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Healthcare Found. of Wilson v. Dlp Healthcare, LLC

2026-06-23No. 25-CVS-33959

Authorities cited

Opinion

majority opinion

Healthcare Found. of Wilson v. DLP Healthcare, LLC, 2026 NCBC 57.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE

SUPERIOR COURT DIVISION

WAKE COUNTY 25CV033959-910

HEALTHCARE FOUNDATION OF

WILSON,

Plaintiff,

v. ORDER AND OPINION

ON MOTION TO DISMISS

DLP HEALTHCARE, LLC; DLP

PARTNER, LLC; and DLP

WILSON HOLDING COMPANY,

LLC (nominal),

Defendants.

1. Wilson Holding Company, LLC (“Wilson Holding”) owns and operates a

hospital and ancillary medical facilities in Wilson, North Carolina. The company has

just two members: Healthcare Foundation of Wilson (“Healthcare Foundation”) and

DLP Healthcare, LLC (“DLP Healthcare”). In 2024, Healthcare Foundation exercised

a contractual put option that allows it to sell its entire membership interest to DLP

Healthcare, which would make DLP Healthcare the sole owner of Wilson Holding.

But the purchase process is in limbo due to disagreements about how to value Wilson

Holding and Healthcare Foundation’s stake in it. In this lawsuit, Healthcare

Foundation asserts claims against DLP Healthcare and its parent company, DLP

Partner, LLC (“DLP Partner”), for breach of contract, breach of fiduciary duty, and

related wrongs.

2. DLP Healthcare and DLP Partner have moved to dismiss all claims under

Rule 12(b)(6) of the North Carolina Rules of Civil Procedure. For the following

reasons, the Court GRANTS in part and DENIES in part the motion.

Womble Bond Dickinson (US) LLP, by Philip J. Mohr, A.J. Horner, and

Wiley Bishop Hughes, for Plaintiff Healthcare Foundation of Wilson.

K&L Gates LLP, by Nathan Huff and Aaron Finkel, for Defendants DLP

Healthcare, LLC and DLP Partner, LLC.

No counsel appeared for Nominal Defendant DLP Wilson Holding

Company, LLC.

Conrad, Judge.

I.

BACKGROUND

3. The Court does not make findings of fact on a Rule 12(b)(6) motion to

dismiss. The following background takes as true the allegations in the amended

complaint.

4. The Wilson Medical Center has a long history in Wilson, North Carolina.

Founded in the 1960s, the hospital boasts nearly 300 beds and has served patients in

practice areas ranging from imaging to surgery to emergency care. (See V. Am.

Compl. ¶ 7, ECF No. 30.)

5. For most of its existence, the hospital was owned and operated by

Healthcare Foundation (a North Carolina nonprofit corporation). That changed in

2013. Looking for help with improving patient services, Healthcare Foundation

linked up with DLP Healthcare (a Delaware LLC) to form Wilson Holding (also a

Delaware LLC) to take over the hospital’s ownership and operations. (See V. Am.

Compl. ¶¶ 1, 2, 4, 8, 9.)

6. Healthcare Foundation is Wilson Holding’s minority member, with just a

twenty-percent stake. DLP Healthcare holds the other eighty percent. When it comes

to management, things are a bit more equal because Wilson Holding’s operating agreement vests authority in a ten-member governing board, half appointed by

Healthcare Foundation and half appointed by DLP Healthcare. The governing board

long ago delegated day-to-day managerial authority to DLP Partner, which is DLP

Healthcare’s parent company. Thus, as a practical matter, Healthcare Foundation

can influence governance through its board appointments, but it has no say in

day-to-day management and cannot unilaterally choose Wilson Holding’s strategic

direction. (See V. Am. Compl. ¶¶ 3, 4, 9–11, 25, 27; Op. Agrmt. § 9.1, ECF No. 29.1;

see also Mgmt. Agrmt., ECF No. 29.3.)

