Southeast Texas Record

Sunday, April 5, 2020

Counterclaim filed in women's dispute over Galveston school

By John Suayan, Galveston Bureau | Oct 3, 2011

GALVESTON - Galveston resident Linda J. Dailey recently filed a counterclaim to a lawsuit alleging she was to blame for the closure of a Galveston school.

Dailey's two-page counterclaim was filed Sept. 2 before the Galveston County 405th District Court, a month after she was sued by Friendswood resident Leticia Craw and Pasadena locals Arlene and Nini Ramirez.

As previously reported, the three women allege trust issues with Dailey led to the shutdown of Health Initiatives Learning Center LLC, stating the defendant was difficult to work with.

Their original petition explains that Dailey never put any money into the operation of the business and spent "less and less time" working for the school, eventually starting her own business even though she continued to receive a salary based on an eight-hour workday.

According to the complainants, their relationship with Dailey increasingly deteriorated to the point she completely left the venture in May 2010.

They tried to inform her of their intentions to close the school because of the likelihood it would never be a financial success, but she "bitterly resisted," the suit says.

Dailey reportedly took over the institution's operations by herself.

The respondent argues the plaintiffs "willfully refused to attend three consecutive meetings" called by her in accordance with the organization's by-laws, stating "appropriate action was taken after the third special called meeting to keep the business operational and fulfill the legal and contractual obligations of the business."

She additionally claims her partners were negligent in running the school since they "refused to fulfill their obligations of their positions within the organization, and also refused to financially undergird the business operations until the business was viable and independent."

The counterclaim further shows the complainants illegally removed all supplies and furniture, disconnected the utilities, refused to meet payroll, refused to refund student tuition paid for with Department of Labor federal grant funds and broke into the premises after the locks were changed.

Dailey consequently seeks the dismissal of the suit and approximately $50,000 from the plaintiffs as well as an amount equal to any judgment in favor of them.

The defendant is representing herself.

Case No. 11-cv-1251

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