MAJOR LAWSUIT AGAINST SCOTT IN FL

IN THE CICRUIT COURT OF THE 7TH JUDICIAL CIRCUIT IN AND FOR ST. JOHNS COUNTY, FLORIDA

AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF NORTHEAST FLORIDA f/k/a DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC,
                                                                                                                                              PLAINTIFF,

VS.

DRYER VENT SUPERHEROES FRANCHISING, LLC, THOMAS SCOTT, LISA SLATE, & AARON SLATTERY
                                                                                                                                            DEFENDANTS.

COMPLAINT FOR DAMAGES

Plaintiffs, AMANDA ELIZABETH BROWN (“Brown”), DRYER VENT SUPERHEROES OF NORTHEAST FLORIDA f/k/a DRYER VENT SUPERHEROES OF JACKSONVILLE (“DVS Jax”), and JAAM JAX, LLC (“JAAM JAX”) (collectively, “Plaintiffs”), sue Defendants DRYER VENT SUPERHEROES FRANCHISING LLC (“DVS Franchising”), THOMAS SCOTT (“Scott”), LISA SLATE (“Slate”), and AARON SLATTERY (“Slattery”) and in support thereof allege as follows:

INTRODUCTION

This action arises from a calculated and deceptive scheme orchestrated by Defendants, who induced Plaintiff under false pretenses to sign a franchise agreement (“Franchise Agreement”) and invest more than $85,000 in a franchise opportunity. Representing themselves as experienced and trustworthy franchisors, Defendants concealed critical litigation history, misrepresented material terms of the Franchise Agreement, and failed to deliver on essential obligations including training, marketing, and operational support. When Plaintiff questioned these discrepancies and sought accountability, Defendants retaliated by abruptly terminating the Franchise Agreement—without justification or refund, and in direct violation of Florida and federal law. Defendants continue to retain all of the funds paid by Plaintiffs, prevent Plaintiffs’ access to critical systems required to perform their service, and prevent Plaintiff from earning a livelihood. This lawsuit seeks to hold Defendants accountable for their fraudulent conduct, statutory violations, and breach of contract, and to recover the substantial damages suffered by Plaintiffs as a result of Defendants’ misconduct.

PARTIES, JURISDICTION, AND VENUE

1. Brown is an individual and resident of St. Augustine, Florida, and at all times relevant was the principal of DVS Jax and JAAM JAX.

2. DVS Jax is a franchise of DVS Franchising owned by JAAM JAX operating in and around Jacksonville, Florida.

3. JAAM JAX is a Florida limited liability company owned and managed by Brown, with authorization to operate DVS Jax in Florida under the applicable rules of the Florida Secretary of State.

4. DVS Franchising is a Tennessee limited liability company that licenses and sells the franchise to companies to operate on its behalf in several states, including Tennessee and Florida.

5. Scott is an individual and resident of Nashville, Tennessee, and at all times relevant is the owner, manager, and principal of DVS Franchising.

6. Slate is an individual and resident of Franklin, Tennessee, and at all times relevant was an employee, affiliate, or agent of Scott and/or DVS Franchising.

7. Alternatively Slate is an individual and resident of Franklin, Tennessee, and at all times relevant was an employee of Home Run Franchises LLC, a Tennessee limited liability company that is an affiliate or agent of Scott and/or DVS Franchising and was providing franchising services on their behalf.

8. Slattery is an individual residing in Hillsborough County, Florida, and at all times relevant was an agent, employee, or affiliate of First Financial.

9. Alternatively, Slattery is an individual residing in Hillsborough County, Florida, and at all times relevant was an agent, employee, representative, or affiliate of Home Run Franchises LLC, a Tennessee limited liability company that is an affiliate or agent of Scott and/or DVS Franchising and was providing financial services on their behalf.

10. This Court has subject matter jurisdiction over this action pursuant to Article V, Section 5(b) of the Florida Constitution and section 26.012 of the Florida Statutes, as the amount in controversy exceeds $50,000, exclusive of interest, costs, and attorneys’ fees.

11. This Court has personal jurisdiction over the Defendants under section 48.193 of the Florida Statutes, as the Defendants committed tortious acts within the State of Florida or otherwise engaged in business activities directed at Florida residents.

12. Venue is proper in St. Johns County, Florida, under section 47.011 of the Florida Statutes, as the causes of action accrued in St. Johns County and the subject transactions took place in St. Johns County.

