. |Onor about March 1, 2023, PLAINTIFF posted on Facebook that he was almost shot on
12 || January 5, 6, and 7, 2023 and nearly killed at several different motels. On or about March 8, 2023,
13 || PLAINTIFF reported the attempted murders on January 5, 6, and 7, 2023 to DPD Detective
14 || BARCLAY. BARCLAY failed to respond to PLAINTIFF’s attempted murder reports by email, phone,
15 || or in person.
16 }}38. = In April 2023, PLAINTIFF left KATHERINE WOODSON’s townhouse and traveled to Las
17 || Vegas, Nevada in order to obtain affordable housing while he looked online for a job in California. In
18 || or about October 2023, PLAINTIFF returned to California. In Las Vegas and California, PLAINTIFF
19 || was also followed and stalked by members of Defendants’ group where they continued to attempt to
20 || frame him for a crime in retaliation.
21 }}39. In January 2024, PLAINTIFF was forced to return to KATHERINE WOODSON’S townhouse
22 || because his financial resources were depleted and he had no other options to reside. PLAINTIFF
23 || continued to be followed and stalked by members of Defendants’ group including numerous Morris's
24 || including family members of Marcus Morris and other DPD officers. In or about February 2024,
25 || PLAINTIFF discovered numerous hidden cameras and audio devices in KATHERINE WOODSON’s
26 || house.
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Case 3]25-cv-01748-G-BT Document 24 _ Filed 02/12/26 Page3/7of54 PagelD <pagelD>

1 || MAY 1, 2024 ILLEGAL IMPERSONATION OF DPD OFFICERS
40. | On May 1, 2024, alleged members of the DPD knocked on the front door of KATHERINE
WOODSON’s townhouse while PLAINTIFF was there alone. There were three alleged DPD officers

ho

and three DPD sedan cars. One African American alleged DPD officer stated they were there to do a
welfare check because someone had allegedly reported that PLAINTIFF was stating he was about to
be killed by the Kingston Clan.

41. | PLAINTIFF later discovered that the African American alleged DPD officer was the relative of

Marcus Morris and was not a DPD officer. He was criminally impersonating a DPD officer in order to

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falsely arrest, assault, or murder PLAINTIFF. PLAINTIFF also believes the other two white, alleged
10 || DPD officers were not police officers and were also illegally impersonating DPD officers. They had
11 || evidently been given the DPD police cars, uniforms, badges, and guns by other DPD officers.

12 || MAY 13, 2024 MURDER ATTEMPTS

13 |}42. Several days later, PLAINTIFF discovered on his hacked and monitored cell phone that JEFF
14 || WOODSON and he are, or JEFF WOODSON believes he is, descendants of the Norman Hauteville
15 || that conquered Southern Italy and Sicily in the 11th century by driving out the Muslims.

16 |}43. On May 13, 2024, KATHERINE WOODSON, MORRIS, MARIELLE LEMASTERS, and

17 || LEE retaliate against PLAINTIFF by trying to murder or assault and battery PLAINTIFF in

18 || KATHERINE WOODSON’s house. Accordingly, PLAINTIFF called 911 to have the DPD intervene.
19 ||44. — Subsequently, two DPD sedan cars and three DPD alleged officers came to KATHERINE

20 |} WOODSON’s townhouse. However, there were again multiple individuals illegally impersonating

21 || DPD officers. All three of the alleged DPD officers had last names connected to the Hauteville family
22 || including two with the same last names as JEFF WOODSON’s former employees, Bailey and

23 || Vasquez.

24 1/45. In addition, the DPD Internal Affairs Department confirmed to PLAINTIFF that there are no
25 || DPD officers with the last name of the other alleged officer, Tanksworth. Therefore, PLAINTIFF

26 || believes that Defendants’ group may have diverted his cell phone 911 call, intercepted it, and sent

27 || people impersonating DPD officers or the DPD conspired with them directly.

