Author Topic: WWASP entities in Turley lawsuit (consolidated)  (Read 2558 times)

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Offline Reddit TroubledTeens

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WWASP entities in Turley lawsuit (consolidated)
« on: November 14, 2011, 01:49:42 AM »
source: http://www.reddit.com/r/troubledteens/c ... te/c2ziqrb

List of companies and people named as defendants in the Turley lawsuit. I culled this list from the suit and removed some wording to make it digestible. This is for reference only; legal document with complete info is here: http://www.wturley.com/Recent-Filings/2 ... iginal.pdf. I’ve tried to group them into categories based mostly on the names of companies, please let me know if I’ve made any errors of if this list can be improved (and yeah, I didn't proofread this very much).

Edit: moved 'PEOPLE' to the top of the list.


PEOPLE

Robert B. Lichfield a principal in charge of the entire “WWASPS Enterprise.”

Ken Kay of Utah, President of WWASPS; last administrator of Brightway Adolescent Hospital; Member / Manager of R&B Management Group, L.L.C

Karr Farnsworth of Utah (prior President/Trustee of WWASPS in 1998; ownership interest in Cross Creek in 1999

Brent M. Facer is an individual that resides in the State of Utah, is a principal in the “WWASPS Enterprise.”

Patricia E. Lichfield is a individual residing in La Verkin, Utah.

TRANSPORT

Adolescent Services, Inc. a/k/a Adolescent Services International Transport; its Registered Agent, Tim Waddoups

MARKETING

Teen Help, L.L.C. d/b/a Adolescent Services International Inc., conducts advertising, marketing, solicitation, and admission for the “WWASPS Enterprise” schools, is one of several companies and partnerships used by Lichfield and Facer to promote and facilitate the scheme complained of herein and is 80% owned by Robert and Patricia Lichfield. The listed member of this entity Timothy Brian Foye, its registered agent, Jean Foye

Teens In Crisis, L.L.C. f/k/a Teens In Crisis, Inc. is a Limited Liability Corporation and was part of the “WWASPS Enterprise” marketing arm. Listed member is Willard Jake Peart, President and former Registered Agent: Willard Jake Peart

OUTSOURCE SERVICES

Cross Creek Outsource Services
was a business, owned by Robert Lichfield (76%) and Brent Facer (24%)

Midwest Outsource Services, L.L.C. is a Limited Liability Company, listed member is Robert B. Lichfield, Registered Agent: Business Kit Services, L.L.C.

Red River Outsource Services, L.L.C., was 76% owned by Robert Lichfield and 34% owned by Brent Facer; had a service contract with Red River Academy; listed member is Robert B. Lichfield, manager; one of its general agents:Robert Lichfield

BILLING


Optimum Billing Services, L.L.C. is a Limited Liability Company, members are Derrick Esplin and Andrea Esplin; Agent, Derrick Esplin, Optimum Billing Services, L.L.C.

R & B Billing, L.L.C. was a Limited Liability Company was initially owned by Robert Lichfield (78%) and Brent Facer (22%), members of this entity are Corby Facer, Mandi Facer, and Jennifer Christensen; Registered Agent, Mandi K. Robinson

CONTRACT SERVICES


Dixie Contract Services, L.L.C. was a Limited Liability Company, members of this entity are AMALFI Coast Investments, Ltd., whose general partner is RBL Management, L.L.C., Lands End Holding Co., Ltd., whose general partner is BMF Management, L.L.C., manager of the entity

National Contracting Services, Inc. was a corporation, Registered Agent: Corporate Services Group, L.L.C., its officer: Edmund Campbell

OTHER ENTITIES

World Wide Association of Specialty Programs and Schools, Inc. f/k/a World Wide Association of Specialty Programs and Schools, L.L.C. (“WWASPS”)
, owned by Defendants Robert B. Lichfield, Brent M. Facer, and Ken Kay

Premier Education, Inc.
was a corporation, owned by Robert Lichfield and Brent Facer; Registered Agent: Stephen J. Bulpitt

AMALFI Coast Investments, Ltd.
is a Limited Partnership, listed partner is RBL Management, L.L.C., one of its owners: Robert Lichfield, other owner Brent Facer

BMF Investments, L.L.C. is a Limited Liability Company, members of this entity, are Brent M. Facer, Britta Facer, Corby Facer, Jillyn Facer, Riley Facer, and Mandi Robinson; Registered Agent: Brent M. Facer

BMF #1, Ltd. was a Limited Partnership, partners of this entity are Brent M. Facer, Jillyn P. Facer, and Robert B. Lichfield, and BMF Management, L.L.C., its Registered Agent, Ralph Atkin

BMF #2, Ltd., was a Limited Partnership, listed partner is BMF Management, L.L.C., its Registered Agent, Brent M. Facer

BMF, Inc. was a trustee and/or owner of Teen Help, Inc., Owner Brent M. Facer

BMF Management, L.L.C. is a Limited Liability Corporation, members of this entity are Brent M. Facer and Jillyn Facer, Registered Agent: Wendy Oldroydk

Company Support Services, L.L.C. is a Limited Liability Company, listed member of this entity is Robert W. Lichfield, manager

Lifelines Family Services, Inc.
is a corporation, doing business as Teen Life Lines, last known registered agent: Donnie Ray Musgrove, Jr.