13. All conditions precedent to this action have been met or waived.

14. Plaintiffs have retained undersigned counsel and agreed to pay a reasonable fee for their representation.

15. The Franchise Agreement provides for an award of attorneys’ fees to the prevailing party.

FACTS GIVING RISE TO THIS ACTION

16. On or before March 14, 2025, Brown was connected to Scott through Ari O’Brien, a professional in franchise development and referrals, to help learn about becoming a franchisee of DVS Franchising.

17. Brown and O’Brien engaged in several phone conversations regarding the potential business opportunity.

18. Brown took meticulous notes during these phone calls.

19. On February 20, 2025, Brown was provided a copy of the DVS Franchising Franchise Disclosure Document (“FDD”). See Exhibit A.

20. On or before March 14, 2025, Brown and Scott engaged in several phone conversations regarding the potential business opportunity with DVS Franchising.

21. The Franchise Agreement specified that the monthly franchising fee would increase during the first three years; however, Scott told Brown on several occasions that the monthly franchise fee was only $1,000.

22. Scott told Brown that the monthly technology fee would be $750 per month, which was confirmed by the Franchise Agreement at Section 6.5.

23. The Franchise Agreement required a monthly marketing fee of $4,000; however, Brown was reassured that this marketing fee would not be assessed until after the first month of business operations, because the initial month’s marketing fee was to be included in the initial $78,000 franchise fee.

24. Brown alerted Scott that she needed to acquire a loan to cover the franchise fee, and Scott directed Brown to pursue a Small Business Administration (“SBA”) loan exclusively through Scott’s associate Slattery.

25. On behalf of DVS Franchising, or as its apparent agent, Slattery provided the SBA with a business plan on behalf of Plaintiffs that stated the monthly marketing budget/fee would be a total of $4,000 per month for two years. See Exhibit B.

26. Plaintiffs secured their small business loan through United Midwest Savings Bank because Slattery told them that was the bank they had to use.

27. Despite Slattery being a broker and not an agent of United Midwest Savings Bank, Scott told Plaintiffs that they needed to work through Slattery instead of securing their own loan.

28. Slattery directed the Plaintiffs to ignore and not to have communication with the bank until after he had spoken with the bank.

29. Slattery directed Plaintiffs to complete the answers differently than Brown intended.

30. Slattery submitted the loan documents with Brown’s signature despite the fact that Brown disagreed with the answers to questions.

31. Slattery was paid $3,000 in addition to the costs because of his services as broker.

32. Slattery and Scott worked together to perpetuate their scheme against Plaintiffs.

33. Neither Slattery nor First Financial are identified on the FDD.

34. On March 14, 2025, Brown and Scott agreed to franchise DVS Jax as a franchisee of DVS Franchising and executed a Franchise Agreement. See Exhibit C.

35. After the Franchise Agreement was signed, Scott, through Alex Gilleland, demanded payment of $7,500 for the first month’s marketing fee.

36. Upon being questioned by Brown, Slate relented and acknowledged that the agreement was that Plaintiffs would not pay a first month’s marketing fee.

37. After confirming to Brown that Plaintiffs would not have to pay a first month’s marketing fee, Slate withdrew her statement based on directive by Scott.

38. The Franchise Agreement stated that training would be provided by Scott and his affiliates to Brown to establish the franchise operations of DVS Jax.

39. At her own expense, Brown traveled to Nashville, Tennessee, for training but Scott did not provide sufficient training to Brown to adequately launch a franchise of DVS Franchising.

40. The FDD disclosed that Brown would be provided a copy of the DVS Franchising Operations Manual, but beyond the Table of Contents provided in the FDD, Brown was not provided any Operations Manual until after the training week was completed. Brown did not have the Operations Manual to reference or consult during the substandard training that was offered.

41. The Federal Trade Commission, through 16 C.F.R. 436, including its subparts (the “FTC Franchise Rule”), requires franchisors to disclosure certain material facts and documents regarding the franchisor and its parents, predecessors, and affiliates to potential franchisees at least 14 calendar days before the execution of a franchise agreement.

42. Also under federal law, the FDD must be updated annually, within 120 days of the franchisor’s fiscal year end, or whenever there are material changes.

43. The FDD provided to Plaintiffs for review in March 2025 had not been updated since April 2, 2024.

44. Scott and DVS Franchising had been embroiled in but failed to disclose material, serious litigation history via the FDD offered to Plaintiffs.

