COUNTERCLAIM

North Point Computers
v. Tom Ronnkvist

Case 025925-Counter Suit  |  JP Precinct #1, Jim Wells County, Texas

$1,385.60 in unpaid labor

Jose L. Sandoval II DBA North Point Computers  |  March 2026

TOM PAID AT POINT OF SALE EVERY TIME - UNTIL HE DIDN'T

DateServiceReceiptAmountStatus
3/21/24ISA controller card#1129$216.00
4/24/24On-site visit #1#1238$112.50
5/15/24On-site visit #2 w/ MTI tech#1300$450.00
5/20/24Pentium II tower + integration#1311$678.00
9/12/24HDD replacement#1650$194.00
Jul '2410.5 hrs labor (8 unbilled)N/A$1,280.00UNPAID
TOTAL PAID$1,650.50
WHY THERE IS NO INVOICE:

NPC is a Cash on Delivery shop. Charges are presented at the point of sale - that is how Tom paid every single previous time. (Exhibits 30-34)

Kyle presented the labor charges. Tom said he forgot his wallet.
Tom kept coming in but dodged the charges each time.

Tom then went silent for 9 months. Jose had no direct contact and had already written off the account - until Tom resurfaced demanding a refund. (Exhibit 48)

THE HARDWARE EXISTS. TOM ACKNOWLEDGED IT.

  • eBay order confirmed May 21, 2024 - HP NetServer E50 Pentium II (Exhibit 25)
  • FedEx delivered 39-lb package to Alice, TX May 23, 2024 (Exhibit 26)
  • The assembled PC is still physically at our shop today, ready for pickup.
  • NPC also purchased $278.85 in USB-to-ISA adapters at our own expense (Exhibit 28)

EXHIBIT 35 - TOM'S OWN RESPONSE

Jose emailed Tom on June 17, 2024:

"We aren't ordering you a new tower, maybe there was a lapse in communication. Instead, Kyle had me purchase some specialty adapters..."


Tom replied: "Thank you, Let me know when you hear something. Thanks"

The project stalled because Tom never provided OS licensing, software media, or MTI licensing - our posted policy states hardware does NOT include software. (Exhibits 53-56)

STORE POLICY & TOM'S OWN EVIDENCE

Tom submitted "Scan 7" - Google AI results showing:
"You cannot buy a new computer with an original Pentium II today."
Only "pre-owned, refurbished, or new old stock" from eBay.
This is exactly what we ordered. Tom knew this was refurbished legacy hardware.
POSTED STORE POLICY - PHOTOGRAPHED (EXHIBITS 53-56)

Custom-ordered parts and hardware are NON-REFUNDABLE.

Hardware sales do NOT include software or licensing.

Charges are presented at point of sale - we do not invoice.


  • 90-day refund window - Tom waited 11 months to request a refund.
  • No warranty expressed for experimental/legacy work.
  • Policy is posted at the shop entrance - 4 photos submitted as evidence.
Tom paid COD five times. He knew the terms. He knew the hardware was refurbished. He said "Thanks" when told no new tower was coming.

RELIEF REQUESTED

1. Award NPC $1,385.60 for unpaid labor.

10.5 hours documented (8 unbilled). Kyle presented charges at point of sale. Tom said he forgot his wallet and kept dodging. (Exhibit 48)

2. Deny Tom's refund claim.

Custom-ordered, non-refundable per posted policy. 11 months past 90-day window. Tom acknowledged no new tower was coming. (Exhibit 35)

3. All parts ready for delivery at no cost

once the labor balance is settled.

Jose L. Sandoval II DBA North Point Computers  |  62 S King St, Alice, TX  |  Case 025925
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