TerraTech Vs VandeVredes 8-18 CV 00602 Jvs Jde

Case 8:18-cv-00602-JVS-JDE Document 1 Filed 04/11/18 Page 1 of 28 Page ID #:1
1 James P. Carter (SBN 150052)

James.Carter@jacksonlewis.com
2 Kelli M. Winkle-Petterson (SBN 267404)
Kelli.Winkle@jacksonlewis.com
3 JACKSON LEWIS P.C.
200 Spectrum Center Drive, Suite 500
4 Irvine, CA 92618
Telephone: (949) 885-1360
5 Facsimile: (949) 885-1380
6 Attorneys for Plaintiff TERRA TECH CORP.
7
8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA
10
11 TERRA TECH CORP., CASE NO.:

12 Plaintiff,
COMPLAINT FOR DAMAGES FOR:
13 v.
KENNETH VANDEVREDE, an (1) BREACH OF CONTRACT
14
individual; MICHAEL VANDEVREDE, (2) BREACH OF FIDUCIARY DUTY
15
an individual; STEVEN VANDEVREDE, (3) CONVERSION
an individual; DANIEL VANDEVREDE; (4) FRAUD
16
DAVID VANDEVREDE, an individual; (5) BREACH OF COVENANT OF
17
GREDA VANDEVREDE, an individual; GOOD FAITH AND FAIR
18 BEVERLY WILLEKES, an individual; DEALING
BRIAN VANDEVREDE, an individual; (6) MISAPPROPRIATION OF
19
GRO-RITE, a corporation; NATURALLY TRADE SECRETS
20 BEAUTIFUL PLANT PRODUCTS, LLC, (7) CONSPIRACY
a limited liability company; and DOES 1 DEMAND FOR JURY TRIAL
21
to 100, inclusive, [F.R. Civ. P. Rule 38; C.D. Cal. Local
22 Rule 38-1]
Defendants.
23
24
25
26
27
28
1 COMPLAINT FOR DAMAGES

1 Plaintiff TERRA TECH CORP. (‘Terra Tech”) alleges against Defendants

2 KENNETH VANDEVREDE, MICHAEL VANDEVREDE, STEVEN VANDEVREDE,
3 DANIEL VANDEVREDE, DAVID VANDEVREDE, GREDA VANDEVREDE,
4 BEVERLY WILLEKES, BRIAN VANDEVREDE, GRO-RITE, INC. and NATURALLY
5 BEAUTIFUL PLANT PRODUCTS, LLC (collectively, “Defendants”), and each of them
6 as follows:
7 NATURE OF THE CASE
8 1. Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE, and
9 STEVEN VANDEVREDE, who were also officers, employees and shareholders of Terra
10 Tech, committed fraud against Terra Tech, stole its intellectual property, proprietary
11 information, and usurped corporate opportunities intended for Terra Tech. This they did
12 in order to benefit themselves and each of the Defendants including GRO-RITE, INC. and
13 NATURALLY BEAUTIFUL PLANT PRODUCTS, LLC, which unknown to Terra Tech
14 until recently, unlawfully compete with Terra Tech.
15 THE PARTIES
16 2. Plaintiff TERRA TECH CORP. (hereinafter “Terra Tech”) is a corporation in
17 good standing with and organized under the laws of the State of Nevada with its principal
18 place of business in Irvine, California.
19 3. Defendant KENNETH VANDEVREDE is, and at all relevant times was, an
20 individual residing in New Jersey. Further, Terra Tech is informed and believes and based
21 thereon alleges that Defendant KENNETH VANDEVREDE has an ownership interest in
22 Defendants GRO-RITE, INC. and NATURALLY BEAUTIFUL PLANT PRODUCTS,
23 LLC.
24 4. Defendant MICHAEL VANDEVREDE is, and at all relevant times was an
25 individual, residing in New Jersey. Further, Terra Tech is informed and believes and based
26 thereon alleges that Defendant MICHAEL VANDEVREDE has an ownership interest in
28 LLC.

1 5. Defendant STEVEN VANDEVREDE is, and at all relevant times was, an

3 thereon alleges that Defendant STEVEN VANDEVREDE has an ownership interest in
5 LLC.
6 6. Defendant DANIEL VANDEVREDE is, and at all relevant times was, an
8 thereon alleges that Defendant DANIEL VANDEVREDE has an ownership interest in
10 LLC.
11 7. Defendant DAVID VANDEVREDE is, and at all relevant times was, an
13 thereon alleges that Defendant DAVID VANDEVREDE has an ownership interest in
15 LLC.
16 8. Defendant GREDA VANDEVREDE is, and at all relevant times was, an
18 thereon alleges that Defendant GREDA VANDEVREDE has an ownership interest in
20 LLC.
21 9. Defendant BEVERLY WILLEKES is, and at all relevant times was, an
23 thereon alleges that Defendant BEVERLY VANDEVREDE has an ownership interest in
25 LLC.
26 10. Defendant BRIAN VANDEVREDE is, and at all relevant times was, an
28 thereon alleges that Defendant BRIAN VANDEVREDE has an ownership interest in


2 LLC.
3 11. Defendant GRO-RITE, INC (“GRO-RITE”) is, and at all relevant times was
4 a corporation, organized under the laws of the State of New Jersey, with its principal place
5 of business in New Jersey.
6 12. Defendant NATURALLY BEAUTIFUL PLANT PRODUCTS, LLC
7 (“NATURALLY BEAUTIFUL”) is, and at all relevant times was a limited liability
8 company, organized under the laws of the State of New Jersey, with its principal place of
9 business in New Jersey.
10 13. Plaintiff does not know the true names of the individuals, corporations,
11 partnerships, or other entities sued and identified herein as DOES 1 through 100. Plaintiff
12 alleges that said Defendants are liable to Plaintiff under the claims for relief set forth below,
13 and requests leave of this Court to amend this Complaint when the true names of said
14 Defendants are discovered.
15 14. Terra Tech is informed and believes and thereon alleges that at all times herein
16 mentioned, each of the Defendants were the agents and/or co-conspirators with each of the
17 remaining defendants, and in acting or omitting to act as alleged were acting or omitting to
18 act within the scope of such agency and/or conspiracy with the knowledge, permission,
19 consent and/or approval of all Defendants, and each of them.
20 JURISDICTION AND VENUE
21 15. Jurisdiction is proper under 28 U.S.C. § 1332(a)(1) because the Court has
22 diversity over this action. The action includes claims solely between a citizen of the State
23 of California and citizens of the State of New Jersey, and the amount in controversy
24 exceeds, exclusive of interest and costs, the sum of Seventy-Five Thousand Dollars
25 ($75,000.00).
26 16. Venue is proper in this judicial district pursuant to an agreement between the
27 parties that Terra Tech and Defendants KENNETH VANDEVREDE, MICHAEL