Narvana Resources, L.L.C.
is a Limited Liability Company, owned by Robert Lichfield (76%), listed member is Robert B. Lichfield, its other Owner Brent Facer

Peacox Enterprises, L.L.C. is a Limited Liability Company, members of this entity are Patricia P. Lichfield, Brent M. Facer, Donna J. Peart, and Dan C. Peart, registered agent, Dan C Peart

R & B Management Group, L.L.C.
was a Limited Liability Company, members of this entity are Jill-Co., Inc., a Nevada corporation, Recaf, Inc., a Nevada corporation, and Ken Kay, manager, Registered Agent: Ken Kay

RBL #1, Ltd. was a Limited Partnership, partners are RBL Management, L.L.C., whose principal is Robert and Patricia Lichfield, as trustees of their successors in trust under the Lichfield Living Trust; and Robert and Patricia Lichfield, as trustees of their own trust; one of its agents: Robert Lichfield

RBL #2, Ltd. was a Limited Partnership, was owned by Robert Lichfield and RBL Management, L.L.C., partner is RBL Management, L.L.C.; one of its agents: Robert Lichfield

RBL Management, L.L.C.
is a Limited Liability Company, listed member of this entity is Robert B. Lichfield, one of its agents: Robert Lichfield

RBL, L.L.C. f/k/a RBL, Inc. (Trustee / owner of Teen Help, Inc.) is a Limited Liability Company, members are Eula Roceil Low and William W. Low, Registered Agent: Dennis Astill

Robert Browning Lichfield Family Limited Partnership
is a Limited Partnership and is a “WWASPS Enterprise” company. listed member is Robert B. Lichfield, registered agent, Patricia P. Lichfield

Jill-Co., Inc. was a corporation, original director of this entity was Jillyn Facer and it had partial ownership interests in companies such as R & B Management, L.L.C.; Registered Agent: Richard S. Bentley, president, Jeannette Seely, P.O. secretary and treasurer, Mandi Robinson

Recaf, Inc. was a corporation, original director was Patricia Lichfield and it had partial ownership interests in companies such as R & B Management, L.L.C.. Registered Agent: INC4You.com, President, Lucille Olsen, Secretary and Treasurer, Cheri Atkin

FACILITIES

Academy at Ivy Ridge, LLC f/k/a The Academy at Ivy Ridge
, a New York Partnership is a business organized under the laws of the State of New York and was a “WWASPS Enterprise” residential school. Members are believed to be Jason Finlinson, prior director, Ann Morley, director, Joseph Mitchell, and Alyn Mitchell. This may be served process by serving NYS Department of State, 41 State Street, Albany, NY 12231, who will mail process to 5428 State Hwy 37, Ogdensburg, NY 12669.

Brightway Adolescent Hospital was located in LaVerkin, Utah and was an admissions hospital for the “WWASPS Enterprise,” which closed in March 1998. Ken Kay was a Director of, and the last administrator of Brightway Adolescent Hospital

The Browning Schools, Inc. d/b/a Browning Distance Learning Academy is a corporation, directors are Karr Farnsworth and Ken Kay and the owners are Robert Lichfield, Brent Facer, and Ken Kay.

Browning Academy, Inc. is a corporation, owners are Robert Lichfield, Brent Facer, and Ken Kay.

Casa By The Sea was a professional association, the following persons managed or were in charge of the entity’s regular place of business: Dace Robert Goulding, a Manager and Karr Farnsworth, the Director.

Carolina Springs Academy was a business organized under the laws of the State of South Carolina and was a “WWASPS Enterprise” residential school. Registered Agent: Elaine Davis

Cross Creek Academy, L.L.C. is a business organized under the laws of the State of Utah and is a “WWASPS Enterprise” residential school. Listed member, is Karr Farnsworth, Registered Agent: Business Kit Services, L.L.C.

Cross Creek Center for Boys, L.L.C.
is a “WWASPS Enterprise” associated-in-fact residential school and is owned by Robert B. Lichfield, Brent Facer, and Recaf, Inc. Listed member is Karr Farnsworth.

Cross Creek Manor, L.L.C. d/b/a Cross Creek Program d/b/a Cross Creek Admissions is a “WWASPS Enterprise” associated-in-fact residential school and is owned by Robert B. Lichfield, Brent Facer, and Recaf, Inc. The members of this entity are Karr Farnsworth and Kerry Gubler; its registered agent, J. Ralph Atkin

Darrington Academy, Inc. was a corporation, Registered Agent: Juanita M. Twiggs

Dundee Ranch was a business located in Costa Rica, owned by Robert Lichfield and Brent Facer, whom were persons who managed or were in charge of the entity’s regular place of business.

High Impact was a business located in Baja, Mexico, Dace Goulding and/or Robert Lichfield were actual and/or apparent agents of High Impact because, at all times relevant to this action, they held themselves out as individuals authorized to act on behalf of High Impact and they were authorized to act, and did in fact act, on behalf of High Impact. There is also some evidence that Dace Goulding did in fact control or manage High Impact.

Majestic Ranch Academy, Inc.
is a corporation and is a “WWASPS Enterprise” associated-in-fact residential school, registered agent, Donna Peart

Midwest Academy, L.L.C. is a Limited Liability Company is a “WWASPS Enterprise” associated-in-fact residential school, owner is Brian Viafanua, Registered Agent: Mark R. Adams

Morava Academy was a business in Brno, Czech Republic, and a “WWASPS Enterprise” associated-infact residential school located in Brno, Czech Republic, J. Ralph Atkins, Steven Roach, and Glenda Roach were persons who managed or were in charge of the entity’s regular place of business.