-8-

PLAINTIFF RYAN WOODSON’S COMPLAINT

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46. The alleged officers were illegally given DPD cars, guns, uniforms, and badges. The alleged
DPD officers failed to question MORRIS at all and only went to the door of the LEMASTERS
townhouse briefly. They also failed to inspect any part of KATHERINE WOODSON’s townhouse.
47. Furthermore, PLAINTIFF left the townhouse about 3:00 a.m. to go toa MARRIOTT hotel, the
Fairfield Inn, and was illegally followed and stalked there by multiple family members of MORRIS to
finish the job. There were also multiple members of MORRIS’s family at this Fairfield Inn conspiring
to assault or kill PLAINTIFF. This fully confirmed that MORRIS, KATHERINE WOODSON,
LEMASTERS, and LEE intended to murder or cause serious harm to PLAINTIFF at KATHERINE
WOODSON’s townhouse.
48. Additionally, it was certainly no coincidence that the Morris’s were there and they were not
there to assist PLAINTIFF in any manner. It also confirms that the DPD intentionally failed to
investigate PLAINTIFF’s attempted murder 911 call and sent him to his death at the Fairfield Inn.
Their malicious intentions were further confirmed when PLAINTIFF was followed and stalked the
next several weeks by family members of MORRIS, Vasquez, and Bailey.
49. On or about Friday, May 24, 2024, PLAINTIFF went to the DPD's downtown location to
discuss his attempted murder reports with a DPD detective and was followed and stalked there by a
Vasquez family member. Prior to entering the building, Vasquez entered.
50. | When PLAINTIFF requested through a DPD officer at the front desk to speak with a detective,
he intentionally lied and stated that no detectives are available the rest of the day and would not be
available to discuss PLAINTIFF's attempted murder report until four days later after Memorial Day.
FIRST CAUSE OF ACTION — CONSPIRARCY
(Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, LEE,
MARRIOTT, WHATABURGER, and AMAZON)

51. PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in the Complaint as though fully set forth at length again.
52. Defendants conspired with each other and other individuals to follow, harass, stalk, frame,
falsely imprison, cause severe emotional distress, assault, and attempt to kill PLAINTIFF in retaliation

for his police reports, 911 calls, and other communications and acts regarding their drug dealing

-9-

PLAINTIFF RYAN WOODSON’S COMPLAINT

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organizations. They met, communicated, and planned the conspiracy with the object or course of
action to be follow, harass, stalk, frame, falsely imprison, cause severe emotional distress, assault, and
attempt to kill PLAINTIFF.
53. Accordingly, Defendants are jointly and severally liable for all of the unlawful acts of their
co-conspirators, including unnamed defendants, in furtherance of the conspiracy. This includes, but is
not limited to, all of Defendants’ co-conspirators who were directed by Defendants to follow, harass,
stalk, frame, falsely imprison, cause severe emotional distress, assault, and attempt to kill PLAINTIFF.
54. | Defendants committed numerous unlawful, overt acts in furtherance of their conspiracy that
proximately caused PLAINTIFF damages including, but not limited to, general and compensatory
damages, punitive damages, damages to PLAINTIFF’s body and physical health, attorneys’ fees, fees
and costs, and severe emotional distress and mental anguish.
SECOND CAUSE OF ACTION — FRAUD
(Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, GARCIA,
BARCLAY, MARRIOTT, AMAZON, and WHATABURGER)

55. | PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in this Complaint as though fully set forth at length again.
56. | From January 1, 2023 through the present through in-person, telephone, text, or email
communications in Dallas, Texas and/or with PLAINTIFF while he was in Las Vegas, Nevada or
Southern California, JEFF WOODSON, KATHERINE WOODSON, and MORRIS fraudulently
misrepresented and concealed to PLAINTIFF the following material information:

- that they were conspiring with MORRIS, LEMASTERS, and LEE to frame him for a
crime or kill him to cover up their association with Laufer, Hixson, and other drug dealers.

- they were related to his California landlords Laufer and Hixson and that they conspired
with them to frame him for a crime in retaliation for his police reports against them.

. they had arranged for the private investigator of PLAINTIFF'S former law firm, LEE, to

frame him or kill him

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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- they had placed numerous hidden cameras and audio devices in KATHERINE
WOODSON's townhouse, in PLAINTIFF'S car, and hacked his cell phone and computer in order to
frame him for a crime or kill him
- they had conspired with MORRIS, LEMASTERS, and LEE to monitor the hidden cameras,
track PLAINTIFF's movements, and direct neighbors and others to follow and stalk him in order to
frame him for a crime

- they conspired with members of the MORRIS and Murray families, Jason Martin
Caswell ,and WHATABURGER to have PLAINTIFF assaulted or killed at Backyard Barbeque on
January 5, 2023, near Churchill Park on January 6, 2023, and at WHATABURGER on January 7, 2023
they were involved in the Martin-Story Gang, a version of the Jesse Woodson James organization, and
other drug cartels

- they conspired with the DPD and City of Dallas to have the DPD refuse to investigate
PLAINTIFF's multiple police reports of attempted murder and crime frame attempts

- they lied about the death of multiple relatives and family friends in order to postpone
PLAINTIFF from filing police reports and a lawsuit against them

- they had arranged for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in January 2023 and attempt to frame or kill him in retaliation