VANDEVREDE, STEVEN VANDEVREDE, DAN VANDEVREDE, DAVID
28

1 VANDEVREDE, and BEVERLY WILLEKES would litigate disputes in the “federal

2 courts located in the County of Orange, State of California.”
3 17. Venue is also proper in this district pursuant to 28 U.S.C. § 1391(b)(3) as this
4 is a judicial district in which each and every Defendant is subject to the Court’s personal
5 jurisdiction. Indeed, Terra Tech is informed and believes, and on that basis alleges that
6 each and every Defendant is a shareholder in entities and/or is an entity that does business
7 across the United States including and especially in Southern California. In fact,
Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE, STEVEN
8
VANDEVREDE, DANIEL VANDEVREDE, DAVID VANDEVREDE, and BEVERLY
9
WILLEKES are shareholders of Terra Tech whose principal place of business is in Irvine,
10
California.
11
FACTUAL ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
12
18. Terra Tech is a cannabis-focused agriculture company that integrates the
13
natural world with technology to create sustainable solutions for cannabis production,
14
extraction and distribution, plant science research and development, food production and
15
Closed Environment Agriculture (a growing process that does not connect to the external
16
environment). Through this development, Terra Tech has created relevant brands in both
17 the cannabis and agriculture industries.
18 19. Terra Tech has also achieved ongoing and unprecedented success whenever
19 it applies for a city, state, and/or governmental agency permit to manufacture, sell or
20 dispense cannabis. In fact, its proprietary applications and strategy, developed over a
21 significant period of time and at great cost in the millions of dollars, have allowed Terra
22 Tech to achieve an unparalleled success at obtaining municipal and governmental agency
23 permits.
24 20. In 2013, Terra Tech entered into an agreement to purchase all shares of Edible
25 Garden from the VandeVrede family, including Defendants KENNETH VANDEVREDE,
26 MICHAEL VANDEVREDE, STEVEN VANDEVREDE, DANIEL VANDEVREDE,
27 DAVID VANDEVREDE, and BEVERLY WILLEKES. Edible Garden, now completely
28 owned and operated by Terra Tech, uses state-of-the-art hydroponic farming to produce

1 and supply fresh herbs and leafy greens on a large scale to supermarkets and restaurants in
2 and around New Jersey. As part of the purchase agreement, Terra Tech leased growing
3 fields from Defendants in New Jersey, a state on the cusp of legalizing marijuana, for the
4 purpose of growing, processing and distributing marijuana when legalized in New Jersey.
5 This agreement further provided that Terra Tech and Defendants KENNETH
6 VANDEVREDE, MICHAEL VANDEVREDE, STEVEN VANDEVREDE, DANIEL
7 VANDEVREDE, DAVID VANDEVREDE, and BEVERLY WILLEKES would litigate
8 disputes in the “federal courts located in the County of Orange, State of California.”
9 21. As part of the 2013 Share Exchange Agreement Defendants KENNETH
10 VANDEVREDE, MICHAEL VANDEVREDE, STEVEN VANDEVREDE, and DANIEL
11 VANDEVREDE each received their pro-rata share of 1,250,000 shares of Terra Tech
12 common stock worth approximately $4 million each. Defendants DAVID VANDEVREDE
13 and BEVERLY WILLEKES each received a pro-rata share of Terra Tech common stock
14 worth approximately $700,000 each.
15 22. After the sale of Edible Garden to Terra Tech, Defendants KENNETH
16 VANDEVREDE, MICHAEL VANDEVREDE, and STEVEN VANDEVREDE became
17 employees and officers of Terra Tech and Edible Garden, which resulted in their regular
18 travels to and work in Orange County, California.
19 23. Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE,
20 STEVEN VANDEVREDE, DANIEL VANDEVREDE, DAVID VANDEVREDE,
21 BEVERLY WILLEKES, GREDA VANDEVREDE, and BRIAN VANDEVREDE, are
22 owners, agents and/or intended beneficiaries of Defendants GRO-RITE and
23 NATURALLY BEAUTIFUL. Defendants GRO-RITE and NATURALLY BEAUTIFUL
24 directly compete with Terra Tech and Edible Gardens. Moreover, Defendants KENNETH
26 VANDEVREDE, DAVID VANDEVREDE, BEVERLY WILLEKES, GREDA
27 VANDEVREDE, and BRIAN VANDEVREDE directly benefit when the family
28 businesses, GRO-RITE and NATURALLY BEAUTIFUL, benefit.

1 24. As described in more detail herein Defendants, and each of them, were co-
2 conspirators with each other when Defendants KENNETH VANDEVREDE, MICHAEL
3 VANDEVREDE, and STEVEN VANDEVREDE committed fraud against Terra Tech,
4 stole its intellectual property, proprietary information, and usurped corporate opportunities
5 intended for Terra Tech in order to benefit of GRO-RITE and NATURALLY
6 BEAUTIFUL which derivatively, benefited Defendants KENNETH VANDEVREDE,
8 DAVID VANDEVREDE, BEVERLY WILLEKES, GREDA VANDEVREDE, and
9 BRIAN VANDEVREDE.
10 CODE OF ETHICS
11 25. On November 4, 2015, Defendants KENNETH VANDEVREDE, MICHAEL
12 VANDEVREDE, and STEVEN VANDEVREDE signed an Acknowledgment of Receipt
13 and Review of Code of Ethics as a part of that employment and/or agency relationship
14 between each of them and Terra Tech. Attached to this Complaint as Exhibit “A” is a copy
15 of the Terra Tech Code of Ethics. Attached to this Complaint as Exhibit “B” is a copy of
16 each of the Defendants’ signed acknowledgments.
17 26. Section III of the Code of Ethics is titled “Conflicts of Interest”, states, in
18 pertinent part: “Covered Persons should not use their position or association with the
19 Company for their own or their family’s personal gain, and should avoid situations in which
20 their personal interests (or those of their family) conflict or overlap, or appear to conflict
21 or overlap, with the Company’s best interests.”1 It then provides five (5) different examples
22 of activities that “give rise to a conflict of interest”:
23 a. “Where a Covered Person’s association with another person or entity
24
would reasonably be expected to interfere with the Covered Person’s
independent judgment as to the Company’s best interests, […]
25
26
27
1
28 “Covered Persons” are defined by the Code of Ethics as, “all directors, officers, and employees of the Company, including
the Company’s principal executive officer and principal financial officer”.

