WRITTEN TESTIMONY AND FACTUAL CHRONOLOGY

Daniel Perley vs. Jonathan Jackson

Matter: Business Disassociation, Theft of Corporate Assets and Intellectual Property, Fraudulent Representation, Religious Discrimination, Malicious Prosecution, False Imprisonment, Unjust Enrichment, Wanton Disregard of Duty Of Care Upon A Terminally Ill Person, Attempted Manslaughter, Arson

Affiant: Daniel Perley ("Perley") Respondent: Jonathan Jackson ("Jackson")

I, Daniel Perley, hereby provide the following written testimony detailing the sequence of events concerning Best Choice Industries, LLC, Jackson Egress Windows, LLC, Jonathan Jackson, and related business operations, torts, and crimes.

I Formation and First Wrongful Disassociation (Best Choice Industries, LLC)

  1. Best Choice Industries, LLC (hereinafter, the "LLC") was formed as a fifty-fifty (50/50) partnership between Perley and Jackson.
  2. Perley’s primary contribution to the LLC was the initial acquisition of all **materials, assets, specialized methodology, and vendor relationships**. Jackson’s contribution was solely cash capital.
  3. Approximately one year after formation, Jackson wrongfully disassociated from the LLC and, without authorization or compensation to Perley, seized complete control of the following assets:
    • All funds under his management (financial/tax management was Jackson’s contribution).
    • All business materials and physical assets.
    • All established vendor and supplier relationships.
  4. Jackson’s actions left Perley solely responsible for operational fieldwork. Jackson continued to profit by procuring products wholesale and marking them up without providing the agreed-upon financial or managerial support.
  5. Perley believes that Jackson may have used a separate, fictitious name filing for "Best Choice Egress Windows," which he controlled, to open an independent bank account and divert funds away from the LLC.

II Crisis, Incarceration, and Default Judgment

  1. The business disruption coincided with Perley suffering a severe back injury resulting in temporary paralysis, rendering him unable to perform necessary fieldwork and without managerial support.
  2. This led to Perley's prosecution and subsequent incarceration on charges of theft by deception. During this incarceration period, communication restrictions prevented Perley from effectively managing or defending the business.
  3. While Perley was incarcerated, the Ohio Attorney General (AG) filed a consumer sales complaint against both Perley and Jackson.
  4. Jackson subsequently canceled the fictitious name filing for "Best Choice Egress Windows."
  5. Jackson retained counsel to defend himself, denying any connection to the LLC. This same counsel then appeared on behalf of Perley and the LLC, filing a **sham pleading** that was subsequently stricken. This action resulted in a **default judgment** being entered against Perley and the LLC.
  6. Perley was never properly served with the consumer sales complaint during his incarceration, which fact the AG was aware of.

III Second Arrangement and Usurpation

  1. Upon Perley’s recovery and stabilization, he re-engaged with Jackson under a new, 50/50 arrangement ("Jackson Egress Windows"). Perley directed his half of the profits toward reimbursing customers impacted by the previous disruption.
  2. Perley re-established the business’s viability by building a new, highly effective website and driving sales to profitable levels using the original, successful business methodology.
  3. This arrangement was abruptly terminated when Jackson’s brother, Justin, committed a theft (stole a customer’s iPad) while working on a job site with Perley.
  4. The same evening, Jackson falsely accused Perley of theft regarding common scrap metal, leading to Perley's second arrest and incarceration.
  5. Jackson subsequently blamed Perley publicly on Angie's List replies to the affected customer’s review, despite police proving his brother’s guilt and recovering the stolen device.
  6. Jackson’s false accusation and subsequent incarceration of Perley allowed Jackson to **entirely usurp the new business**, including the assets, website, and methodology Perley had just re-established. Perley was forced to leave the state of Ohio.

IV Six Years of Unjust Enrichment

  1. For the following six years, Jackson continued operating the business, leveraging the specialized skills, methodology, intellectual property (IP), and marketing assets (including the website, materials, and trained personnel) originally contributed or re-developed by Perley.
  2. Jackson profited substantially from the **unjust enrichment** derived from the use of Perley's IP.

V Third Engagement, Theft of Digital IP, and Final Disassociation

  1. Approximately six years later, Jackson contacted Perley due to a decline in business, suggesting he could "make things right" if Perley assisted in a modernization effort. Perley accepted accommodation on Jackson’s property.
  2. For the next eighteen (18) months, Perley transformed the company by developing and implementing a complete digital infrastructure, including:
    • A suite of lead-generating web applications and utilities (useful content).
    • A bespoke Customer Relationship Management (CRM) system** for sales pipeline management, online document signing, and customer portals.
    • Extensive strategic content creation and specialized tools (egress window building permit generator and CAD editor).
  3. Perley provided this web development as a service through his own LLC. He was not operating in a mere 'webmaster' role for Jackson Egress Windows. He provided highly skilled and full-stack development services for Jackson as an independant business and contractor; and received 1099s from Jackson. All digital assets were set up under **Perley’s own Google Cloud Platform (GCP) account, which was chosen by Google for the Google Cloud Startup Sponsorship Program after Perley submitted his ides and plans for a human-centric CRM and CMS System.
  4. In addition to digital IP, Perley **invented a new one-piece, fusion-welded window system ("TrueFrame")** and designed/built the necessary manufacturing system, significantly reducing installation complexity and cost.
  5. As Perley sought to finalize patent research and requested a written agreement for compensation before releasing the TrueFrame product, Jackson initiated a final act of betrayal.
  6. Jackson cut off power to Perley's residence and, with his son, attempted to log into the GCP Console to **remove Perley’s access and steal all digital resources**.
  7. Perley's security protocols successfully detected the attempted digital theft and suspended the accounts of both Jackson and his son, preventing the theft of these valuable SaaS-ready assets.
  8. This final incident confirms Jackson’s pattern of wrongful disassociation, theft of intellectual property, and unjust enrichment, necessitating formal legal action to recover damages.