TICK TOCK TICK TOCK HEY TURNER MEET BUBBA LOL!!!!!
Post# of 11107
Posted On: 04/17/2014 6:28:58 PM
TICK TOCK TICK TOCK HEY TURNER MEET BUBBA LOL!!!!!!$$$PVEC$$$
After PV Enterprises invested a substantial sum into the Ocean Star Pacific, certain issues
with the vessel’s hull were identified, which required significant repairs. Due to the high costs of
repair, PV Enterprises considered obtaining investment capital for the Ocean Star Pacific.
PV Enterprises employed, at that time, an individual named David Turner. Initially an
accountant with the company, Turner eventually became the company’s CFO. Turner indicated
that he knew an individual named Quang Meredith (“Quang”), who might be a potential investor.
Throughout June and July of 2012, Turner introduced Quang to Peter, and they began discussing
the potential investment.
Ultimately, the parties came to a verbal agreement on the investment whereby Quang
would invest $4 million into the project and, in exchange, would receive 100% of the profits
from the casino on board the vessel for two years.
In accordance with the discussions, Peter agreed to send Turner to Texas to do an
inventory of Quang’s assets and to complete a document formalizing the agreement. That day,
Turner forwarded a copy of the terms of the agreement to Peter. However, the terms of the
formalized “agreement” Turner forwarded were strikingly different form the parties’ agreement
of days earlier. It was later discovered that Turner and Quang had a long-standing, personal
relationship and that Turner was seeking to benefit from his relationship with Quang to the
detriment of PV Enterprises. Peter had Turner return from Texas immediately, and Peter
personally traveled to meet with Quang.
When Quang and Peter met, they were able to agree – again – on specific terms relating
to Quang’s investment, including the infusion of $4 million in exchange for profit rights of the
ship’s casino for two years. Based on their agreement that day, Peter signed the promissory note
based specifically on the parties’ agreement that Quang would fund the investment within ten to
2
SUPPLEMENTAL MOTION FOR NEW TRIAL
fourteen days. The promissory note was also intended to cover certain American Express
payments for certain crew member and vendor expenses in connection with the project. The
parties agreed that a document would be circulated formalizing their agreement that day.
However, for the second time, the contract circulated was materially different from the
parties’ agreement - it mirrored the previously rejected version.
Despite obtaining Peter’s signature on the Promissory Note by representing that he would
agree to the terms personally discussed between himself and Peter, Quang refused to fund the
investment. Quang then called American Express and challenged his own payments as “fraud,”
though American Express eventually found in favor of the payees.
Despite obtaining Peter’s signature on the promissory note by promising to invest in PV
Enterprises’ Ocean Star Pacific project, which he later failed to do, Quang has now filed a
lawsuit seeking recovery on the promissory note he obtained by making false representations.
B. Procedural History.
On March 7, 2013, Plaintiff filed the present lawsuit claiming breach of contract, among
other causes of action, against PV Enterprises and Peter in connection with the note. On
December 23, 2013, just two days before Christmas, Plaintiff filed a motion for summary
judgment in this case against Defendants. On January 13, 2014, in an attempt to respond to the
Motion for Summary Judgment, Peter filed a motion to dismiss Plaintiff’s petition, which
indicated it was filed by both Peter and PV Enterprises, Inc.1
Plaintiff set the motion for summary judgment for hearing on January 17, 2014.
However, Defendants did not receive notice of the summary judgment hearing set for January
After PV Enterprises invested a substantial sum into the Ocean Star Pacific, certain issues
with the vessel’s hull were identified, which required significant repairs. Due to the high costs of
repair, PV Enterprises considered obtaining investment capital for the Ocean Star Pacific.
PV Enterprises employed, at that time, an individual named David Turner. Initially an
accountant with the company, Turner eventually became the company’s CFO. Turner indicated
that he knew an individual named Quang Meredith (“Quang”), who might be a potential investor.
Throughout June and July of 2012, Turner introduced Quang to Peter, and they began discussing
the potential investment.
Ultimately, the parties came to a verbal agreement on the investment whereby Quang
would invest $4 million into the project and, in exchange, would receive 100% of the profits
from the casino on board the vessel for two years.
In accordance with the discussions, Peter agreed to send Turner to Texas to do an
inventory of Quang’s assets and to complete a document formalizing the agreement. That day,
Turner forwarded a copy of the terms of the agreement to Peter. However, the terms of the
formalized “agreement” Turner forwarded were strikingly different form the parties’ agreement
of days earlier. It was later discovered that Turner and Quang had a long-standing, personal
relationship and that Turner was seeking to benefit from his relationship with Quang to the
detriment of PV Enterprises. Peter had Turner return from Texas immediately, and Peter
personally traveled to meet with Quang.
When Quang and Peter met, they were able to agree – again – on specific terms relating
to Quang’s investment, including the infusion of $4 million in exchange for profit rights of the
ship’s casino for two years. Based on their agreement that day, Peter signed the promissory note
based specifically on the parties’ agreement that Quang would fund the investment within ten to
2
SUPPLEMENTAL MOTION FOR NEW TRIAL
fourteen days. The promissory note was also intended to cover certain American Express
payments for certain crew member and vendor expenses in connection with the project. The
parties agreed that a document would be circulated formalizing their agreement that day.
However, for the second time, the contract circulated was materially different from the
parties’ agreement - it mirrored the previously rejected version.
Despite obtaining Peter’s signature on the Promissory Note by representing that he would
agree to the terms personally discussed between himself and Peter, Quang refused to fund the
investment. Quang then called American Express and challenged his own payments as “fraud,”
though American Express eventually found in favor of the payees.
Despite obtaining Peter’s signature on the promissory note by promising to invest in PV
Enterprises’ Ocean Star Pacific project, which he later failed to do, Quang has now filed a
lawsuit seeking recovery on the promissory note he obtained by making false representations.
B. Procedural History.
On March 7, 2013, Plaintiff filed the present lawsuit claiming breach of contract, among
other causes of action, against PV Enterprises and Peter in connection with the note. On
December 23, 2013, just two days before Christmas, Plaintiff filed a motion for summary
judgment in this case against Defendants. On January 13, 2014, in an attempt to respond to the
Motion for Summary Judgment, Peter filed a motion to dismiss Plaintiff’s petition, which
indicated it was filed by both Peter and PV Enterprises, Inc.1
Plaintiff set the motion for summary judgment for hearing on January 17, 2014.
However, Defendants did not receive notice of the summary judgment hearing set for January
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