Superior Energy Lawsuit

2016-24818 / Court: 295
4/19/2016 9:55:03 PM
Chris Daniel - District Clerk Harris County
Envelope No. 10116539
By: Krystal Franklin
Filed: 4/19/2016 9:55:03 PM
CAUSE NO. ______________
v.
CHRISTOPHER J. RUSSO, MARTIN A.
LEBLANC, ET. AL.,
Defendants.
IN THE DISTRICT COURT
OF HARRIS COUNTY, TEXAS
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SUPERIOR ENERGY SERVICES, INC.,

STABIL DRILL SPECIALTIES, L.L.C, and
SESI, L.L.C.
Plaintiffs,
______ JUDICIAL DISTRICT
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PLAINTIFFS VERIFIED ORIGINAL PETITION AND

REQUEST FOR INJUNCTIVE RELIEF AND REQUESTS FOR DISCLOSURE
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Plaintiffs Superior Energy Services, Inc. (Superior), Stabil Drill Specialties, L.L.C
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(Stabil Drill), and SESI, L.L.C (SESI) (collectively Plaintiffs), file this their Verified
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Original Petition and Request for Injunctive Relief, wherein they complain of Defendants Martin
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A. LeBlanc (LeBlanc), Christopher J. Russo (Russo), Scott Kerstetter (Kerstetter), Daniel
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Anthony (Anthony), Mike Sheffield (Sheffield), Laguna Oil Tools, LLC, Quest Holdings,
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LLC, Renegade Performance Properties, LLC, Renegade Oil Tools, LLC, Renegade
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Manufacturing, LLC, Renegade Performance Coatings, LLC, LeBlanc Real Estate Investments,
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LLC, Triple RRR Investments, LLC, Triton Hardbanding Service, LLC, MSI Inspection Service,
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LLC, and Maverick Rental Tools, LLC (collectively Defendants), and further seek disclosures
from all Defendants pursuant to Texas Rule of Civil Procedure 194. In support of their claims,
Plaintiffs submit the following to the Court:
DISCOVERY CONTROL PLAN
1.
Plaintiffs intend that discovery be conducted under Level 3 of TEX. R. CIV. P. 190.
NATURE OF THE CASE

2.
This is a case of company officers of an oil field supply and services company
abusing their positions of trust and power to misappropriate, divert, and usurp corporate assets
and corporate opportunities. Although the schemes employed by the various defendants may
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sometimes seem complex, essentially, this case is about corporate officers using their position of
trust and responsibility to siphon cash away from Plaintiffs by using multiple companies that
they jointly owned and/or controlled.
This Original Petition and Request for Injunctive Relief and Requests for
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Disclosure relies upon verified facts for the injunctive relief sought in compliance with the Texas
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Christopher J. Russo and Martin A. LeBlanc (collectively the Officers) were the
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Rules of Civil Procedure. See Verification of Christine Chaney (attached as Exhibit A).
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executive officers who ran Stabil Drill, a subsidiary of Superior and SESI. These individuals
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engaged in a complex scheme of selfdealing primarily by creating separate but interwoven
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corporate entities (which they owned or controlled) to overcharge Stabil Drill for goods and
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services, usurp corporate opportunities, and to benefit themselves by being on both sides of
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various transactions. In spite of their fiduciary duty to their employer, LeBlanc and Russo
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engaged in their nefarious conduct with the help of other individuals and entities, who are also
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Defendants in this matter. By the time that the Plaintiffs discovered that their Officers were
betraying their positions of trust, the Officers had directed the payment of more than $65 million
over the course of a number of years to various entities owned and/or controlled by them or their
co-conspirators. During this period, this group of third parties and Officers engaged in a scheme
to divert funds and corporate resources, including the diversion of monies and sales proceeds
from Stabil Drill and its parent companies in Texas, ultimately resulting in damages to Plaintiffs.
5.
Plaintiffs now come before the Court to seek redress and to recover damages from
the Defendants for the wrongs perpetrated against them. Plaintiffs also seek injunctive and
equitable relief as further described herein.
PARTIES
Superior Energy Services, Inc. is a Delaware corporation with its principal place
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of business in Houston, Texas, and is the ultimate parent corporation of SESI, L.L.C. and Stabil
Drill Specialties, L.L.C.
SESI, L.L.C. is a Delaware limited liability company with its principal place of
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business in Houston, Texas, and is the direct parent company of Stabil Drill Specialties, L.L.C.
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Its member is Superior Energy Services, Inc., a Delaware corporation with its principal place of
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business in Houston, Texas.
Stabil Drill Specialties, L.L.C. is a Louisiana limited liability company with its
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principal place of business in Lafayette, Louisiana. Its member is SESI, L.L.C., whose principal
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place of business is in Houston, Texas.
Christopher J. Russo is an individual and a resident and citizen of Louisiana.
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Based on public records and available information, he may be served with the citation and
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petition on the Texas Secretary of State, pursuant to TEX. CIV. PRAC. & REM. CODE, Section
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17.044, by certified mail to Service of Process, Texas Secretary of State, P.O. Box 12079, Austin
Texas 78711-2079 with forwarding instructions to: Christopher J. Russo, 103 Vanburg Place,
Lafayette, LA 70508-1825.
10.
Martin A. LeBlanc is an individual and a resident and citizen of Louisiana. Based
on public records and available information, he may be served with the citation and petition on
the Texas Secretary of State, pursuant to TEX. CIV. PRAC. & REM. CODE, Section 17.044, by
certified mail to Service of Process, Texas Secretary of State, P.O. Box 12079, Austin Texas
78711-2079 with forwarding instructions to: Martin A. LeBlanc, 118 Rue Chavaniac, Lafayette,
LA 70508-7312.
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Scott Kerstetter is an individual and a resident and citizen of Louisiana. Based on
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public records and available information, he may be served with the citation and petition on the
Texas Secretary of State, pursuant to TEX. CIV. PRAC. & REM. CODE, Section 17.044, by certified
mail to Service of Process, Texas Secretary of State, P.O. Box 12079, Austin Texas 78711-2079
Daniel Anthony is an individual and a resident and citizen of Texas. Based on
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with forwarding instructions to: Scott Kerstetter, 437 Shelly Drive, Lafayette, LA 70503.
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public records and available information, he may be served with the citation and petition by
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certified mail at the following addresses: Daniel Anthony 7380 Harbor Dr., Montgomery, TX
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77356-4771; and, also forwarding to a second address: Daniel Anthony 102 Jenny Lane,
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Mike Sheffield is an individual and a resident and citizen of Oklahoma. Based on
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Montgomery, TX 77356-4416.
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public records and available information, he may be served with the citation and petition on the
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Texas Secretary of State, pursuant to TEX. CIV. PRAC. & REM. CODE, Section 17.044, by certified
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mail to Service of Process, Texas Secretary of State, P.O. Box 12079, Austin Texas 78711-2079
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with forwarding instructions to: Mike Sheffield, 101 N Sara Road, Yukon, OK 73099; and also
forwarding to a second address: Mike Sheffield, 1517 Autumn Creek Drive, Edmond, OK
73003.
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Laguna Oil Tools, LLC is a Louisiana limited liability company with its principal
place of business in Youngsville, Louisiana. Its member is Scott Kerstetter, who is a resident
and citizen of Youngsville, LA. Based on public records and available information, Laguna Oil
Tools LLC, engages in business in Texas but does not have designated resident agent in Texas.
Thus, it may be served with the citation and petition on the Texas Secretary of State, pursuant to
TEX. CIV. PRAC. & REM. CODE, Section 17.044, by certified mail to Service of Process, Texas
Scott Kerstetter, 103 Guernsey Lane, Youngsville, LA 70592.