45. As examples, the FDD failed to disclose the following causes of action:

    a. Case No. 23-0022-IV – Clozetivity Franchising v. Thomas Scott, Up Closets, et al (Davidson                 County, TN)

    b. Case No. 22-1256-BC – Goldberger v. Brand Journalists, Thomas Scott, et al (Davidson County,             TN)

     c. Case No. 22-1310 Scott v. Clozetivity Franchising, Goldberger (Davidson County, TN)

    d. Case No. 22-1311 – Farris v. Dryer Vent Squad, (Davidson County, TN)

    e. Case No. 23-cv-00685 Gilleland v. Home Based Franchise Group, Dryer Vent, etal (N.D. Ala 2023)

    f. Case No. 23-cv-00125 Clozetivity v. Scott, et al (M.D. TN 2023)

    g. Case No. 22-cv-773 – Birdwell Enterprises v. Clozetivity, (M.D. TN 2022)

    h. Case No.22-cv-00774, Cotton v. Dryer Vent Squad, et al (M.D. TN 2023)

    i. Case No. 22-cv-00775, Lunt v. Frost Shades, et al (M.D. TN 2022)

46. In fact, DVS Franchising and Scott disclosed only a single legal action, an administrative proceeding in Maryland, in the FDD: In the Matter of Frost Shades Franchising LLC, Administrative Proceeding before the Securities Commissioner of Maryland, Case No. 2021-0171.

47. Brown specifically inquired about Defendants’ legal and regulatory history.

48. Scott assured Brown that there was not any serious litigations or legal actions associated with his history.

49. Notwithstanding the lack of disclosure of the litigation history, since Plaintiffs became engaged with Defendants, the Plaintiffs have received numerous phone calls from other frustrated franchisees and Scott’s former business partners detailing the unethical practices and confirming a broader course of Defendants’ conduct.

50. Scott further assured Brown that he would always work with his franchisees to resolve disputes.

51. Scott has made no good faith attempt to resolve this dispute with Plaintiffs.

1 In addition to the cases listed above, Plaintiffs are aware of the following website which tracks serious litigation events involving Defendants. https://thomasscotthomerunfranchiseshistory.blogspot.com, accessed July 24, 2025.

52. Plaintiffs would not have agreed to arbitrate disputes generally with Defendants and would not have agreed to arbitrate disputes in Defendants’ preferred location of Nashville, Tennessee, if Plaintiffs had been properly informed about Defendants’ propensity for litigious conflicts.

53. Plaintiffs would not have entered into the Franchise Agreement had they known that Defendants were repeat litigants.

54. Scott and DVS Franchising intentionally concealed the litigation history to induce Brown to agree to the arbitration provision within the Franchise Agreement.

55. The FDD also failed to disclose certain relevant business experiences of Defendants, including Scott’s previous partnership with two individuals who had created a franchise network of substantially similar business models as those that Scott established after leaving the partnership.

56. Many of the lawsuits to which Defendants are parties and that are referenced in this Complaint involve disputes between Defendants and Scott’s former partners alleging fraud, breach of contract, breach of care and loyalty, and unjust enrichment.

57. Despite filings to the contrary, on April 26, 2025, Scott emailed Plaintiffs stating that “Neither Dryer Vent Superheroes nor Up Closets are in any litigation with anyone.”

58. The Franchise Agreement and the FDD both included an ACH authorization form that specified the minimum and maximum amounts for withdrawals from Plaintiffs’ designated accounts. See Exhibit D.

59. After executing the Franchise Agreement, Defendants demanded that Plaintiffs execute a different ACH authorization form that did not allow Plaintiffs to specify the minimum and maximum amounts. See Exhibit E.

60. Plaintiffs responded to Defendants’ demand by requesting a meeting to discuss the demand and requiring production of the agreed upon ACH form provided with the FDD and Franchise Agreement, but Defendants did not agree to a meeting and have not produced the ACH form provided in the Franchise Agreement.

61. On May 25, 2025, Slate sent a marketing invoice to Plaintiffs for $3,500 for Facebook marketing.

62. This invoice did not account for the $2,500 that Plaintiffs had already paid on Google marketing for the month.

63. Plaintiffs responded by clarifying the income over the month and that the minimum spend required under the Franchise Agreement had been met.

64. Defendants responded by demanding $6,000 additional spending for Facebook advertising and threatening to shut down the marketing for Plaintiffs.

65. On May 31, 2025, Slate suspended Plaintiffs’ marketing services without prior notice.

66. Throughout June and up until June 19, 2025, Brown attempted to meet with Scott and resolve the alleged disputes regarding the operation of the franchise. Scott refused to participate in such sessions without the attendance of Brown’s husband and Brown’s father.

