Lawsuit Highlights

Allied Underground – a Bertram, Texas underground utility contractor – filed suit against High Point Site Services, LLC and three of its former senior officers: Carson Bowen (ex-VP), Michael Lusinger (ex-President of Operations), and Deborah Maynard (ex-Office Manager). The petition alleges that while still employed and compensated by Allied, the three individuals secretly formed High Point on January 17, 2025, used Allied’s trade secrets, customer lists, and proprietary bid data to launch the company, diverted Allied clients and projects to High Point, and destroyed electronic evidence upon resignation in April 2025. There are 9 causes of action

Allied alleges High Point Site Services and three other defendants took proprietary bid formulas, customer lists, vendor lists, and financial data — including a sensitive “Bedding and Haul Off” worksheet — and used them to launch High Point.

Trade Secret Misappropriation

Breach of Fiduciary Duty

Trade Secret Misappropriation

Breach of Fiduciary Duty

Allied alleges High Point Site Services and three other defendants took proprietary bid formulas, customer lists, vendor lists, and financial data — including a sensitive “Bedding and Haul Off” worksheet — and used them to launch High Point.

Competing While Still Employed

Breach of Fiduciary Duty

Allied alleges Bowen and Lusinger submitted bids for High Point Site Services, signed a lease for office space, and ordered equipment from Allied’s vendors — all while drawing Allied salaries and using Allied devices.

Allied alleges all three defendants, who formed High Point Site Services, factory-reset company devices, deleted emails and chats, and forwarded confidential files to personal accounts before resigning — allegedly to conceal their activities.

Data Destruction

Breach of Fiduciary Duty

Data Destruction

Breach of Fiduciary Duty

Allied alleges all three defendants, who formed High Point Site Services, factory-reset company devices, deleted emails and chats, and forwarded confidential files to personal accounts before resigning — allegedly to conceal their activities.

Customer Diversion

Breach of Fiduciary Duty

The petition alleges the High Point Site Services defendants solicited Allied clients during a company-funded hunting trip (over $10,000, reimbursed by Allied), and diverted at least two ongoing projects from Allied to High Point Site Services.

Allied alleges its business phone number ending in 3353 was ported off its company plan without authorization around November 2024, and is now being used by Lusinger to contact Allied’s clients on behalf of High Point Site Services.

Phone Number Theft

Breach of Fiduciary Duty

Phone Number Theft

Breach of Fiduciary Duty

Allied alleges its business phone number ending in 3353 was ported off its company plan without authorization around November 2024, and is now being used by Lusinger to contact Allied’s clients on behalf of High Point Site Services.

Fraudulent Invoicing

Breach of Fiduciary Duty

The petition alleges High Point Site Services defendants directed Allied employees to invoice clients for work not yet performed, artificially inflating reported profits to qualify for performance-based bonuses.

ALLIED UNDERGROUND LLC’S ORIGINAL PETITION

Plaintiff Allied Underground, LLC (“Allied”) files this Original Petition against Defendants High Point Site Services, LLC (“High Point”), Carson Bowen (“Bowen”), Michael Lusinger (“Lusinger”), and Deborah Maynard (“Maynard”) (collectively, “Defendants”). Allied shows the following in support of its Petition:

INTRODUCTION
This lawsuit concerns highly compensated company officers stealing trade secrets, violating federal and state laws, and breaching fiduciary duties to found and operate a company that unfairly competes directly against their former employer. While this alone is legally improper and morally reprehensible, the full story renders Defendants’ conduct even more disturbing. In committing the various illegal, unlawful, and tortious actions described herein, Defendants Bowen, Lusinger, and Maynard have sought to enrich themselves at the expense of their former employer, mentor, friend, and fellow local community member—Allied owner and President Leonard Meredith—and leverage their roles as trusted officers of Allied to destroy the company that Leonard painstakingly built over many years on their way out the door.

In early 2024, Leonard took his first steps into a long-earned retirement by stepping back from his hands-on approach to managing the day-to-day aspects of Allied as he had done for years prior. As a result, Bowen, Lusinger, and Maynard were each further promoted to more senior roles within Allied and entrusted with all material aspects of Allied’s operations. These senior roles came not only with further significant compensation raises, robust bonus structures, and stock options within Allied, but also with near-total access to confidential and closely held information touching on every aspect of Allied’s business, including confidential, proprietary, and trade secret information about Allied’s financials, bids, projects, customers, vendors, personnel, strategic direction, and other key aspects of Allied’s operations.

Notwithstanding their senior roles at Allied, Bowen, Lusinger, and Maynard began hatching a plan to exit Allied to found a directly competitive company, High Point, based on Allied’s stolen trade secrets and proprietary information and the years of experience, mentorship, and training that Leonard and Allied had invested in each of them—all while concealing High Point’s existence in violation of their various fiduciary duties owed as officers and employees of Allied. Since its formation on or around January 17, 2025, High Point is already servicing the very clients that Bowen, Lusinger, and Maynard serviced during their employment with Allied in the very same geographic area using the same vendors used by Allied and even the same crews formerly employed by Allied.