7. For added protection, Healthcare Foundation negotiated a separate put

agreement that allows it to require DLP Healthcare to buy its minority interest in

certain circumstances. The put agreement defines the purchase price as a percentage

of Wilson Holding’s appraised value, with the appraisal to be performed by a qualified

appraiser selected by the governing board. Closing must take place no “later than

sixty (60) days following the date” the final appraised value is issued, and “each party

shall execute and deliver all such further documents and instruments and take all

such further actions as may be necessary in order to consummate the” put

transactions. (Put Agrmt. §§ 2, 4, 5, 7, ECF No. 29.2; see also V. Am. Compl. ¶ 25;

Op. Agrmt. § 1.)

8. As time went by, Healthcare Foundation lost faith in DLP Partner’s

management of the hospital. Especially worrisome were budget cuts, staff shortages,

and a perceived decline in the quality of care. Although Healthcare Foundation

proposed reforms, its efforts were frustrated by a divided governing board. So, in August 2024, Healthcare Foundation exercised its put option and began the process

of selling its minority interest to DLP Healthcare. (See, e.g., V. Am. Compl. ¶¶ 29,

31, 34, 36.)

9. A few months later, Wilson Holding’s governing board retained an appraiser

called BDO to assess “the fair market value of a 100.0% interest” in Wilson Holding

“as of a date to be determined (the ‘Valuation Date’).” The appraisal agreement

contemplates a few months’ worth of work in two phases. The deliverables for phase

one include “financial schedules detailing preliminary valuation conclusions.” The

deliverable for phase two is “a full draft report.” The appraisal agreement has a

three-year term. (V. Am. Compl. ¶¶ 37, 38, 42; Ex. A, ECF No. 44.)

10. BDO started by requesting preliminary valuation information. In that

request, it asked the parties to “confirm the date of valuation (the ‘Valuation Date’)”

and noted “that all financial and market information will be leveraged as of the date

of valuation.” DLP Healthcare replied as follows: “Planning to use the period ending

12/31/2024 and provide [calendar year] 2024 financials once available later this

month.” As alleged, Healthcare Foundation agreed with the proposed valuation date

and “conveyed its acceptance in the follow-up calls and communications held with

BDO and DLP Healthcare representatives.” Through these communications,

Healthcare Foundation alleges, the parties formed a contract to use 31 December

2024 as the valuation date. Healthcare Foundation refers to this alleged contract as

the Valuation Date Agreement. (V. Am. Compl. ¶¶ 45, 47–50; see also Prelim.

Request Ex. B, ECF No. 45.)

11. Over the next six months, BDO gathered and assessed a great deal of

financial information. It also met with and swapped emails with party

representatives on a regular basis. Along the way, BDO produced two appraisal

drafts for the parties’ review, each time using 31 December 2024 as the valuation

date. Although Healthcare Foundation and DLP Healthcare offered expansive

feedback on both drafts, neither objected to the valuation date. (See V. Am. Compl.

¶¶ 51, 53, 55–57, 63–65, 69.)

12. When BDO produced its third draft in June 2025, the appraisal process

broke down. In this nearly final draft, BDO tentatively assessed Wilson Holding’s

value at a figure approaching $300 million. DLP Healthcare strenuously objected

and, for the first time in the appraisal process, stated that it opposed the use of 31

December 2024 as the valuation date. Healthcare Foundation, by contrast, urged

BDO to finish its work and issue its final report. Then, in July 2025, DLP Partner

stepped in as Wilson Holding’s manager and instructed BDO not to issue the final

appraisal. (See V. Am. Compl. ¶¶ 71, 72, 74, 76, 77, 85, 90, 91.)

13. Soon after, Healthcare Foundation brought this lawsuit. It alleges that BDO

would have issued a final appraisal by the end of July 2025 and closing on the put

option would have occurred by the end of September 2025 had DLP Partner not called

a halt to the process. Moreover, BDO’s appraisal allegedly would have entitled

Healthcare Foundation to receive roughly $55 million for its minority interest.

According to Healthcare Foundation, DLP Healthcare and DLP Partner were unwilling to pay that amount and therefore reneged on the Valuation Date

Agreement and halted the appraisal process. (See V. Am. Compl. ¶¶ 96, 100, 101.)