67. Brown’s husband and father are not signatories to the Franchise Agreement and are not participating principals or officers of the Plaintiff entities.

68. Brown is the sole member and manager of the Plaintiff entities according to filings with the Florida Secretary of State – Department of Corporations.

69. Prior to and since the execution of the Franchise Agreement, Scott has demanded Brown use only preferred partners, with whom he has a relationship, for certain services related to the operation of DVS Jax.

70. Although some were disclosed as partners, the requirement to use many of these partners is not included in the Franchise Agreement or the FDD.

71. The requirement to use these partners is financially advantageous to Scott because of his relationship with those businesses.

72. On June 6, 2025, DVS Franchising and Scott, through counsel, sent notice to Brown that she was allegedly in breach of the Franchise Agreement for (1) failure to pay the monthly royalty fee and the monthly technology fee; (2) failure to execute the ACH agreement; and (3) turning off the online marketing. Exhibit F.

73. Previously, on June 5, 2025, Plaintiffs had paid the monthly royalty fee and the monthly technology fee. This alleged breach was thus cured before the letter being sent.

74. The ACH agreement being demanded by Defendants is materially different from the agreed-upon ACH form found in the FDD and Franchise Agreement.

75. The correspondence falsely alleged that DVS Jax had turned off the marketing, when it was instead disabled/turned off by Slate.

76. On July 9, 2025, DVS Franchising and Scott abruptly and without justification terminated the Franchise Agreement for “noncompliance with the Agreement in our letter dated June 6, 2025...” 

77. This correspondence is factually inaccurate as Brown had cured the payment owed before the previous letter, had requested an appropriate and agreed upon ACH form, and confirmed that she did not terminate the marketing.

78. Despite the inaccurate assertion that Brown had failed to respond to cooperate with the previous correspondence, Brown had made several continued attempts to resolve this matter.

79. Defendants did not make attempts to resolve the dispute prior to termination of the Plaintiffs’ access as required by their oral assurance and the Franchise Agreement.

80. The July 9, 2025, correspondence from Defendants added that Plaintiffs (1) failed to provide the bank account information and (2) had not paid for additional marketing activities.

81. As of the date of the correspondence, Brown had still not been provided the agreed upon ACH authorization form.

82. Brown was not informed of any additional marketing activities before the July 9, 2025 correspondence. Further, DVS Jax had already met the requirement minimum marketing spend.

83. The correspondence indicated it was a “for cause termination” and denied Brown any rights under the Franchise Agreement.

84. The Franchise Agreement provides for a $75 late fee for owed balance of fees and an 18% per annum interest charge.

85. The Franchise Agreement does not authorize contract termination over an alleged debt of $1,129.

86. DVS Franchising is registered with the Florida Department of Agriculture and Consumer Services as a business opportunity under license No. BF54807.

87. Scott and DVS Franchising agreed to provide Brown a business opportunity.

88. Scott and DVS Franchising marketed this business opportunity as a chance for Brown to start a business.

89. Brown was required to pay a fee in excess of $500 to DVS Franchising.

90. Scott and DVS agreed to provide a sales and marketing program that would provide business income to Brown.

91. Upon information and belief, DVS Franchising has not filed written notice with the Florida Department of Corporations stating that DVS Franchising has substantially complied with the Federal Trade Commission.

92. Upon information and belief, DVS Franchising has not paid the annual fee, for the year preceding the purported sale of DVS Jax, to the Florida Department of Corporations as required for substantial compliance with the Federal Trade Commission.

93. The FDD does not contain a Florida disclosure statement Complaint with Fla. Stat. § 559.803.

FIRST CAUSE OF ACTION
(Declaratory Judgment Fraudulent Inducement to Invalidate the Arbitration Provision)
(Scott and DVS Franchising)

94. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

95. Scott and DVS Franchising made false statements, omissions, or representations about their litigation history.

96. Scott and DVS Franchising made false statements, omissions, or representations about their professional history, experience, and associations.

97. Defendants knew or should have known these statements were false at the time they were made.

98. Defendants intended these statements to induce Brown to accept the arbitration provision.

99. The arbitration provision (Section 20 of the Franchise Agreement) requires, among other things: (1) internal dispute resolution, (2) mediation, (3) arbitration, and (4) venue in Tennessee.

100. Defendants knew, or should have known, that making truthful statements would have led Plaintiffs not to enter into the arbitration provision.

