Filing # 192709803 E-Filed 02/26/2024 12:05:38 PM
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`NOT A CERTIFIED COPY
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`EXHIBIT A
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`FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 02/26/2024 12:05:38 PM
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`CHENEY BROTHERS,INC.
`FOOD SERVICE DISTRIBUTORS
`ONE CHENEY WAY
`RIVIERA BEACH,FL. 33404-7000
`www.cheneybrothers.com
`
`CheneyGERD.
`Brothers
`
`aeeae Esq.
`561-845-4745
`Direct Line:
`Fax:
`561-684-7935
`RachelleM@CheneyBrothers.com
`
`February 3, 2022
`
`Via Federal Express
`Wesley Richards
`1001 SW Charcoal Ave.
`Port St. Lucie, FL 34953
`
`Dear Mr. Richards:
`
`Re: Cheney Bros., Inc. v. Wesley Richards
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`NOT A CERTIFIED COPY
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`On behalf of Cheney Bros., Inc. (d/b/a Cheney Brothers), I forward this correspondence
`demanding immediate resolution ofa serious matter.
`
`You were employed as a pilot since approximately Decembenof2018. During that time, Cheney
`Brothers has provided you with generous compensation, valuable experience andtraining, and a
`professional work environment.
`
`Bythe last quarter of 2022, it was determined ‘that purchase orlease of a new aircraft would be
`necessary. Ultimately, a Citation Sovereign was purchased. You were well aware ofthe need for
`
`and the ultimate purchase of same. Youywere.also well aware thatyouandtheotherpilotswould
`needto receive comprehensivetrairling
`and,certification in order to operate the new aircraft.
`
`You, in fact, proceeded with the training, completed same, andreceivedacertification to operate
`the new aircraft. Between the tuition and the expensesassociated with the training, Cheney
`Brothers spen(approximately $50,000.
`\Cheney Brothers did this based on your
`
` rep
`acknowledgement and
`representation that you intended to remain in Cheney Brothers’ employ.
`Unfortunately, it now appearsthat your representation and acknowledgmentin this regard were
`3knowinglyfalse’ll
`Not even.a month)after receiving final certification on the new aircraft, we received confirmation
`that you had applied for employment elsewhere. Shortly thereafter you resigned. Upon
`knowledge and belief, you were actively seeking and applying for employment elsewhere before
`and while availing yourself of the training — the training paid for by Cheney Brothers. Had
`CheneyBrothers been awareofthis fact, it would not have paid for yourrecenttraining.
`
`Webelieve you deceived Cheney Brothers knowingly and with the intent to obtain a substantial
`benefit to which you were notentitled. Thus, we believe your actions constitute, among other
`things, fraudulent inducement, fraudulent misrepresentation, and unjust enrichment.
`
`CheneyG®.
`Brothers
`
`2801 WaitesSprings Blvd, Ocala, FL 34475 @ 352.291.7800oflice @ 800.939.4018toll-free
`! Cheney Way, Riviera Beach, FL 33404
`@ 561.845.4700office @ 800.432.1341 toll-free
`| Cheney Way, Punta Gorda. FL 33982-4401
`@ 941.505.5885office @ 844.234.1341] toll-free
`195 Business Park Dr., Statesville NC 28677
`®@ 919.778.3000 office @ 800.899.3921 toll-free
`
`

`

`Accordingly, I hereby demand,on behalf of Cheney Brothers,that you immediately contact me
`with arrangements for repaymentof the $50,000, {f agreeable arrangements are not made, we
`will have no choice but to proceed against you with formallegal action. Additionally,
`if it i
`determined that your new employer knew of
`fraudulent conduct and was an a y;
`he
`same, we will not hesitate to pursue it with legaaction as well.
`ccomplice in
`sahththis oanaiaes en It is my understanding that Mr. Russell attempted
`secking what
`is equitable. We arehopefulyoun his attempt. Cheney Brothers is only
`and appropriately.
`will recognize such and respondprofessionally
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`To avoid further legal action please respo
`later t
`,
`diy ?
`P
`
`nd
`
`i
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`to ‘on with a proposal for repayment
`
`by no
`ry
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`NOT A CERTIFIED COPY
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`Sincetely,
`
`Rachelle McBride
`
`Rachelle McBride, Esq.
`General Counsel
`
`ip.
`Cheney
`°
`Brothers
`
`1 Cheney Way. Riviera Beach, FL 33404
`2801 W.Silver Springs Blvd, Ocala, FI. 34475
`| Cheney Way, Punta Gorda, FL 33982-4101
`402 Commerce Ct., Goldsboro, NC 27532
`195 Business Park Dr.. Statesville, NC 28677
`
`@ 361.845.4700 office @ 800.432.1341 toll-free
`@ 352.291.7800 office @ 800.939.4018 toll-free
`i
`® 941.505.5885 office @ 844.234.1341 toll-free
`© 919.7783000 office @ 800.899.3921 toll-free
`@ 919.778.3000office @ 800.899.3921 toll-tree
`
`