Renewable Energy Equipment Leasing, LLC v. Team Gemini, LLC, 2:14-cv-02687

REEL sued Team Gemini, TGPC, and Gemini Holdings for breach of contract, promissory estoppel, quantum meruit, and declaratory relief arising from advisory/financial services and work on the SWACO/COR3 project; Gemini Holdings was later dismissed.
Team Gemini and TGPC defaulted by failing to respond to orders; the court adopted a prior recommendation to enter default judgment as to liability and referred damages to the magistrate judge.
REEL moved for summary judgment on damages seeking $1,725,000 and submitted an affidavit and documentary support; defendants did not respond and some mailings to Team Gemini were returned undeliverable.
REEL’s evidence showed employee compensation, travel, and other project-related expenses; REEL claimed employee time charges and commissions tied to financings and contracts.
The magistrate independently reviewed the record, found REEL established liability, but reduced the damages award to $1,455,521 based on documentary support and rejected certain estimates and undocumented benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Liability after default	REEL: well-pleaded allegations establish breach/alternative restitution claims	Defendants: no response (default)	Court: liability accepted on default; damages to be determined
Amount of damages	REEL: requests $1,725,000 based on employee time, travel, and contract-based fees	Defendants: unopposed but court must verify evidentiary support	Court: awarded $1,455,521 based on supported payroll/travel entries; excluded undocumented/estimated items
Risk of double recovery from multiple theories	REEL: entitled to recover but not double recover	Defendants: no response	Court: cautioned against duplicative recovery and ensured award avoids double recovery
Piercing the corporate veil	REEL: requests veil piercing to reach affiliates if Team Gemini lacks assets	Defendants: not argued (no response); veil-piercing not pleaded	Court: denied veil-piercing—REEL failed to plead or prove complete control plus fraud/illegal act and resulting unjust loss

United States v. Conces, 507 F.3d 1028 (6th Cir. 2007) (defaulted defendant’s well-pleaded allegations on liability are taken as true)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (movant’s burden to show absence of genuine dispute on material facts at summary judgment)
Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (standard for genuine issue of material fact at summary judgment)
Joe Hand Promotions, Inc. v. Yakubets, 3 F. Supp. 3d 261 (E.D. Pa. 2014) (damages hearing not required where documentary evidence or affidavits establish amount)
Belvedere Condo. Unit Owners’ Assn. v. R.E. Roark Cos., Inc., 67 Ohio St.3d 274 (Ohio 1993) (elements required to pierce the corporate veil)
Dombroski v. WellPoint, Inc., 119 Ohio St.3d 506 (Ohio 2008) (veil-piercing requires proof of control and misconduct)