Wolfe Pups File

Case: 61CH1:23-cv-01822 Document #: 1 Filed: 11/20/2023 Page 1 of 14
IN THE CHANCERY COURT OF RANKIN COUNTY, MISSISSI~PI IF lllLIElll)

NOV 20 2023
JORGE SOLIS and WOLF PUPS, LLC
LARRY SWA
Chancery Clerk R LES
' ankin Coun ty
v. No. : Zs-/ '82'2 (M}
TONI BETH WINSTEAD
EMERGENCY PETITION FOR TEMPORARY RESTRAINING ORDER AND

INJUNCTIVE RELIEF
Petitioners, Jorge Solis and Wolf Pups, LLC, bring this Emergency Petition for Temporary
Restraining Order and Injunctive Relief under Miss. R. Civ. P. 65. In support, Petitioners would
show the following:
I. THE PARTIES
1) Petitioner Jorge Solis is an adult citizen of Mississippi residing m Pucket,
Mississippi.
2) Petitioner Wolf Pups, LLC is a Mississippi limited liability company whose
managing member is Jorge Solis and which does business as a child care facility located at 204
and 207 George St., Brandon, Mississippi 39042.
3) Respondent Toni Beth Winstead is an adult citizen of Mississippi residing m
Brandon, Mississippi .
II. JURISDICTION
4) This Court has jurisdiction over this matter under the Mississippi Constitution,
Article 6, §§ 159-60, and Miss. Code§ 9-5-81. The Chancery Court specifically holds equitable
jurisdiction over claims for injunctive relief. Derr Plantation, Inc. v. Swarek, 14 So. 3d 711, 718
(Miss. 2009).
III. STATEMENT OF FACTS
5) On/around October 4, 2023, Petitioner Wolf Pups purchased After School Care,
Inc. from its 100% shareholder, Mary Francis Dotson ("Francis"). 1 Francis remains the official
Director of Wolf Pups until Jorge's wife, Brittany Solis (a 50% owner of Wolf Pups, LLC), obtains
her Director's license (which should be approved very soon).
6) After School Care is located at 204/207 George St., Brandon, Mississippi 39042 .
Wolf Pups' purchase included all the assets of After School Care, Inc., including its physical assets,
goodwill, trade secrets, and client portfolio (among other things), and Wolf Pups assumed the lease
on the building housing the child care facility (which was formerly leased by After School Care,
Inc.).
7) Respondent Toni Beth Winstead ("Beth") had been employed by After School
Care, Inc. for several years, serving as the Director of the child care facility. Upon learning of its
sale to Wolf Pups, Beth submitted an employment application to Wolf Pups on October 20, 2023 .
Beth also made available a certificate purportedly from the Mississippi State Department of
Health's Child Care Facilities Licensure Branch indicating that Beth was a licensed Child Care
Facility Director. (A copy of Beth's purported Certificate of Licensure is attached as Exhibit 1.)
8) Within days of receiving Beth's job application, Wolf Pups hired Beth as the
Director of Wolf Pups' child care facility.
9) However, on November 3, 2023, Beth submitted a letter of resignation, effective
November 6, 2023, explaining :
I am committed to ensuring a smooth transition and will do everything I can to help

