Trailer Trash: IFP Thug With a JD and Felon Andrew Peter Lehman Sr’s Story Doesn’t Square With Defendants

IV. FACTUAL BACKGROUND

8. In or about December of 2024, the Plaintiff met the Defendant Hope Heil at an alcohol and drug recovery meeting wherein the Plaintiff volunteered to assist Defendant Hope Heil as a mentor and sponsor to aid Defendant Hope Heil in her Drug and Alcohol recovery.

9. In or about February of 2025, the Plaintiff employed the Defendant Hope Heil in an administrative capacity at his tax consulting business, Aequitas Tax Consulting Inc”, located in Harris County, to assist in data entry and tax return preparation; on the condition that she maintained her sobriety.

As an additional benefit of the employment with the Plaintiff, the Plaintiff assisted in paying the fees for the Defendants’ outpatient drug and alcohol treatment in the Woodlands, TX.

11. In February 2025, at the direction of the Plaintiff and on behalf of his Corporation, the Defendant Hope Heil opened four (4) business bank accounts under the Plaintiffs corporation AEQUITAS TAX CONSULTING INC including (2) Cheeking accounts XXXXXXXX4464, and XXXXXXXX4580, and (2) savmgs accounts XXXXXXXX4503, AND XXXXXXXX451G: for operational purposes, agreeing to later add Plaintiff as an account holder.

These accounts were funded with $100.00 opening deposits by the Plaintiff, and the Plaintiff set the online account access confidentially using his secret username and passcode, and set the recovery access with only corporate address, corporate phone number and corporate email on the ZELLE online account via www.bankofamerica.com.

12. Over the next 30-6O days these accounts were funded with over $25,000.00 of Plaintiffs business revenues, without the knowledge of the Defendants, and the Plaintiff had continued use of these accounts for corporate expenditure and corporate distributions.

13. During this time, Defendant Hope Heil continued to dupe the Plaintiff that she would be corning out to assist in the conversion of these accounts back into the name of the plaintiff and after providing full assurances that she had no intent of trying to access these accounts and that she was “working on her sobriety.”

14. Defendant Hope Heil failed to return to work, made repeated excuses for not finalizing the account. access, and yet on more than 8 occasions duped the Plaintiff into sending her money on cashapp so that she could get herself together, pay her motel, get an uber, and or pay her children’s expenses so that she could return sober to work and allow the Plaintiff access back to his business accounts that she had illegally converted.

15. In or about March 7, 2025, the Defendant asked the Plaintiff if she could return to work because she needed funds to pay for “her 4 children’s expenses although on this date Defendant Hope Heil returned to work drunk and high on drugs and it was clear that the Defendant Hope Heil had relapsed.

16. At this meeting on or about J\i[arch 7, 2025, the plaintiff encouraged the Defendant to get back into recovery and or to go back to her mother’s home rather than in the “drug house that Hope Heil was staying.” The Plaintiff gave Defendant monies and sent her in an Uber back to her mother’s house in Tomball, TX with the expectation that the Defendant would get cleaned up and that they could meet up shortly thereafter and go to the bank together.

17.Soon thereafter, on or about March 10, 2025, Plaintiff went to meet the Defendant Hope Heil at a seedy motel in Northwest Houston, the Platinum Inn, for the sole purpose of going to Bank of America to perform the banking transactions that were required to resume the Plaintiffs business activities
and allow him access to his own corporate funds, but at this meeting

18. Defendant remained in the motel while the Plaintiff waitied outside as per the defendant request and stalled in refusing to go into the bank to lawfully switch the corporate bank accounts back into the name of the plaintiff so that the defendant would no longer have any control over any of these accounts that the plaintiff  was operating out of.

19.Despite the plaintiff providing monies to the defendant to satisfy her extortionary requests, Plaintiff waited for the Defendant Hope Heil outside of the defendants motel room, and the defendant hope heil stalled and stalled after promising Plaintiff she would go into the bank with him, and despite
the Plaintiff providing Defendant monies via extortionary threats of the Defendant Hope heil, she stalled long enough until the bank of America branch was closed for the day.

20. On or about March 25-26, 2025, Defendant Hope Heil entered Plaintiff’s premises under false pretenses that she would go with the Plaintiff to the bank of America branch to convert the accounts back to Plaintiff or alternatively, however, was discovered using illegal narcotics on-site, and refused to leave until extorting $300.00 frorn Plaintiff via CASHAPP.

In the presence of a witness, Layla Howard, Defendant Hope Heil also attempted to steal Plaintiff’s personal property, including luxury clothing and shoes.

21.  On March 26, 202:5, shortly after being ejected, Defendant Hope Heil removed Plaintiffs access to the four corporate bank accounts at Bank of America in a manner that prevented the Plaintiff from having online access, or any access to his corporate bank accounts created for AEQUITAS TAX CONSULTING INC, a company owned and operated by Plaintiff

Andrew Lehman and has since retained foll control over them, unlawfully converting over $25,000.00 in fonds that were deposited into these accounts by clients of the plaintiff, some of the funds in which were deposited in trust for the tax preparation or monies owed by the IRS and these accounts that were wrongfully converted on this date to eliminate the plaintiff access to these corporate find were monies solely entrusted to the plaintiff, for the benefit of the plaintiff and belonging solely to Plaintiff and his company.

22. On information and belief, the Defendant Hope Heil went into the bank of America branch on her own without the knowledge and consent of the Plaintiff, and rather than convert the accounts back into his name materially misrepresented the status of the plaintiffs accounts to customer service representative of bank of America and had the plaintiff’s corporate accounts “locked up” and the plaintiff’s online access to the bank accounts was suspended or deleted such that the Plaintiff could no longer access the funds in these corporate accounts set up for his purposes preventing the Plaintiff from lawfully accessing his corporate funds and lawfully operating his business with these operating bank accounts containing approximately $25,000.00.

23.Thereafter Defendant Hope Heil blocked the Plaintiff from accessing the bank accounts and from even contacting her on her iphone.

Case nonsuited WITH PREJUDICE TO REFILING by Lehman on May 8, 2025.