101. Brown justifiably relied on Scott’s statements to agree to the arbitration provision.

102. Plaintiffs have been injured by Defendants’ false statements including, but not limited to, loss of the franchise fee, loss of other fees paid to Scott and his associates, loss of business revenue, loss of business opportunity, and loss of the DVS Jax franchise.

103. By reason of the foregoing, Plaintiffs are entitled to rescission of the arbitration provision—entitling them to venue in Florida where the substantial transactions occurred; repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees; and actual damages and all amounts incurred as a result of Defendants’ fraud, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

104. WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order declaring the arbitration provision in the Franchise Agreement unenforceable due to fraudulent inducement, enjoining DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT from initiating, continuing, or compelling arbitration proceedings; granting Plaintiffs the reasonable attorney’s fees and costs of this action; and any further relief this Court deems appropriate, just, and necessary.

SECOND CAUSE OF ACTION
(Fraud in the Inducement)
(Scott and DVS Franchising)

105. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

106. Scott and DVS Franchising made false statements, omissions, or representations about their litigation history.

107. Scott and DVS Franchising made false statements, omissions, or representations about their professional history, experience, and associations.

108. Defendants knew or should have known these statements were false at the time they were made.

109. Alternatively, Defendants made these statements with reckless disregard for the truth.

110. Defendants intended these statements to induce Brown to enter into the Franchise Agreement.

111. Scott knew, or should have known, that making truthful statements would have led Brown not to enter into the Franchise Agreement.

112. Brown relied on Scott’s statements to enter into the Franchise Agreement.

113. Brown would not have executed or entered into the Franchise Agreement if she had known that Scott’s statements were false.

114. Brown’s reliance on Scott’s statements was reasonable at the time because his statements were apparently corroborated by what Defendants held out as a legally compliant FDD.

115. Brown’s reliance on Scott’s statements was reasonable at the time because she did not possess facts or information that Scott was being untruthful.

116. Plaintiffs have been injured by Scott’s false statements including, but not limited to, loss of the franchise fee, loss of other fees paid to Scott and his associates, loss of business revenue, loss of business opportunity, and loss of the DVS Jax franchise.

117. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for their fraud and rescission of the Franchise Agreement; repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees; and actual damages and all amounts incurred as a result of Defendants’ fraud, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for fraud, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

THIRD CAUSE OF ACTION
(Violation of Florida’s Unfair and Deceptive Trade Practices Act)
(Scott and DVS Franchising)

118. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

119. Scott and DVS Franchising made false statements, omissions, or representations about their litigation history.

120. Scott and DVS Franchising made false statements, omissions, or representations about their professional history, experience, and associations.

121. These materially false statements offend established public policy and/or are immoral, unethical, oppressive, or substantially injurious to consumers.

122. These statements were likely to mislead a consumer and did mislead Brown.

123. Brown relied on Scott’s statements to enter into the Franchise Agreement.

124. Brown would not have executed or entered into the Franchise Agreement if she had known that Scott’s statements were false.

125. Brown’s reliance on Scott’s statements injured her because Scott canceled the Franchise Agreement when Brown questioned his activity surrounding the Franchise Agreement.

126. Plaintiffs have been injured by Scott’s deceptive practices including, but not limited to, loss of the franchise fee, loss of other fees paid to Scott and his associates, loss of business revenue, loss of business opportunity, and loss of the DVS Jax franchise.

127. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for Defendants’ violation of Fla. Stat. Chapter 501, Part II, including rescission of the Franchise Agreement; repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees; and actual damages and all amounts incurred as a result of Defendants’ conduct, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for violation of Fla. Stat. Chapter 501, Part II, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Courts deems appropriate, just, and necessary.

FOURTH CAUSE OF ACTION
(Fraud in the Performance of the Franchise Agreement)
(Scott and DVS Franchising)

128. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

129. Scott and DVS Franchising made false statements, omissions, or representations about their litigation history.

130. Scott and DVS Franchising made false statements, omissions, or representations about their professional history, experience, and associations.

131. Scott knew these statements were false at the time they were made.

132. Alternatively, Scott made these statements with reckless disregard for the truth.

133. Scott intended these statements to induce Brown to operate and continue operating DVS Jax.

134. Scott intended these statements to induce Brown to make payments to Scott and DVS Franchising that were not required under the Franchise Agreement.

135. Brown would not have operated DVS Jax if she had known that Scott’s statements were false.

136. Brown has notified Scott that she is no longer able to operate DVS Jax because of his fraud.

137. Brown’s reliance on Scott’s statements was reasonable at the time because she trusted that he was being honest with her.