14. The amended complaint asserts a few direct claims and a few derivative

claims on behalf of Wilson Holding. Listed in the order pleaded, the claims include

the following: 1) a direct claim for breach of contract against DLP Healthcare; 2) a

direct claim for breach of fiduciary duty against DLP Partner; 3) a direct claim for

aiding and abetting breach of fiduciary duty against DLP Healthcare; 4) a derivative

claim for breach of fiduciary duty against DLP Partner; 5) a derivative claim for

tortious interference with contract against DLP Partner; and 6) a direct claim for

breach of the implied covenant of good faith and fair dealing against DLP Healthcare.

(See, e.g., V. Am. Compl. ¶¶ 107, 109, 113, 119, 128, 143, 148, 155, 159, 163.)

15. DLP Healthcare and DLP Partner have moved to dismiss all claims against

them. The motion is fully briefed, and the Court held a hearing on 14 May 2025. The

motion is ripe for decision.

II.

LEGAL STANDARD

16. A Rule 12(b)(6) motion to dismiss “tests the legal sufficiency of the

complaint.” Isenhour v. Hutto, 350 N.C. 601, 604 (1999) (citation and quotation marks

omitted). The motion should be granted only when “(1) the complaint on its face

reveals that no law supports the plaintiff’s claim; (2) the complaint on its face reveals

the absence of facts sufficient to make a good claim; or (3) the complaint discloses

some fact that necessarily defeats the plaintiff’s claim.” Corwin v. British Am.

Tobacco PLC, 371 N.C. 605, 615 (2018) (citation and quotation marks omitted).

17. In deciding the motion, the Court must treat all well-pleaded allegations as

true and view the facts and permissible inferences “in the light most favorable to” the

nonmoving party. Sykes v. Health Network Sols., Inc., 372 N.C. 326, 332 (2019)

(citation and quotation marks omitted). However, the Court need not accept as true

any “conclusions of law or unwarranted deductions of fact.” Wray v. City of

Greensboro, 370 N.C. 41, 46 (2017) (citation and quotation marks omitted). The Court

may also “consider documents which are the subject of a plaintiff’s complaint and to

which the complaint specifically refers,” without converting the motion to a motion

for summary judgment. Oberlin Cap., L.P. v. Slavin, 147 N.C. App. 52, 60 (2001).

III.

ANALYSIS

18. The Valuation Date Agreement is central to the amended complaint and the

arguments supporting and opposing the motion to dismiss. Every asserted claim is

premised at least in part on the allegation that Healthcare Foundation and DLP

Healthcare formed a contract to use 31 December 2024 as the valuation date for the

appraisal being performed by BDO. Although DLP Healthcare and DLP Partner seek

dismissal on several grounds, they lean heavily on the argument that no such

agreement exists and that, without it, no claim can survive. Thus, the Court begins

with the Valuation Date Agreement and Healthcare Foundation’s contract claims.

A. Contract Claims

19. Healthcare Foundation claims that DLP Healthcare breached the Valuation

Date Agreement by renouncing their chosen valuation date. In addition, it claims

that DLP Healthcare breached the put agreement and Wilson Holding’s operating agreement by encouraging or directing DLP Partner to instruct BDO not to issue the

final appraisal. The same actions are also alleged to be breaches of the implied

covenant of good faith and fair dealing in each contract.

20. Before turning to the parties’ arguments, let’s pause to clarify which State’s

law applies to these claims. Happily, the parties seem to be on the same page. They

agree that North Carolina law governs the Valuation Date Agreement, including

whether a contract was formed. And they agree that Delaware law governs the put

agreement and the operating agreement because each has a Delaware choice-of-law

clause. Having no reason to doubt the parties’ consensus on either point, the Court

will follow their lead. See, e.g., Tanglewood Land Co. v. Byrd, 299 N.C. 260, 262

(1980) (“[W]here parties to a contract have agreed that a given jurisdiction’s

substantive law shall govern the interpretation of the contract, such a contractual

provision will be given effect.”); Fast v. Gulley, 271 N.C. 208, 211 (1967) (noting the

usual rule that “[m]atters bearing upon the execution, interpretation and validity of

a contract are determined by the law of the place where it is made” (cleaned up)).

21. Under North Carolina law, the elements of a claim for breach of contract are

the existence of a valid contract and a breach of that contract’s terms. See Poor v.