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Secretary of State, P.O. Box 12079, Austin, TX 78711-2079 with forwarding instructions to:
Quest Holdings, LLC is an Oklahoma limited liability company with its principal
place of business in Oklahoma City, Oklahoma. Upon information and belief, its members are
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(1) Mike Sheffield, who is a resident and citizen of Oklahoma; (2) LeBlanc Real Estate
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Investments, LLC, with its principal place of business in Louisiana, and whose members are (i)
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Martin A. LeBlanc, who is a resident and citizen of Louisiana, (ii) Janice C. LeBlanc, who is a
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resident and citizen of Louisiana, and (iii) Joseph C. LeBlanc, who is a resident and citizen of
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Tennessee; and (3) Christopher J. Russo, who is a resident and citizen of Louisiana. Based on
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public records and available information, Quest Holdings, LLC engages in business in Texas, but
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does not have a designated resident agent in Texas. Thus, it may be served with the citation and
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17.044, by certified mail to Service of Process, Texas Secretary of State, P.O. Box 12079,
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Austin, TX 78711-2079 with forwarding instructions to: Mike Sheffield, 101 N Sara Road,
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Yukon, OK 73099, and also forwarding a second copy to Christopher J. Russo, 103 Vanburg
Place, Lafayette, LA 70508-1825.
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Renegade Performance Properties, LLC is a Louisiana limited liability company
with its principal place of business in Youngsville, Louisiana.
Its members are (1) Scott
Kerstetter, who is a resident and citizen of Louisiana; (2) Triple RRR Investments, LLC, with its
principal place of business in Louisiana, and whose members are (i) Gary J. Russo, who is a
resident and citizen of Louisiana; (ii) Lynda T. Landry, who is a resident and citizen of
Louisiana; (iii) Christopher J. Russo, who is a resident and citizen of Louisiana; and (3) Martin
A. LeBlanc, who is a resident and citizen of Lafayette, LA. Based on public records and
available information, Renegade Performance Properties, LLC engages in business in Texas, but
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does not have a designated resident agent in Texas. Thus, it may be served with the citation and
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Austin, TX 78711-2079 with forwarding instructions to: Tammy B. Scelfo, Allen & Gooch,
Renegade Oil Tools, LLC is a Louisiana limited liability company registered to
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2000 Kaliste Saloom Road, Suite 400, Lafayette, LA 70508.
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do business in Texas with its principal place of business in Youngsville, Louisiana. Its current
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and past members include (1) Daniel Anthony, who is a resident and citizen of Texas; (2) Scott
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Kerstetter, who is a resident and citizen of Louisiana; (3) Christopher J. Russo, who is a resident
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and citizen of Louisiana; (4) Triple RRR Investments, LLC, with its principal place of business
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in Louisiana, and whose members are all residents and citizens of Louisiana; (5) Martin A.
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LeBlanc, who is a resident and citizen of Louisiana; and (6) Robin Redding, who is a resident
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and citizen of Louisiana. Based on public records and available information, Renegade Oil
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Tools, LLC engages in business in Texas, and has a designated resident agent in Texas. Thus, it
may be served with the citation and petition by certified mail on its Texas registered agent:
Daniel Anthony, 9739 Shepard Hill Road, Willis, TX 77318; and also the residences of Daniel
Anthony: 17380 Harbor Dr., Montgomery, TX 77356-4771 and 102 Jenny Lane, Montgomery,
TX 77356-4416, and forwarding an additional copy to Christopher J. Russo, 103 Vanburg Place,
Lafayette, LA 70508-1825.
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Renegade Manufacturing, LLC is a Louisiana limited liability company with its
principal place of business in Youngsville, Louisiana. On information and belief, its members
are (1) Scott Kerstetter, who is a resident and citizen of Louisiana; and (2) Jamie Paul Leger,
who is a resident and citizen of Louisiana. Based on public records and available information,
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Renegade Manufacturing, LLC engages in business in Texas, but does not have a designated
resident agent in Texas. Thus, it may be served with the citation and petition on the Texas
Secretary of State, pursuant to TEX. CIV. PRAC. & REM. CODE, Section 17.044, by certified mail
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to Service of Process, Texas Secretary of State, P.O. Box 12079, Austin, TX 78711-2079 with
Renegade Performance Coatings, LLC is a Louisiana limited liability company
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forwarding instructions to: Scott Kerstetter, 437 Shelly Drive, Lafayette, LA 70503.
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with its principal place of business in Youngsville, Louisiana. Its current and past members
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include (1) Daniel Anthony, who is a resident and citizen of Texas; (2) Scott Kerstetter, who is a
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resident and citizen of Louisiana; (3) Christopher J. Russo, who is a resident and citizen of
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Louisiana; (4) Triple RRR Investments, LLC, with its principal place of business in Louisiana,
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and whose members are all residents and citizens of Louisiana; (5) Martin A. LeBlanc, who is a
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resident and citizen of Louisiana; and (6) Robin Redding, who is a resident and citizen of
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Louisiana. Based on public records and available information, Renegade Performance Coatings,
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LLC engages in business in Texas, but does not have a designated resident agent in Texas. Thus,
it may be served with the citation and petition on the Texas Secretary of State, pursuant to TEX.
CIV. PRAC. & REM. CODE, Section 17.044, by certified mail to Service of Process, Texas
Secretary of State, P.O. Box 12079, Austin Texas 78711-2079 with forwarding instructions to:
Tammy B. Scelfo, Allen & Gooch, 2000 Kaliste Saloom Road, Suite 400, Lafayette, LA 70508.
20.
LeBlanc Real Estate Investments, LLC is a Louisiana limited liability company
with its principal place of business in Lafayette, Louisiana. Its members are (1) Martin A.
LeBlanc, who is a resident and citizen of Louisiana; (2) Janice C. LeBlanc, who is a resident and
citizen of Louisiana; and (3) Joseph C. LeBlanc, who is a resident and citizen of Tennessee.
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Based on public records and available information, LeBlanc Real Estate Investments, LLC
engages in business in Texas, but does not have a designated resident agent in Texas. Thus,
LeBlanc Real Estate Investments, LLC may be served with the citation and petition on the Texas
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Secretary of State, pursuant to TEX. CIV. PRAC. & REM. CODE, Section 17.044, by certified mail
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to Service of Process, Texas Secretary of State, P.O. Box 12079, Austin Texas 78711-2079 with
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Triple RRR Investments, LLC is a Louisiana limited liability company with its
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forwarding instructions to: Martin A. LeBlanc, 118 Rue Chavaniac, Lafayette, LA 70508.
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principal place of business in Lafayette, Louisiana. Its members are (1) Gary J. Russo, who is a
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resident and citizen of Louisiana; (2) Lynda T. Landry, who is a resident and citizen of
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Louisiana; and (3) Christopher J. Russo, who is a resident and citizen of Louisiana. Based on
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public records and available information, Triple RRR Investments, LLC engages in business in
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Texas, but does not have a designated resident agent in Texas. Thus, Triple RRR Investments,
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LLC may be served with the citation and petition on the Texas Secretary of State, pursuant to
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TEX. CIV. PRAC. & REM. CODE, Section 17.044, by certified mail to Service of Process, Texas
Secretary of State, P.O. Box 12079, Austin, TX 78711-2079 with forwarding instructions to:
Gary J. Russo, 600 Jefferson Street, Suite 1200, Lafayette, LA 70501.
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Triton Hardbanding Service, LLC is a Mississippi limited liability company with
its principal place of business in Edmond, Oklahoma. Its member is Mike Sheffield, who is a
resident and citizen of Oklahoma. Based on public records and available information, Triton
Hardbanding Service, LLC engages in business in Texas, but does not have a designated resident
agent in Texas. Thus, Triton Hardbanding Service, LLC may be served with the citation and
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Austin, TX 78711-2079 with forwarding instructions to: Randal M. Hill, CPA, 335 North 14th
Avenue, Laurel, MS 39440; and also Randal M. Hill, CPA, P.O. Box 4314, Laurel, MS 39440.
23.
MSI Inspection Service, LLC is a Mississippi limited liability company with its
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principal place of business in Edmond, Oklahoma. Its member is Mike Sheffield, who is a
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resident and citizen of Oklahoma. Based on public records and available information, MSI
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Inspection Service, LLC engages in business in Texas, and has a designated resident agent in
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Texas. Thus, it may be served with the citation and petition by certified mail on its Texas
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Maverick Rental Tools, LLC is an Oklahoma limited liability company with its
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registered agent: James S. Ates, 2603 S. Boston, Monahans, TX 79756.
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principal place of business in Edmond, Oklahoma. Upon information and belief, its members are
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Christopher J. Russo who is a resident and citizen of Louisiana and Mike Sheffield who is a
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resident and citizen of Oklahoma. Based on public records and available information, Maverick
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Rental Tools, LLC engages in business in Texas and has a designated resident agent in Texas.
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Thus, it may be served with the citation and petition on by certified mail its Texas registered
agent: Julius R. Cecil, Jr., 830 Highway 1943 W, Warren, TX 77664.
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CONDITIONS PRECEDENT
Plaintiffs have complied with, and fulfilled, any conditions precedent to the
assertion of their claims and to their entitlement to the relief prayed for herein.
JURISDICTION AND VENUE

26.
This Court has jurisdiction over the Defendants because they all have continuous
and systematic contacts with the State of Texas in the course of their business such that
exercising jurisdiction does not offend the traditional notions of fair play and substantial justice.
Specifically, this Court has jurisdiction over the Officers because they entered
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into agreements in Texas, worked for a company whose parent companies have their working
headquarters in Texas, made statements and representations to individuals in Texas and were
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paid by Plaintiffs who are also in Texas. The Officers engaged in a continuous pattern of
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tortious conduct within the State of Texas along with the aid of the other Defendants. Together,
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the Officers and the other Defendants conspired to divert monies, assets, and usurp corporate
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opportunities of the Plaintiffs, including acts and schemes involving Texas transactions and
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agreements. In doing so, the Officers and other Defendants contracted with Texas residents and
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performed work or other agreements in whole or in part in Texas. The ultimate effect of these
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schemes was to drain monies, assets and usurp opportunities from the Plaintiffs, to the detriment
All of the non-officer Defendants, including Scott Kerstetter, Daniel Anthony,
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of at least two companies operating with their headquarters in Houston, Texas.
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Mike Sheffield, Laguna Oil Tools, LLC, Quest Holdings, LLC, Renegade Performance
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Properties, LLC, Renegade Oil Tools, LLC, Renegade Manufacturing, LLC, Renegade
Performance Coatings, LLC, LeBlanc Release Estate Investments, LLC, Triple RRR
Investments, LLC, Triton Hardbanding Service, LLC, MSI Inspection Service, LLC, and
Maverick Rental Tools, LLC all either sold goods and/or engaged in real estate transactions,
including the sale and rental of properties, to Stabil Drill in the State of Texas.
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Defendants also received money from Stabil Drill and/or SESI for payment of salaries, bonuses,
goods, services, and/or rent.
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This Court also has jurisdiction over Laguna Oil Tools, LLC, Quest Holdings,
LLC, Renegade Performance Properties, LLC, Renegade Oil Tools, LLC, Renegade
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Manufacturing, LLC, Renegade Performance Coatings, LLC, LeBlanc Real Estate Investments,
LLC, Triple RRR Investments, LLC, Triton Hardbanding Service, LLC, MSI Inspection Service,
LLC, Maverick Rental Tools, LLC, and jurisdiction over each entitys Members, because these
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entities are alter egos of the Officers and of their Members, officers and directors as detailed
Venue is proper in Harris County, Texas, pursuant to TEX. CIV. PRAC. & REM.
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below.
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CODE 15.002(a) because all or a substantial part of the events or omissions giving rise to the
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claims occurred in Harris County and because the Officers and Defendants made statements or
Plaintiffs seek damages both in an amount within the jurisdictional requirements
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representations to individuals or companies located in Harris County, Texas.
Plaintiffs demand a trial by jury and have tendered the required fee to the Court.
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JURY DEMAND
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and limits of this Court. Plaintiffs seek monetary relief over $1,000,000.
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DISCOVERY RULE AND THE DEFENDANTS FRAUDULENT CONCEALMENT