Pacific View Retreat was a business and a "WWASPS Enterprise" associated-in-fact residential school located in Mexico. Upon information and belief, Robert Lichfield was an actual and/or apparent agent of Pacific View Retreat. By virtue of the agency relationship between Pacific View Retreat and Robert Lichfield and pursuant to Utah Code Ann. §16-17 301(3), this Defendant may be served by serving its Agent: Robert Lichfield

Paradise Cove
was a business and a "WWASPS Enterprise" associated-in fact residential school located in Western Samoa, Ruland Brian Vaifanua and Angela Joy Vaifanua

Red River Academy, L.L.C. is a Limited Liability Company located in LeCompte, Louisiana. It is a “WWASPS Enterprise” residential school. The members are Brent Hall, and Octwell, L.L.C., whose principals, Robert and Linda Huddleston, Registered Agent: Brent Hall

Red Rock Academy was a d/b/a of Narvin Lichfield, was a “WWASPS Enterprise” residential school, Registered Agent: Morris Peacock

Red Rock Springs, L.C. was a Limited Liability Company, was a “WWASPS Enterprise” residential school, are Tim Waddoups and Narvin Lichfield, Registered Agent: Tim Waddoups

Spring Creek Lodge, L.L.C.
d/b/a Spring Creek Admissions was a business operating in the State of Montana and was conducting business in the State of Utah. The members are Dan Peart and Donna Peart; Recaf, Inc., a Nevada corporation; and Jill-Co., Inc., a Nevada corporation. Registered Agent: J. Ralph Atkins

Sunrise Beach was a business located in Punta Sam, Cancun, Mexico, was a “WWASPS Enterprise” residential school, Steven Roach and Glenda Roach were persons who managed or were in charge of the entity’s regular place of business.

Tranquility Bay a d/b/a of The Caribbean Centre for Change, Ltd.
, was a “WWASPS Enterprise” residential school, located in Calabash Bay, Jamaica, owned by Robert Lichfield and Brent Facer, and managed by Jay Kay

Sky View Academy, L.L.C. was a business organized under the laws of the State of Nevada and was a “WWASPS Enterprise” residential school. Listed member is Orval Hagerman, Registered Agent: INC4You.com, L.L.C.
« Last Edit: November 14, 2011, 03:19:05 AM by Reddit TroubledTeens »

Offline Ursus

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Re: WWASP entities in Turley lawsuit (consolidated)
« Reply #1 on: November 14, 2011, 02:06:46 AM »
It's so nice to see it summarized in a (really quite mind boggling) LIST. Thanks, Reddit TroubledTeens!! . . . :notworthy:

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« Last Edit: December 31, 1969, 07:00:00 PM by Guest »
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Re: WWASP entities in Turley lawsuit (consolidated)
« Reply #2 on: November 14, 2011, 02:38:38 AM »
Thanks, Ursus! You are too kind!

Aaaaand now, here's the listing of Turley's defendants before my edits, for reference...