- they had arranged for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in April 2023 to Las Vegas, Nevada and California and attempt to
frame or kill him in retaliation

- they had arranged for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in March 2024 to Las California and attempt to frame or kill him in
retaliation

- they conspired with MORRIS, LEMASTERS, LEE, and the DPD to have fake DPD
officers go to KATHERINE WOODSON's townhouse on May 1, 2024 for an alleged welfare check on
PLAINTIFF

- they attempted with MORRIS, LEMASTERS, and LEE to murder PLAINTIFF at
KATHERINE WOODSON's townhouse on May 13, 2024

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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- they conspired with MORRIS, LEMASTERS, LEE, DPD, the Bailey family, the
Vasquez family, and the Tanksworth family to have fake DPD officers respond to PLAINTIFF's 911
call of attempted murder

- they conspired with MORRIS, LEMASTERS, LEE, DPD, the Bailey family, the
Vasquez family, and others to follow, stalk, assault PLAINTIFF, and attempt to frame him for a crime
in Dallas, California and other states after his May 13, 2024 911 call and previous police reports
57. From March 2023 through the present, GARCIA and BARCLAY fraudulently concealed to
PLAINTIFF that they were conspiring with JEFF WOODSON, KATHERINE WOODSON, MORRIS,
and others to intentionally refuse to investigate PLAINTIFF's multiple reports of attempted murder and
crime framing.

58. Despite PLAINTIFF providing the name, address, photograph of the attempted shooter,
identities of individuals who impersonated DPD officers and detailed other information, DPD,
GARCIA, and BARCLAY intentionally failed to make a single phone call, email, text, in-person visit,
or take any other action to investigate PLAINTIFF's police reports. Their actions were outside the
scope of their employment with DPD and/or CITY OF DALLAS so this cause of action is not subject
to any tort claim act.

59. From January 1, 2023 through the present in Dallas, Texas, employees of AMAZON who had
authority to act and speak on its behalf fraudulently concealed to PLAINTIFF multiple times that it and
its employees were conspiring with JEFF WOODSON, KATHERINE WOODSON, MORRIS, and
others to intentionally attempt to frame him for a crime.

60. On January 7, 2023 in Dallas, Texas, employees at WHATABURGER who had authority to act
and speak on its behalf fraudulently concealed to PLAINTIFF that it and its employees were
conspiring with JEFF WOODSON, KATHERINE WOODSON, MORRIS, and others to intentionally
attempt to kill him, assault him, or frame him for a crime.

61. On May 13, 2024 in Dallas, Texas, employees at MARRIOTT who had authority to act and
speak on its behalf fraudulently concealed to PLAINTIFF that it and its employees at Fairfield Inn
were conspiring with JEFF WOODSON, KATHERINE WOODSON, MORRIS, and others to

intentionally attempt to kill him, assault him, or frame him for a crime.

-]2-

PLAINTIFF RYAN WOODSON’S COMPLAINT

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62. | MARRIOTT fraudulently misrepresented and concealed to PLAINTIFF that the Fairfield Inn
was placing PLAINTIFF on May 13. 2024 in a hotel room adjacent to members of the MORRIS
family who had followed and stalked him there after his 911 call for attempted murder in order for the
MORRIS family to cause PLAINTIFF substantial harm. MARRIOTT also fraudulently misrepresented
and concealed to PLAINTIFF that the Fairfield Inn had members of the MORRIS family fraudulently
impersonating employees to cause PLAINTIFF substantial harm.
63. | JEFF WOODSON, KATHERINE WOODSON, MORRIS, GARCIA, BARCLAY, AMAZON,
WHATABURGER, and MARRIOTT made all of these false statements and fraudulent concealments
to PLAINTIFF, knew that the fraudulent statements representations him were false when they were
made, they intended that PLAINTIFF rely on the fraudulent representations and fraudulent
concealments, PLAINTIFF reasonably and justifiably relied on the fraudulent representations,
PLAINTIFF suffered substantial harm, and PLAINTIFF’s reliance on the fraudulent representations
was a substantial factor in causing him substantial harm.
THIRD CAUSE OF ACTION —- NEGLIGENCE
(Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS,
WILLIAM LEMASTERS, LEE, AMAZON, WHATABURGER, MARRIOTT, and SNL)

64. | PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in this Complaint as though fully set forth at length again.
65. JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, WILLIAM
LEMASTERS, LEE, AMAZON, WHATABURGER, MARRIOTT, and SNL (collectively "Negligent
Defendants") owed PLAINTIFF a legal duty to exercise reasonable care in connection with their
dealings with PLAINTIFF. The Negligent Defendants breached their legal duty to PLAINTIFF by
negligently acting and conspiring to do the following:

- Frame PLAINTIFF for a crime or kill him to cover up their association with Laufer,
Hixson, and other drug dealers.