TOLLS THE APPLICABLE STATUTES OF LIMITATION
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The causes of action asserted herein are not time barred because of the discovery
rule, which applies to these claims, and because of acts of fraudulent concealment by the
Officers and by the other Defendants, that toll the applicable statutes of limitation as well as the
accrual of the causes of action.
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Specifically, the Officers owed a fiduciary duty to the Plaintiffs, when they failed
to discharge their duties and disclosure for example, that they had an ownership or controlling
interest in a number of the Defendants, that the Officers personally profited from improper
transactions between the Defendants and Stabil Drill, that the Officers misappropriated corporate
below).
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opportunities from Stabil Drill and gave them to one or more of the Defendants (as outlined
Such fraudulent concealment, in violation of the Officers fiduciary duties to the
Plaintiffs, tolls limitations on the causes of action asserted herein. The other Defendants who
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conspired with the Officers also took affirmative steps to conceal the scheme and these
Moreover, limitations are tolled by the discovery rule (that is, the asserted causes
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fraudulent activities.
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of action did not accrue) until the Plaintiffs injuries could have been reasonably discovered.
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Recently, the Plaintiffs conducted an internal investigation when they became aware of the
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potential for a conflict of interest and ultimately learned recently of the Officers and other
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Defendants malfeasance. They filed this lawsuit shortly thereafter.
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FACTUAL BACKGROUND
Superior Energy Services, Inc., a publicly-traded Delaware corporation
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Christopher J. Russo and Martin A. LeBlanc Become Executive Officers of Stabil Drill
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headquartered in Houston, is a global provider of oilfield services. Superior Energy Services,

Inc. is the publicly-traded company and ultimate parent of Stabil Drill and SESI, L.L.C.
Superior provides the stock awarded to the Officers. Stabil Drill, a wholly-owned subsidiary
incorporated and based in Louisiana, is engaged in the sale, rental, manufacture and repair of
oilfield tools and equipment for downhole projects. SESI, L.L.C (1) is a Delaware corporation
that is a direct subsidiary of Superior Energy Services, Inc., (2) is the owner of Stabil Drill, and
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(3) is the entity that provides the funds to pay the Officers salaries and bonuses. Martin A.
LeBlanc began serving as Stabil Drills Chief Financial Officer (CFO) (after Superior acquired
Stabil Drill) in the late 1990s and Christopher J. Russo served as Stabil Drills Chief Operating
of Stabil Drill and its business relations for a number of years.
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Officer (COO) for many years. LeBlanc and Russo have been the individuals in direct control
SESI and Plaintiffs Became Suspicious and Had Their Fears Confirmed
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In early 2016, Plaintiffs became suspicious of the Officers activities and the
An internal investigation
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deficiencies of the Officers corporate disclosures to Plaintiffs.
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revealed that the Officers engaged in transactions with a number of interlocked corporate entities
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owned and controlled by LeBlanc, Russo and Kerstetter. Additional investigation revealed that
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Defendant Laguna Oil Tools, LLC was basically a sham corporation set up so that LeBlanc,
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Russo, and Kerstetter, by and through the various corporate entities they controlled, could divert
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corporate opportunities, direct profit from Stabil Drill transactions, and overbill Stabil Drill for
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Since approximately 2008, the Officers began to create an enterprise to enrich
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various products and services using the various entities they controlled.
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themselves using various companies in which they owned or had effective control of an interest.
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With the Defendants active collusion and assistance, they engaged in self-dealing and profited
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from both sides of business transactions involving Stabil Drill. The Officers either failed to
disclose their ownership interest or managed to hide their financial interests in various
companies and/or obfuscate the real purpose and business of the various entities which they
owned or effectively controlled. The following chart demonstrates the extent of the Officers
ownership interests in other companies that were doing business with Stabil Drill either directly
or through the sham company Laguna Oil Tools, LLC.
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Company
Renegade Performance Properties,
Renegade Oil Tools, LLC
Renegade Performance Coatings, LLC
Quest Holdings, LLC
LeBlanc Real Estate Investments, LLC
Triple RRR Investments, LLC
Maverick Rental Tools, LLC
Renegade Manufacturing, LLC
Laguna Oil Tools, LLC
LeBlanc
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X
X
X
Russo
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X
X
X
Kerstetter
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X
X
X
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X
X
The chart below details the amounts of money paid to entities in which the
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It demonstrates, for example, that
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Officers had a personal, financial, or business interest.
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LeBlanc and Russo allowed payments to and received financial benefits from a number of
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entities that have conducted business directly with Stabil Drill:
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Specifically, the Officers received financial benefits from various entities,
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Total Payments by Stabil Drill

$38.7 MM
$9.3 MM
$13.5 MM
$4.34 MM
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Company
Laguna Oil Tools, LLC
Triton Hardbanding Service, LLC
MSI Inspection Service, LLC
Quest Holdings, LLC
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including Laguna Oil Tools, LLC (Laguna), an entity at least superficially owned by
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Defendant Scott Kerstetter. On information and belief, Laguna is actually jointly managed and
or controlled by LeBlanc, Russo and Kerstetter, and serves as a pass through-entity for various
Renegade entities (also owned by LeBlanc, Russo, Kerstetter, Anthony or other Defendants) who
conspired to misappropriate funds, assets, trade secrets and usurp corporate opportunities from
the Plaintiffs.
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Plaintiffs believe that LeBlanc and Russo received improper financial benefits
from other entities, including Quest Holdings, LLC, Triton Hardbanding Service, LLC, MSI
Inspection Service, LLC, and Maverick Rental Tools, LLC. In fact, when one begins to put the
web of deceit together, numerous wrongful acts are then identifiable.
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Recently Discovered Specific Wrongdoings By Defendants
While functioning in their fiduciary capacity as Stabil Drills Chief Financial
Officer and Chief Operating Officer, respectively, LeBlanc and Russo received invoices
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submitted by Laguna Oil Tools, LLC for approval, even though both Officers were secretly
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sharing Lagunas profits with Defendant Kerstetter. Christopher J. Russo also received repeated
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email requests from Kerstetter to fabricate Stabil Drill purchase orders to match existing Laguna
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invoices. This continued practice ensured that there would be a constant stream of money
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flowing from Stabil Drill to Laguna, from which it would then flow into the personal pockets of
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LeBlanc, Russo and Kerstetter. On information and belief, the Officers disclosed to various third
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parties confidential and protected information that belonged to Plaintiffs, such as, for example,
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providing Laguna and other entities with the internal prices, financials, and other similarly
Laguna itself improperly used various Defendants, (e.g. Renegade Oil Tools, LLC
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compiled information that was meant for Plaintiffs use only.
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and Renegade Performance Properties, LLC) that were owned, at least in part, by the Officers.
The Officers also conspired with individuals like Kerstetter, Sheffield and Anthony to set up
these sham corporations to facilitate their improper schemes. Thus, the Officers personally made
fortunes by sending work to, and creating purchase orders for, an entity that hired other
companies owned by the Officers. In fact, Laguna and Renegade Oil Tools, LLC share the same
physical address, employees, and general liability insurance. Shipping records also indicate that
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equipment that Laguna Oil Tools, LLC provided to Plaintiffs actually originated from Renegade
Oil Tools, LLC, the company set up by the Officers and outsiders Kerstetter and Anthony.
Moreover, the email signature for the Laguna accountant reflects the names of both Laguna Oil
Tools, LLC and Renegade Oil Tools, LLC. The amount of money paid to Laguna in furtherance
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of Defendants scheme to milk Stabil Drill is approximately $38.7 million. In December 2012,
Stabil Drill sold property located in Youngsville, Louisiana, to Laguna for $535,000. Mere
months later, Laguna sold the same property to another one of the Officers entities, Defendant
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Renegade Performance Properties, for $700,000. On information and belief, the Officers did not
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The Officers also failed to disclose their ownership interests in Defendant Quest
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concerning this transaction.
No disclosures were made to Plaintiffs
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profit for themselves and the other Defendants.
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sell the property to Laguna at an arms-length transaction and used the proceeds to personally
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Holdings, LLC (Quest). Quest owns various properties that it leased or sold to Stabil Drill.
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Christopher J. Russo owns 33% of Quest while another entity, LeBlanc Real Estate Investments,
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LLC (LeBlanc Real Estate), owns another 33%, with Defendant Mike Sheffield owning
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another 33%. LeBlanc Real Estates registered agent and member is none other than Stabil
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Drills Chief Financial Officer, Martin A. LeBlanc. Since 2008, Stabil Drill paid at least $1.7
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million to Quest for rent on a building located in Yukon, Oklahoma, and $2.67 million to
purchase that same property as well as another property located in Midland, Texas. The Officers
never disclosed to Plaintiffs their ownership interests in Quest. Russo also failed to disclose his
ownership in Maverick Rental Tools, LLC (Maverick). Maverick was owned 50% by Russo
and 50% by Defendant Mike Sheffield. Although Maverick was not a vendor of Stabil Drill,
Sheffield was the registered agent and/or owner of MSI Inspection Service, LLC (MSI) and
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Triton Hardbanding Service, LLC (Triton), both vendors of Stabil Drill. Additionally, on
information and belief, Maverick, MSI, and Triton were jointly managed. Since 2008, Stabil
Drill paid MSI and Triton $13.5 million and $9.3 million, respectively. The fact that Stabil Drill
sent over $22 million to an entity owned by one of its officers underground business partners
45.
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indicates a clear lack of disclosure, impropriety and/or illegal activity.
Stabil Drill sells and rents oilfield tools and looks to expand its product offerings
to its customers.
In complete disregard of their legal obligations, the Officers failed to
In September 2013, LeBlanc and Kerstetter met with a
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oilfield tool called an agitator.
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adequately disclose a business opportunity to the Plaintiffs related to the development of an
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company, Cauldron Oil Tools (Cauldron), to discuss a business opportunity with one of the
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Officers other entities. As the CFO of Stabil Drill however, LeBlanc had a duty to present the
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deal to the Plaintiffs, and to disclose all material information related thereto. Instead of fulfilling
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his duty, LeBlanc declined Cauldrons investment opportunity on behalf of Stabil Drill and
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Plaintiffs, and instead gave the idea to Kerstetter so that he could develop the agitator and sell
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itor products derived therefromback to Stabil Drill. In September 2014, Kerstetter filed a
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patent application on behalf of Laguna for an agitator Laguna called a Drill String Vibrator or
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DSV. The Officers basically gifted the DSV to Kerstetter and Laguna and indirectly gifted the
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proceeds from the DSV back to themselves. The Officers never negotiated a contract with
Kerstetter so that Stabil Drill would benefit from the DSV. Instead, the Officers improperly
directed Stabil Drill to pay for the development of the DSV but let Kerstetter keep the patent
rights. Laguna then charged Stabil Drill for the tools. The Officers had a fiduciary duty to put
Stabil Drills interests above their own financial interest and the interest of their friends. The
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Officers eventually benefitted with a stake in the DSV and subsequent profits through their
interest in Laguna.
CAUSES OF ACTION
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COUNT ONE: BREACH OF FIDUCIARY DUTY