B. DEFENDANTS:
1. Defendant World Wide Association of Specialty Programs and Schools, Inc. f/k/a
World Wide Association of Specialty Programs and Schools, L.L.C. (“WWASPS”),
owned by Defendants Robert B. Lichfield, Brent M. Facer, and Ken Kay, all of whom
are citizens of the State of Utah, and one of several companies and partnerships used by
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 24 OF 116
Lichfield and Facer to promote and facilitate the scheme complained of herein.
Defendant may be served process by serving its registered agent, Ken Kay, 1240 E. 100
S #9, St. George, Utah 84790.
2. Defendant Robert B. Lichfield a resident of Toquerville, Utah, and a principal in
charge of the entire “WWASPS Enterprise.” This Defendant may be served at: 317
Lichfield Lane, Toquerville, Utah 84774.
3. Defendant Ken Kay of Utah, President of WWASPS; last administrator of Brightway
Adolescent Hospital; Member / Manager of R&B Management Group, L.L.C. This
Defendant may be served at: 611 West 110 South, St. George, Utah 84770.
4. Defendant Cross Creek Center for Boys, L.L.C. is a “WWASPS Enterprise”
associated-in-fact residential school and is owned by Robert B. Lichfield, Brent Facer,
and Recaf, Inc. The listed member of this entity, as filed with the Utah Secretary of
State, is Karr Farnsworth, a citizen of the State of Utah. Defendant may be served
process by serving its registered agent, J. Ralph Atkin, 240 E. 100 S #10, St. George,
Utah 84790.
5. Defendant Cross Creek Manor, L.L.C. d/b/a Cross Creek Program d/b/a Cross
Creek Admissions is a “WWASPS Enterprise” associated-in-fact residential school
and is owned by Robert B. Lichfield, Brent Facer, and Recaf, Inc. The members of this
entity, as filed with the Utah Secretary of State, are Karr Farnsworth and Kerry Gubler,
both of whom are citizens of the State of Utah. Defendant may be served process by
serving its registered agent, J. Ralph Atkin, 1240 E. 100 S #10, St. George, Utah
84790.
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 25 OF 116
6. Defendant Karr Farnsworth of Utah (prior President/Trustee of WWASPS in 1998;
ownership interest in Cross Creek in 1999). Defendant may be served process at 154 N
3920, Hurricane, Utah 84737.
7. Defendant Teen Help, L.L.C. d/b/a Adolescent Services International Inc., which
conducts advertising, marketing, solicitation, and admission for the “WWASPS
Enterprise” schools, is one of several companies and partnerships used by Lichfield and
Facer to promote and facilitate the scheme complained of herein and is 80% owned by
Robert and Patricia Lichfield. The listed member of this entity, as filed with the Utah
Secretary of State, is Timothy Brian Foye, a citizen of the State of Utah. Defendant
may be served process by serving its registered agent, Jean Foye, 32 N. Mall Dr. Bldg
RS, St. George, Utah 84790.
8. Defendant Adolescent Services, Inc. a/k/a Adolescent Services International
Transport was a corporation organized under the laws of the State of Utah with its
principal place of business located at 270 E. 855 S, Ivins, UT 84738. This Defendant
may be served by serving its Registered Agent, Tim Waddoups at the business address,
270 E 855 S, Ivins, UT 84738.
9. Defendant AMALFI Coast Investments, Ltd. is a Limited Partnership organized
under the laws of the State of Utah. The listed partner, as filed with the Utah Secretary
of State, is RBL Management, L.L.C., an entity organized under the laws of the State
of Utah and whose principal is a citizen of the State of Utah. Pursuant to Utah Code
Ann. §16-17-301(3), this Defendant may be served by handing process to one of its
owners: Robert Lichfield at 317 Lichfield Lane, Toquerville, UT 84774 or his other
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 26 OF 116
address: 1240 E. 100 S. #9, St. George UT 84790, or by serving its other Owner Brent
Facer at his home address: 704 S. Anasazi Circle, Washington UT 84780-2013.
10. Defendant BMF #1, Ltd. was a Limited Partnership that was organized under the laws
of the State of Utah. The partners of this entity are Brent M. Facer, Jillyn P. Facer, and
Robert B. Lichfield, all of whom are citizens of the State of Utah, and BMF
Management, L.L.C., an entity organized under the laws of the State of Utah and
whose principals are citizens of the State of Utah. This Defendant may be served by
serving its Registered Agent, Ralph Atkin at 390 Del Mar Drive, St. George, UT
84790.
11. Defendant BMF #2, Ltd., was a Limited Partnership that was organized under the laws
of the State of Utah. The listed partner, as filed with the Utah Secretary of State, is
BMF Management, L.L.C., an entity organized under the laws of the State of Utah and
whose principals are citizens of the State of Utah. This Defendant may be served by
serving its Registered Agent, Brent M. Facer at 321 N. Mall Dr. Ste Q101, St. George,
UT 84790.
12. Defendant BMF, Inc. was a trustee and/or owner of Teen Help, Inc. This Defendant
may be served by serving its Owner Brent M. Facer at 321 N. Mall Dr. Ste. Q101, St.
George, UT 84790.
13. Defendant BMF Investments, L.L.C. is a Limited Liability Company organized under
the laws of the State of Utah. The members of this entity, as filed with the Utah
Secretary of State, are Brent M. Facer, Britta Facer, Corby Facer, Jillyn Facer, Riley
Facer, and Mandi Robinson, all of whom are citizens of the State of Utah. This
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 27 OF 116
Defendant may be served by serving its Registered Agent: Brent M. Facer, 321 N. Mall
Dr. Ste Q101, St . George, UT 84790.
14. Defendant BMF Management, L.L.C. is a Limited Liability Corporation organized
under the laws of the State of Utah. The members of this entity, as filed with the Utah
Secretary of State, are Brent M. Facer and Jillyn Facer, both of whom are citizens of
the State of Utah. This Defendant may be served by serving its Registered Agent:
