GALVESTON - Houston resident Santos Emilio Pereira has filed suit against Brenda Marquez, CHC Heritage Square LLC and Elite United Construction over $17,000.

Pereira alleges that he is owed $1,000 from Marquez and $15,500 from CHC Heritage Square for worked performed on their properties in Texas City.

"The plaintiff has fully complied with the agreement," states the lawsuit filed March 22 in Galveston County Court at Law No. 2. "The defendants defaulted in paying the debt."

The defendants face claims of breach of contract, common law fraud, statutory fraud, negligent misrepresentation, quantum meruit and unjust enrichment.

Court papers show the three parties "entered into agreements which the plaintiff was to construct and install crushed concrete entryways/driveways/parking lots" on or around last September.

Pereira insists he performed all work as per agreement, but the defendants breached the agreements entered into him by failing to pay him for labored performed or materials used.

"The plaintiff has demanded payment but to date the debt is still owed to plaintiff," the original petition says.

It adds Pereira has accelerated the debt in accordance to the terms of the agreement.

He ultimately points out that he experienced pain and suffering, out-of-pocket expenses, reasonable expenses of temporary transportation, lost wages and profits and damage to his credit reputation.

In addition to the $16,500 in question, Pereira seeks at least $10,000 in attorney's fees.

Attorney Javier Marcos Jr. of Houston is representing the plaintiff, and Galveston County Court at Law No. 2 Judge Barbara Roberts is presiding over the case.

Cause No. 64,951

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