Moreover, because founding a direct competitor used Allied’s stolen trade secrets and proprietary information was not enough, Bowen, Lusinger, and Maynard actively worked during their final months, weeks, and days at Allied to divert as many customers, projects, vendors, and employees as possible away from Allied and to High Point. On company time and using company resources, Bowen, Lusinger, and Maynard submitted competing bids on behalf of High Point, contacted and solicited Allied customers to cease doing business with Allied and begin doing business with High Point, attempted to solicit fellow Allied employees to leave Allied and join High Point, and ordered equipment, set up leases and utilities, and performed other administrative and managerial tasks on behalf of High Point while actively employed with Allied and using Allied-issued electronic devices and other company resources. Then, to cover up their wrongdoing, Bowen, Lusinger, and Maynard deleted, altered, and destroyed data contained on their Allied-issued electronic devices and accounts in an attempt to delete the electronic evidence of their scheme.

As a direct result of Bowen, Lusinger, and Maynard’s violations of numerous statutory and common law duties that they owed and continue to owe Allied in order to enrich themselves and their competing enterprise High Point, Allied has suffered and will continue to suffer significant damages, including actual and compensatory damages, lost profits (which, upon information and belief, have been transferred to High Point), and the loss of existing business relationships, business opportunities, goodwill and business reputation, and confidential and trade secret information.

PLAINTIFF ALLIED UNDERGROUND LLC’S AMENDED PETITION
Plaintiff Allied Underground, LLC (“Allied”) files this Amended Petition against Defendants High Point Site Services, LLC (“High Point”), Carson Bowen (“Bowen”), Michael Lusinger (“Lusinger”), and Deborah Maynard (“Maynard”) (collectively, “Defendants”). Allied shows the following in support of its Amended Petition:

INTRODUCTION
This lawsuit concerns highly compensated company officers and key employees stealing trade secrets and other property of Allied, violating federal and state laws, and breaching fiduciary duties to found and operate a company that unfairly competes directly against their former employer. While this alone is legally improper and morally reprehensible, the full story renders Defendants’ conduct even more disturbing. In committing the various illegal, unlawful, and tortious actions described herein, Defendants Bowen, Lusinger, and Maynard have sought to enrich themselves at the expense of their former employer, mentor, friend, and fellow local community member— Allied owner and President Leonard Meredith—and leverage their roles as trusted officers of Allied to destroy the company that Leonard painstakingly built over many years on their way out the door.

In early 2024, Leonard took his first steps into a long-earned retirement by stepping back from his hands-on approach to managing the day-to-day aspects of Allied as he had done for years prior. As a result, Bowen, Lusinger, and Maynard were each further promoted to more senior roles within Allied and entrusted with all material aspects of Allied’s operations. These senior roles came not only with further significant compensation raises, robust bonus structures, and stock options within Allied, but also with near-total access to confidential and closely held information touching on every aspect of Allied’s business, including confidential, proprietary, and trade secret information about Allied’s financials, bids, projects, customers, vendors, personnel, strategic direction, and other key aspects of Allied’s operations.

Notwithstanding their senior roles at Allied, Bowen, Lusinger, and Maynard began hatching a plan to exit Allied to found a directly competitive company, High Point, based on Allied’s stolen trade secrets and proprietary information and the years of experience, mentorship, and training that Leonard and Allied had invested in each of them—all while concealing High Point’s existence in violation of their various fiduciary duties owed as officers and employees of Allied. Since its formation on or around January 17, 2025, High Point is already servicing the very clients that Bowen, Lusinger, and Maynard serviced during their employment with Allied in the very same geographic area using the same vendors used by Allied and even the same crews formerly employed by Allied.

Moreover, because founding a direct competitor used Allied’s stolen trade secrets and proprietary information was not enough, Bowen, Lusinger, and Maynard actively worked during their final months, weeks, and days at Allied to divert as many customers, projects, vendors, and employees as possible away from Allied and to High Point. On company time and using company resources, Bowen, Lusinger, and Maynard submitted competing bids on behalf of High Point, contacted and solicited Allied customers to cease doing business with Allied and begin doing business with High Point, attempted to solicit fellow Allied employees to leave Allied and join High Point, and ordered equipment, set up leases and utilities, and performed other administrative and managerial tasks on behalf of High Point while actively employed with Allied and using Allied-issued electronic devices and other company resources. Then, to cover up their wrongdoing, Bowen, Lusinger, and Maynard deleted, altered, and destroyed data contained on their Allied-issued electronic devices and accounts in an attempt to delete the electronic evidence of their scheme.

Bowen, Lusinger, and Maynard also fraudulently inflated Allied’s profits during the final months of their employment in order to secure discretionary bonuses only available if they hit certain profit-based metrics and to hide the fact that they were diverting work from Allied to High Point, including by bidding jobs with Allied intellectual property on High Point’s behalf. In addition to this fraud, the Individual Defendants misappropriated one of Allied’s long-time phone numbers for their exclusive personal use by logging into Allied’s company phone plan and “porting” the phone number to Lusinger’s personal phone plan without Allied’s authorization.

As a direct result of Bowen, Lusinger, and Maynard’s violations of numerous statutory and common law duties that they owed and continue to owe Allied in order to enrich themselves and their competing enterprise High Point, Allied has suffered and will continue to suffer significant damages, including actual and compensatory damages, lost profits (which, upon information and belief, have been transferred to High Point), and the loss of existing business relationships, business opportunities, goodwill and business reputation, and confidential and trade secret information.