- Negligently acting and conspiring with their relative California landlords Laufer and

Hixson to frame him for a crime in retaliation for his police reports against them.

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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- Arranging for the private investigator of PLAINTIFF'S former law firm, LEE, to enter
into a relationship with KATHERINE WOODSON 's next door neighbor LEMASTERS to frame or kill
PLAINTIFF

- Placing numerous hidden cameras and audio devices in KATHERINE WOODSON's
townhouse, in PLAINTIFF'S car, and hacking his cell phone and computer in order to frame him for a
crime or kill him

- Illegally monitor the hidden cameras, track PLAINTIFF's movements, and direct
neighbors and others to follow and stalk him in order to frame him for a crime

- Conspiring with members of the MORRIS and Murray families and Jason Martin
Caswell to have PLAINTIFF assaulted or killed at Backyard Barbeque on January 5, 2023, near
Churchill Park on January 6, 2023, and at WHATABURGER on January 7, 2023

- Being involved in or be members of the Martin-Story Gang, a version of the Jesse
Woodson James organization, and other drug cartels

- Conspiring with the DPD and City of Dallas to have the DPD refuse to investigate
PLAINTIFF's multiple police reports of attempted murder and crime frame attempts

- Lying about the death of a family member and a family friend in order to postpone
PLAINTIFF from filing police reports and a lawsuit against them

- Arranging for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in January 2023 and attempt to frame or kill him in retaliation

- Arranging for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in April 2023 to Las Vegas, Nevada and California and attempt to
frame or kill him in retaliation

- Arranging for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in March 2024 to Las California and attempt to frame or kill him in
retaliation

- Conspiring to have fake DPD officers go to KATHERINE WOODSON's townhouse on
May 1, 2024 for an alleged welfare check on PLAINTIFF

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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- Attempting to murder PLAINTIFF at KATHERINE WOODSON 's townhouse on May
13, 2024

- Conspiring with the DPD, the Bailey family, the Vasquez family, and the Tanksworth
family to have fake DPD officers respond to PLAINTIFF's 911 call of attempted murder

- Conspiring with the DPD, the Bailey family, the Vasquez family, and others to follow,
stalk, assault PLAINTIFF, and attempt to frame him for a crime in Dallas, California and other states
after his May 13, 2024 911 call and previous police reports
66. As the owner of the LEMASTERS' townhouse, WILLIAM LEMASTERS had a legal duty to

properly screen who was living there, properly supervise their activities, provide adequate security, and

ensure that his tenants were not engaged in criminal conduct to frame, injure, or kill PLAINTIFF.

67. AMAZON negligently concealed to PLAINTIFF multiple times that it and its employees were
conspiring with JEFF WOODSON, KATHERINE WOODSON, MORRIS, and others to intentionally
attempt to frame him for a crime. AMAZON breached its duty to PLAINTIFF to exercise reasonable
care and refrain from acting negligently by failing to properly hire, train, and supervise its employees.
68. On January 7, 2023 in Dallas, Texas, WHATABURGER negligently concealed to PLAINTIFF
that it and its employees were conspiring with JEFF WOODSON, KATHERINE WOODSON,
MORRIS, and others to intentionally attempt to kill him, assault him, or frame him for a crime.
WHATABURGER breached its duty to PLAINTIFF to exercise reasonable care and refrain from
acting negligently by failing to properly hire, train, and supervise its employees.

69. MARRIOTT breached its duty to PLAINTIFF to exercise reasonable care and refrain from
acting negligently by failing to provide him with a habitable hotel room; properly screen hotel guests;
not interfere with PLAINTIFF’S use and peaceful enjoyment of the hotel room; refrain from
intentionally placing PLAINTIFF in a hotel room adjacent to members of the MORRIS family who
had followed and stalked him there after his 911 call for attempted murder in order for the MORRIS
family to cause PLAINTIFF substantial harm; refrain from permitting members of the MORRIS
family to fraudulently impersonate employees; refrain from placing other members of the MORRIS
family in the hotel to cause PLAINTIFF substantial harm; properly hire and supervise its employees;
and, failing to provide adequate security.

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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1 ||70. | SNL breached its duty to PLAINTIFF to exercise reasonable care and refrain from acting

2 || negligently by failing to properly screen the purchasers of its townhomes, supervise the activities of the

eS)

townhouse owners and others on the property, provide adequate security, and construct the townhouses
to provide security to owners and guests.

