CF Staffing Solutions, LLC v. District Healthcare Services, LLC
2:24-cv-02355
D. Nev.May 2, 2025Background
- Plaintiffs CF Staffing Solutions, LLC and Max Casal sued District Healthcare Services, LLC, Breaking Silos in Medicine, LLC, and Habib Shamte, M.D. over alleged breaches of agreements for medical billing and related services.
- Casal and Shamte allegedly entered into an oral agreement: Casal would provide business services and proprietary information in exchange for a 5% equity stake in Breaking Silos and related service contracts for CF Staffing.
- Both District Healthcare and Breaking Silos terminated their relationships with CF Staffing in September 2024; Plaintiffs claim these terminations violated contractual obligations.
- The suit was removed from state to federal court; plaintiffs amended their complaint, naming Casal as a new plaintiff and clarifying claims.
- Defendants moved to dismiss the breach of contract and unjust enrichment claims against Shamte and asked to transfer venue to Washington, D.C.; they argued inconsistencies in pleadings, failure to state claims, Statute of Frauds, and inappropriate forum.
- The court denied all motions to dismiss and denied transfer to D.C., finding the claims sufficient and venue proper in Nevada.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Inconsistency between original and amended complaint | Amendments clarified miscommunication; substance not changed | Inconsistencies warrant dismissal | Substitution of party did not warrant dismissal; factual expansion is plausible |
| Breach of contract claim sufficiency | Essential terms and mutual assent are sufficiently alleged | Essential terms unspecified; no mutual assent | Complaint sufficiently alleges contract elements |
| Application of Statute of Frauds | Obligations could be performed within one year | Oral agreement required writing under Statute of Frauds | Agreement not barred as obligations could be performed within one year |
| Unjust enrichment sufficiency/alternativeness | Pleads unjust enrichment in the alternative to contract claim | No unjust enrichment if contract exists; no benefit alleged | Can plead both at this stage; FAC alleges sufficient facts |
| Transfer to District of Columbia | Significant Nevada contacts; agreements negotiated in Nevada | D.C. is defendant home forum; little connection to Nevada | No factor supports transfer; Nevada proper |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (clarifies plausibility standard for Rule 12(b)(6) motions)
- Ashcroft v. Iqbal, 556 U.S. 662 (sets the pleading standard for plausibility)
- Hoffman v. Blaski, 363 U.S. 335 (proper venue and personal jurisdiction criteria for transfer)
- May v. Anderson, 119 P.3d 1254 (elements for breach of contract under Nevada law)
- Certified Fire Prot. Inc. v. Precision Constr., 283 P.3d 250 (Nevada law on contract formation and essential terms)