(The Officers)
46.
Plaintiffs incorporate by reference the factual allegations above as set forth herein.
47.
As executive officers of Stabil Drill, both LeBlanc and Russo owed fiduciary
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duties to Stabil Drill, Superior and SESI as a matter of law. These duties include the duty of
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obedience, duty of loyalty (to act in good faith and not allow personal interests to prevail over
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that of the Plaintiffs), and duty of care (to act and perform corporate duties in the same manner
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as an ordinary prudent person would under similar circumstances). The Officers therefore had
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the duty to fully disclose all material facts relative to their ownership interest in other entities, to
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avoid committing fraud against the corporation, to avoid self-dealing, and to avoid usurping
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Both LeBlanc and Russo breached their fiduciary duties multiple times during the
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corporate opportunities.
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course of several years. Their breaches of fiduciary duties include, but are not limited to, the
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following:
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a. Deliberately failing to disclose or inadequately disclosing their complete financial

interests in various business entities that had business relations with Stabil Drill,
including but not limited to Laguna Oil Tools, LLC, Renegade Manufacturing,
LLC, Renegade Performance Properties, LLC, Renegade Oil Tools, LLC,
Renegade Performance Coatings, LLC, Quest Holdings, LLC, LeBlanc Real
Estate Investments, LLC, Triple RRR Investments, LLC, Triton Hardbanding
Services, LLC, MSI Inspection Service, LLC and Maverick Rental Tools, LLC.
The Officers also failed to disclose that certain business entities owned by them
conducted business with Defendants who provided goods or services to Stabil
Drill. Effectively, the Officers set themselves up as undisclosed suppliers to
Stabil Drill.
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b. Approving invoices submitted by Laguna to Stabil Drill even though both

Officers were secretly sharing Lagunas profits with defendant Kerstetter.
c. Fabricating purchase orders from Stabil Drill to match invoices from Laguna.
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d. Disclosing and sharing the Plaintiffs confidential and protected information to

some or all of the Defendants, including internal prices, customer lists, financials,
and other similarly compiled information that was meant for Plaintiffs use only.
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e. Selling Plaintiffs property to Laguna or other undisclosed entities that were

owned, at least in part, by the Officers. Such transactions include the December
2012 sale to Laguna of property located in Youngsville, Louisiana, for $535,000
and the sale to Quest Holdings, LLC of properties located in Yukon, Oklahoma,
and Midland, Texas.
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f. Binding Plaintiffs, including Stabil Drill, to property rental agreements pursuant

to which Quest Holdings, LLC (a company co-owned by Russo and LeBlanc)
received rental payments for the property located in Yukon, Oklahoma and by
requiring Stabil Drill to purchase property from Quest.
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g. Sending Stabil Drills business to MSI and Triton, entities owned and/or operated
by Sheffield, a business partner of Russo in Maverick, an undisclosed entity
owned in part by Russo.
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h. Failing to adequately disclose all material information to Plaintiffs, failing to put

Stabil Drills interests above their own interests, and usurping the business
opportunity relating to the development of the DSV.
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As a result of the Officers breaches of their fiduciary duties, Plaintiffs have
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Usurping other corporate opportunities from Stabil Drill.
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j.
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i. Improperly approving Laguna invoices for the development costs of the DSV and
approving invoices for DSV tools.
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suffered damages for which they are entitled to compensation in an amount to be determined at
trial. Plaintiffs may suffer additional losses as legal proceedings continue and for which they are
entitled to recover damages.
COUNT TWO: COMMON LAW FRAUD MISREPRESENTATIONS
AND OMISSIONS
(All Defendants)
50.
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51.
The Defendants made material misrepresentations and omissions to Plaintiffs as
part of a scheme to make themselves richer through improper and illegal methods. As a direct
result of such material misrepresentations and omissions, Plaintiffs continued to trust and rely on
the Officers (each of whom owed the Plaintiffs a fiduciary duty) and the other Defendants to
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conduct business fairly and not to take advantage of their positions to Plaintiffs detriment.
Example of Defendants material misrepresentations and omissions include, but are not limited
to:
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a. The Officers deliberately chose not to disclose or inadequately disclosed their

complete financial interests in various other business entities that had business
relations with Stabil Drill, including but not limited to Laguna Oil Tools, LLC,
Renegade Manufacturing, LLC, Renegade Performance Properties, LLC,
Renegade Oil Tools, LLC, Renegade Performance Coatings, LLC, Quest
Holdings, LLC, LeBlanc Real Estate Investments, LLC, Triple RRR Investments,
LLC, Triton Hardbanding Services, LLC, MSI Inspection Service, LLC and
Maverick Rental Tools, LLC. The Officers also failed to disclose that certain
business entities owned by them conducted business with other Defendants who,
in turn, provided goods or services to Stabil Drill. Effectively, the Officers set
themselves up as undisclosed suppliers to Stabil Drill.
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b. The Officers approved Stabil Drills payment of invoices from Laguna and
Kerstetter even though the Officers knew that the invoices were not reflective of
the value of the work provided to Stabil Drill.
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c. Laguna and Kerstetter submitted invoices to Stabil Drill for payment knowing
that the invoices did not accurately depict the value and/or quantity of the work
performed or tools sold.
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d. The Officers fabricated purchase orders from Stabil Drill to match invoices from
Laguna.
e. The Officers sold Stabil Drill property to Laguna or other undisclosed entities that
were owned, at least in part, by the Officers. The Officers made false
representations and/or omissions concerning their own level of interest in such
sales. The sales include the December 2012 sale to Laguna of property located in
Youngsville, Louisiana for $535,000 and the sale to Quest Holdings, LLC of
properties located in Yukon, Oklahoma, and Midland, Texas. The Defendants
purchasing the properties, first Laguna and then Renegade Performance
Properties, LLC, deliberately chose not to disclose the interest of the Officers in
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the respective entities and led Stabil Drill to believe that the transaction was done
at arms-length and were fair to all those involved.
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f. The Officers bound Plaintiffs, including Stabil Drill, to property rental agreements
pursuant to which Quest Holdings, LLC received rental payments for the property
located in Yukon, Oklahoma. Quest chose not to disclose the interest of the
Officers and led Stabil Drill to believe that the terms of the rental agreement were
based on market value in Oklahoma and by allowing Stabil Drill to purchase
property from Quest.
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g. The Officers sent Stabil Drills business opportunities to MSI and Triton, which
are entities that are owned and/or operated by Mike Sheffield, a business partner
of Christopher J. Russo in Maverick. MSI and Triton submitted invoices to Stabil
Drill for payment knowing that the invoices did not accurately depict the value
and/or quantity of the work performed or tools sold.
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h. Failing to adequately disclose all material information to Plaintiffs, failing to put

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i. The Officers approved invoices sent to Stabil Drill from Laguna relating to the
development and purchase/rental of DSV tools. Laguna, for its part, sent invoices
to Stabil Drill which misrepresented the work done and value provided to Stabil
Drill. Laguna also misrepresented that the prices for the tools provided to Stabil
Drill were reasonable and offered at market prices. Laguna also submitted
invoices to Stabil Drill for payment knowing that the invoices did not accurately
depict the value of the goods provided to Stabil Drill.
These false representations and omissions of past or existing material facts were
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52.
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j. Misrepresenting and/or omitting material information to defraud Stabil Drill out

of corporate opportunities.
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made by the Defendants who knew that the representations and omissions were false or made
The
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recklessly without any knowledge of the truth and as a positive assertion.
misrepresentations and omissions were made with the intent that it should be acted on by the
Plaintiffs.
Plaintiffs then relied on these false representations and omissions by paying
substantial amounts of money to the Defendants, whether in the form of salary and bonuses to
the Officers, or in the form of money for services and/or property to the other Defendants. As a
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direct result of these false representations, Plaintiffs have improperly paid over $65 million to
Defendants.
53.
Plaintiffs have suffered damages for which they are entitled to compensation in an
continue and for which they are entitled to recover damages.
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amount to be determined at trial. Plaintiffs may suffer additional losses as legal proceedings
COUNT THREE: AIDING AND ABETTING BREACH OF