Hill, 138 N.C. App. 19, 26 (2000). When these elements are alleged, “it is error to

dismiss a breach of contract claim under Rule 12(b)(6).” Woolard v. Davenport, 166

N.C. App. 129, 134 (2004).

22. Delaware law is similar. To state a claim, “the plaintiff must demonstrate:

first, the existence of the contract, whether express or implied; second, the breach of an obligation imposed by that contract; and third, the resultant damage to the

plaintiff.” VLIW Tech., LLC v. Hewlett-Packard Co., 840 A.2d 606, 612 (Del. 2003).

23. In moving to dismiss the contract claims, DLP Healthcare argues that the

Valuation Date Agreement is not a valid contract because it lacks mutual assent. 1

According to DLP Healthcare, it did not make a contractual offer when it stated that

it was “[p]lanning to use the period ending 12/31/2024” in response to BDO’s

preliminary request for information. Without an offer, DLP Healthcare contends,

there could be no acceptance by Healthcare Foundation and, thus, no contract. And

absent a Valuation Date Agreement, it continues, there could be no independent

breach of the put agreement, the operating agreement, or the implied covenant.

24. It is true that mutual assent is essential to the formation of a contract. But

“[w]hether mutual assent is established and whether a contract was intended

between parties are questions for the trier of fact.” Snyder v. Freeman, 300 N.C. 204,

217 (1980). At the pleading stage, the burden on Healthcare Foundation is light. It

does not have to prove its case. It need only allege sufficient facts to put the opposing

parties on notice of “the transactions, occurrences, or series of transactions or

occurrences” that give rise to the claim. N.C. R. Civ. P. 8(a).

25. The amended complaint clears that “relatively low bar.” Vanguard Pai

Lung, LLC v. Moody, 2019 NCBC LEXIS 39, at *11 (N.C. Super. Ct. June 19, 2019).

1 In its opening brief, DLP Healthcare also argues that no contract was formed due to a lack

of consideration. But a mutual agreement to use a particular valuation date in lieu of all other possible dates satisfies the requirement of consideration for contract formation. See, e.g., Davis v. Woods, 286 N.C. App. 547, 562 (2022) (defining consideration broadly to include any “benefit, right, or interest bestowed upon the promisor, or any forbearance, detriment, or loss undertaken by the promisee”).

Neither the put agreement nor the appraisal agreement establishes a valuation date

for the appraisal process. As alleged, though, choosing a valuation date was an

essential precondition for BDO’s work. The appraisal agreement makes this clear.

So does BDO’s preliminary request for information, which asked the parties to

“confirm” the valuation date and stated that “all financial and market information

will be leveraged as of the date of valuation.” (Prelim. Request 1.) It was in this

context that DLP Healthcare responded that 31 December 2024 would be the

valuation date. The parties allegedly then had “follow-up calls and communications”

in which Healthcare Foundation accepted DLP Healthcare’s proposed date, thus

forming the Valuation Date Agreement. (V. Am. Compl. ¶ 49.) What’s more, the

amended complaint alleges that Healthcare Foundation and DLP Healthcare

repeatedly used 31 December 2024 as the valuation date in communications with

each other and BDO for a period of roughly six months with no objections. (See, e.g.,

V. Am. Compl. ¶¶ 51, 56, 56, 60, 68.)

26. The Court cannot conclude from these allegations that Healthcare

Foundation “could prove no set of facts in support of its claim which would entitle it

to relief.” Spring v. Lawson, 2026 NCBC LEXIS 97, at *20–21 (N.C. Super. Ct. Apr.

27, 2026) (cleaned up). Taken as true and construed in the light most favorable to

Healthcare Foundation, the allegations show that the parties mutually assented to

use 31 December 2024 as the valuation date. Accordingly, the Court concludes that

Healthcare Foundation has sufficiently alleged the existence of a valid contract and

a breach of its terms. See Lannan v. Bd. of Gov. of Univ. of N.C., 285 N.C. App. 574, 599 (2022) (affirming denial of motion to dismiss and stating that “[a]lthough the

allegation of the meeting of the minds is sufficient at this stage, ultimately whether

there was a meeting of the minds is a question for the trier of fact”).