71. Negligent Defendants' breaches as alleged above were a substantial factor as well as a direct
and legal cause of the damages and harm suffered by PLAINTIFF.

72. | PLAINTIFF’s damages include, but are not limited to, general and compensatory damages,

punitive damages, damages to PLAINTIFF’s body and physical health, attorneys’ fees, fees and costs,

oO manny DN

and severe emotional distress that includes PLAINTIFF’s mental suffering, mental anguish, fright,
10 || horror, nervousness, grief, anxiety, worry, shock, humiliation, and shame that an ordinary, reasonable

11 || person would be unable to cope with it. PLAINTIFF’s damages for MARRIOTT'S negligence

12 || substantially exceeds his economic damages for MARRIOTT'S breaches of contract.

13 FOURTH CAUSE OF ACTION —- NEGLIGENT MISREPRESENTATION

14 (Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS,
15 WILLIAM LEMASTERS, LEE, AND MARRIOTT)

16

17 ||73. | PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every

18 || previously alleged paragraph in this Complaint as though fully set forth at length again.

19 ||74. JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, WILLIAM

20 |} LEMASTERS, LEE, AND MARRIOTT (collectively "Negligent Defendants") owed PLAINTIFF a
21 || legal duty to exercise reasonable care in connection with their dealings with PLAINTIFF.

22 ||75. The Negligent Defendants negligently misrepresented or negligently concealed to PLAINTIFF
23 |{all of the preceding material information in the Negligence cause of action.

24 ||76. As the owner of the LEMASTERS' townhouse, WILLIAM LEMASTERS had a legal duty to
25 || properly screen who was living there, properly supervise their activities, provide adequate security, and
26 || ensure that his tenants were not engaged in criminal conduct to frame, injure, or kill PLAINTIFF.

27 ||77. MARRIOTT negligently represented or negligently concealed to PLAINTIFF that it was

28 || failing to provide him with a habitable hotel room; properly screen hotel guests; not interfere with

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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PLAINTIFF’S use and peaceful enjoyment of the hotel room; refrain from intentionally placing
PLAINTIFF in a hotel room adjacent to members of the MORRIS family who had followed and
stalked him there after his 911 call for attempted murder in order for the MORRIS family to cause
PLAINTIFF substantial harm; refrain from permitting members of the MORRIS family to fraudulently
impersonate employees; refrain from placing other members of the MORRIS family in the hotel to
cause PLAINTIFF substantial harm; properly hire and supervise its employees; and, failing to provide
adequate security.

78. Defendants made all of these negligent statements and negligent concealments to PLAINTIFF,
knew that the fraudulent misrepresentations were false when they were made, they intended that
PLAINTIFF rely on the negligent representations and negligent concealments, PLAINTIFF reasonably
and justifiably relied on the negligent misrepresentations, PLAINTIFF suffered substantial harm
caused by their negligent misrepresentations, and PLAINTIFF’s reliance on the negligent
misrepresentations was a substantial factor in causing him substantial harm and damages.

79. | PLAINTIFF’s damages include, but are not limited to, general and compensatory damages,
punitive damages, damages to PLAINTIFF’s body and physical health, attorneys’ fees, fees and costs,
and severe emotional distress that includes PLAINTIFF’s mental suffering, mental anguish, fright,
horror, nervousness, grief, anxiety, worry, shock, humiliation, and shame that an ordinary, reasonable
person would be unable to cope with it. PLAINTIFF’s damages for MARRIOTT'S negligence
substantially exceeds his economic damages for MARRIOTT'S breaches of contract.

FIFTH CAUSE OF ACTION — ASSAULT
(Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, LEE,
AND MARRIOTT)

80. | PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in this Complaint as though fully set forth at length again.

81. JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, LEE, AND
MARRIOTT (collectively "Assaulting Defendants") assaulted PLAINTIFF by intentionally
committing the following acts:

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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- Attempting to frame PLAINTIFF for a crime or kill him to cover up their association
with Laufer, Hixson, and other drug dealers.

- Negligently acting and conspiring with their relative California landlords Laufer and
Hixson to frame him for a crime in retaliation for his police reports against them.

