Exhibits & Public Records

Primary-source documents in the Garcia v. Bayport Laboratories, LLC, et al. litigation. Court proceedings are public-record under Texas and federal law; SEC, FDA, and OSHA filings are public regulatory disclosures.

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Federal Court — Garcia v. Bayport Laboratories, LLC, et al.

Court: U.S. District Court for the Southern District of Texas, Houston Division Case No.: 4:25-cv-3676 Judge: Hon. Keith P. Ellison

Federal court hearing transcripts

  • PI Motion Hearing Transcript — December 8, 2025 — Hon. Keith P. Ellison — [link to Federal_Hearing_Transcript_2025-12-08.pdf after upload]

Key federal filings (Plaintiffs)

  • Plaintiffs' Original Complaint (filed August 5, 2025) — [link to PDF after upload]
  • Motion for Preliminary Injunction — [link]
  • Order Granting Preliminary Injunction (Hon. Ellison, December 9, 2025) — [link]
  • Plaintiffs' Motion to Disqualify Plaintiffs' Counsel (Gregory L. Deans) — [link]

Key federal filings (Defendants)

  • Defendants' Rule 7.1 Certificate of Interested Persons (Dkt. 13, filed September 17, 2025) — [link]
  • Defendants' Answer and Counterclaims (filed August 18, 2025) — [link]
  • Affidavit of Bryson Manalang (Bayport Director of Social Media, sworn September 11, 2025) — [link]
  • Affidavit of Gregory Deans (Plaintiffs' counsel, September 11, 2025) — [link]

Federal docket access

State Court — Bayport Laboratories, LLC v. Garcia

Court: Harris County District Court, 151st Judicial District Cause No.: 2025-41725 Status: Abated as of late 2025; Temporary Injunction dissolved January 20, 2026

Court hearing transcripts (Temporary Injunction proceedings)

The TI hearing spanned multiple days. All transcripts are public record.

  • TI Hearing Day 1 — January 30, 2026 — [link to State_TI_Hearing_Day_1_2026-01-30.pdf after upload]
  • TI Hearing Day 2–3 — [link to State_TI_Hearing_Day_2-3.pdf after upload]
  • TI Hearing Days 4–8 — [link to State_TI_Hearing_Day_4-8.pdf after upload]
  • Earlier hearing transcript — [link to State_TI_Hearing_Earlier_Transcript.pdf after upload]

Key state filings

  • Plaintiff's Original Petition (Bayport, filed July 3, 2025, 2:58 PM) — [link]
  • Ex Parte TRO (issued June 16, 2025) — [link to State_Ex_Parte_TRO_2025-06-16.pdf after upload]
  • Affidavit of Yaumara Camacho (sworn June 13, 2025; submitted in support of the ex parte TRO) — [link to Yaumara_Camacho_Affidavit_2025-06-13.pdf after upload]
  • Order Dissolving Temporary Injunction (Hon. Lynn Hughes, January 20, 2026) — [link]
  • Plaintiff's Exhibits — Rule of Procedure Binder 4 — [link to State_Plaintiffs_Exhibit_Binder_4.pdf after upload] (includes Manalang affidavit, social media screenshots, internal Bayport documents introduced at the TI hearing)

SEC EDGAR — KDC/One (Knowlton Development Corp Inc)

The parent company in the Bayport ownership chain. Knowlton Development Corp Inc (CIK 0001846055; formerly Knowlton Development Parent, Inc.) filed for an IPO in 2021 that was later withdrawn. The S-1 lists the principal shareholders — Cornell Capital affiliates, CDPQ affiliates, and others — that ultimately control Bayport Laboratories.

SIC code: 2844 — Perfumes, Cosmetics & Other Toilet Preparations Headquarters: 375 Boulevard Roland-Therrien, Suite 210, Longueuil, Québec J4H 4A6, Canada

OSHA — Whistleblower Complaint #301055161

Complainant: Milagros Garcia Respondent: Bayport Laboratories, LLC Statute: Section 11(c) of the Occupational Safety and Health Act Filed: June 6, 2025 Status: Open

Documents

  • OSHA Whistleblower Complaint #301055161 — [link to PDF after upload]
  • Bayport's OSHA Position Statement (June 19, 2025; invokes the state-court TRO; signed by Kevin S. Dunagan, The Dunagan Law Firm, P.C.) — [link to Bayport_OSHA_Position_Statement_2025-06-19.pdf after upload]
  • Bayport's Late Affidavits at OSHA (March 17, 2026 — nine months after Garcia's 20-day deadline) — [link]
  • Garcia v. Bayport — Procedural Violations Timeline (March 29, 2026 work product) — [link]

FDA — Inspection EIR 1773711606

The U.S. Food and Drug Administration inspected the Bayport Laboratories facility and independently documented violations — confirming the safety concerns Milagros Garcia had reported. Bayport had characterized those concerns as "false allegations" in its court filings.