1 b. “The holding of a financial interest by a Covered Person in any present or

2
potential competitor, customer, supplier, or contractor of the Company
creates a conflict of interest, […].
3
c. “The acceptance by a Covered Person of a membership on the board of
4 directors, or serving as a consultant or advisor to any board or any
5 management, of a business that is a present or potential competitor,
customer, supplier, or contractor of the Company, creates a conflict of
6
interest, […].
7
d. “Engaging in any transaction involving the Company, from which the
8 Covered Person can benefit financially or otherwise, a part from the usual
9 compensation received in the ordinary course of business, creates a conflict
of interest.
10
e. “The use or disclosure of any unpublished information regarding the
11
Company, obtained by a Covered Person in connection with his or her
12 employment for personal benefit, creates a conflict of interest.”
13
27. The Code of Ethics requires Defendants to avoid all actual and apparent
14
conflicts. It further requires that a Defendant report even suspected conflicts to his superior
15
immediately.
16
28. Defendant KENNETH VANDEVREDE is an officer and director for
17
Psyblock LLC. Defendants MICHAEL VANDEVREDE and STEVEN VANDEVREDE
18
are directors for Psyblock LLC.
19
29. Defendant KENNETH VANDEVREDE is an officer and director for
20
AgroPlastics LLC.
21
30. No Defendant disclosed his conflicts with Psyblock LLC and/or AgroPlastics
22
LLC to Terra Tech. Terra Tech did not give permission for nor did it have any knowledge
23
of Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE and STEVEN
24
VANDEVREDE’S relationship with these two entities. In fact, Terra Tech did not learn
25
of the Defendants’ conflicts and failure to disclose them until late February 2018.
26
31. Section VII of the Code of Ethics is titled “Corporate Opportunities.” It states
27
that “Covered Persons are prohibited from taking for themselves personally (or for the
28
benefit of friends or family members) opportunities that are discovered through the use of

1 Company assets, property information, or position, or using Company assets, property,

2 information, or position for personal gain.”
3 32. Similarly, section VIII requires that Covered Persons maintain non-public,
4 proprietary information confidential and section X prohibits the use from theft,
5 carelessness and waste of company assets.
6 33. As stated above each Defendant agreed to all of the terms of the Code of
7 Conduct including those identified above. In brief, each Defendant breached the terms of
8 the Code of Conduct by:
9 a. diverting Terra Tech opportunities to VandeVrede family entities
10 including but not limited to opportunities with Chill Waze, CBD Water
11 and Cultivar, three companies that would have offered Terra Tech
12 strategic and lucrative corporate alliances (for example, and as discussed
13 in more detail below, Chill Waze sells high-end cannabis accessories
14 which aligns well with Terra Tech’s business model);
15 b. disseminating Terra Tech’s proprietary application documents and process
16 to other entities for the benefit of the VandeVrede entities including GRO-
17 RITE;
18 c. failing to disclose conflicts of interest between their positions as officers
19 and employees with Terra Tech and Psyblock LLC (and AgroPlastics LLC
20 as it pertains to Defendant KENNETH VANDEVREDE only);
21 d. using Terra Tech intellectual property including, but not limited to, Daily
22 Revenue Reports, Nevada Cannabis Permit Applications, Compliance
23 Memorandums and Terra Tech Google Analytics in order to usurp
24 opportunities intended for Terra Tech and divert them to the VandeVrede
25 family entities;
26 e. using Terra Tech employees to produce PowerPoint presentations, and
27 engage in other work, which was subsequently used to divert opportunities
28 from Terra Tech to the VandeVrede family entities; and,

1 f. using Terra Tech money to expense items that were used for the benefit of
2 the diversion of these opportunities and the VandeVrede family, not Terra
3 Tech.
4 34. Furthermore, Defendant KENNETH VANDEVREDE signed an
5 acknowledgment of the Employee Manual on September 7, 2017, which restates the
6 policies of the Code of Ethics in Sections 5-2 through 5-4 and other portions of Section 5.
7 Therefore, Defendant KENNETH VANDEVREDE also breached the terms of the
8 Employee Manual for the reasons stated above and below.
9 STOCK OPTION AGREEMENT
10 35. On January 8, 2016, and May 24, 2017, Defendants KENNETH
11 VANDEVREDE, MICHAEL VANDEVREDE, and STEVEN VANDEVREDE signed
12 and entered into a Stock Option Agreement (“Agreement”) between each Defendant and
13 Terra Tech. A copy of the May 24, 2017, Option Agreement is attached to this Complaint
14 as Exhibit “C”. As stated within the Agreement at paragraph 1.2, the Option was made to
15 each Defendant in consideration of the services to be rendered by each Defendant.
16 36. Paragraph 10 of the Agreement spells out the non-compete and non-
17 solicitation condition of the Agreement. In pertinent part, each Defendant agreed and
18 covenanted not to:
19
(a) contribute his … knowledge, as an employee, … agent, …to an entity
20 engaged in the same or similar business as the Company and its Affiliates,
21 including those engaged in the business of cultivating, producing, or
dispensing medical marijuana, herbs or produce for a period of one (1) year
22 following the Participant’s termination of Continuous Service; […] (c)
23 directly or indirectly, solicit, contact …, attempt to contact or meet with the
current, former, or prospective customers of the Company or any of its
24
Affiliates for purposes of offering or accepting goods or services similar to or
25 competitive with those offered by the Company or any of its Affiliates for a
period of one (1) year following the Participant’s termination of Continuous
26
Service.”
27
37. Upon a breach of the non-compete and non-solicitation covenant of the
28
Agreement, the Defendants agreed that they would forfeit their Options under the Plan and

1 that Terra Tech could seek a temporary restraining order or permanent injunction without
2 showing any actual damages or that money damages would not afford an adequate remedy,
3 and without the necessity of posting any bond or other security.
4 38. As stated above each Defendant agreed to all of the terms of the Stock Options
5 Agreement including those identified above. And, each Defendant breached the terms of
6 the Agreement as outlined above and below.
7 Defendants’ Breaches and Other Malfeasances against Terra Tech
8 39. In or about June 2017, Terra Tech became concerned that MICHAEL
9 VANDEVREDE and STEVEN VANDEVREDE were using Terra Tech and Edible
10 Garden facilities, equipment, and other assets such as manpower, for the benefit of
11 NATURALLY BEAUTIFUL, a separate VANDEVREDE business. Eventually, both
12 Defendants MICHAEL VANDEVREDE and STEVEN VANDEVREDE resigned as
13 officers and directors from Terra Tech though they both remained employees of Terra
14 Tech, in leadership positions with fiduciary duties, and officers of Edible Garden.
15 40. Due, in part, to the fact that Defendants KENNETH VANDEVREDE,
16 MICHAEL VANDEVREDE and STEVEN VANDEVREDE were and are fiduciaries to
17 both Terra Tech and Edible Garden, Terra Tech is informed and believes and on that basis
18 alleges that Defendants MICHAEL VANDEVREDE, STEVEN VANDEVREDE and
19 DANIEL VANDEVREDE knew about all of Defendant KENNETH VANDEVREDE’S
20 fraudulent breaches of contract, fiduciary duty and other wrongdoings outlined below, and
21 conspired to wrong Terra Tech. To that end, Terra Tech is informed and believes and on
22 that basis alleges that Defendants DAVID VANDEVREDE, GREDA VANDEVREDE,
23 BEVERLY WILLEKES, and BRIAN VANDEVREDE also knew about Defendant
24 KENNETH VANDEVREDE’S conduct and conspired to wrong Terra Tech.
25 I. Cultivar Opportunity
26 41. On August 30, 2017, Defendant KENNETH VANDEVREDE forwarded an
27 email from his GRO-RITE email account to his Terra Tech account with pictures of the
28 Cultivar Facility in Salinas, California. He also forwarded it to Defendants MICHAEL