ensure that the children and parents continue to receive the high-quality care and
support that they deserve.
For clarity, the individual parties and associated persons are identified by first names only .
No disrespect is intended.
2
I want to express my gratitude to our entire team for the support and collaboration
we've shared during my time here. 1 am thankful for the wonderful experiences and
opportunities that this position has provided me. Once again, I apologize for any
inconvenience my resignation may cause and appreciate your understanding in this
matter. Thank you for the opportunity to be a part of this daycare, and I wish the
daycare center continued success in the future.
(A copy of Beth ' s resignation letter is attached as Exhibit 2.)
10) Another employee, Erica Hollinghead (who had worked for After School Care),
also resigned effective November 6, 2023.
11) Consequently, until Jorge's wife, Brittany Solis, obtains her Child Care Director's
license from the Department of Health (which should be issued very soon), Franics is the facility's
temporary Director. But Franics has retained no ownership or other interest in the child care
facility .
12) When Beth submitted her resignation to Wolf Pups on Friday, November 3, 2023,
the child care facility was at maximum capacity with fifty (50) children enrolled. By Monday,
November 6, 2023 (the effective date of Beth's resignation), that number was cut in half, to twenty-
five (25) children.
13) Puzzled by the immediate, precipitous drop in enrollment, Jorge asked Wolf Pups
employees what could have caused the sudden drop in enrollment. These employees, including
Mary Thurman, advised Jorge and his wife, Brittany, that Beth must have taken Wolf Pups' client
list (which it had purchased from After School Care), called or texted the parents, and advised
them she (Beth) had opened her own child care facility at her house in Brandon. (See the Affidavit
of Mary Thurman, attached as Exhibit 3, Jr9.) Beth also falsely told Wolf Pups' clients that their
children would not be safe at Wolf Pups and invited them to enroll their children at Beth's newly-
opened child care facility. Ex. 3 Jr9.
3
14) On November 6, 2023, Wolf Pups' employee Mary Thurman, who lives in the same
neighborhood as Beth, drove by Beth's house located at 840 Owen Boone Rd. in Brandon,
Mississippi, and Beth's mother's house next door (823 Owen Boone Road). Ex. 3 !r6. Mary
witnessed Beth, Erica Hollinghead, and about seventeen children outside around the house, which
was clearly being used as a child care facility, but failed to have a fence as required by 15 Miss.
Adm in. Code. Pt. 11, Subpt. 55, R. 1. 11.9. Id. Children were running around outside the house,
unrestrained by any outside barrier. Mary took a photo of Beth's "child care facility," which is
attached as Exhibit A to her Affidavit (Ex. 3). Mary's Affidavit also states that:
Although the picture is taken from a distance and the children's faces are hard to
identify, I am certain that at least two of the children in the picture are After School
Care/Wolf Pups' clients, who had apparently switched to Beth's "child care
facility." And the remainder of the children all look like former After School
Caer/Wolf Pups' clients, but I cannot say with 100% certainty.
Ex. 3 if6.
15) A search in the Mississippi Department of Health's public database for licensed
child care facilities reveals that the Department of Health has not issued a license for Beth's "child
care facility." Further, a search of all licensed child care facilities in Rankin County revealed no
child care facility associated with Beth. And a search of the Mississippi Department of Health's
public database did not reveal that Beth was a licensed Child Care Director. Notably, the document
Beth produced to Wolf Pups indicating she held a Child Care Facility Director license is not signed
by anyone at the Department of Health. Jorge is informed and believes that the "license" held by
Beth is bogus and that she lacks a valid Child Care Facility Director's license. See Ex. 3 !rl 0.
16) After Beth's resignation and misappropriation of Wolf Pups' client list, additional
incidents came to light. For instance, Beth has stricken children with a ruler. Ex. 3 !r4(a). And
while working for Francis at After School Care, Inc., Beth instructed another employee, Erica
4
Hollinghead, to strike children with a ruler, causing the children to grimace in pain. 2 See Ex. 3
Jr4(b). (Counsel has a copy of the video showing Ms. Hollinghead assaulting the children, which
it will make available to the Court before a hearing on this Petition.) Beth also struck children with
a ruler, but preferred to instruct other employees to strike the children because she did not want
the children to report to their parents that Beth assaulted them. Ex. 3 Jr!r4(a)-(b ).
17) On another occasion, Beth posted pictures to Facebook of children at After School
Care, Inc. kissing one another on Valentine's Day. Ex. 3 Jr4(c). Beth was forcing the children to
kiss one another so she could post the pictures to Facebook. Id. One parent, Rikki Michelle