- Arranging for the private investigator of PLAINTIFF'S former law firm, LEE, to enter
into a relationship with KATHERINE WOODSON 's next door neighbor LEMASTERS to frame or kill]
PLAINTIFF

- Placing numerous hidden cameras and audio devices in KATHERINE WOODSON's
townhouse, in PLAINTIFF'S car, and hacking his cell phone and computer in order to frame him for a
crime or kill him

- Illegally monitor the hidden cameras, track PLAINTIFF's movements, and direct
neighbors and others to follow and stalk him in order to frame him for a crime

: Conspiring with members of the MORRIS and Murray families and Jason Martin
Caswell to have PLAINTIFF assaulted or killed at Backyard Barbeque on January 5, 2023, near
Churchill Park on January 6, 2023, and at WHATABURGER on January 7, 2023

- Be involved in or be members of the Martin-Story Gang, a version of the Jesse
Woodson James organization, and other drug cartels

- Conspiring with the DPD and City of Dallas to have the DPD refuse to investigate
PLAINTIFF's multiple police reports of attempted murder and crime frame attempts

- Lying about the death of a family member and family friend in order to postpone
PLAINTIFF from filing police reports and a lawsuit against them

- Arranging for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in January 2023 and attempt to frame or kill him in retaliation

- Arranging for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in April 2023 to Las Vegas, Nevada and California and attempt to

frame or kill him in retaliation

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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- Arranging for members of their affiliated criminal gangs to follow and stalk
PLAINTIFF when he left Dallas in March 2024 to Las California and attempt to frame or kill him in
retaliation

- Conspiring to have fake DPD officers go to KATHERINE WOODSON's townhouse on
May 1, 2024 for an alleged welfare check on PLAINTIFF

- Attempting to murder PLAINTIFF at KATHERINE WOODSON's townhouse on May
13, 2024

- Conspiring with the DPD, the Bailey family, the Vasquez family, and the Tanksworth
family to have fake DPD officers respond to PLAINTIFF's 911 call of attempted murder

- Conspiring with the DPD, the Bailey family, the Vasquez family, and others to follow,
stalk, assault PLAINTIFF, and attempt to frame him for a crime in Dallas, California and other states
after his May 13, 2024 911 call and previous police reports
82. Defendants’ intentional acts caused PLAINTIFF to reasonably apprehend imminent, harmful or
offensive contacts by Defendants and their co-conspirators. Defendants had the apparent ability to
carry out the numerous, continuous threats of harm and PLAINTIFF clearly did not consent to
Defendants’ intentional acts.
83. | PLAINTIFF’s damages for numerous assaults include, but are not limited to, general and
compensatory damages, punitive damages, damages to PLAINTIFF’s body and physical health,

attorneys’ fees, fees and costs, and severe emotional distress.

SIXTH CAUSE OF ACTION — STALKING
(Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, and
LEE)
84. PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in the Complaint as though fully set forth at length again.
85. | On numerous occasions, Defendants engaged in harassing behavior toward PLAINTIFF that
was reasonably likely to harass, annoy, alarm, abuse, torment, or embarrass him. As a result, he

reasonably feared for his safety. Further, Defendants while engaged in the harassing behavior toward

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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PLAINTIFF by acts or words threatened to inflict bodily injury on him or to commit an offense against
PLAINTIFF or to his property.
86. Defendants had the apparent ability to carry out the threat, Defendants’ apparent ability to carry
out the threat caused PLAINTIFF to reasonably fear for his safety. PLAINTIFF demanded multiple
times clearly demanded that Defendants’ stop their harassing behavior. However, after the demands by
PLAINTIFF, Defendants’ continued the harassing behavior. PLAINTIFF reported Defendants'
harassing behavior to the DPD, but DPD refused to take any action against Defendants yet again.
87. Stalking Defendants conspired with neighbors and others to stalk PLAINTIFF and formed,
operated, and took action to further the conspiracy by monitoring the illegal hidden cameras in
KATHERINE WOODSON's townhouse and directing others to follow, stalk, and cause harm to
PLAINTIFF. Therefore, Stalking Defendants are liable for the acts of the co-conspirators who
followed, stalked, assaulted, and caused harm to PLAINTIFF.
88. | PLAINTIFF’s damages for Defendants' illegal stalking include, but are not limited to, general
and compensatory damages, punitive damages, damages to PLAINTIFF’s body and physical health,
attorneys’ fees, fees and costs, and severe emotional distress.
SEVENTH CAUSE OF ACTION — FALSE IMPRISONMENT
(Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, and
LEE)

89. | PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in the Complaint as though fully set forth at length again.
90. Due to Defendants continuously and illegally monitoring PLAINTIFF's movements on hidden
cameras and either following, stalking, assaulting, and attempting to frame PLAINTIFF for a crime, or
directing others to follow, stalk, assault, and try to frame him for a crime, Defendants intentionally
restricted PLAINTIFF's freedom of movement by making him apprehensive and forcing him to not
leave his residence and confine him in the residence in order to avoid their following, stalking,
assaulting, and attempting to frame him for a crime.
91. | PLAINTIFF did not consent to being confined in his residence that was caused by Defendants'

intentional conduct. Defendants' action were without lawful authority and PLAINTIFF was certainly

