ST. LOUIS – Two members of two limited liability companies that operate a preschool are seeking to remove two other members.
Chad Beffa and Jennifer Beffa filed a complaint on Nov. 21 in the St. Louis 22nd Judicial Circuit Court against Nicholas Clement, Linda Clement, CB Investment Co. and Kingshighway Hills Preschool Plus citing quantum meruit and other counts.
According to the complaint, the plaintiffs and the Clements are members of CB LLC and KHPP LLC, and that the limited liability companies own property and operate a preschool in St. Louis. The plaintiffs allege the Clements sought a buyout of the plaintiff’s interest and that Nicholas Clement has “engaged in belligerent and harassing conduct.” The plaintiffs also allege the Clements have failed to provide agreed maintenance services or human resources duties.
The plaintiffs seek to remove the Clements from CB LLC and KHPP LLC over allegations of dereliction of duty.
The plaintiffs seek actual damages and restitution and all other relief deemed appropriate. They are represented by Jonathan P. Beck of Beck Ostrom Sweet LLC in St. Louis.
St. Louis 22nd Judicial Circuit Court case number 1822-CC11694