1 VANDEVREDE, STEVEN VANDEVREDE and DANIEL VANDEVREDE and stated,

2 “check out. We could do something with these guys.”
3 42. However, Terra Tech had been in negotiations already with
4 Cultivar/CannaCraft since April of 2017. In fact, Defendant KENNETH VANDEVREDE
5 knew that Terra Tech was already negotiating with Culitvar because he, in his Terra Tech
6 capacity, visited their California site in July of 2017.
7 43. Therefore, Terra Tech is informed and believes and based thereon alleges that
8 Defendant KENNETH VANDEVREDE, with the aid of Defendants MICHAEL
9 VANDEVREDE, STEVEN VANDEVREDE and DANIEL VANDEVREDE, attempted
10 to usurp or did usurp an opportunity Terra Tech had with Cultivar for their GRO-RITE,
11 NATURALLY BEAUTIFUL and/or VandeVrede family businesses.
12 44. Terra Tech did not give permission for nor did it have any knowledge of
13 Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE and STEVEN
14 VANDEVREDE’S involvement in diverting the Cultivar opportunity. In fact, Terra Tech
15 did not learn that this opportunity was diverted until February 2018.
16 II. Summed Growers Opportunity
17 45. On or about February 27, 2017, Defendant KENNETH VANDEVREDE
18 received an email at his Terra Tech email address from Jake Van Wingerden from Summed
19 Growers regarding a cannabis opportunity. Instead of providing that opportunity to Terra
20 Tech or Edible Garden, he forwarded the email, with the opportunity, to Defendants
21 MICHAEL VANDEVREDE, STEVEN VANDEVREDE and DANIEL VANDEVREDE
22 who were operating competing entities, GRO-RITE and NATURALLY BEAUTIFUL,
23 which are owned, at least in part, by the VandeVrede family.
24 46. Terra Tech did not give permission for nor did it have any knowledge of
25 Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE and STEVEN
26 VANDEVREDE’S involvement in diverting the Summed Growers opportunity. In fact,
27 Terra Tech did not learn that this opportunity was diverted until February 2018.
28

1 III. Chill Waze Opportunity

2 47. Defendant KENNETH VANDEVREDE used Terra Tech’s name as a way to
3 develop opportunities with vendors and business partners. Once a dialogue was opened,
4 however, he dropped Terra Tech without informing anyone at Terra Tech, including other
5 executives or members of the board, and instead pursued these opportunities for his family
6 businesses and GRO-RITE.
7 48. For example, on or about May 18, 2017, Chill Waze CEO Vincent Gareffa
8 emailed Defendant KENNETH VANDEVREDE at his Terra Tech email address to pitch
9 Chill Waze’s idea for partnering with Terra Tech. Chill Waze is an online “headshop” that
10 sells, among other products, high-end cannabis accessories. Defendant KENNETH
11 VANDEVREDE never provided anyone at Terra Tech or Edible Garden the opportunity
12 to hear Chill Waze’s pitch and, instead, copied Defendant DANIEL VANDEVREDE at
13 GRO-RITE on all emails he exchanged with Chill Waze.
14 49. On August 2, 2017, and August 11, 2017, Defendant KENNETH
15 VANDEVREDE used Terra Tech resources for his own personal gain when he used his
16 Terra Tech American Express credit card to pay for lunch with Chill Waze.
17 50. On or about August 23, 2017, Chill Waze CEO Gareffa emailed Defendant
18 KENNETH VANDEVREDE at his Terra Tech email address to break down ownership of
19 Chill Waze and attached a PowerPoint presentation, which identifies Defendant
20 KENNETH VANDEVREDE as a “Silent Partner/Operations” and Defendant DANIEL
21 VANDEVREDE as “COO/Inventory and Logistics”. Moreover, the PowerPoint
22 presentation indicated that the warehouse was going to be the GRO-RITE location in New
23 Jersey, implying that Chill Waze intended to compete with Terra Tech in New Jersey. They
24 exchanged an additional email on August 30, 2017, which also was diverted to GRO-RITE.
25 51. On September 19, 2017, Chill Waze CEO Gareffa sent an updated PowerPoint
26 to Defendant KENNETH VANDEVREDE at his Terra Tech email address for their
27 developing business plan. Knowing that he was breaching covenants to Terra Tech and
28

1 Edible Garden, Defendant KENNETH VANDEVREDE responded with “Please send all
2 emails to ken@grorite.com”.
3 52. On September 21, 2017, Defendant KENNETH VANDEVREDE asked a
4 Terra Tech employee to send over the Terra Tech Property ID in order to login and access
5 google analytics for the Terra Tech website. Defendant KENNETH VANDEVREDE
6 immediately forwarded Terra Tech’s Property ID to CEO Gareffa at Chill Waze so that he
7 could login as a Terra Tech user and access Terra Tech proprietary information.
8 53. At no point in time did Defendant KENNETH VANDEVREDE communicate
9 this opportunity with Chill Waze to Terra Tech, or obtain permission to allow an outsider
10 into Terra Tech’s proprietary data base.
11 54. Further, Terra Tech did not give permission for nor did it have any knowledge
12 of Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE and STEVEN
13 VANDEVREDE’S involvement in diverting the Chill Waze opportunity. In fact, Terra
14 Tech did not learn that this opportunity was diverted until February 2018.
15 IV. CBD Water Opportunity
16 55. In a more recent example of how Defendant KENNETH VANDEVREDE has
17 been using Terra Tech’s name and resources to attract vendors and business partners, but
18 then keep the opportunities for his family, GRO-RITE, and NATURALLY BEAUTIFUL,
19 Defendant KENNETH VANDEVREDE took an opportunity presented by Ken Voorhees
20 of Ungerer & Co on February 6, 2018, for the Plant Based organic CBD Water packer.
21 CBD is a cannabidiol infused extra virgin olive oil derived from the hemp plant.
22 56. On February 7, 2018, Mr. Voorhees emailed Defendant KENNETH
23 VANDEVREDE at his Terra Tech email address and stated, “Organic CBD Water 50%
24 Vande 50% Voorhees, $50k each initial seed money. We can open after launch to others.
25 [sic]” An additional email was exchanged on February 8, 2018, regarding the look of the
26 bottle.
27 57. On February 20, 2018, Defendant KENNETH VANDEVREDE met with Mr.
28 Aaron Harris to discuss CBD Water. Defendant KENNETH VANDEVREDE charged his