27. DLP Healthcare’s remaining arguments as to these claims are scattershot.

It contends, for example, that Healthcare Foundation failed to allege that the

conditions precedent to the exercise of the put option were satisfied. This argument

comes nowhere near the mark. As Healthcare Foundation correctly points out, it had

the right to exercise the put option upon the tenth anniversary of the put agreement

and timely did so. (See Put Agrmt. § 2.)

28. Next, DLP Healthcare argues that the put agreement does not govern the

appraisal process, so that renouncing the chosen valuation date and causing BDO to

withhold its final appraisal are not breaches of the put agreement. Again, the Court

cannot conclude that Healthcare Foundation could prove no set of facts that would

entitle it to relief. Taken as true, the allegations tend to show that DLP Healthcare

took steps to delay or avoid purchasing Healthcare Foundation’s interest, contrary to

the requirement to “take all such further actions as may be necessary in order to

consummate the” transaction. (Put Agrmt. § 7; see also, e.g., V. Am. Compl. ¶ 157.)

29. DLP Healthcare also argues that the amended complaint does not allege a

breach of the operating agreement. What is alleged, though, is that DLP Healthcare

used its influence as an affiliate of DLP Partner to meddle in Wilson Holding’s

management even though the operating agreement prohibits the members from

participating in management. (See, e.g., Am. Compl. ¶¶ 3, 51, 91, 96 (alleging that DLP Healthcare and DLP Partner were jointly represented by officials from their

common parent company).) Discovery may show that DLP Healthcare lacks that

influence or did not meddle. But the allegations, taken as true, are sufficient to state

a claim under a notice-pleading standard.

30. Last, DLP Healthcare argues that the claim for breach of the implied

covenant does nothing more than recapitulate the claim for breach of contract. “The

implied covenant, inherent in all agreements, ensures that the parties deal honestly

and fairly with each other when addressing gaps in their agreement.” Glaxo Grp.

Ltd. v. Drit LP, 248 A.3d 911, 919 (Del. 2021). Although a claim for breach of the

implied covenant is “rarely invoked successfully” under Delaware law, the courts of

that State have cautioned against dismissing even “doubtful” claims when factual

uncertainty exists at the pleading stage. Wnyh, LLC v. AccuMED Corp., 2018 Del.

Ch. LEXIS 173, at *19–20 (Del. Ch. May 31, 2018) (citation and quotation marks

omitted). Such is the case here. Given the uncertainty surrounding the Valuation

Date Agreement and the disputed facts related to the alleged breaches, it would be

“premature to address the possible relevance of the implied covenant” to Healthcare

Foundation’s claims. Id. at *20.

31. Accordingly, the Court denies the motion to dismiss the claims for breach of

contract and breach of the implied covenant of good faith and fair dealing.

B. Fiduciary Claims

32. The amended complaint includes direct and derivative claims against DLP

Partner for breach of fiduciary duty, as well as a direct claim against DLP Healthcare for aiding and abetting a breach of fiduciary duty. As Wilson Holding’s manager,

DLP Partner is alleged to owe fiduciary duties to Wilson Holding and its members.

DLP Partner supposedly breached these duties when it directed BDO not to issue the

final appraisal, thus promoting DLP Healthcare’s interests over Healthcare

Foundation’s. As alleged, DLP Healthcare encouraged DLP Partner to halt the

appraisal, thus aiding and abetting the breach.

33. Again, the parties seem to be on the same page as to which State’s law

applies to these claims. Because Wilson Holding is a Delaware company, Delaware

law governs its internal affairs, including the fiduciary obligations of its manager.

See Bluebird Corp. v. Aubin, 188 N.C. App. 671, 680 (2008) (discussing “internal

affairs doctrine”).