FIDUCIARY DUTY AND FRAUD
(All Defendants)
55.
All of the Defendants aided and abetted in the Officers breaches of fiduciary duty
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as set forth above in Count One: Breach of Fiduciary Duty and Count Two: Fraud and
The Defendants knew that the Officers had a fiduciary duty to the Plaintiffs and
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56.
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Misrepresentation, which are incorporated herein by reference.
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yet did all they could to, inter alia, request fake purchase orders, send fake invoices overcharging
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Plaintiffs for the work and/or services performed, fail to disclose or inadequately disclosing
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business interests, conceal ownership or financial interests, purchase property from Plaintiffs for
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prices not reflective of arms-length transactions, and request, receive, and use Plaintiffs trade
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Each of the Defendants also furthered the fraudulent scheme discussed above by,
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secrets.
for example, requesting fake purchase orders, sending and receiving fake invoices, overcharging
Plaintiffs for the work/services performed, concealing ownership or financial interests, and
purchasing property from Plaintiffs for prices not reflective of arms-length transactions while
representing that the prices were fair.
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58.
Due to the Defendants unlawful acts, Plaintiffs have suffered and continue to
suffer irreparable harm, as well as economic and non-economic damages, in an amount to be

determined at trial. The Defendants conduct was willful, malicious, and fraudulent, thereby also
entitling Plaintiffs to exemplary damages.
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COUNT FOUR: TRADE SECRET MISAPPROPRIATION/VIOLATION OF

UNIFORM TRADE SECRET ACT
(The Officers)
60.
Martin A. LeBlanc and Christopher J. Russo have abused their positions of trust
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59.
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by disclosing and/or using Stabil Drills, Superiors and/or SESIs trade secret information,
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particularly the Plaintiffs financial data and customer and supplier information, to illegally aid
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their undisclosed side businesses and other third parties. The Officers actions violate the Texas
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Specifically, the Plaintiffs had legally protectable trade secret information
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Uniform Trade Secrets Act. TEX. CIV. PRAC. & REM. CODE Chapter 134A.
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consisting of, inter alia, compiled customer and vendor/supplier lists, cost sheets for its products
Plaintiffs compiled this information at great cost to them and protected the
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by Plaintiffs.
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and services, costs and prices quoted by its suppliers and competitors, and other data compiled
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information from disclosure to others. As executive officers, LeBlanc and Russo had an express
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and implied contractual and confidential relationship which obligated them to not use and/or
disclose the information to others.
Yet, despite this obligation, Plaintiffs disclosed this
information to various outside entities that have been named as Defendants in this case.
62.
Plaintiffs suffered injury by the disclosure of the trade secret information in an
amount over the jurisdictional limits of this Court to be determined at trial by a jury. Plaintiffs
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also seek to recover their reasonable and necessary attorneys fees incurred as a result of these
wrongful acts under TEX. CIV. PRAC. & REM. CODE Chapter 134A.
COUNT FIVE: NEGLIGENCE AND GROSS NEGLIGENCE
(The Officers)
64.
As executive officers, LeBlanc and Russo owed a duty to Plaintiffs to act as
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63.
reasonable prudent executive officers. Both individuals violated this duty when they committed
Breach of Fiduciary Duty and Count Two:
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Misrepresentation.
The Officers acts, when viewed objectively, involved an extreme riskif not the
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65.
Fraud &
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the acts listed in Count One:
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certainty of riskof potential harm to Plaintiffs. Specifically, the Officers should have known
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that diverting millions of dollars away from Stabil Drill or otherwise usurping the Plaintiffs
of
corporate opportunities would result in extreme harm to the Plaintiffs. Despite being aware of
As a result of the Officers negligence and gross negligence, Plaintiffs have
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66.
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this risk, the Officers proceeded with conscious indifference to the welfare of Plaintiffs.
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suffered damages for which they are entitled to compensation in an amount to be determined at
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trial. Plaintiffs may suffer additional losses as legal proceedings continue and for which they are
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entitled to recover damages.
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COUNT SIX: NEGLIGENCE AND NEGLIGENT MISREPRESENTATIONS

(All Defendants)
67.
The Plaintiffs incorporate by reference the factual allegations above as set forth
68.
The Defendants owed a duty to Plaintiffs to act as a reasonably prudent person
herein.
and use reasonable care to not engage in acts that would harm the Plaintiffs. Defendants violated
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that duty by, for example, usurping corporate opportunities away from Plaintiffs, and diverting
millions of dollars of profits from the Plaintiffs.
69.
The Defendants have acted negligently and have made material representations
and omissions to Plaintiffs in the course of business and in business transactions in which they
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had pecuniary interests. As a direct result of such negligent acts and material misrepresentations
and omissions, which were false, Plaintiffs continued to trust and rely on the Officers and the
other Defendants to conduct business fairly and not to Plaintiffs detriment.
Examples of
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Defendants negligent acts, material representations and omissions, include, but are not limited
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to:
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a. Laguna and Kerstetter knew, or should have known, that the invoices submitted to
Stabil Drill for payment did not accurately depict the value and/or quantity of the
work performed or tools sold.
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b. Accepting fabricated purchase orders from Stabil Drill to match invoices

submitted by Laguna, or did not exercise reasonable care or competence to ensure
that the purchase orders were correct.
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c. The Officers sold Plaintiffs property to Laguna or other undisclosed entities

owned, at least in part, by the Officers who made representations and/or
omissions concerning their own level of interest in such sales. The sales include
the December 2012 sale to Laguna of property located in Youngsville, Louisiana,
for $535,000 and the sale to Quest Holdings, LLC of properties located in Yukon,
Oklahoma, and Midland, Texas. The Defendants purchasing the properties, first
Laguna and then Renegade Performance Properties, LLC, deliberately or
carelessly, failed to disclose the interest of the Officers in the respective entity and
led Stabil Drill to believe that the transaction was done at arms-length and fair to
all those involved.
d. The Officers bound Plaintiffs to property rental agreements pursuant to which
Quest Holdings, LLC received rental payments for the property located in Yukon,
Oklahoma. Quest Holdings, LLC deliberately or carelessly failed to disclose the
interest of the Officers and led Stabil Drill to believe that the terms of the rental
agreement was based on market price in Oklahoma and by allowing Stabil Drill to
purchase property from Quest.
e. The Officers sent Stabil Drills business to MSI and Triton, entities owned and/or
operated by Sheffield, a business partner of Russo in Maverick. MSI and Triton
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submitted invoices to Stabil Drill for payment that they knew or should have
known did not accurately depict the value and/or quantity of the work performed
or tools sold.
f. Failing to adequately disclose all material information to Plaintiffs, failing to put
The Defendants failed to exercise reasonable care or competence in running their
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g. The Officers approved invoices sent to Stabil Drill from Laguna relating to the
development and purchase/rental of DSV tools. Laguna, for its part, sent invoices
to Stabil Drill which misrepresented the research and development costs of the
DSV tools. Laguna also deliberately or carelessly misrepresented that the prices
for the tools provided to Stabil Drill were reasonable and offered at market prices.
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companies and in obtaining or communicating information regarding these matters to Plaintiffs.
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As a result, Plaintiffs justifiably relied upon the Defendants misrepresentations to their
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detriment by continuing to employ and pay salaries, bonuses, and award stock to the Officers all
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Plaintiffs justifiably relied on these representations because the Officers and other
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71.
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the while paying for goods and services from various Defendants.
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Defendants did all they could, including not disclosing their personal interests in and amongst
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each other, to make it seem that these transactions were done at arms-length and for fair and
At the time the Defendants made their negligent representations, the
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72.
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equitable prices.
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representations were in fact false. The Defendants failed to exercise reasonable care in making
the many misrepresentations to Plaintiffs. Plaintiffs did not have access to this information and
did not discover it until matters were recently investigated.
73.
Defendants also acted without reasonable care or prudence in their actions toward
the Plaintiffs, and these negligent acts and omissions also inflicted financial losses upon the
Plaintiffs for which they are entitled to compensation and damages.
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74.
The Defendants acts of negligence and negligent misrepresentations caused
Plaintiffs to incur damages. Plaintiffs have suffered damages for which they are entitled to
compensation in an amount to be determined at trial. Plaintiffs may suffer additional losses as
legal proceedings continue and for which they are entitled to recover additional damages.
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COUNT SEVEN: CIVIL CONSPIRACY

(All Defendants)
76.
The Defendants knowingly planned and acted in a concerted fashion amongst
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themselves and with third parties in a concerted conspiracy to usurp, divert, and procure
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Plaintiffs assets and corporate opportunities. Using the Officers positions of trust and fidelity,
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the third party entities, and an improper scheme, the Defendants conspired to commit improper
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and illegal acts against Plaintiffs and engaged in a series of acts to carry out the scheme to the
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The Officers set up various third party entities, including Maverick, Quest, and
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77.
of
detriment of Plaintiffs.
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the various Renegade companies which companies were used to drain Plaintiffs assets and in
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doing so breachedor aid in the breach ofthe Officers fiduciary duties. For example, Laguna
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and Renegade Oil Tools were used by the Officers, Kerstetter, and Anthony, to sell goods,
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services and/or to rent items to Plaintiffs for personal profit and gain in violation of the law. The
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Officers hid from Plaintiffs the true business of the companies they owned in order to profit from
Stabil Drill. All of the Defendants had a meeting of the minds and worked in a concerted fashion
to send fake or inaccurate invoices to the Plaintiffs, conceal true ownership interests, and/or
engage in covert real estate transactions.
78.
For example, the Officers, Laguna, and Kerstetter had a meeting of the minds and
an agreement to breach fiduciary duties, to defraud Stabil Drill, Superior, and SESI, to
27
misappropriate trade secrets, to conceal ownership or financial interests, overcharge for products,
and usurp Plaintiffs opportunity to invest in, and partner with, Cauldron to develop an agitator.
They profited from these illegal activities. Also, the Officers, Renegade Oil Tools, Kerstetter and
Anthony had a meeting of the minds for a similar illegal scheme to breach fiduciary duties, to
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defraud Stabil Drill, Superior and SESI, to misappropriate trade secrets, to conceal ownership or
financial interests, overcharge for products, and usurp Plaintiffs opportunity and to profit from
these illegal activities.
Due to the Defendants concerted unlawful acts with each other, Plaintiffs have
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79.
The Defendants conduct was willful,
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damages, in an amount to be determined at trial.
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suffered and continue to suffer irreparable harm, as well as economic and non-economic
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malicious, and fraudulent, thereby also entitling Plaintiffs to exemplary damages.
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COUNT EIGHT: DECLARATORY JUDGMENT ACTION