1 parking in Morristown, New Jersey, to the Terra Tech corporate credit card for that
2 meeting.
3 58. At no point in time did Defendant KENNETH VANDEVREDE communicate
4 this opportunity with CBD Water to Terra Tech, or obtain permission to purse the
5 opportunity with CBD Water outside his capacity as an officer and director for Terra Tech.
6 59. Terra Tech did not learn that this opportunity was diverted until February
7 2018.
8 V. Great Meadows Design Group Opportunity
9 60. On or about January 22, 2018, Daniel Grover from the Great Meadows Design
10 Group emailed Defendant KENNETH VANDEVREDE at his Terra Tech email address to
11 ask Defendant KENNETH VANDEVREDE if he had sent over the executed contract or
12 non-disclosure agreement.
13 61. Great Meadows Design Group (“Great Meadows”) is a consulting engineering
14 company that provides electrical, mechanical, plumbing, and fire protection engineering
15 services for new and existing facilities.
16 62. From January 31, 2018 through February 22, 2018, the two exchanged emails
17 regarding corporate names and obtaining a New Jersey cannabis permit for “Lincoln Park
18 and Belvidere locations.”
19 63. At no point did Defendant KENNETH VANDEVREDE disclose this
20 opportunity with Great Meadows to Terra Tech, or that Great Meadows would be a
21 competitor of Terra Tech. Therefore, Terra Tech did not give Defendant KENNETH
22 VANDEVREDE permission to redirect this opportunity to another business or his family
23 entities.
25 2018.
26 VI. Burton Trent Public Affairs Opportunity
27 65. On January 31, February 6 and 22, 2018, Defendant KENNETH
28 VANDEVREDE received emails at his Terra Tech email address from Thomas

1 Mastrangelo, a cannabis lobbyist, to discuss the next potential steps in growing the
2 cannabis side of the VandeVrede family business with GRO-RITE.
3 66. At no point did Defendant KENNETH VANDEVREDE disclose the
4 opportunity to obtain permits from New Jersey with Thomas Mastrangelo to Terra Tech.
5 Terra Tech did not give Defendant KENNETH VANDEVREDE permission to divert this
6 opportunity to GRO-RITE.
8 2018.
9 VII. Unlawful Use of Proprietary Information and Intellectual Property
10 68. On or about August 23, 2017, Defendant KENNETH VANDEVREDE
11 received an email at his Terra Tech email address from Quantum 9 CEO Michael Mayes
12 for a telephone call to take place on August 25, 2017. Defendant KENNETH
13 VANDEVREDE forwarded the email from CEO Mayes to Defendants DANIEL
14 VANDEVREDE, MICHAEL VANDEVREDE and STEVEN VANDEVREDE stating
15 “Help us write our family cannabis permits for NJ.” Defendant STEVEN VANDEVREDE
16 responded and asked, “What’s this for?” Defendant KENNETH VANDEVREDE
17 responded, “Consultant that will help our family write the NJ cannabis application for us.
18 Scored #1 in PA. Has a 93% success rate.”
19 69. Quantum 9 is an international hemp and medical cannabis consulting firm,
20 which provides consultants to those seeking permits, marijuana cultivation, processing and
21 dispensing.
22 70. From August 25, 2017, through February 6, 2018, Defendant KENNETH
23 VANDEVREDE exchanged emails at his Terra Tech email address with CEO Mayes from
24 Quantum 9, which culminated in Quantum 9 sending a work order, contract and non-
25 disclosure agreement to Defendant KENNETH VANDEVREDE, which he forwarded to
26 himself at his GRO-RITE email address, identifying GRO-RITE as the contracting party
27 with Quantum 9 and the entity that would benefit from the work order from Quantum 9.
28 At no point did Defendant KENNETH VANDEVREDE disclose this opportunity to Terra

1 Tech. Worse, Terra Tech is informed and believes that Defendant KENNETH
2 VANDEVREDE used Terra Tech’s propriety and confidential application process in order
3 to market himself and his family to Quantum 9.
4 71. Terra Tech did not learn that the Quantum 9 opportunity was diverted until
5 February 2018; nor did it learn that Defendant KENNETH VANDEVREDE used Terra
6 Tech’s propriety and confidential application process in order to market himself and his
7 family to Quantum 9 until February 2018.
8 72. On November 30, 2017, Defendant KENNETH VANDEVREDE emailed
9 Terra Tech’s proprietary Nevada Permit Applications to Mark Hanselman and David
10 Alston, individuals who are not affiliated or associated with Terra Tech.
11 73. Terra Tech did not learn that Defendant KENNETH VANDEVREDE emailed
12 this propriety application until February 2018.
13 74. From December 28, 2017, to January 9, 2018, Defendant KENNETH
14 VANDEVREDE emailed with David Hollberg, the Pequannock, New Jersey Township
15 Manager/CFO. They agreed to set up a meeting, which took place on January 10, 2018, at
16 GRO-RITE, to discuss GRO-RITE’S application to grow cannabis.
17 75. At no point did Defendant KENNETH VANDEVREDE disclose the
18 opportunity to obtain permits from New Jersey with David Hollberg to Terra Tech. For
19 that matter, Terra Tech did not give Defendant KENNETH VANDEVREDE permission
20 to divert this opportunity to GRO-RITE.
21 76. Moreover, Terra Tech is informed and believes and on that basis alleges that
22 Defendant KENNETH VANDEVREDE used Terra Tech’s proprietary application
23 documents to submit an application to Pequannock Township.
24 77. Terra Tech did not learn that this opportunity was diverted and proprietary
25 information was potentially disclosed until February 2018.
26 VIII. Misrepresentations and Misappropriations
27 78. Defendant KENNETH VANDEVREDE attended Terra Tech board meetings
28 on September 26, 2017, and December 19, 2017. At each of these meetings, the board