Wendy Oldroydk, at 321 N. Mall Dr., Ste Q101, St. George, UT 84790.
15. Defendant Brent M. Facer is an individual that resides in the State of Utah, is a
principal in the “WWASPS Enterprise.” This Defendant may be served at:321 North
Mall Drive, Suite Q101, St. George, Utah 84790.
16. Defendant Brightway Adolescent Hospital was located in LaVerkin, Utah and was an
admissions hospital for the “WWASPS Enterprise,” which closed in March 1998. Ken
Kay was a Director of, and the last administrator of Brightway Adolescent Hospital,
and is a citizen of the State of Utah. This Defendant may be served by serving the
Director: Ken Kay at 611 W 110 South Cir., St. George UT 84770.
17. Defendant The Browning Schools, Inc. d/b/a Browning Distance Learning
Academy is a corporation organized under the laws of the State of Utah and is
conducting its business from the State of Utah. This Defendant’s directors are Karr
Farnsworth and Ken Kay and the owners are Robert Lichfield, Brent Facer, and Ken
Kay. Pursuant to Utah Code Ann. §16-17-301(3), this Defendant may be served by
handing process to one of its owners: Robert Lichfield at 317 Lichfield Lane,
Toquerville, UT 84774 or his other address: 1240 E. 100 S. #9, St. George UT 84790,
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 28 OF 116
or by serving its other Owner Brent Facer at his home address: 704 S. Anasazi Circle,
Washington UT 84780-2013.
18. Defendant Browning Academy, Inc. is a corporation organized under the laws of the
State of Utah and is conducting its business from the State of Utah. The owners of this
corporation are Robert Lichfield, Brent Facer, and Ken Kay. Pursuant to Utah Code
Ann. §16-17-301(3), this Defendant may be served by handing process to one of its
owners: Robert Lichfield at 317 Lichfield Lane, Toquerville, UT 84774 or his other
address: 1240 E. 100 S. #9, St. George UT 84790, or by serving its other Owner Brent
Facer at his home address: 704 S. Anasazi Circle, Washington UT 84780-2013.
19. Defendant Casa By The Sea was a professional association organized under the laws
of Mexico, but was conducting its business from the State of Utah. This Defendant had
the following persons who managed or were in charge of the entity’s regular place of
business: Dace Robert Goulding, a Manager and Karr Farnsworth, the Director.
Pursuant to Utah Code Ann. §16-17-301(3), this Defendant may be served by handing
a copy to its Director, Karr Farnsworth at 154 N. 3920 W., Hurricane, UT 84737 or
Manager, Dace Goulding at 1640 Appalachian Hwy, Blue Ridge, GA 30513-4960.
20. Defendant Company Support Services, L.L.C. is a Limited Liability Company
organized under the laws of the State of Utah. The listed member of this entity, as filed
with the Utah Secretary of State, is Robert W. Lichfield, manager of the entity and a
citizen of the State of Utah. This Defendant may be served with process on its
Registered Agent: Robert W. Lichfield, 50 S. State St., Ste A, LaVerkin UT 84745.
21. Defendant Cross Creek Outsource Services was a business located in the State of
Utah, conducted business in the State of Utah, and was owned by Robert Lichfield
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 29 OF 116
(76%) and Brent Facer (24%). Pursuant to Utah Code Ann. §16-17-301(3), this
Defendant may be served by handing process to one of its owners: Robert Lichfield at
317 Lichfield Lane, Toquerville, UT 84774 or his other address: 1240 E. 100 S. #9, St.
George UT 84790, or by serving its other Owner Brent Facer at his home address: 704
S. Anasazi Circle, Washington UT 84780-2013.
22. Defendant Darrington Academy, Inc. was a corporation organized under the laws of
the State of Georgia and may be served with process on its Registered Agent: Juanita
M. Twiggs, 7101 Waldan Crossing Dr., Canton, GA 30115.
23. Defendant Dixie Contract Services, L.L.C. was a Limited Liability Company
organized under the laws of the State of Utah and which conducted its business within
the State of Utah. The members of this entity, as filed with the Utah Secretary of State,
are AMALFI Coast Investments, Ltd., whose general partner is RBL Management,
L.L.C., an entity organized under the laws of the State of Utah and whose principal is a
citizen of the State of Utah; Lands End Holding Co., Ltd., whose general partner is
BMF Management, L.L.C., an entity organized under the laws of the State of Utah and
whose partners are citizens of the State of Utah; and Jean Schulter Foye, the manager
of the entity and a citizen of the State of Utah. This Defendant may be served by
serving its Registered Agent, Jean Foye at 1240 E. 100 S. #9, St. George, UT 84790.
24. Defendant Dundee Ranch was a business located in Costa Rica, but was conducting its
business from the State of Utah, and owned by Robert Lichfield and Brent Facer,
citizens of the State of Utah, and whom were persons who managed or were in charge
of the entity’s regular place of business. Pursuant to Utah Code Ann. §16-17-301(3),
this Defendant may be served by handing process to one of its owners: Robert
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 30 OF 116
Lichfield at 317 Lichfield Lane, Toquerville, UT 84774 or his other address: 1240 E.
100 S. #9, St. George UT 84790, or by serving its other Owner Brent Facer at his home
address: 704 S. Anasazi Circle, Washington UT 84780-2013.
25. Defendant High Impact was a business located in Baja, Mexico, but was conducting
its business from the State of Utah. Dace Goulding and/or Defendant Robert Lichfield,
citizens of Utah were actual and/or apparent agents of High Impact because, at all times
relevant to this action, they held themselves out as individuals authorized to act on
behalf of High Impact and they were authorized to act, and did in fact act, on behalf of
High Impact. There is also some evidence that Dace Goulding did in fact control or
manage High Impact. By virtue of the agency relationship between High Impact, Dace