138. Brown’s reliance on Scott’s statements was reasonable at the time because she did not possess facts or information that Scott was being untruthful.

139. Plaintiffs have been injured by Scott’s false statements including, but not limited to, loss of the franchise fee, loss of other fees paid to Scott and his associates, loss of incidental costs for the startup of the business including travel, lodging, and meals, loss of business revenue, loss of business opportunity, and loss of the DVS Jax franchise.

140. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for their fraud and rescission of the Franchise Agreement; repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees; and actual damages and all amounts incurred as a result of Defendants’ conduct, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for fraud, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

FIFTH CAUSE OF ACTION
(Failure to Include/Execute Florida Disclosure Statement)
(Scott and DVS Franchising)

141. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

142. Scott and DVS Franchising had a duty to provide a Florida Disclosure Statement pursuant to Fla. Stat. § 559.803.

143. Fla. Stat. § 559.803 specifies certain requirements designed to protect Florida consumers from fraudulent activity and misrepresentation.

144. Scott and DVS Franchising failed to include such statement and did not meet the requirements of Florida law.

145. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for their violation of Fla. Stat. § 559.3803, including repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of Defendants’ conduct or failure to act, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for violation of Fla. Stat. § 559.803, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

SIXTH CAUSE OF ACTION
(Prohibited Actions Under the Sale of Business Opportunities Act)
(Scott and DVS Franchising)

146. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

147. Scott and DVS Franchising made material misrepresentations regarding the total investment required from Plaintiffs for Brown’s purchase of DVS Jax, including the monthly fees and ancillary fees associated with the Franchise Agreement.

148. Scott and DVS Franchising made material misrepresentations regarding the training and management assistance available to Brown under her purchase of DVS Jax, including, but not limited to, Defendants’ promising training and then failing to provide such training.

149. Scott and DVS Franchising made material misrepresentations regarding their litigation history, including the failure to disclose several relevant past and present lawsuits and settlements.

150. Scott and DVS Franchising made material misrepresentations regarding their professional history, including the failure to disclosure several relevant business associations.

151. Fla. Stat. § 559.813 penalizes a seller who uses untrue or misleading statements in the sale of a business, including that the buyer is entitled to a full rescission of the contract if demand is made within one year of the execution of the contract.

152. Brown demanded rescission of the contract in its entirety within one year of the execution of the Franchise Agreement.

153. Scott and DVS Franchising failed to rescind the contract and provide to Brown a refund of all sums paid to Defendants.

154. Scott and DVS Franchising are in continuing breach of Fla. Stat. § 559.813.

155. Fla. Stat. § 559.813 provides for the recovery of damages and attorney’s fees for Defendants’ violation of this section.

156. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for their violation of Fla. Stat. § 559.813, including repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of Defendants’ conduct or failure to act, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for violation of Fla. Stat. § 559.813, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

SEVENTH CAUSE OF ACTION
(In the Alternative – Breach of Contract)
(Scott and DVS Franchising)

157. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

158. Brown entered into a Franchise Agreement with DVS Franchising.

159. The Franchise Agreement was supposed to exist for a period of 10 years.

160. DVS Franchising was required to provide training and support under the Franchise Agreement.

161. DVS Franchising did not provide such training and support.

162. DVS Franchising was authorized to impose late fees and interest in the event that appropriate payments were not made.

163. DVS Franchising was supposed to provide marketing and advertising support.

164. DVS Franchising terminated marketing and advertising before the end of the contract without justification.

165. DVS Franchising terminated the Franchise Agreement before the end of the contract without justification.

166. Plaintiffs lost revenue, income clients, contact with clients, and the ability to perform its services to its clients due to DVS Franchising’s unlawful and unilateral termination of the Franchise Agreement.

167. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for their breach of contract, including repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of Defendants’ fraud, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for their breach of contract, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

EIGHTH CAUSE OF ACTION
(Unjust Enrichment)
(Scott and DVS Franchising)

168. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

169. Brown entered into a Franchise Agreement with DVS Franchising.

170. The Franchise Agreement was supposed to exist for a period of 10 years.

171. Brown paid DVS Franchising more than $85,000 under the Franchise Agreement and alleged costs incurred.

172. DVS Franchising was required to provide training and support under the Franchise Agreement.

173. DVS Franchising did not provide such training and support.

174. DVS Franchising was authorized to impose late fees and interest in the event that appropriate payments were not made.