1 expressly asked Defendant KENNETH VANDEVREDE whether his family was

2 competing with Terra Tech in cannabis. He misrepresented that they were not. In actuality,
3 Defendant KENNETH VANDEVREDE led the family business charge to focus on
4 cannabis cultivation in New Jersey.
5 79. During their employ with Terra Tech and Edible Garden, Defendants
6 MICHAEL VANDEVREDE and STEVEN VANDEVREDE were provided with health
7 insurance for themselves and their family under the Executive Level Plan. To obtain this
8 plan, Defendants MICHAEL VANDEVREDE and STEVEN VANDEVREDE were to
9 work at least 30 hours per week. However, they worked no more than 28 hours per week
10 thereby obtaining benefits for themselves and their family under false pretenses and
11 effectively, stealing Terra Tech resources.
12 FIRST CAUSE OF ACTION
13 (Breach of Contract Against Defendants KENNETH VANDEVREDE, MICHAEL
14 VANDEVREDE and STEVEN VANDEVREDE and Does 1 – 100)
15 80. Terra Tech repeats and re-alleges all the allegations contained in Paragraphs
16 1 through 79 inclusive, and by this reference incorporates the same herein as though fully
17 set forth.
18 81. Terra Tech and Defendants KENNETH VANDEVREDE, MICHAEL
19 VANDEVREDE, STEVEN VANDEVREDE, DANIEL VANDEVREDE, DAVID
20 VANDEVREDE, BEVERLY WILLEKES, and GREDA VANDEVREDE entered into the
21 2013 Share Exchange Agreement.
23 VANDEVREDE and STEVEN VANDEVREDE entered into the Code of Ethics and the
24 two Stock Option Agreements.
25 83. Defendant KENNETH VANDEVREDE separately signed and agreed to the
26 terms of Terra Tech’s Employment Manual.
27 84. Terra Tech performed all of its duties and obligations to Defendants

1 DANIEL VANDEVREDE, DAVID VANDEVREDE, BEVERLY WILLEKES, GREDA

2 VANDEVREDE under the terms of the contracts.
5 BEVERLY WILLEKES, GREDA VANDEVREDE, however, engaged in activity that was
6 prohibited by the contracts. Each Defendant breached the terms of both agreements as
7 outline in paragraphs 10 through 75, above.
8 86. Defendants’ breaches of contract, as alleged above, were and are a substantial
9 factor in causing Terra Tech harm.
10 87. As a direct and proximate result of these material breaches of the contracts,
11 Terra Tech has sustained economic damages, including but not limited to lost business
12 opportunities, in sums according to proof.
13 SECOND CAUSE OF ACTION
14 (Breach of Fiduciary Duty Against Defendants KENNETH VANDEVREDE,
15 MICHAEL VANDEVREDE and STEVEN VANDEVREDE and Does 1 – 100)
18 set forth.
19 89. By virtue of their employment with Terra Tech and Edible Garden, and their
20 positions as directors with Terra Tech and Edible Garden, Defendants KENNETH
21 VANDEVREDE, MICHAEL VANDEVREDE and STEVEN VANDEVREDE
22 maintained positions of trust and confidence with Terra Tech.
23 90. Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE and
24 STEVEN VANDEVREDE, and each of them, used their positions of trust and confidence
25 to further their own interest rather than Terra Tech’s, and breached their fiduciary duties to
26 Terra Tech by engaging in the acts alleged in this Complaint.
27 91. As a direct, foreseeable, and proximate result of Defendants KENNETH
28 VANDEVREDE, MICHAEL VANDEVREDE and STEVEN VANDEVREDE’S

1 breaches of their fiduciary duties to Terra Tech, Terra Tech has suffered damages in an
2 amount according to proof.
4 STEVEN VANDEVREDE’S were willful and malicious in their actions and justify an
5 award of punitive damages in an amount sufficient to punish Defendants KENNETH
6 VANDEVREDE, MICHAEL VANDEVREDE and STEVEN VANDEVREDE and deter
7 future conduct of this type.
8 THIRD CAUSE OF ACTION
9 (Conversion Against Defendants KENNETH VANDEVREDE, MICHAEL
11 VANDEVREDE, GREDA VANDEVREDE, BEVERLY WILLEKES, and BRIAN
12 VANDEVREDE and Does 1 – 100)
15 set forth.
16 94. Pursuant to the terms of the Code of Ethics, the Stock Option Agreement and
17 the Employee Manual, Terra Tech has clear legal ownership and right to possession in its
18 (1) intellectual, proprietary property in the form of permit applications, (2) its PowerPoint
19 presentations, (3) daily revenue reports, (4) Google analytics, (5) compliance
20 memorandums, (6) stock options, and (7) other personal and intellectual property subject
21 to conversion.
23 STEVEN VANDEVREDE wrongfully misappropriated Terra Tech’s (1) intellectual,
24 proprietary property in the form of permit applications, (2) its PowerPoint presentations,
25 (3) daily revenue reports, (4) Google analytics, (5) compliance memorandums, (6) stock
26 options, and (7) other personal and intellectual property owned by Terra Tech for the
27 benefit of themselves, GRO-RITE, NATURALLY BEAUTIFUL, DANIEL
28 VANDEVREDE, DAVID VANDEVREDE, GREDA VANDEVREDE, BEVERLY

1 WILLEKES, and BRIAN VANDEVREDE and to Terra Tech’s detriment, in violation of

2 Terra Tech’s property rights.
3 96. Terra Tech is further informed and believes and on that basis alleges that
4 Defendants GRO-RITE, NATURALLY BEAUTIFUL, DANIEL VANDEVREDE,
5 DAVID VANDEVREDE, GREDA VANDEVREDE, BEVERLY WILLEKES, and
6 BRIAN VANDEVREDE co-conspired with Defendants KENNETH VANDEVREDE,
7 MICHAEL VANDEVREDE and STEVEN VANDEVREDE in order to misappropriate
8 Terra Tech’s property.
9 97. As a proximate result of acts of conversion by Defendants’, and each of them,
10 Terra Tech has been deprived of its property rights and suffered damages in excess of the
11 jurisdictional minimum of this court, in an amount to be proven at trial.
12 98. The aforementioned acts of Defendants, and each of them, were willful,
13 wanton, malicious, and oppressive, were undertaken with the intent to defraud, and justify
14 the awarding of exemplary and punitive damages.
15 FOURTH CAUSE OF ACTION
16 (Fraud Against Defendants KENNETH VANDEVREDE, MICHAEL
18 VANDEVREDE, BEVERLY WILLEKES, AND GREDA VANDEVREDE and
19 Does 1 – 100)
22 set forth.
25 BEVERLY WILLEKES, and GREDA VANDEVREDE have suppressed and concealed
26 certain material facts which they had a duty to disclose to Terra Tech.
27 101. In particular, Defendants KENNETH VANDEVREDE, MICHAEL