Goulding, and/or Robert Lichfield. Pursuant to Utah Code Ann. §16-17-301(3), this
Defendant may be served by serving its Agent: Robert Lichfield at 317 Lichfield Lane,
Toquerville, UT 84774 or his other address: 1240 E. 100 S. #9, St. George UT 84790,
or Agent: Dace Goulding at 1640 Appalachian Hwy, Blue Ridge, GA 30513-4960.
26. Defendant Lifelines Family Services, Inc. is a corporation organized under the laws of
the State of Utah, doing business as Teen Life Lines. This Defendant may be served
upon its last known registered agent: Donnie Ray Musgrove, Jr., 61 N Main, St.
George, Utah 84770.
27. Defendant Majestic Ranch Academy, Inc. is a corporation organized under the laws
of the State of Utah and is a “WWASPS Enterprise” associated-in-fact residential
school. Defendant may be served process by serving its registered agent, Donna Peart,
6450 N Manhead Road, Randolph, Utah 84060.
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 31 OF 116
28. Defendant Midwest Academy, L.L.C. is a Limited Liability Company, organized
under the laws of the State of Iowa, and is a “WWASPS Enterprise” associated-in-fact
residential school. The owner of this entity, as filed with the Iowa Secretary of State, is
Brian Viafanua, a citizen of the State of Utah. This Defendant may be served with
process on its Registered Agent: Mark R. Adams, 4201 Westown Pkwy., Ste. 250,
West Des Moines, IA 50266.
29. Defendant Midwest Outsource Services, L.L.C. is a Limited Liability Company
organized under the laws of the State of Utah. The listed member of this entity, as filed
with the Utah Secretary of State, is Robert B. Lichfield, a citizen of the State of Utah.
This Defendant may be served by serving its Registered Agent: Business Kit Services,
L.L.C., 390 Del Mar Dr., St. George, UT 84790.
30. Defendant Morava Academy was a business in Brno, Czech Republic, and a
“WWASPS Enterprise” associated-in-fact residential school located in Brno, Czech
Republic, which conducted its business in the State of Utah. J. Ralph Atkins, Steven
Roach, and Glenda Roach were persons who managed or were in charge of the entity’s
regular place of business. Pursuant to Utah Code Ann. §16-17-301(3), this Defendant
may be served by handing a copy to Manager J. Ralph Atkins, at 390 Del Mar Drive,
St. George, UT 84790, or Manager Steven Roach or Manager Glenda Roach, at 5
Country Hills Rd., Montevallo, AL 35115-5457, or Karr Farnsworth, at 154 N 3920 W,
Hurricane, UT 84737.
31. Defendant National Contracting Services, Inc. was a corporation organized under the
laws of the State of Nevada and conducted its business in the State of Utah. This
Defendant may be served with process on its Registered Agent: Corporate Services
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 32 OF 116
Group, L.L.C., 723 Casino Center Blvd., 2nd Fl., Las Vegas, NV 89101, and upon its
officer, as filed with the Nevada Secretary of State: Edmund Campbell, 723 Casino
Center Blvd., 2nd Fl., Las Vegas, NV 89101.
32. Defendant Narvana Resources, L.L.C. is a Limited Liability Company organized
under the laws of the State of Utah, is owned by Robert Lichfield (76%), and conducts
its business from the State of Utah. The listed member of this entity, as filed with the
Utah Secretary of State, is Robert B. Lichfield, a citizen of the State of Utah. Pursuant
to Utah Code Ann. §16-17-301(3), this Defendant may be served by handing process to
one of its owners: Robert Lichfield at 317 Lichfield Lane, Toquerville, UT 84774 or
his other address: 1240 E. 100 S. #9, St. George UT 84790, or by serving its other
Owner Brent Facer at his home address: 704 S. Anasazi Circle, Washington UT 84780-
2013.
33. Defendant Optimum Billing Services, L.L.C. is a Limited Liability Company
organized under the laws of the State of Utah. The members of this entity, as filed with
the Utah Secretary of State, are Derrick Esplin and Andrea Esplin, both of whom are
citizens of the State of Utah. This Defendant may be served by serving its Registered
Agent, Derrick Esplin, Optimum Billing Services, L.L.C., 50 S. State St., La Verkin
UT 84745 on 02/24/2010.
34. Defendant Pacific View Retreat was a business and a "WWASPS Enterprise"
associated-in-fact residential school located in Mexico, but conducted its business from
the State of Utah. Upon information and belief, Robert Lichfield was an actual and/or
apparent agent of Pacific View Retreat. By virtue of the agency relationship between
Pacific View Retreat and Robert Lichfield and pursuant to Utah Code Ann. §16-17-
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 33 OF 116
301(3), this Defendant may be served by serving its Agent: Robert Lichfield at 317
Lichfield Ln., Toquerville, UT 84774 or at 1240 E. 100 S. #9, St. George, UT 84790.
35. Defendant Paradise Cove was a business and a "WWASPS Enterprise" associated-infact
residential school located in Western Samoa, but conducted its business from the
State of Utah. Ruland Brian Vaifanua and Angela Joy Vaifanua managed and/or were
in charge the entity's regular place of business. Pursuant to Utah Code Ann. §16-17-
301(3), this Defendant may be served by serving its Manager Ruland Brian Vaifanua or
Manager Angela Vaifanua at 255 S. 1150 W., Hurricane, UT 84737-2441.
36. Defendant Patricia E. Lichfield is a individual residing in La Verkin, Utah. This
Defendant may be served at: 2332 Ridge View Drive, Hurricane, Utah 84737.
37. Defendant Peacox Enterprises, L.L.C. is a Limited Liability Company organized
under the laws of the State of Utah. The members of this entity, as filed with the Utah
Secretary of State, are Patricia P. Lichfield, Brent M. Facer, Donna J. Peart, and Dan C.
Peart, all of whom are citizens of the State of Utah. Defendant may be served process
by serving its registered agent, Dan C Peart, 6450 Manhead Rd., Randolph, Utah
84064.
38. Defendant Premier Education, Inc. was a corporation organized under the laws of the