175. DVS Franchising was supposed to provide marketing and advertising support.

176. DVS Franchising terminated marketing and advertising before the end of the contract without justification.

177. DVS Franchising terminated the Franchise Agreement before the end of the contract without justification.

178. DVS Franchising has retained the full amount of sums paid by Brown and refuses to return any amounts paid.

179. DVS Franchising acknowledged the receipt of the benefits and its refusal to return any of these amounts to Brown in writing on July 9, 2025.

180. DVS Franchising alleges that DVS Jax and/or Brown owe $1,129 for a fee incidental to services under the Franchise Agreement.

181. DVS Franchising refuses to return more than $85,000 based on an alleged dispute over $1,129.

182. It would be inequitable for DVS Franchising to retain the benefit of the funds received under the Franchise Agreement without having provided Brown with the benefit she was expecting under the Franchise Agreement.

183. The Franchise Agreement is unenforceable given the fraud perpetuated by Defendants.

184. The Franchise Agreement, if enforceable, does not allow for the termination of the contract by Defendants in the event of an alleged minor breach by Plaintiffs.

185. Plaintiffs lost revenue, income clients, contact with clients, and the ability to perform services to clients due to DVS Franchising’s unlawful and unilateral refusal to refund the fees after due demand by Brown.

186. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for unjust enrichment, including repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of Defendants’ unlawful conduct, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for their unjust enrichment, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

NINTH CAUSE OF ACTION
(Tortious Business Interference)
(Scott and DVS Franchising)

187. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

188. Brown entered into a Franchise Agreement with DVS Franchising.

189. The Franchise Agreement was supposed to exist for a period of 10 years.

190. DVS Jax solicited and began providing services for customers in the permitted geographic region upon execution of the Franchise Agreement.

191. DVS Franchising maintained control of the customer database and marketing of DVS Jax.

192. DVS Jax signed customers to annual service agreements.

193. DVS Franchising knew of DVS Jax’s customers and service frequency.

194. DVS Franchising terminated marketing and advertising before the end of the contract without justification.

195. DVS Franchising terminated the Franchise Agreement before the end of the contract without justification.

196. DVS Franchising’s actions were intended to prevent Plaintiffs from operating, including to deprive Plaintiffs of income so that Plaintiffs could not maintain or defend against legal action by Scott and DVS Franchising.

197. DVS Franchising’s actions prevented Plaintiffs from servicing their customers.

198. DVS Franchising’s actions caused Plaintiffs to lose customers and income.

199. Plaintiffs lost revenue, income clients, contact with clients, and the ability to perform services to clients due to Defendants’ unlawful and unilateral termination of the Franchise Agreement.

200. By reason of the foregoing, Plaintiffs are entitled to judgment against Scott and DVS Franchising for their tortious interference with a business expectancy, including repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of Defendants’ tortious interference, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against DRYER VENT SUPERHEROES FRANCHISING, LLC, and THOMAS SCOTT for Defendants’ tortious interference, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

TENTH CAUSE OF ACTION
(Breach of Contract)
(Lisa Slate)

201. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

202. Brown entered into a Franchise Agreement with DVS Franchising.

203. The Franchise Agreement was supposed to exist for a period of 10 years.

204. DVS Franchising was supposed to provide marketing and advertising support.

205. Slate was authorized to control and manage the marketing and advertising of DVS Jax.

206. Slate terminated marketing and advertising before the end of the contract without justification.

207. Plaintiffs lost revenue, income clients, contact with clients, and the ability to perform services to clients due to Slate’s unlawful and unilateral termination of the marketing services.

208. By reason of the foregoing, Plaintiffs are entitled to judgment against Slate for her breach of contract, including repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of her breach of contract, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against LISA SLATE for her breach of contract, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

ELEVENTH CAUSE OF ACTION
(Tortious Business Interference)
(Lisa Slate)

209. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

210. Brown entered into a Franchise Agreement with DVS Franchising.

211. The Franchise Agreement was supposed to exist for a period of 10 years.

212. DVS Jax solicited and began providing services for customers in the permitted

geographic region upon execution of the Franchise Agreement.

213. DVS Franchising maintained control of the customer database and marketing of DVS Jax.

214. DVS Franchising authorized Slate to access the customer database, account, marketing, advertising, and schedule of DVS Jax as an Agent of DVS Franchising.

215. DVS Jax signed customers to annual service agreements.

216. Slate knew of DVS Jax’s customers and service frequency.

217. Slate terminated marketing and advertising before the end of the contract without

justification.