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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aware of the intentionally caused confinement in his residence because he wanted to leave the
residence and live a normal life.
92. | PLAINTIFF suffered harm and damages caused by Defendants' false imprisonment including.
but not limited to, general and compensatory damages, punitive damages, damages to PLAINTIFF’s
body and physical health, attorneys’ fees, fees and costs, and severe emotional distress and mental
anguish.
EIGHTH CAUSE OF ACTION — INTENTIONAL INFLICTION OF EMOTIONAL
DISTRESS
(Against Defendants JEFF WOODSON, KATHERINE WOODSON, MORRIS, LEMASTERS, LEE,
and MARRIOTT)

93. | PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in the Complaint as though fully set forth at length again.
94. | DEFENDANTS?’ intentional conduct was outrageous; DEFENDANTS intended to cause
PLAINTIFF emotional distress or DEFENDANTS acted with reckless disregard of the probability that
PLAINTIFF would suffer emotional distress; DEFENDANTS knew that PLAINTIFF was present
when the conduct occurred; PLAINTIFF suffered severe emotional distress; and DEFENDANTS’
conduct was a substantial factor in causing PLAINTIFF’s severe emotional distress.
95. PLAINTIFF’s severe emotional distress includes, but is not limited to, PLAINTIFF’s mental
suffering, mental anguish, fright, horror, nervousness, grief, anxiety, worry, shock, humiliation, and
shame that an ordinary, reasonable person would be unable to cope with it. PLAINTIFF’s damages for
Defendants’ intentional infliction of emotional distress substantially exceeds his economic damages for
Defendants’ MARRIOTT's breaches of contract.

NINTH CAUSE OF ACTION — VIOLATION OF 42 U.S.C. sec. 1983

(Against Defendants DPD and CITY OF DALLAS)

96. PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in the Complaint as though fully set forth at length again.
97. DPDand CITY OF DALLAS, at all times relevant herein subjected PLAINTIFF to conduct

that occurred under color of state law, including but not limited to, under color of the statute,

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PLAINTIFF RYAN WOODSON’S COMPLAINT

Case 3]25-cv-01748-G-BT Document 24 _ Filed 02/12/26 Page51lof54 PagelD <pagelD>

1 || ordinance, regulation, custom, or usage, of Texas.

2 1198. DPD and CITY OF DALLAS subjected, or caused to be subjected, PLAINTIFF to the

3 || deprivation of his rights, privileges, or immunities secured by the Fourth Amendment to the

4 || Constitution of the United States of America by conducting an illegal search and seizure of

5 || PLAINTIFF, his real property residence, and his personal property without a warrant or probable cause

6 || and used excessive force during the illegal detainment of PLAINTIFF.

7 1199, DPD and CITY OF DALLAS also subjected, or caused to be subjected, PLAINTIFF to the

8 || deprivation of his rights, privileges, or immunities secured by the Fourteenth Amendment to the

9 || Constitution of the United States of America and violated his procedural due process rights by
10 || intentionally refusing to take any action against Defendants regarding PLAINTIFF's multiple DPD
11 || reports on Defendants’ attempts to murder him in January 2023 and May 13, 2024 and their numerous
12 || attempts to illegally frame him for crimes he did not commit.
13 }}100. DPD and CITY OF DALLAS not only failed to make a single phone call or visit to Defendants
14 || to question them on the attempted murders and crime framing, but DPD and CITY OF DALLAS
15 || participated in the criminal activity against PLAINTIFF by attempting to frame him for crimes,
16 || refusing to arrest KATHERINE WOODSON, MORRIS, LEMASTERS, and LEE for attempted
17 || murder, and therefore permitting the MORRIS family to illegally follow and stalk PLAINTIFF to the
18 || Fairfield Inn to finish the job.
19 |}101. CITY OF DALLAS, DPD and its officers unlawfully conspired with JEFF WOODSON,
20 |} KATHERINE WOODSON, MORRIS, LEMASTERS, and LEE to retaliate against PLAINTIFF for
21 ||his police reports by wrongfully detaining him and committing assault, battery, excessive use of force,
22 || and false imprisonment against PLAINTIFF and violating his constitutional rights.
23 |}102. The actions of DPD and CITY OF DALLAS were the direct and proximate cause of the
24 || deprivation of PLAINTIFF’S constitutional rights under the Fourth and Fourteenth Amendments to the
25 || U.S. Constitution, and the substantial harm and damages he suffered.
26
27
28