1 VANDEVREDE, BEVERLY WILLEKES, and GREDA VANDEVREDE knew and

2 concealed from Terra Tech the following material facts:
3 a. The VandeVrede family was and is competing in cannabis;
4
b. Defendant KENNETH VANDEVREDE diverted opportunities with
Chill Waze, CBD Water and Cultivar from Terra Tech to the
5 VandeVrede family entities;
6
c. Persons and entities outside of Terra Tech were provided with Terra
Tech’s application process, for the benefit of themselves and their
7 family;
8 d. Persons and entities outside of Terra Tech were privy to Terra Tech’s
Daily Revenue Reports, Nevada Cannabis Permit Applications,
9 Compliance Memorandums and Terra Tech Google Analytics;
10 e. There is a conflict of interest between Terra Tech and Psyblock LLC
(and AgroPlastics LLC as it pertains to Defendant KENNETH
11 VANDEVREDE only);
12 f. Defendants used Terra Tech employees to produce PowerPoint
presentations, which were subsequently used to divert an opportunity
13 from Terra Tech to the VandeVrede family entities; and,
14 g. Defendants used Terra Tech money to expense items that were used for
the purpose of the diverting these opportunities to the VandeVrede
15 family, and away from Terra Tech.
16
102. Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE and
17
STEVEN VANDEVREDE had a duty to disclose these material facts as a result of their
18
fiduciary relationship with Terra Tech. In addition, Defendants KENNETH
19
VANDEVREDE, MICHAEL VANDEVREDE and STEVEN VANDEVREDE had an
20
independent duty to disclose these material facts since they undertook to make other
21
affirmative representations about these matters, and were thus bound to make full and fair
22
disclosure of all material facts.
23
103. Moreover, Defendant KENNETH VANDEVREDE intentionally
24
misrepresented that his family was not involved in the cannabis industry to the board when
25
directly asked. However, that was a lie as his family businesses, in particular GRO-RITE,
26
is involved in the cannabis industry in direct competition with Terra Tech.
27
28


3 BEVERLY WILLEKES, and GREDA VANDEVREDE suppressed, concealed and
4 misrepresented material facts with the intent to induce reliance from Terra Tech to enter
5 into contracts and take further related actions, and defraud Terra Tech.
6 105. At all relevant times, Terra Tech was unaware of the material facts that were
7 suppressed and concealed by Defendants until on or about February 28, 2018. If Terra
8 Tech had been aware, it would have taken steps to protect its ownership interests, property
9 rights, and corporate opportunities and to protect against Defendants KENNETH
11 VANDEVREDE, DAVID VANDEVREDE, BEVERLY WILLEKES, and GREDA
12 VANDEVREDE’S wrongful conduct.
13 106. As a proximate result of Defendants KENNETH VANDEVREDE,
15 DAVID VANDEVREDE, BEVERLY WILLEKES, and GREDA VANDEVREDE’S
16 intentional and fraudulent suppression, and concealment of the above-described material
17 facts, Terra Tech has suffered, and continues to suffer damages, in an amount currently
18 unascertained, but according to proof at trial.
19 107. The aforementioned conduct of Defendants KENNETH VANDEVREDE,
21 DAVID VANDEVREDE, BEVERLY WILLEKES, and GREDA VANDEVREDE
22 constitutes fraud, suppression and/or concealment of material facts known to them, with
23 the intent on the part of Defendants of inducing reliance and thereby depriving Terra Tech
24 of property and/or legal rights or otherwise causing injury, and was despicable conduct that
25 subjected Terra Tech to cruel and unjust hardship in conscious disregard of the Terra
26 Tech’s rights, so as to justify an award of exemplary and punitive damages.
27
28

1 FIFTH CAUSE OF ACTION

2 (Breach of Covenant of Good Faith and Fair Dealing Against Defendants
3 KENNETH VANDEVREDE, MICHAEL VANDEVREDE, STEVEN
4 VANDEVREDE, DANIEL VANDEVREDE, DAVID VANDEVREDE, BEVERLY
5 WILLEKES, AND GREDA VANDEVREDE and Does 1 – 100)
8 set forth.
9 109. In every contract, the law recognizes an implied covenant of good faith and
10 fair dealing. The covenant is to the effect that neither party to the contract will do anything
11 deliberately to deprive the other of the benefits of the agreement.
14 VANDEVREDE, BEVERLY WILLEKES, and GREDA VANDEVREDE entered into the
15 2013 Share Exchange Agreement, Code of Ethics and the two Stock Option Agreements.
16 111. Defendant KENNETH VANDEVREDE separately signed and agreed to the
17 terms of Terra Tech’s Employment Manual.
18 112. Terra Tech performed all of its duties and obligations to Defendants
20 DANIEL VANDEVREDE, DAVID VANDEVREDE, BEVERLY WILLEKES, and
21 GREDA VANDEVREDE under the terms of the contracts.
24 BEVERLY WILLEKES, and GREDA VANDEVREDE, however, engaged in activity that
25 was not only prohibited by the contracts, but also substantially interfered with Terra Tech’s
26 right to receive the benefits of the contracts by unilaterally usurping corporate
27 opportunities, using Terra Tech personnel, intellectual property and funds for their own
28 personal gain, and otherwise competing with Terra Tech in New Jersey.

1 114. As a direct and proximate result of Defendants KENNETH VANDEVREDE,

3 DAVID VANDEVREDE, BEVERLY WILLEKES, and GREDA VANDEVREDE’S
4 conduct, Terra Tech has sustained economic damages, including but not limited to lost
5 business opportunities, in sums according to proof.
6 SIXTH CAUSE OF ACTION
7 (Misappropriation of Trade Secrets Against Defendants KENNETH
9 VANDEVREDE, DAVID VANDEVREDE, GREDA VANDEVREDE, BEVERLY
10 WILLEKES, BRIAN VANDEVREDE, GRO-RITE, INC. and NATURALLY
11 BEAUTIFUL PLANT PRODUCTS, LLC and Does 1 – 100)
14 set forth.
15 116. Terra Tech owns its proprietary application process, daily revenue reports,
16 Nevada cannabis permit applications, compliance memorandums and Terra Tech Google
17 analytics.
18 117. Terra Tech’s proprietary application process, daily revenue reports, Nevada
19 cannabis permit applications, compliance memorandums and Terra Tech Google analytics
20 were trade secrets at the time of the misappropriation.
23 GREDA VANDEVREDE, BEVERLY WILLEKES, BRIAN VANDEVREDE, GRO-
24 RITE, NATURALLY BEAUTIFUL, and DOES to be determined improperly acquired,
25 used and/or disclosed the trade secrets.
26 119. Terra Tech was harmed by the improper acquisition, use and/or disclosure of
27 its trade secrets in sums according to proof and Defendants were unjustly enriched by the
28 improper acquisition, use and/or disclosure.