218. Slate’s actions were intended to prevent DVS Jax from operating, including to

deprive Plaintiffs of income so that Plaintiffs could not maintain or defend against legal action.

219. Slate’s actions prevented Plaintiffs from servicing their customers.

220. Slate’s actions caused Plaintiffs to lose customers and income.

221. DVS Jax lost revenue, income clients, contact with clients, and the ability to perform services to clients due to Slate’s unlawful and unilateral termination of marketing and advertising services.

222. By reason of the foregoing, Plaintiffs are entitled to judgment against Slate for her tortious interference with a business expectancy, including repayment of all fees, costs, and expenses incurred in execution and performance of the Franchise Agreement including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of her conduct, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against LISA SLATE for her tortious interference, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

TWELTH CAUSE OF ACTION
(Fraud)
(Aaron Slattery)

223. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

224. Slattery told Plaintiffs they could only secure their loan through him.

225. Slattery told Plaintiffs not to talk to the bank until he had spoken with the bank and Plaintiffs.

226. Slattery knew that Plaintiffs could secure a small business loan through any bank of their choosing applicable to SBA guidelines.

227. Slattery intended Plaintiffs to rely on his representation of exclusive services to induce Plaintiffs to work with and pay him.

228. Slattery did not want Plaintiffs to talk to the bank until after he had confirmed that the bank would allow him to run the process instead of Plaintiffs.

229. Slattery knew his statements were false.

230. Plaintiffs relied on Slattery and employed him to secure the loan.

231. Plaintiffs suffered damages in increased costs due to paying a broker for the loan, lost revenue, income, and clients, contact with clients, and the ability to perform services to clients due to Slattery’s fraud.

232. By reason of the foregoing, Plaintiffs are entitled to judgment against Slattery for his fraud, including repayment of all fees, costs, and expenses incurred in execution and

performance of the loan including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of his conduct, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against AARON SLATTERY for his fraud, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

THIRTEENTH CAUSE OF ACTION
(Aiding and Abetting Scott and DVS Franchising)
(Aaron Slattery)

233. Plaintiffs repeat and reallege the factual information and allegations in Paragraphs 16 through 93 as if fully set forth herein.

234. Slattery was an agent, representative, affiliate, or employee of Scott and/or DVS Franchising.

235. Slattery knew that Scott and DVS Franchising had a scheme to unlawfully take advantage of potential franchisees.

236. Slattery knew that Scott and DVS Franchising would change the terms of the agreement after the franchisee agreed to the terms.

237. Slattery knew that Scott and DVS Franchising would reward him for perpetuating their criminal and wrongful acts.

238. Slattery advised and assisted Scott and DVS Franchising in accomplishing their criminal and unlawful scheme against potential franchisees by controlling the loan application process.

239. Slattery intended that Scott and DVS Franchising would accomplish their criminal and unlawful scheme against potential franchisees so that he would be compensated.

240. Plaintiffs suffered damages in increased costs due to paying a broker for the loan, lost revenue, income, and clients, contact with clients, and the ability to perform services to clients due to Slattery’s participation in Defendants’ wrongful and illegal conduct.

241. By reason of the foregoing, Plaintiffs are entitled to judgment against Slattery for his fraud, including repayment of all fees, costs, and expenses incurred in execution and performance of the loan including, but not limited to, the franchise fee, the small business loan funding fees, closing fees, interest, marketing and advertising fees, technology fees, plus actual damages and all amounts incurred as a result of his conduct, including, but not limited to, pre and post judgment interest, costs, and attorney’s fees.

WHEREFORE, Plaintiffs AMANDA ELIZABETH BROWN, DRYER VENT SUPERHEROES OF JACKSONVILLE, and JAAM JAX, LLC, respectfully request this Court enter an order for final judgment against AARON SLATTERY for his conduct, for the costs of this action, for the reasonable attorney’s fees, and any further relief this Court deems appropriate, just, and necessary.

JURY TRIAL DEMAND

Plaintiffs hereby demands a trial by jury of their peers on all issues appropriate for consideration by a jury.

Respectfully submitted,
BLACK LAW P.A.
Attorneys for Plaintiffs

1401 East Broward Boulevard
Victoria Park Centre, Suite 304

Fort Lauderdale, Florida 33301
Telephone: (954) 320-6220

By: /s/ Patrick Wier
KELSEY K. BLACK, ESQ.
Florida Bar No. 0078925
kb@blacklawpa.com
PATRICK WIER, ESQ.
Florida Bar No. 1029540
pw@blacklawpa.com