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TO THE HONORABLE COURT:

Plaintiff Vertex Solutions LLC ("Vertex" or "Plaintiff") files this Original Petition against Defendant GreenLeaf Technologies, Inc. ("GreenLeaf" or "Defendant") and respectfully shows the Court as follows:

I. Discovery Control Plan

1. Plaintiff intends to conduct discovery under Level 2 of Texas Rule of Civil Procedure 190.3 and affirmatively pleads that this suit is not governed by the expedited actions process in Rule 169 because Plaintiff seeks monetary relief over $250,000, including attorneys' fees.

II. Parties

2. Plaintiff Vertex Solutions LLC is a Texas limited liability company with its principal place of business in Travis County, Texas.

3. Defendant GreenLeaf Technologies, Inc. is a Texas corporation with its principal place of business in Travis County, Texas. Defendant may be served with process through its registered agent, CT Corporation System, at 1999 Bryan Street, Suite 900, Dallas, TX 75201.

III. Jurisdiction and Venue

4. This Court has subject matter jurisdiction over this action because the amount in controversy exceeds this Court's minimum jurisdictional limits. TEX. GOV'T CODE § 24.007.

5. Venue is proper in Travis County pursuant to TEX. CIV. PRAC. & REM. CODE § 15.002(a)(1) because the Defendant's principal office is located in Travis County. Venue is also proper under Section 8.3 of the parties' Agreement, which designates Travis County, Texas as the exclusive venue for litigation arising out of the Agreement.

IV. Factual Background

6. On or about September 8, 2025, Plaintiff and Defendant entered into a written Software Development Agreement (the "Agreement") whereby Plaintiff agreed to develop custom inventory management software for Defendant in exchange for payment of $180,000.

7. A true and correct copy of the Agreement is attached hereto as Exhibit A and incorporated by reference.

8. Pursuant to the Agreement, Defendant agreed to pay Plaintiff in three installments: (a) $60,000 upon execution; (b) $60,000 upon beta delivery; and (c) $60,000 upon final acceptance.

9. Defendant paid the first two installments totaling $120,000.

10. Plaintiff fully performed its obligations under the Agreement, delivering the completed software on January 15, 2026, in accordance with the contractual deadline.

11. The software delivered by Plaintiff conforms to the specifications set forth in Exhibit A to the Agreement.

12. Despite Plaintiff's full performance, Defendant has refused to pay the final installment of $60,000.

13. On or about February 4, 2026, Plaintiff demanded payment from Defendant. Defendant refused.

14. On or about February 20, 2026, Plaintiff, through counsel, again demanded payment. Defendant has continued to refuse payment.

V. Causes of Action

COUNT ONE: BREACH OF CONTRACT

15. Plaintiff incorporates by reference the allegations in paragraphs 1 through 14.

16. The Agreement is a valid and enforceable contract between Plaintiff and Defendant.

17. Plaintiff fully performed its obligations under the Agreement by delivering conforming software on or before the contractual deadline.

18. Defendant breached the Agreement by failing and refusing to pay the final installment of $60,000 as required by Section 3.1(c) of the Agreement.

19. As a direct and proximate result of Defendant's breach, Plaintiff has suffered damages in the amount of at least $60,000, plus interest accruing at the contractual rate of 1.5% per month pursuant to Section 3.3 of the Agreement.

COUNT TWO: QUANTUM MERUIT (ALTERNATIVE)

20. Plaintiff incorporates by reference the allegations in paragraphs 1 through 14.

21. In the alternative, if the Agreement is found unenforceable for any reason, Plaintiff provided valuable services to Defendant in the form of custom software development.

22. Defendant accepted and has retained the benefit of Plaintiff's services.

23. It would be unjust for Defendant to retain these benefits without paying Plaintiff the reasonable value of the services rendered.

24. The reasonable value of Plaintiff's services is at least $180,000, of which Defendant has paid only $120,000, leaving a balance of $60,000 due.

VI. Damages

25. As a result of Defendant's breach, Plaintiff has suffered damages including:

• Unpaid contract balance: $60,000.00
• Accrued interest through February 28, 2026: $1,350.00
• Additional interest continues to accrue at 1.5% per month

VII. Attorneys' Fees

26. Pursuant to Section 8.4 of the Agreement, the prevailing party in any litigation is entitled to recover its reasonable attorneys' fees and costs.

27. Plaintiff has been required to retain the services of Harrison & Cole LLP to prosecute this action and has agreed to pay reasonable attorneys' fees for such services.

28. Plaintiff requests recovery of its reasonable and necessary attorneys' fees incurred in this action, as well as fees incurred on appeal, if any.

VIII. Conditions Precedent

29. All conditions precedent to Plaintiff's claims have been performed or have occurred.

IX. Prayer

WHEREFORE, Plaintiff Vertex Solutions LLC respectfully requests that the Court grant the following relief:

1. Judgment against Defendant for actual damages in the amount of $60,000, plus prejudgment interest at the contractual rate;
2. Judgment against Defendant for reasonable attorneys' fees and costs;
3. Post-judgment interest at the maximum legal rate;
4. Costs of court; and
5. Such other and further relief to which Plaintiff may be justly entitled.

Respectfully submitted,

HARRISON & COLE LLP

Rebecca Harrison
Texas Bar No. 12345678
2500 Congress Avenue, Suite 1200
Austin, Texas 78701
(512) 555-2400 (telephone)
(512) 555-2401 (facsimile)
rharrison@harrisoncole.com

ATTORNEY FOR PLAINTIFF
VERTEX SOLUTIONS LLC