(All Defendants)
81.
Plaintiffs seek a declaratory judgment from this Court, pursuant to TEX. CIV.
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80.
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PRAC. & REM. CODE 37.001, et seq., with respect to the rights, status, and legal relations
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between Plaintiffs and the Defendants based on the terms of any agreements between them.
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Specifically, Plaintiffs seek a declaration action including, but not limited to, the following relief
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under the parties agreements:

a. That Plaintiffs no longer have any obligation(s) to perform or pay or conduct any
activity if such an obligation would otherwise not exist but for an agreement
between any of the Plaintiffs on one hand and any of the Defendants on the other;
and
b. That Plaintiffs are entitled to a lien, constructive trust, or other appropriate
equitable relief for all of their damages from the assets, cash, or other means of
the Defendants.
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82.
Under TEX. CIV. PRAC. & REM. CODE Chapter 37, Plaintiffs are also entitled to
recover their reasonable and necessary attorneys fees, and court costs, as are equitable and just
for this declaratory judgment action.
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COUNT NINE: TORTIOUS INTERFERENCE WITH PROSPECTIVE

BUSINESS RELATIONS
(The Officers, Laguna, and Kerstetter)
83.
84.
Due to the need for agitators, there was a reasonable probability that Plaintiffs
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would have entered into a business relationship with Cauldron for the development of agitators.
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However, the Officers, Kerstetter, and Laguna intentionally, maliciously, unlawfully, and with
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tortious desire to prevent such a relationship from occurring, ensured that Plaintiffs would never
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became adequately aware of the Cauldron opportunity or downplayed the opportunity so as to
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take it for themselves. Instead, the Officers, Laguna, and Kerstetter redirected this opportunity to
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Laguna knowing that the relationship with Cauldron would not occur if the opportunity was
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redirected elsewhere without adequately disclosing it to Plaintiffs or attempting to downplay
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such opportunity. The Officers also failed to adequately protect the interests of Stabil Drill. As a
These acts of interference damaged Plaintiffs because Plaintiffs then placed orders
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85.
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result of this interference, Plaintiffs never entered into a business relationship with Cauldron.
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for tools from Laguna that could have been developed by Stabil Drill or partially owned by
Stabil Drill or Plaintiffs themselves, or by a business partner. Laguna also charged Plaintiffs for
the entirety of the development costs and likely overcharged Plaintiffs for the costs of using the
tool as well, and then the Officers gifted the patent to Kerstetter.
COUNT TEN: MONEY HAD AND RECEIVED/UNJUST ENRICHMENT
(All Defendants)
86.
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87.
The Defendants all secured money for themselves, through fraud and by taking
undue advantage of the Plaintiffs, which, in equity and good conscience, belongs to the
Plaintiffs. Such money includes money received by the Officers from false or inflated expense
reports; claiming expenses that were incurred by them personally for non-business related
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activity or for their LLCs related businesses and then, seeking payment from Stabil Drill; any
ill-gotten profits made by overcharging the Plaintiffs, whether due to the sale of goods, services,
or property; any profits made by Laguna from the sale and/or rental of tools; and any salary,
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bonus, and other long term incentives paid to a respective Officer after the date the respective
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Officer began breaching his fiduciary duties to the Plaintiffs.
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COUNT ELEVEN: ACTION FOR ACCOUNTING

(All Defendants)
89.
At all relevant times, the Officers owed the Plaintiffs a fiduciary duty pursuant to
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88.
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which the Plaintiffs placed their trust in the Officers. Yet, in breach of their fiduciary duty, the
The Officers made large profits by virtue of their wrongful acts
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corporate opportunities.
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Officers perpetrated fraud on the Plaintiffs and usurped Plaintiffs money, property, and
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described above. Plaintiffs are entitled to a return of the profits, monies and other assets
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wrongfully diverted by the Officers but the amount of such improper proceeds and the amount of
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Plaintiffs proportionate shareif not 100%is not known to Plaintiffs.

90.
Plaintiffs are informed and believe that there is now due and owing to Plaintiffs
from the Officers certain sums of money in payment of Plaintiffs share of the profits, monies
and other assets of the businesses the Officers secretly operated in violation of their fiduciary
duties and at the expense of Plaintiffs. The amount due and owing to Plaintiffs is not known to
Plaintiffs because the Officers and their agents have had the sole possession and control of the
30
financial records and books of the various corporate entities. The facts and accounts presented in
this case are so complex that adequate relief may not be obtained at law without an accounting.
Among other acts, the Officers created fictitious purchase orders and honored false invoices on
behalf of the Plaintiffs at markups that are not known by Plaintiffs. The Officers also usurped
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corporate opportunities to generate business for their underground businesses who have, on
information and belief, made more money due to the usurpation of the opportunity. Indeed, the
exact nature and extent of the sales, expenses, and inventory are unknown to the Plaintiff and
The Defendant LLCs are hereinafter defined collectively as Laguna Oil Tools,
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cannot be determined without an accounting of the transactions of the parties.
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LLC, Quest Holdings, LLC, Renegade Performance Properties, LLC, Renegade Oil Tools, LLC,
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Renegade Manufacturing, LLC, Renegade Performance Coatings, LLC, LeBlanc Real Estate
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Investments, LLC, Triple RRR Investments, LLC, Triton Hardbanding Service, LLC, MSI
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Inspection Service, LLC, and Maverick Rental Tools, LLC. The Defendant LLCs perpetrated
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fraud on the Plaintiffs and usurped Plaintiffs money, property, other assets and corporate
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opportunities. The Defendant LLCs profited by virtue of their wrongful acts described above.
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Plaintiffs are entitled to a return of the profits, monies, and other assets wrongfully made by the
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Defendant LLCs but the amount of such improper proceeds and the amount of Plaintiffs
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proportionate shareif not 100%is not known to Plaintiffs.

92.
Plaintiffs are informed and believe that there is now due and owing to Plaintiffs
from the Defendants certain sums of money in payment of Plaintiffs share of the net profits of
the Defendant LLCs. The amount due and owing to Plaintiffs is not known to Plaintiffs because
the Defendants and their agents, including the Officers, have had the sole possession and control
of the financial records and books of the Defendant LLCs. The facts and accounts presented in
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this case are so complex that adequate relief may not be obtained at law without an accounting.
The Defendant LLCs created and sent fictitious and/or inaccurate invoices to the Plaintiffs,
marking up the price of the services and/or goods provided. Laguna also usurped corporate
opportunities to generate business and on information and belief, made more money due to the
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usurpation of the opportunity. Indeed, the exact nature and extent of the sales, expenses, and
inventory are unknown to the Plaintiff and cannot be determined without an accounting of the
transactions of the Defendants.
Plaintiffs are entitled to an accounting from both the Officers and the other
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Defendants for all profits, monies, and other assets that they have diverted by engaging in the
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wrongful acts described above. The Defendants have commingled the Plaintiffs assets with
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other assets and likely used Plaintiffs assets to purchase other properties and assets, such that the
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accounting sought by the Plaintiffs is not determinable through normal discovery procedures.
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Discovery is also inadequate because Plaintiffs have been kept in the dark by the Officerswho
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owed Plaintiffs a fiduciary dutyas to the extent of the fraudulent schemes.
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COUNT TWELVE: PUNITIVE/EXEMPLARY DAMAGES

(All Defendants)
95.
The Defendants conduct was willful, intentional and/or grossly negligent. The
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Defendants knew that the above-mentioned actions, including their misrepresentations,

omissions and willful and deliberate misappropriations of corporate funds and assets were
harmful to Plaintiffs.
Nonetheless, they proceeded with conscious indifference to violate
Plaintiffs rights.
96.
The Defendants, in the acts and conduct described above, also engaged in
intentional, deliberate, knowing and malicious conduct designed to deceive Plaintiffs. The acts
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and omissions of the Defendants included an extreme degree of risk, considering the probability
and magnitude of the potential harm to Plaintiffs. Plaintiffs have wrongfully paid over $65
million and continue to risk losing even more as contractual obligations come dueobligations
which would not have existed but for the wrongful conduct of the Defendants. The Defendants
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had actual, subjective awareness of the risks involved, but nevertheless proceeded to act with
conscious indifference to the rights, safety and/or welfare of Plaintiffs.
As a result, the
Defendants acts, conduct and omissions were undertaken intentionally and fraudulently, in bad
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faith, with malice, and deliberately and/or with gross negligence; Defendants should be held
As a result, the Plaintiffs seek punitive and exemplary damages in an amount to
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97.
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accountable and subjected to punitive/exemplary damages as provided for under Texas law.
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be determined by the jury under Texas law. TEX. CIV. PRAC. & REM. CODE 41.003.
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COUNT THIRTEEN: ATTORNEYS FEES

(All Defendants)
99.
Plaintiffs are entitled to an award of their attorneys fees, costs of court, pursuant
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to the applicable Texas law, including TEX. CIV. PRAC. & REM. CODE 37.001, 37.009 and
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Plaintiffs therefore seek an award of all such attorneys fees, costs, and expenses
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134A.005.
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incurred in this litigation from the Defendants.