Morrow, contacted After School Care to demand that it take down the pictures of her child,
explaining it bordered on child pornography. (A copy of Ms. Morrow's message is attached as
Exhibit 4; see Ex. 3 Jr4(c).)
18) On other occasions, After School Care would exceed the 50-child limit imposed by
the Department of Health. Ex. 3 Jr4(d) . Whenever the Department of Health would inspect the
facility, Beth would instruct another employee to take the excess number of children and hide them
in a car or take them to a nearby church so the Department of Health would not cite After School
Care, Inc. for exceeding its 50-child limit. Id.
19) Beth now operates an unlicensed child care facility that fails to comply with the
Regulations Governing Child Care Facilities found at 15 Miss. Admin. Code 11, Subpart 55. See
Ex. 3 Jr6. Jorge is also informed and believes that Beth lacks a valid Child Care Facility Director's
license.
2
Erica Hollinghead left After School Care to work for Beth at her "child care facility ." Ms.
Hollinghead, however, cannot legally provide child care services because she lacks a high school
diploma or GED, either of which is required under the Regulations Governing the Licensure of
Child Care Facilities to work with children at a licensed child care facility, 15 Miss. Admin. Code.
Pt. 11, Subpt. 55.
5
20) Beth has also wrongfully misappropriated Wolf Pups ' trade secret (its client list)
for her own benefit, and wrongfully disparaged Wolf Pups to its clients, also for her own benefit
(so they would enroll their children at Beth ' s unlicensed facility). See Ex. 3 Jr6.
21) Moreover, Jorge is informed and believes that Beth was behind a "surprise" state
inspection by a lady who identified herself only as "Chrissie." "Chrissie" appeared unannounced
at Wolf Pups on November 9, 2023, at about 7:30 a.m., and advised she was conducting a surprise
inspection. "Chrissie" ultimately cited Wolf Pups because its temporary Director, Francis, was not
present at the time of inspection. (A copy of the citation is attached as Exhibit 5.)
22) Suspicious, Jorge investigated and determined that "Chrissie" is actually Chrissie
Vanderford Ryals, whose jurisdiction lies in Hinds, not Rankin County (where Wolf Pups' child
care facility is located).
23) Beth has demonstrably lacked concern for the children under her care. Not only has
she struck-and ordered others to strike-the children, but she was also running After School Care
with lead paint.
24) Wolf Pups hired The Pickering Firm, Inc. , an engineering firm , to inspect the child
care facility for lead paint and other hazardous substances. Pickering issued a report dated
November 13, 2023, showing high levels of lead on the windows in the annex building, which is
where children were kept at After School Care. (A copy of Pickering's Report is attached as
Exhibit 6.) Beth shou ld not be running a child care facility.
25) Jorge and Wolf Pups now seek a Temporary Restraining Order and Injunction: (I)
prohibiting Beth from operating her "child care facility" until the Department of Health can
investigate; (2) prohibiting Beth from falsely disparaging Wolf Pups to its current and former
6
clients, and (3) ordering Beth to contact any Wolf Pups client to whom Beth has falsely disparaged
Wolf Pups and retract in writing her false statement(s) disparaging Wolf Pups.
IV. CAUSES OF ACTION
Count One -Temporary Restraining Order
26) Petitioners incorporate and restate Paragraphs 1 through 25 above .
27) Beth is operating an unlicensed child care facility while disregarding the
Regulations Governing Licensure of Child Care Facilities. She has no fence around her " child care
facility" and is using Erica Hollinghead to care for the children, even though Erica is disqualified
from such a position due to her lack of a high school diploma or GED. See 15 Miss. Adm in. Code
Pt. 11 , Subpt. 55, R. 1.11.9(8); R. 1.5.4(1). And these are just two violations discovered in plain
sight. Beth's " child care facility" is certain to violate several other Regulations, which are lengthy
and detailed in their mandates for how a child care facility must be structured and operated.
28) The Regulations Governing Child Care Facilities are designed to "protect and
promote the health and safety of children in this state by providing for licensing of child care
facilities as defined herein to assure that certain minimum standards are maintained in such
facilities ." 15 Miss. Adm in . Code Pt. 11, Subpt. 55, R. 1.1.2(1 ).3
29) Beth ' s failure to follow the Regulations and failure to obtain the appropriate
licenses from the Department of Health places the children enrolled in her facility at grave risk of
A "child care facility" is defined in the Regulation s as : "A place which provides shelter
and personal care for six or more children who are not related within the third degree computed
according to the civi I law to the operator and who are under 13 years of age, for any part of the
twenty-four hour day, whether such place be organized or operated for profit or not. The term