State of Utah, and was owned by Robert Lichfield and Brent Facer. This Defendant
may be served with process on its Registered Agent: Stephen J. Bulpitt, 1223 W. 1320
N., Pleasant Grove, UT 84062.
39. Defendant R & B Billing, L.L.C. was a Limited Liability Company organized under
the laws of the State of Utah, was initially owned by Robert Lichfield (78%) and Brent
Facer (22%), and conducted its business in the State of Utah. The members of this
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 34 OF 116
entity, as filed with the Utah Secretary of State, are Corby Facer, Mandi Facer, and
Jennifer Christensen, all of whom are citizens of the State of Utah. This Defendant
may be served by serving its Registered Agent, Mandi K. Robinson at 1240 E. 100 S
#10, St. George, UT 84790.
40. Defendant R & B Management Group, L.L.C. was a Limited Liability Company
organized under the laws of the State of Utah. The members of this entity, as filed with
the Utah Secretary of State, are Jill-Co., Inc., a Nevada corporation, Recaf, Inc., a
Nevada corporation, and Ken Kay, manager of the entity and a citizen of the State of
Utah. This Defendant may be served by serving its Registered Agent: Ken Kay at 1240
East 100 South # 9, St. George, UT 84790.
41. Defendant RBL #1, Ltd. was a Limited Partnership organized under the laws of the
State of Utah and which conducted its business in the State of Utah. The partners of
this entity are RBL Management, L.L.C., an entity organized under the laws of the
State of Utah and whose principal is a citizen of the State of Utah; Robert and Patricia
Lichfield, both of whom are citizens of the State of Utah, as trustees of their successors
in trust under the Lichfield Living Trust; and Robert and Patricia Lichfield, both of
whom are citizens of the State of Utah, as trustees of their own trust. Pursuant to Utah
Code Ann. §16-17-301(3), this Defendant may be served by handing process to one of
its agents: Robert Lichfield at 317 Lichfield Lane, Toquerville, UT 84774 or his other
address: 1240 E. 100 S. #9, St. George UT 84790.
42. Defendant RBL #2, Ltd. was a Limited Partnership organized under the laws of the
State of Utah, was owned by Robert Lichfield and RBL Management, L.L.C., and
conducted its business in the State of Utah. The listed partner for this entity, as filed
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 35 OF 116
with the Utah Secretary of State, is RBL Management, L.L.C., a Utah entity whose
principal is a citizen of the State of Utah. Pursuant to Utah Code Ann. §16-17-301(3),
this Defendant may be served by handing process to one of its agents: Robert Lichfield
at 317 Lichfield Lane, Toquerville, UT 84774 or his other address: 1240 E. 100 S. #9,
St. George UT 84790.
43. Defendant RBL Management, L.L.C. is a Limited Liability Company organized
under the laws of the State of Utah. This listed member of this entity, as filed with the
Utah Secretary of State, is Robert B. Lichfield, a citizen of the State of Utah. Pursuant
to Utah Code Ann. §16-17-301(3), this Defendant may be served by handing process to
one of its agents: Robert Lichfield at 317 Lichfield Lane, Toquerville, UT 84774 or his
other address: 1240 E. 100 S. #9, St. George UT 84790.
44. Defendant RBL, L.L.C. f/k/a RBL, Inc. (Trustee / owner of Teen Help, Inc.) is a
Limited Liability Company organized under the laws of the State of Utah. The
members of this entity, as filed with the Utah Secretary of State, are Eula Roceil Low
and William W. Low, both of whom are citizens of the State of Utah. This Defendant
may be served with process on its Registered Agent: Dennis Astill, 0533 S. 700 E., Ste.
103, Sandy, UT 84070.
45. Defendant Red River Academy, L.L.C. is a Limited Liability Company located at
2810 Hwy 71 South, LeCompte, Louisiana 71346. It is a “WWASPS Enterprise”
residential school and was organized under the laws of the State of Louisiana. The
members of this entity, as filed with the Louisiana Secretary of State, are Brent Hall, a
citizen of the State of Louisiana, and Octwell, L.L.C., an entity organized under the
laws of the State of Utah and whose principals, Robert and Linda Huddleston, are
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 36 OF 116
citizens of the State of Utah. This Defendant may be served with process on its
Registered Agent: Brent Hall, 2810 Hwy. 71 South, LeCompte, Louisiana 71346.
46. Defendant Red River Outsource Services, L.L.C., located in LaVerkin Utah, was
76% owned by Robert Lichfield and 34% owned by Brent Facer; had a service contract
with Red River Academy; and is conducting its business from the State of Utah. The
listed member of this entity, as filed with the Utah Secretary of State, is Robert B.
Lichfield, manager of the entity and a citizen of the State of Utah. Pursuant to Utah
Code Ann. §16-17-301(3), this Defendant may be served by handing process to one of
its general agent: Robert Lichfield at 317 Lichfield Lane, Toquerville, UT 84774 or his
other address: 1240 E. 100 S. #9, St. George UT 84790.
47. Defendant Red Rock Academy was a d/b/a of Narvin Lichfield, was organized under
the laws of the State of Utah, was a “WWASPS Enterprise” residential school, and
conducted its business in the State of Utah. This Defendant may be served with
process on its Registered Agent: Morris Peacock, 63 S 300 E #100, St. George, UT
84770.
48. Defendant Red Rock Springs, L.C. was a Limited Liability Company organized under
the laws of the State of Utah, was a “WWASPS Enterprise” residential school, and
conducted its business in the State of Utah. The members of this entity, as filed with
the Utah Secretary of State, are Tim Waddoups and Narvin Lichfield, both of whom are
citizens of the State of Utah. This Defendant may be served with process on its
Registered Agent: Tim Waddoups, 151 W. Brigham Rd., #3, St. George, UT 84790.
