HOLDEN WILLITS PLC Case No.: S1100CV202600818 Two North Central Avenue, Suite 2000 HON. THE HON ROBERT CARTER Of Phoenix, Arizona 85004
Telephone (602) 508-6210
Facsimile (602) 508-6211
Michael J. Holden (State Bar No. 006361) [email protected]
Attorneys for Plaintiff Hardrock Concrete Placement Co, Inc.
SUPERIOR COURT OF ARIZONA COUNTY OF PINAL
HARDROCK CONCRETE PLACEMENT CO., | Case No.
INC., an Arizona corporation, COMPLAINT
Plaintiff, Vvs.
CONSTRUCTABLE, INC., an Arizona corporation; MARANA AEROSPACE SOLUTIONS, INC., doing business as Ascent Aviation Services, an Oregon corporation; JOHN AND JANE DOE I-IV; ABC CORPORATIONS I-IV; and BLACK AND WHITE PARTNERSHIPS I-1V,
Defendants.
For its Complaint against the above-named defendants, plaintiff Hardrock Concrete Placement Co., Inc. (“Hardrock”) alleges as follows: GENERAL ALLEGATIONS 1. Hardrock is an Arizona corporation doing business in the state of Arizona. Hardrock holds, and at all times material hereto held, a valid license as a contractor pursuant to Arizona Revised Statutes, Title 32, Chapter 10. 2. Upon information and belief, defendant Constructable, Inc. (“Constructable™) is an Arizona corporation authorized to transact and doing business in the State of Arizona.
3. Upon information and belief, defendant Marana Aerospace Solutions, Inc. (“Marana”), doing business as Ascent Aviation Services, is an Oregon corporation doing business in the State of Arizona. Marana has a leasehold interest in certain real property (“the Subject Property™) that is the subject of this litigation. The legal description of the Subject Property is attached as Exhibit 1 and incorporated herein by reference./
4. On or about September 5, 2025, Hardrock recorded a mechanic’s and materialman’s lien against Marana’s leasehold interest in the Subject Property (“the Lien™). The Lien was recorded at document no. 2025-072092 in the official records of Pinal County, Arizona. A true and correct copy of the Lien as recorded is attached hereto as Exhibit 2 and incorporated herein by reference. Hardrock subsequently recorded partial releases of the Lien on October 7, 2025 and December 15, 2025. True and correct copies of the recorded Partial Releases of Lien are attached as Exhibit 3 and incorporated herein by reference.
5. Defendants John Doe and Jane Doe I-IV, ABC Corporations I-IV and Black and White Partnerships I-IV represent unknown parties who have an interest in or claim to the Subject Property. The true names of these defendants are presently unknown. Hardrock may request leave to amend its Complaint when the true names of these are ascertained.
6. Defendants have caused events to occur in Pinal County, Arizona, out of which the claim that is the subject of this Complaint arose. In addition, the lien sought to be foreclosed by this Complaint is upon land situated in Pinal County. Venue is therefore proper in Pinal County, Arizona.
7. Under Rule 26.2(c), Ariz. R. Civ. Proc., Tier 2 discovery is proper in this case because Hardrock’s claim is more than $50,000 but less than $300,000.
HARDROCK CONCRETE PLACEMENT CO VS. 10 CONSTRUCTABLE, INC., an Arizona corporation; MARANA AEROSPACE 11 SOLUTIONS, INC