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PLAINTIFF RYAN WOODSON’S COMPLAINT

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TENTH CAUSE OF ACTION —- BREACH OF CONTRACT
(Against Defendant MARRIOTT)

103. PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in the Complaint as though fully set forth at length again.
104. PLAINTIFF entered into a written contract with MARRIOTT on May 13, 2024 and he fully
performed his obligations under the contract by paying the fee for a one night stay and the deposit.
105. MARRIOTT'S obligations under the written contract included, but were not limited to,
providing PLAINTIFF with a habitable hotel room; properly screen hotel guests; not interfere with
PLAINTIFF’S use and peaceful enjoyment of the hotel room; refrain from intentionally placing
PLAINTIFF on May 13. 2024 in a hotel room adjacent to members of the MORRIS family who had
followed and stalked him there after his 911 call for attempted murder in order for the MORRIS family
to cause PLAINTIFF substantial harm; refrain from permitting members of the MORRIS family to
fraudulently impersonate employees; refrain from placing other members of the MORRIS family in the
hotel to cause PLAINTIFF substantial harm; properly hire and supervise its employees; provide
adequate security; refrain from attempting to frame PLAINTIFF for a crime; and refrain from
intentionally inflicting severe emotional distress on PLAINTIFF.
106. MARRIOTT breached the written contracts by failing to meet any of their obligations as
alleged herein under the contracts.

107. MARRIOTT'S material breaches caused PLAINTIFF substantial damages.

ELEVENTH CAUSE OF ACTION — BREACH OF THE IMLPLIED COVENANT OF GOOD
FAITH AND FAIR DEALING
(Against Defendant MARRIOTT)
108. PLAINTIFF repleads, realleges, and hereby incorporates by reference each and every
previously alleged paragraph in this Complaint as though fully set forth at length again.
109. A breach of contract may be established on the basis of either an express provision of the
contract or on the implied covenant of good faith and fair dealing.

110. Every contract imposes upon each party a duty of good faith and fair dealing in the
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PLAINTIFF RYAN WOODSON’S COMPLAINT

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performance of the contract such that neither party shall do anything which will have the effect of
destroying or injuring the right of either party to receive the benefits of the contract. Under
PLAINTIFF’S contract with MARRIOTT, it was under a duty to perform in good faith and fair dealing
so PLAINTIFF was not deprived of the benefits of the written contract.

111. However, MARRIOTT breached its duty of good faith and fair dealing under the written
contract with PLAINTIFF by failing to provide him with a habitable hotel room; properly screen hotel
guests; not interfere with PLAINTIFF’S use and peaceful enjoyment of the hotel room; refrain from
intentionally placing PLAINTIFF in a hotel room adjacent to members of the MORRIS family who
had followed and stalked him there after his 911 call for attempted murder in order for the MORRIS
family to cause PLAINTIFF substantial harm; refrain from permitting members of the MORRIS
family to fraudulently impersonate employees; refrain from placing other members of the MORRIS
family in the hotel to cause PLAINTIFF substantial harm; properly hire and supervise its employees;
and, failing to provide adequate security.

112. PLAINTIFF has fully performed all conditions, covenants and all else required of him under
the contracts and complied with his duty to act in good faith and fair dealing.

113. PLAINTIFF has been damaged and harmed by MARRIOTT'S breaches of the implied
covenant of good faith and fair dealing and the breaches as alleged above were a substantial factor as

well as a direct and legal cause of the damages and harm suffered by PLAINTIFF.

PRAYER
WHEREFORE, PLAINTIFF prays for Judgment against DEFENDANTS as follows:
1. That Judgment be entered in PLAINTIFF’S favor;

2. For general and special damages, punitive damages, and exemplary damages;
3. For attorneys’ fees and costs of suit.
4, For all other relief the court deems proper.

PLAINTIFF RYAN WOODSON’S COMPLAINT

Case 3:25-cv-01748-G-BT Document 24 _ Filed 02/12/26 Page54o0f54 PagelD <pagelD>

3. For attorneys’ fees and costs of suit.

10 4. For all other relief the court deems proper.

I]

12 || DATED: October 19, 2024 Ex D3
R oodson

13 Plaintiff in pro per
10749 Sandpiper Ln.
14 Dallas, Texas 75230
Tel.: 214-502-1121
15 Email: rwealif@gmail.com
16
17
18
19
20
21
22
5.

PLAINTIFF RYAN WOODSON’S COMPLAINT