1 120. Defendants’ acquisition, use and/or disclosure of its trade secrets was a
2 substantial factor in causing Terra Tech’s harm and/or Defendants’ unjust enrichment.
3 SEVENTH CAUSE OF ACTION
4 (Conspiracy Against Defendants KENNETH VANDEVREDE, MICHAEL
6 VANDEVREDE, GREDA VANDEVREDE, BEVERLY WILLEKES, BRIAN
7 VANDEVREDE, GRO-RITE, INC. and NATURALLY BEAUTIFUL PLANT
8 PRODUCTS, LLC and Does 1 – 100)
11 set forth.
12 122. A conspiracy is an agreement by two or more persons to commit a wrongful
13 act. Such an agreement may be made orally or in writing or may be implied by the conduct
14 of the parties.
18 RITE, NATURALLY BEAUTIFUL, and DOES to be determined were aware of and/or
19 planned to (1) breach contracts with Terra Tech, (2) convert Terra Tech property, (3) divert
20 corporate opportunities for Terra Tech to themselves and/or other Defendants including
21 but not limited to GRO-RITE and NATURALLY BEAUTIFUL, (4) conceal and
22 misrepresent material facts and (5) misappropriate trade secret information.
26 RITE and NATURALLY BEAUTFIUL agreed amongst themselves and/or intended that
27 the (1) breach of contracts with Terra Tech, (2) conversion of Terra Tech property, (3)
28 diversion of corporate opportunities for Terra Tech to themselves and/or other Defendants

1 including but not limited to GRO-RITE and GRO-RITE and NATURALLY BEAUTFIUL,
2 (4) concealment and misrepresentation of material facts and (5) misappropriation of trade
3 secret information be committed.
4 125. This agreement and/or intention became apparent, in part, when Defendant
5 KENNETH VANDEVREDE forwarded emails to MICHAEL VANDEVREDE, STEVEN
6 VANDEVREDE and DANIEL VANDEVREDE at their GRO-RITE email accounts. At
7 no point did anyone from GRO-RITE disclose that its co-conspirators were engaging in
8 the above-mentioned wrongful conduct.
9 126. As a proximate result of Defendants’ conspiracy, Terra Tech has suffered, and
10 continues to suffer damages, in an amount currently unascertained, but according to proof
11 at trial.
12 127. The aforementioned conduct of Defendants constitutes conspiracy, and was
13 despicable conduct that subjected Terra Tech to cruel and unjust hardship in conscious
14 disregard of the Terra Tech’s rights, so as to justify an award of exemplary and punitive
15 damages.
16 PRAYER FOR RELIEF
17 WHEREFORE, Terra Tech prays for judgment against all Defendants as follows:
18 1. For compensatory damages, in an amount to be proved at trial;
19 2. For prejudgment interest at the highest legal rate;
20 3. For the return of its shares exchanged under the 2013 Share Exchange
21 Agreement;
22 4. For the return of its (1) intellectual, proprietary property in the form of permit
23 applications, (2) its PowerPoint presentations (3) daily revenue reports, (4)
24 Google analytics, (5) compliance memorandums, and (6) stock options;
25 5. For the return of the options owned by the individual Defendants and the right
26 to exercise the vested options;
27 6. For exemplary and/or punitive damages;
28 7. For costs of suit incurred;


TerraTech Vs VandeVredes 8-18 CV 00602 Jvs Jde

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TerraTech Vs VandeVredes 8-18 CV 00602 Jvs Jde

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Case 8:18-cv-00602-JVS-JDE Document 1 Filed 04/11/18 Page 1 of 28 Page ID #:1

1 James P. Carter (SBN 150052)

8 UNITED STATES DISTRICT COURT

11 TERRA TECH CORP., CASE NO.:

1 COMPLAINT FOR DAMAGES

1 Plaintiff TERRA TECH CORP. (‘Terra Tech”) alleges against Defendants

2 COMPLAINT FOR DAMAGES

1 5. Defendant STEVEN VANDEVREDE is, and at all relevant times was, an

3 COMPLAINT FOR DAMAGES

1 Defendants GRO-RITE, INC. and NATURALLY BEAUTIFUL PLANT PRODUCTS,

27 parties that Terra Tech and Defendants KENNETH VANDEVREDE, MICHAEL

4 COMPLAINT FOR DAMAGES

1 VANDEVREDE, and BEVERLY WILLEKES would litigate disputes in the “federal

5 COMPLAINT FOR DAMAGES

6 COMPLAINT FOR DAMAGES

7 COMPLAINT FOR DAMAGES

1 b. “The holding of a financial interest by a Covered Person in any present or

8 COMPLAINT FOR DAMAGES

1 Company assets, property information, or position, or using Company assets, property,

9 COMPLAINT FOR DAMAGES

10 COMPLAINT FOR DAMAGES

11 COMPLAINT FOR DAMAGES

1 VANDEVREDE, STEVEN VANDEVREDE and DANIEL VANDEVREDE and stated,

12 COMPLAINT FOR DAMAGES

1 III. Chill Waze Opportunity

13 COMPLAINT FOR DAMAGES

14 COMPLAINT FOR DAMAGES

15 COMPLAINT FOR DAMAGES

16 COMPLAINT FOR DAMAGES

17 COMPLAINT FOR DAMAGES

1 expressly asked Defendant KENNETH VANDEVREDE whether his family was

18 COMPLAINT FOR DAMAGES

1 DANIEL VANDEVREDE, DAVID VANDEVREDE, BEVERLY WILLEKES, GREDA

19 COMPLAINT FOR DAMAGES

20 COMPLAINT FOR DAMAGES

1 WILLEKES, and BRIAN VANDEVREDE and to Terra Tech’s detriment, in violation of

21 COMPLAINT FOR DAMAGES

1 VANDEVREDE, BEVERLY WILLEKES, and GREDA VANDEVREDE knew and

22 COMPLAINT FOR DAMAGES

1 104. Defendants KENNETH VANDEVREDE, MICHAEL VANDEVREDE,

23 COMPLAINT FOR DAMAGES

1 FIFTH CAUSE OF ACTION

24 COMPLAINT FOR DAMAGES

1 114. As a direct and proximate result of Defendants KENNETH VANDEVREDE,

25 COMPLAINT FOR DAMAGES

26 COMPLAINT FOR DAMAGES

27 COMPLAINT FOR DAMAGES

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