"child care facility" includes day nurseries, day care centers, child care centers, preschool
programs, and any other facility that fall within the scope of the definition set forth above." 15
Miss . Admin. Code Pt. 11 , Subpt. 55 , R. 1.1.4(4).
7
immediate and irreparable injury, as Beth has not complied with the Regulations' prov1s1ons
ensuring her "child care facility" is safely operated with qualified personnel.
30) Wolf Pups will also suffer immediate and irreparable injury if Beth is allowed to
operate her unlicensed child care facility, as Beth ' s clients were either all or substantially all
improperly taken from Wolf Pups upon Beth ' s misappropriation of Wolf Pups ' client list, which
is considered a trade secret by law. See Fred's Stores of Miss. v. M H Drugs, 725 So. 2d 902, 911
(Miss. 1998) (finding that a client list was a trade secret.).
31) Further, as a Wolf Pups' employee, who was hired as its Director to run the
facility's day-to-day operations, Beth owed Wolf Pups fiduciary duties, including duties of good
faith and loyalty. Hill v. Southeastern Floor Covering, 596 So. 2d 874, 877 (Miss. 1992) (holding
that the general manager of a business, who was responsible for day-to-day operations, owed the
business a fiduciary duty).
32) Beth has already caused Wolf Pups to sustain significant losses- half of its clients
left the facility based on Beth ' s misappropriation of Wolf Pups' client list (a trade secret by law)
and using the client list for her own benefit. Wolf Pups has suffered, and will continue to suffer,
immediate and irreparable damage to its goodwill and financial damages from the loss of business,
which Beth wrongfully diverted from Wolf Pups to herself while making false allegations about
Wolf Pups .
33) Petitioner thus respectfully requests that the Court enter an Order temporarily
restraining Respondent from operating her child care facility until the Department of Health can
investigate.
WHEREFORE, Petitioners Jorge Solis and Wolf Pups, LLC respectfully request that the
Court issue an Emergency Order: (1) restraining and prohibiting Respondent Toni Beth Winstead
8
from operating her "child care facility" until the Department of Health can investigate and
determine the licensure status of Beth and her child care facility, (2) restraining and prohibiting
Beth from falsely disparaging Wolf Pups to its current and former clients, and (3) ordering Beth
to contact Wolf Pups ' current or former clients, or anybody else, to whom Beth has falsely
disparaged Wolf Pups and retract in writing her false statement(s) disparaging Wolf Pups.
Count Two - Injunctive Relief
34) Petitioners incorporate and restate Paragraphs 1 through 25 above.
35) Petitioner seeks an injunction prohibiting Respondent from using Wolf Pups ' client
list, prohibiting Respondent from falsely disparaging Wolf Pups to its current and former clients,
or anyone, and affirmatively requiring that Beth contact all of Wolf Pups ' clients to whom Beth
falsely disparaged Wolf Pups and retracting in writing her false statements.
36) Beth, as Wolf Pups ' Director, owed duties to Wolf Pups, including the fiduciary
duties of good faith and loyalty. Hill, 596 So. 2d at 877. As the Mississippi Supreme Court
instructed in Laseter v. Sistrunk, 251 Miss. 92, 103 (Miss. 1964):
[T]he agent or employee is bound to the exercise of the utmost good faith and
loyalty toward his principal or employer. He is duty bound not to act adversely to
the interest of his employer by serving or acquiring any private interest of his own
in antagonism or opposition thereto. This is a rule of common sense and honesty as
well as of law.
37) Under Mississippi law, a movant shall receive a temporary injunction upon
showing: (1) a substantial likelihood of prevailing on the merits, (2) necessity to prevent
irreparable injury, (3) that the threatened injury to the plaintiff outweighs the harm an injunction
might cause to the defendant, and (4) that the injunction is consistent with the public interest. Carr
v. Miss. Lottery Corp. , 350 So. 3d 1068, 1074 (Miss. 2022).
9
38) Here, Petitioners are preparing a lawsuit against Beth for misappropriation of trade
secrets, tortious interference with business relations, unfair or deceptive trade practices,
defamation, and unjust enrichment.
a) As to the first prong, there is no question that Petitioners will prevail on the
merits of their claims.
1. As for misappropriation of trade secrets, Wolf Pups need show that
it possessed trade secrets, that Beth misappropriated the trade
secrets, and that the misappropriation caused or threatened damage
to the plaintiff. Miss. Code § 75-26-3; see Fred's Stores of Miss. v.
M H Drugs, 725 So. 2d 902 , 910 (Miss. 1998).
11. For tortious interference with business relationships, Wolf Pups
must show that Beth (I) engaged in intentional and willful acts, (2)
calculated to cause damage, (3) for an unlawful purpose, and (4)
actual damage to Wolf Pups. MBF Corporation v. Century Business
Communications, Inc., 663 So.2d 595, 598 (Miss. 1995). But to
make a prima facie Wolf Pups need only show (1) a loss and (2)