COUNT FOURTEEN: ALTER EGO/PIERCING THE CORPORATE VEIL
(All Defendants)
101.
Plaintiffs incorporate by reference the factual allegations above as set forth
herein.
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102.
Laguna Oil Tools, LLC, Quest Holdings, LLC, Renegade Performance Properties,
LLC, Renegade Oil Tools, LLC, Renegade Manufacturing, LLC, Renegade Performance
Coatings, LLC, LeBlanc Real Estate Investments, LLC, Triple RRR Investments, LLC, Triton
Hardbanding Service, LLC, MSI Inspection Service, LLC, and Maverick Rental Tools, LLC are,
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and in the past were, alter egos of the members who managed them (Members) and have been
used to perpetrate actual fraud. Therefore, the Members should be held personally liable for the
harms they caused, using their respective LLC(s), to the Plaintiffs.
For example, Laguna is the alter ego of Defendant Scott Kerstetter and was used
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103.
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by Kerstetter for the purpose of perpetrating, and for perpetrating actual fraud on the Plaintiffs
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for the direct personal benefit of Kerstetter. Laguna sent false and fabricated invoices to the
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Plaintiffs to fraudulently take Plaintiffs money under the disguise of legitimate business
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transactions. Laguna also purchased property from Plaintiffs at less-than-market-value prices
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while representing that the prices were fair. Lagunas primaryif not solecustomer is Stabil
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Drill, further showing that Laguna was essentially created and operated to siphon money and
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opportunities away from Plaintiffs and to perpetrate fraud. Renegade Oil Tools, LLC is another
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example of its members using the LLC for the purpose of perpetrating and perpetrating actual
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fraud on the Plaintiffs for the direct personal benefit of its members. Renegade Oil Tools, LLCs
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members include Daniel Anthony, Scott Kerstetter, Christopher J. Russo, and Martin A.
LeBlanc. Renegade Oil Tools, LLC sent inaccurate and/or false invoices to Plaintiffs, using
Laguna as a pass through entity to create another layer of separation between the Plaintiffs and
Renegade Oil Tools. This layer, however, is a sham. In fact, Renegade Oil Tools, LLC and
Laguna share the same physical address, employees, and general liability insurance,
underscoring that its sole purpose was to act as an instrument to carry out the fraud designed by
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its members and other third parties, including Laguna. The MSI and Triton, LLCs owned and
operated by Defendant Mike Sheffield along with Maverick Rental Tools, LLC, owned and
operated by Defendant Mike Sheffield and Christopher J. Russo, were also similarly used for the
purpose of perpetrating fraud, and did perpetrate fraud, on the Plaintiffs for Sheffields and
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Russos personal benefit. Similarly, MSI and Triton were used to send fictitious invoices to
Plaintiffs to steal money by making false representations. Just like the other Defendant LLCs,
MSI and Triton were used by their respective members for the purpose of perpetrating, and for
The Members should be estopped from using their respective Defendant LLCs as
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104.
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perpetrating actual fraud on the Plaintiffs for the direct personal benefit of the members.
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shields and conduits for misappropriating money, property, trade secrets, and corporate
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opportunities belonging to Plaintiffs. The Defendant LLCs exist primarily to carry out the
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fraudulent schemes of its Members who have all repeatedly perpetrated fraud against the
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Plaintiff. Indeed, the Defendant LLCs are nothing but a tool and conduit for its Members to
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further their individual and collective objective of draining Stabil Drill and Plaintiffs while
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simultaneously evading personal obligations and responsibilities for the harms they have caused
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to Plaintiffs. The Defendant LLCs share much of their resources in furtherance of their
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fraudulent scheme as well, such as Laguna sharing an accountant, insurance, and address with
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Renegade Oil Tools, LLC. Therefore, the Members should be held personally liable for the
harms they have caused to the Plaintiffs while using their LLCs as conduits and tools for
perpetrating fraud.
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COUNT FIFTEEN: REQUEST FOR TEMPORARY AND

PERMANENT INJUNCTIVE AND OTHER EQUITABLE RELIEF
(All Defendants)
105.
106.
Pursuant to Texas Civil Practices & Remedies Code 65.011 and 134A.003,
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Plaintiffs further request a temporary injunction during the pendency of litigation and a
permanent injunction upon entry of final judgment. Injunctive relief is necessary to prevent the
Defendants and their members, managers, officers, and directors, from taking actions that would
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render any judgment in this litigation ineffectual or any action that would cause irreparable
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injury to any real or personal property, including any actual or threatened transfer of funds or
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assets to third parties or destruction of any documents and evidence, outside the ordinary course
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of business, or other acts that will otherwise irreparably damage the value of Plaintiffs judgment
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Plaintiffs are willing to post a bond upon entry of a
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relief protecting their trade secrets.
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in this case. Also, Plaintiffs business interests may be improperly damaged without injunctive
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The absence of a temporary injunction lasting the duration of the litigation until
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temporary injunction. TEX. R. CIV. P. 684.
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trial causes imminent and irreparable harm to the Plaintiffs because Defendants would be able to
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(1) use Plaintiffs money that has been wrongfully acquired in the course of Defendants illegal
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conduct in their own business or personal matters, (2) transfer money and property to other third
parties not in this litigation and outside the reach of this Court and Plaintiffs, (3) destroy
evidence that will be invaluable to Plaintiffs in showing the Defendants wrongful acts to the
Jury and this Court, and (4) continue to use or disclose Plaintiffs trade secrets in an industry that
is highly competitive and works on a small profit margin, thereby harming Plaintiffs. Indeed, on
information and belief, much of the Defendants assets simply consist of the money wrongfully
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acquired from the Plaintiffs, as Plaintiffs are either the sole or the most significant customers of
Defendant companies. Based on the imminent risk of harm and irreparable injury if the stolen
and wrongfully acquired money and assetswhich are currently in the possession and control of
the Defendantsare hidden from Plaintiffs, and based on the comparatively low harm to
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Defendants who can still operate as long as they do not do so in violation of the requested
injunction, and for the preservation of the status quo pending a final adjudication of the rights of
the parties, Plaintiffs request that the Court enter a temporary injunction, lasting until final
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judgment, which enjoins the Defendants, as indicated below, from the following:
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a. Defendants Martin A. LeBlanc, Christopher J. Russo, Scott Kerstetter, Daniel

Anthony, and Mike Sheffield as well as their respective spouses and collective or
respective agents, servants, employees, attorneys, and accountants and any other
person or entity acting in concert or at their instruction or on their behalf, are
enjoined and restrained from transferring, withdrawing, liquidating, spending,
concealing, encumbering, removing, dissipating, distributing, assigning, granting
a lien or security interest in, or otherwise disposing of any funds, real or personal
property, accounts, contracts, shares of stock, other assets or any interest therein
(collectively Assets), or allowing the same to occur, for any Assets acquired by
or through sales made to any of the Plaintiffs or acquired as payment for services
rendered.
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b. Defendants Laguna Oil Tools, LLC, Quest Holdings, LLC, Renegade

Performance Properties, LLC, Renegade Oil Tools, LLC, Renegade
Manufacturing, LLC, Renegade Performance Coatings, LLC, LeBlanc Real Estate
Investments, LLC, Triple RRR Investments, LLC, Triton Hardbanding Service
LLC, MSI Inspection Service, LLC, and Maverick Rental Tools, LLC, as well as
their respective agents, servants, employees, attorneys, and accountants and any
other person or entity acting in concert or at its instruction or on its behalf, are
enjoined and restrained from transferring, withdrawing, liquidating, spending,
concealing, encumbering, removing, dissipating, distributing, assigning, granting
a lien or security interest in, or otherwise disposing of any Assets, or allowing the
same to occur, for any Assets acquired by or through sales made to any of the
Plaintiffs.
c. The Defendants are enjoined and restrained from disclosing, using or transferring
any intellectual property or trade secrets belonging to Plaintiffs to themselves or
to third parties. For purposes of all relief in this Temporary Injunction, the terms
intellectual property or trade secrets means any intellectual property owned or
developed or wrongfully usurped from the Plaintiffs, or any of its Members,
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Managers, Directors, Officers, employees, agents and representatives, including