  • FDA Establishment Inspection Report (EIR) 1773711606 — [link to PDF after upload]
  • FDA inspection database: search EIR 1773711606 at fda.gov

Texas Department of Insurance (TDI)

  • TDI Problem Report ID 444690 (Scottsdale Indemnity / Nationwide bad-faith complaint)
  • Scottsdale Indemnity Company response to TDI (February 5, 2026 letter)
  • TDI Closing Letter (March 9, 2026 — TDI concluded its review of complaint #444690) — [link to TDI_Closing_Letter_2026-03-09_Problem_444690.pdf after upload]

Texas Public Information Act (PIR) Requests

Public-records requests submitted under the Texas Public Information Act for documents related to Bayport Laboratories' Texas operations and registrations.

  • TX SOS filings — Bayport Laboratories LLC — [link]
  • HPD Incident Report #1338433-25 (October 12, 2025; harassment, escalated to Major Assault Division) — [link]
  • Other PIA requestor responses — [link]

Corporate Filings — Delaware & California Secretary of State

Public Secretary of State filings for the SOS Bty / SOS Beauty family of entities — KDC/One client brands referenced in the Bayport ownership chain. These records establish formation jurisdictions, registered agents, principal office addresses, and officer/manager identities.

Delaware Division of Corporations

  • Delaware Division of Corporations Filing — File No. 4418450 (entity formed December 11, 2020) — [link to Delaware_DOC_Filing_4418450.pdf after upload]

California Secretary of State — Statements of Information

  • SOS BTY PRODUCTS LLC — CA Statement of Information (Delaware LLC registered in California; principal office Beverly Hills, CA) — [link to SOS_Bty_Products_LLC_CA_SOI.pdf after upload]
  • SOS BTY PRODUCTS LLC — Filing Detail (CA SOS document #202035610809; formed December 16, 2020) — [link to SOS_Bty_Products_filing_info.pdf after upload]
  • SOS BEAUTY INC. — CA Statement of Information — [link to SOS_Beauty_Inc_CA_SOI.pdf after upload]
  • SOS BTY GROUP, LLC — CA Statement of Information (Delaware LLC registered in California) — [link to SOS_Bty_Group_LLC_CA_SOI.pdf after upload]

Texas — Related Court Records

  • Order Dissolving Temporary Injunction — Unofficial Copy (Marilyn Burgess, Harris County District Clerk; Bayport Laboratories, LLC v. Garcia, Cause No. 2025-41725) — [link to Dissolved_TI_unofficial_copy.pdf after upload]

Insurance & Stowers

  • Scottsdale Indemnity Company / Nationwide — Policy EKI3547741
    • Carrier: Scottsdale Indemnity Company (administered by Nationwide Professional & Specialty Claims)
    • Coverage: Business & Management Indemnity Policy, Employment Practices (EP)
    • Period: November 1, 2024 – November 1, 2025
    • Loss limit: $1,000,000 + $1,000,000 aggregate (costs)
  • Stowers Demand ($930,000, January 4, 2026) — [link]
  • Curative Stowers Demand (early March 2026) — [link]

Insurance coverage correspondence (Keith A. Little, Bailey Cavalieri LLC — coverage counsel for Scottsdale/Nationwide)

  • Letter to Garcia, December 2, 2025 (acknowledges global $2.5M settlement demand; first response) — [link to Little_Letter_2025-12-02.pdf after upload]
  • Letter to Garcia, December 23, 2025 (formal coverage denial under Policy EKI3547741) — [link to Little_Letter_2025-12-23_Coverage_Denial.pdf after upload]
  • Email to Garcia, December 29, 2025 (subject: "URGENT: Civil Conspiracy by Mr. Little and Insurance, Demand for Correction of Material Misrepresentations and Bad Faith Denial") — [link to Little_Letter_2025-12-29_Civil_Conspiracy_Email.pdf after upload]

How to use this page

If you are a journalist, researcher, advocacy organization, or court-records litigant: every document linked here is a public record or public regulatory disclosure. Cite the filing/inspection number (above) in any reporting. For copies that aren't yet uploaded, contact:

info@bayportlabslawsuits.com (subject: "EXHIBITS — [document name]")

For broader story context, see the Case Story, Timeline, and Press pages.

Source-Based Content. No Legal Advice. Copyright & Fair Use. No Harassment or Doxxing. Documents on this page are filed in public court dockets or with public regulatory agencies; their inclusion is for journalistic and research purposes. Last updated: May 2026. Media contact: info@bayportlabslawsuits.com.