Beth's conduct caused the loss. Id.
111. For unfair or deceptive trade practices, the Mississippi Consumer
Protection Act prohibits unfair or deceptive acts or practices in or
affecting commerce. Miss. Code § 75-24-5.
1v. For defamation, Wolf Pups need show that (I) Beth made a false
and defamatory statement concerning Wolf Pups (or its owners,
Jorge and Brittany Solis); (2) to a third party ; (3) without privilege
10
and with fault rising to the level of at least negligence; and (4)
causing harm caused by the publication. Short v. Versiga, 283 So.
3d 182, 185 (Miss. 201 9).
v. For unjust enrichment, Wolf Pups need show that Beth has money
or property which in good conscience and justice he should not
retain but should deliver to Wolf Pups . Cates v. Swain, 215 So. 3d
492, 494 (Miss. 2013).
Wolf Pups can easily make a prima facie case for each claim. Beth, who
owed Wolf Pups a fiduciary duty, took Wolf Pups' confidential trade information-its client list-
and misappropriated that trade information to steal Wolf Pups' clients for use in her own fledgling
"child care facility" by falsely disparaging Wolf Pups. Beth published her false statements to the
clients, which caused Wolf Pups damages to its reputation and goodwill, and lost income through
lost business. Beth acted intentionally and willfully, her acts were calculated to cause damage to
the Petitioners' business, and Beth acted with the unlawful purpose of causing damage.
b) As for the second prong, the injunction is necessary to prevent irreparable
injury to Wolf Pups. Beth has already injured Wolf Pups by misappropriating its client list and
falsely disparaging Wolf Pups' operations. As a result, Wolf Pups' business lost half of its clients.
Should Beth continue to falsely disparage Wolf Pups, Wolf Pups' goodwill and business
operations will suffer irreparable harm and could result in it closing soon after it opened. Moreover,
if Beth is not enjoined from operating her child care facility, the children face irreparable injury or
death because Beth's child care facility fails to comply with the Department of Health's many
Regulations for Child Care Facilities.
11
c) As for the third prong, the threatened injury to Wolf Pups far outweighs any
injury to Beth. Beth has no right to operate an unlicensed child care facility, much less with clients
Beth misappropriated from Wolf Pups. Thus, Beth cannot claim any legally cognizable injury upon
the Court's issuance of an injunction.
d) As for the fourth prong, issuing an injunction would support the public ' s
interest. The public has an interest in seeing the laws enforced, and businesses have an interest in
protecting their customer base. See, e.g., Redd Pest Control Co., Inc. v. Heatherly, 157 So. 2d 133,
136 (1963) ("The primary right of the employer is that of protecting the business from loss of
customers by the activities of the former employees who have peculiar knowledge of and
relationships with the employer's customers."). [f Beth is not enjoined from falsely disparaging
Wolf Pups and allowed to continue running an unlicensed child care facility , her failures to follow
the Health Department Rules and Regulations applicable to child care facilities, Wolf Pups could
be forced to close. Further, the children at Beth's facility are at risk of serious injury or death.
Indeed, as shown in Exhibit A to Mary Thurman ' s Affidavit, children were spread all around the
property at Beth's "child care facility," with no fence to keep them from the street or wandering
off. Beth was also using Erica Hollinghead-a woman with a history of striking little children with
a ruler-as a child care provider in violation of the Regulations because Erica lacks a high school
diploma or GED. The public has no interest in allowing Beth to run an unlicensed child care facility
stocked with clients Beth misappropriated from Wolf Pups. Further, an injunction would support
the public's interest in maintaining the integrity of corporate trade secrets and employee loyalty.
Were Beth allowed to misappropriate Wolf Pups' trade secrets for her own benefit and falsely
disparage Wolf Pups without consequence, it would render meaningless Mississippi's laws
prohibiting employees from committing similar unfair trade practices.
12
WHEREFORE, Petitioners Jorge Soil is and Wolf Pups, LLC respectfully request that the
Court enter an Order directing Respondent Beth Winstead to immediately cease operating her
"child care facility," immediately cease falsely disparaging Wolf Pups, and order Beth to retract
in writing all fal se statements she made disparaging Wolf Pups, Jorge Solis, or Brittany Solis
(Jorge ' s wife), to Wolf Pups ' clients.
Respectfully submitted, this 20th day of November 2023.
sl Jason M Kirschberg
Jason M. Kirschberg (MBN I 04860)
Jeffery P. Reynolds (MBN 5305)
REYNOLDS I KIRSCHBERG
P.O. Box 24597
Jackson, Mississippi 39225
Tel: (601) 355-7773
jason@rklitigators .com
jeff@rklitigators.com
Signed, this W ~ day of November 2023.
Jorge Solis
13
VERIFICATION
STATE OF MISSISSIPPI
COUNTY OF ti, /or