but not limited to, patents, patent applications, processes, trade secrets, products,
services, research and development, ideas, inventions, know-how, negative-knowhow, studies or results, project reports, ideas, discoveries, improvements,
writings, drawings, notes, reports, invention records, logs, marketing strategy,
customer information, customer identities, customer contacts, pricing lists for raw
material or final products, or supplier identities and contacts or pricing.
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d. The Defendants are enjoined and restrained from deleting, altering, destroying or
removing any emails, documents, data information, electronic postings, social
media, text messages, voicemails, records, files, history data or properties,
relating in any way to the operation of the Defendants, or their past acts in taking
assets, monies, intellectual property, or other items from the Plaintiffs, whether
outright or through fictitious or actual sales, in order that a proper accounting can
be made for these actions in the company accounting and tax documents.
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e. The Defendants must return to the Plaintiffs any assets in possession, custody, or
control, such as receivables, equipment, inventory, intellectual property, knowhow, customers, customer information, or contracts, which belong to any of the
Plaintiffs.
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f. The Defendants shall cease and desist taking any actions or engaging in any
activities, including through any third-party entities such as Laguna, which are
inconsistent with the rights of the Plaintiffs to its assets, such as money,
receivables, equipment, inventory, intellectual property, know-how, customers,
customer information, or contracts. In the event Defendants have already made
any agreements or arrangements relating to the Plaintiffs assets which are
inconsistent with the Plaintiffs ownership of such assets, they are hereby ordered
to rescind such agreements or arrangements and to cease and desist from any
further performance under such agreements or arrangements.
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g. The Defendants are ordered to provide an accounting from both the Officers and
the remaining Defendants for all profits, assets, and corporate opportunities they
have taken, diverted, usurped or received by engaging in the wrongful acts
described above.
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h. The Defendants are enjoined and restrained from taking any action to sell all or
substantially all of their assets.
108.
Plaintiffs request the Court to use its equitable powers and impose a constructive
trust over all money gotten by Defendants due to their tortious conduct described above,
including but not limited to the Defendants breaches of fiduciary duty, fraud, conspiracy, trade
secrets misappropriation, or the aiding or abetting thereof.
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109.
Plaintiffs further request the Court to use its equitable powers and find that
Plaintiffs are entitled to an accounting from the Officers and the Defendant LLCs for all profits
they have made by engaging in the wrongful acts described above.
110.
Plaintiff also request that, as part of the Courts permanent injunction the Officers
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must forfeit all salaries, bonuses, and compensation received from the Plaintiffs since the first
instance of the Officers tortious conduct. Additionally, Plaintiff request that the Court find that
the Defendants must disgorge any money gotten due to their tortious conduct.
A permanent injunction is appropriate in this case to preserve the status quo
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concerning Plaintiffs trade secrets. Plaintiffs have demonstrated a probable right to the relief
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sought. Absent permanent injunctive relief from the Court against the Defendants, there will be
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probable, imminent, and irreparable injury. The injury to Plaintiffs will be caused by the
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Defendants concealment of their assets so that any judgment entered in the case is rendered
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Based on the evidence submitted at trial, Plaintiffs request that the Court enter a
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permanent injunction against Defendants and their respective agents, attorneys, and all persons
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or entities acting in concert with them, and that the Court require the Plaintiffs to take the
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following actions, and to cease, desist, and refrain from taking action, as follows:
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a. Defendants Laguna Oil Tools, LLC, Quest Holdings, LLC, Renegade Performance
Properties, LLC, Renegade Oil Tools, LLC, Renegade Manufacturing, LLC,
Renegade Performance Coatings, LLC, LeBlanc Real Estate Investments, LLC,
Triple RRR Investments, LLC, Triton Hardbanding Service LLC, MSI Inspection
Service, LLC, and Maverick Rental Tools, LLC, as well as their respective agents,
servants, employees, attorneys, and accountants and any other person or entity acting
in concert or at its instruction or on its behalf, are enjoined and restrained from
transferring, withdrawing, liquidating, spending, concealing, encumbering, removing,
dissipating, distributing, assigning, granting a lien or security interest in, or otherwise
disposing of any funds, real or personal property, accounts, contracts, shares of stock,
other assets or any interest therein (collectively Assets), or allowing the same to
occur, for any Assets acquired by or through sales made to any of the Plaintiffs.
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b. The Defendants are enjoined and restrained from disclosing, using or transferring any
intellectual property, confidential information or trade secrets belonging to Plaintiffs
to themselves or to third parties. For purposes of all relief in this Permanent
Injunction, the terms intellectual property or trade secrets means any intellectual
property owned or developed or wrongfully usurped from the Plaintiffs, or any of its
Members, Managers, Directors, Officers, employees, agents and representatives,
including but not limited to, patents, patent applications, processes, trade secrets,
products, services, research and development, ideas, inventions, know-how, negativeknow-how, studies or results, project reports, ideas, discoveries, improvements,
writings, drawings, notes, reports, invention records, logs, marketing strategy,
customer information, customer identities, customer contacts, pricing lists for raw
material or final products, or supplier identities and contacts or pricing.
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c. The Defendants are enjoined and restrained from engaging in or conducting any
business or performing any services for any person or entity involving any intellectual
property, trade secrets, or confidential information owned or developed by Plaintiffs
or wrongfully usurped from the Plaintiffs.
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d. The Defendants shall cease and desist taking any actions or engaging in any activities
through any third-party entities, which would violate the terms of this injunction and
undermine the operations of the Plaintiffs or the value of Plaintiffs intellectual
property, trade secrets, or confidential information.
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e. The Defendants are enjoined and restrained from entering into any agreements or
arrangements with themselves or any third party in which any technology, products,
services, know-how or processes related to any intellectual property, trade secrets, or
confidential information owned or wrongfully usurped from the Plaintiffs are sold,
licensed, transferred, or commercialized; or in the event any such agreement has
already been entered by the Defendants, they are hereby ordered to rescind such
agreements or arrangements and to cease and desist from any further performance
under such agreements or arrangements.
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f. The Defendants must return to the Plaintiffs any assets in possession, custody, or
control, such as receivables, equipment, inventory, intellectual property, know-how,
customers, customer information, or contracts, which belong to any of the Plaintiffs.
REQUESTS FOR DISCLOSURE TO ALL DEFENDANTS:
Pursuant to Texas Rule of Civil Procedure 194, Defendants are requested to disclose,
within 50 days of service of this request, the information or material described in Rule 194.2.
Specifically, pursuant to Rule 194, each and every defendant is requested to disclosure, within 50
days of service of this request, the information or material described in Rule 194.2(a)-(l).
40
PRAYER FOR RELIEF

WHEREFORE, after the trial of this action, Plaintiffs pray that Plaintiffs have and
recover against Defendants as follows:
b. Actual damages incurred;
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a. Judgment for damages in an amount to be determined by the Court or jury;
c. Exemplary/punitive damages in an amount to be determined by the Court or jury;

d. Prejudgment and post judgment interest as provided by law;
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f. Declaratory judgment as prayed for herein;
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e. Reasonable attorneys fees, costs, and expenses;
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g. All costs of court allowed by law;
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h. Temporary and permanent injunctive relief against the Defendants as prayed for
herein; and
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i. Such other and further relief as this Court deems to be just, proper and equitable,
and as provided under Texas law.
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Dated: April 19, 2016
Respectfully submitted,
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/s/ C. Thomas Kruse

C. Thomas Kruse
Texas Bar No. 11742535
[email protected]
Matthew W. Caligur
[email protected]
Sashe D. Dimitroff
[email protected]
BAKER & HOSTETLER, LLP
811 Main Street, Suite 2600
Houston, Texas 77002
(713) 751-1600 Telephone
(713) 751-1717 Telecopier
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COUNSEL FOR PLAINTIFFS

SUPERIOR ENERGY SERVICES, INC.,
STABIL DRILL SPECIALTIES, L.L.C., AND
SESI, L.L.C.
42

Superior Energy Lawsuit

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2016-24818 / Court: 295

CAUSE NO. ______________

IN THE DISTRICT COURT

OF HARRIS COUNTY, TEXAS

SUPERIOR ENERGY SERVICES, INC.,

______ JUDICIAL DISTRICT

PLAINTIFFS VERIFIED ORIGINAL PETITION AND

A. LeBlanc (LeBlanc), Christopher J. Russo (Russo), Scott Kerstetter (Kerstetter), Daniel

NATURE OF THE CASE

engaged in a complex scheme of selfdealing primarily by creating separate but interwoven

business in Houston, Texas.

place of business is in Houston, Texas.

Christopher J. Russo is an individual and a resident and citizen of Louisiana.

Martin A. LeBlanc is an individual and a resident and citizen of Louisiana. Based

Scott Kerstetter is an individual and a resident and citizen of Louisiana. Based on

Daniel Anthony is an individual and a resident and citizen of Texas. Based on

Mike Sheffield is an individual and a resident and citizen of Oklahoma. Based on

Scott Kerstetter, 103 Guernsey Lane, Youngsville, LA 70592.

Renegade Performance Properties, LLC is a Louisiana limited liability company

with its principal place of business in Youngsville, Louisiana.

Its members are (1) Scott

Renegade Oil Tools, LLC is a Louisiana limited liability company registered to

2000 Kaliste Saloom Road, Suite 400, Lafayette, LA 70508.

Renegade Manufacturing, LLC is a Louisiana limited liability company with its

Renegade Performance Coatings, LLC is a Louisiana limited liability company

LeBlanc Real Estate Investments, LLC is a Louisiana limited liability company

Triton Hardbanding Service, LLC is a Mississippi limited liability company with

registered agent: James S. Ates, 2603 S. Boston, Monahans, TX 79756.

JURISDICTION AND VENUE

All of the non-officer Defendants, including Scott Kerstetter, Daniel Anthony,

of at least two companies operating with their headquarters in Houston, Texas.

Plaintiffs seek damages both in an amount within the jurisdictional requirements

representations to individuals or companies located in Harris County, Texas.

DISCOVERY RULE AND THE DEFENDANTS FRAUDULENT CONCEALMENT

Defendants malfeasance. They filed this lawsuit shortly thereafter.

Superior Energy Services, Inc., a publicly-traded Delaware corporation

headquartered in Houston, is a global provider of oilfield services. Superior Energy Services,

of Stabil Drill and its business relations for a number of years.

deficiencies of the Officers corporate disclosures to Plaintiffs.

Since approximately 2008, the Officers began to create an enterprise to enrich

It demonstrates, for example, that

Officers had a personal, financial, or business interest.

entities that have conducted business directly with Stabil Drill:

Specifically, the Officers received financial benefits from various entities,

Total Payments by Stabil Drill

Recently Discovered Specific Wrongdoings By Defendants

While functioning in their fiduciary capacity as Stabil Drills Chief Financial

compiled information that was meant for Plaintiffs use only.

concerning this transaction.

No disclosures were made to Plaintiffs

profit for themselves and the other Defendants.

indicates a clear lack of disclosure, impropriety and/or illegal activity.

In complete disregard of their legal obligations, the Officers failed to

In September 2013, LeBlanc and Kerstetter met with a

oilfield tool called an agitator.

adequately disclose a business opportunity to the Plaintiffs related to the development of an

COUNT ONE: BREACH OF FIDUCIARY DUTY

a. Deliberately failing to disclose or inadequately disclosing their complete financial

b. Approving invoices submitted by Laguna to Stabil Drill even though both

d. Disclosing and sharing the Plaintiffs confidential and protected information to