49. Defendant Robert Browning Lichfield Family Limited Partnership is a Limited
Partnership organized under the laws of the State of Utah, and conducting its business
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 37 OF 116
in the State of Utah, and is a “WWASPS Enterprise” company. The listed member of
this entity, as filed with the Utah Secretary of State, is Robert B. Lichfield, a citizen of
the State of Utah. Defendant may be served process by serving its registered agent,
Patricia P. Lichfield, 1240 East 100 S #9, St. George, Utah 84790.
50. Defendant Spring Creek Lodge, L.L.C. d/b/a Spring Creek Admissions was a
business operating in the State of Montana and was conducting business in the State of
Utah. The members of this entity, as filed with the Utah Secretary of State, are Dan
Peart and Donna Peart, both of whom are citizens of the State of Utah; Recaf, Inc., a
Nevada corporation; and Jill-Co., Inc., a Nevada corporation. This Defendant may be
served with process on its Registered Agent: J. Ralph Atkins, 1240 E. 100 S., #10, St.
George, UT 84790.
51. Defendant Sunrise Beach was a business located in Punta Sam, Cancun, Mexico, was
a “WWASPS Enterprise” residential school, and conducted its business in the State of
Utah. Steven Roach and Glenda Roach were persons who managed or were in charge
of the entity’s regular place of business. Pursuant to Utah Code Ann. §16-17-301(3),
this Defendant may be served by handing a copy to Manager Glenda Roach or
Manager Steven Roach, at 5 Country Hills Rd., Montevallo, AL 35115-5457.
52. Defendant Tranquility Bay a d/b/a of The Caribbean Centre for Change, Ltd., was a
“WWASPS Enterprise” residential school, located in Calabash Bay, Jamaica, but
conducted its business in the State of Utah. It was owned by Robert Lichfield and Brent
Facer, and managed by Jay Kay, all of whom are citizens of the State of Utah, and who
managed or were in charge of the entity’s regular place of business. Pursuant to Utah
Code Ann. §16-17-301(3), this Defendant may be served by serving one of its Owners,
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 38 OF 116
Robert Lichfield at 317 Lichfield Lane, Toquerville, UT 84774.
53. Defendant Academy at Ivy Ridge, LLC f/k/a The Academy at Ivy Ridge, a New
York Partnership is a business organized under the laws of the State of New York and
was a “WWASPS Enterprise” residential school. The members of this entity are
believed to be Jason Finlinson, prior director of the entity and a citizen of the State of
New York, Ann Morley, director of the entity and a citizen of the State of New York,
Joseph Mitchell, a citizen of the State of New York, and Alyn Mitchell, a citizen of the
State of New York. This Defendant may be served process by serving NYS
Department of State, 41 State Street, Albany, NY 12231, who will mail process to 5428
State Hwy 37, Ogdensburg, NY 12669.
54. Defendant Carolina Springs Academy was a business organized under the laws of the
State of South Carolina and was a “WWASPS Enterprise” residential school. This
Defendant may be served with process by serving its Registered Agent: Elaine Davis,
42 Green Acres Lane, Donalds, SC 29638.
55. Defendant Jill-Co., Inc. was a corporation organized under the laws of the State of
Nevada but which did business in the State of Utah. The original director of this entity
was Jillyn Facer and it had partial ownership interests in companies such as Defendant
R & B Management, L.L.C. This Defendant may be served with process on its
Registered Agent: Richard S. Bentley, 7809 Brook Valley Dr., Las Vegas, NV 89123
and service upon its president, Jeannette Seely, P.O. Box 285, 291 W. 500 N.,
LaVerkin, UT 84745 and its secretary and treasurer, Mandi Robinson, 1011 S. Red
River Dr., Washington, UT 84780.
56. Defendant Recaf, Inc. was a corporation organized under the laws of the State of
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 39 OF 116
Nevada but which did business in the State of Utah. The original director of this entity
was Patricia Lichfield and it had partial ownership interests in companies such as
Defendant R & B Management, L.L.C. This Defendant may be served with process on
its Registered Agent: INC4You.com, 701 N. Green Valley Pkwy., #200, Henderson,
NV 89074, and service upon its President, Lucille Olsen, 2306 S. Pelican Pond Rd.,
Wellsville, UT 84339, and its Secretary and Treasurer, Cheri Atkin, 1240 E. 100 S
#10, St. George, UT 84790.
57. Defendant Cross Creek Academy, L.L.C. is a business organized under the laws of
the State of Utah and is a “WWASPS Enterprise” residential school. The listed
member, as filed with the Utah Secretary of State, is Karr Farnsworth, a citizen of the
State of Utah. This Defendant may be served with process on its Registered Agent:
Business Kit Services, L.L.C., 390 Del Mar Dr., St. George, UT 84790.
58. Defendant Sky View Academy, L.L.C. was a business organized under the laws of the
State of Nevada and was a “WWASPS Enterprise” residential school. The listed
member of this entity, as filed with the Nevada Secretary of State, is Orval Hagerman,
a citizen of the State of Montana. This Defendant may be served with process on its
Registered Agent: INC4You.com, L.L.C., 701 N. Green Valley Pkwy., #200,
Henderson, NV 89074.
59. Defendant Teens In Crisis, L.L.C. f/k/a Teens In Crisis, Inc. is a Limited Liability
Corporation organized under the laws of the State of Utah and which was part of the
“WWASPS Enterprise” marketing arm. The listed member of this entity, as filed with
the Utah Secretary of State, is Willard Jake Peart, a citizen of the State of Utah. This
Defendant may be served with process on its President and former Registered Agent:
PLAINTIFFS’ ORIGINAL COMPLAINT - PAGE 40 OF 116
Willard Jake Peart, 95 West 100 S., Ste. 119, Logan, UT 84321, or at 291 W. 500 N.,
LaVerkin, UT 95856 or 171 S. Main St., Hurricane, UT 84737.
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