PERSONALLY appeared before me, the undersigned authority in and for the said county
and state, Jorge Solis who, after having been first duly sworn, states on oath that the matters and
facts set forth in the above and foregoing Emergency Petition are true and correct as stated therein,
to the best of his information and belief.
SWORN TO AND SUBSCRIBED BEFORE ME on this the zotl day of November

2023.
14
Case: 61CH1:23-cv-01822 Document #: 1-1 Filed: 11/20/2023 Page 1 of 2

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Case: 61CH1:23-cv-01822 Document #: 1 Filed: 11/20/2023 Page 1 of 14

IN THE CHANCERY COURT OF RANKIN COUNTY, MISSISSI~PI IF lllLIElll)

EMERGENCY PETITION FOR TEMPORARY RESTRAINING ORDER AND

show the following:

1) Petitioner Jorge Solis is an adult citizen of Mississippi residing m Pucket,

2) Petitioner Wolf Pups, LLC is a Mississippi limited liability company whose

and 207 George St., Brandon, Mississippi 39042.

3) Respondent Toni Beth Winstead is an adult citizen of Mississippi residing m

III. STATEMENT OF FACTS

her Director's license (which should be approved very soon).

Director of Wolf Pups' child care facility.

9) However, on November 3, 2023, Beth submitted a letter of resignation, effective

November 6, 2023, explaining :

I am committed to ensuring a smooth transition and will do everything I can to help

also resigned effective November 6, 2023.

five (25) children.

opened child care facility. Ex. 3 Jr9.

explaining it bordered on child pornography. (A copy of Ms. Morrow's message is attached as

Exhibit 4; see Ex. 3 Jr4(c).)

Care, Inc. for exceeding its 50-child limit. Id.

care facility is located).

with lead paint.

Exhibit 6.) Beth shou ld not be running a child care facility.

IV. CAUSES OF ACTION

Count One -Temporary Restraining Order

26) Petitioners incorporate and restate Paragraphs 1 through 25 above .

(Miss. 1998) (finding that a client list was a trade secret.).

business a fiduciary duty).

Count Two - Injunctive Relief

34) Petitioners incorporate and restate Paragraphs 1 through 25 above.

instructed in Laseter v. Sistrunk, 251 Miss. 92, 103 (Miss. 1964):

v. Miss. Lottery Corp. , 350 So. 3d 1068, 1074 (Miss. 2022).

defamation, and unjust enrichment.

merits of their claims.

1. As for misappropriation of trade secrets, Wolf Pups need show that

it possessed trade secrets, that Beth misappropriated the trade

secrets, and that the misappropriation caused or threatened damage

to the plaintiff. Miss. Code § 75-26-3; see Fred's Stores of Miss. v.

M H Drugs, 725 So. 2d 902 , 910 (Miss. 1998).

11. For tortious interference with business relationships, Wolf Pups

calculated to cause damage, (3) for an unlawful purpose, and (4)

actual damage to Wolf Pups. MBF Corporation v. Century Business

Communications, Inc., 663 So.2d 595, 598 (Miss. 1995). But to

Beth's conduct caused the loss. Id.

111. For unfair or deceptive trade practices, the Mississippi Consumer

Protection Act prohibits unfair or deceptive acts or practices in or

affecting commerce. Miss. Code § 75-24-5.

and defamatory statement concerning Wolf Pups (or its owners,

causing harm caused by the publication. Short v. Versiga, 283 So.

3d 182, 185 (Miss. 201 9).

or property which in good conscience and justice he should not

492, 494 (Miss. 2013).

b) As for the second prong, the injunction is necessary to prevent irreparable

Regulations for Child Care Facilities.

the Court's issuance of an injunction.

prohibiting employees from committing similar unfair trade practices.

(Jorge ' s wife), to Wolf Pups ' clients.

Respectfully submitted, this 20th day of November 2023.