34. To state a claim for breach of fiduciary duty under Delaware law, a plaintiff

must allege “(1) that a fiduciary duty existed and (2) that the defendant breached

that duty.” Beard Rsch., Inc. v. Kates, 8 A.3d 573, 601 (Del. Ch. Apr. 23, 2010), aff’d

sub nom. ASDI, Inc. v. Beard Rsch., Inc., 11 A.3d 749 (Del. 2010). For an aiding and

abetting claim, the plaintiff must allege “(1) the existence of a fiduciary relationship,

(2) a breach of the fiduciary’s duty, (3) knowing participation in that breach by the

defendants, and (4) damages proximately caused by the breach.” In re Mindbody,

Inc., S’holder Litig., 332 A.3d 349, 389 (Del. 2024) (cleaned up).

35. DLP Partner does not dispute in this motion that it owes fiduciary duties to

Wilson Holding and its members. Rather, it argues that it did not favor DLP

Healthcare over Healthcare Foundation—and therefore did not breach its fiduciary duties—by directing BDO to withhold the final appraisal. Pausing the appraisal

process, it contends, was a neutral decision meant to give Wilson Holding’s members

time to work out their disagreement about the appropriate valuation date to use for

the appraisal.

36. This argument lacks force because it presumes that the Valuation Date

Agreement does not exist. The amended complaint adequately alleges not only that

such an agreement exists (as discussed above) but also that DLP Partner knew about

it and directed BDO not to issue the final appraisal once it became clear that

Healthcare Foundation’s membership interest was worth far more than DLP

Healthcare wanted to pay. (See V. Am. Compl. ¶¶ 97, 128.) As alleged, millions of

dollars ride on the choice of valuation date. (See V. Am. Compl. ¶¶ 101, 103.) The

amended complaint adequately alleges that DLP Healthcare stood to benefit from

DLP Partner’s interference at Healthcare Foundation’s expense and that DLP

Partner also stood to benefit indirectly as DLP Healthcare’s parent. (See V. Am.

Compl. ¶ 97.) These allegations adequately state a claim for breach of fiduciary duty

based on DLP Partner’s self-interested misuse of managerial authority.

37. DLP Partner maintains that the derivative claim for breach of fiduciary duty

must be dismissed. This is so, DLP Partner contends, because directing BDO not to

issue the appraisal does not implicate any duty owed to Wilson Holding, even if it

might implicate a duty owed to Healthcare Foundation. But DLP Partner cites no

law for that proposition. The duty of loyalty requires the manager to put the interest

of the company and members ahead of its own self-interest. See, e.g., Cede & Co. v. Technicolor, 634 A.2d 345, 361 (Del. 1993) (“Essentially, the duty of loyalty mandates

that the best interest of the corporation and its shareholders takes precedence over

any interests possessed by a director, officer or controlling shareholder and not

shared by the stockholders generally.”). The allegation that DLP Partner acted to

benefit itself is sufficient to state a claim for breach of the duty of loyalty.

38. Even if the claim for breach of fiduciary duty against DLP Partner survives,

DLP Healthcare argues that it cannot be liable for aiding and abetting because the

amended complaint does not allege knowing participation or damages. The Court

disagrees.

39. Although Delaware courts have observed that it is difficult to prove knowing

participation, they have also acknowledged that it is not quite as difficult to plead

that element. The complaint must allege “facts making it reasonably conceivable that

the defendant knowingly supported a breach of duty and that his resulting assistance

to the primary actor constituted substantial assistance in causing the breach.” In re

Oracle Corp. Derivative Litig., 2020 Del. Ch. LEXIS 218, at *33 (Del. Ch. June 22,

2020) (emphasis in original). Here, the amended complaint alleges that DLP

Healthcare used its influence as a close affiliate to instigate DLP Partner’s decision

to stop BDO from issuing the final appraisal. (See V. Am. Compl. ¶¶ 96, 98, 128.) A

reasonable inference that arises from the allegations is that DLP Partner would not

have interfered with BDO’s performance if DLP Healthcare had not urged it to do so.

(See V. Am. Compl. ¶ 96.) These allegations are not extensive, and Healthcare

Foundation may face challenges in proving its case. But “[a]t this preliminary stage of the litigation,” the Court “cannot rule out the possibility” that DLP Healthcare

knowingly participated in DLP Partner’s breach of its fiduciary duties. Stewart v.

Wilmington Tr. SP Servs., 112 A.3d 271, 321 (Del. Ch. Mar. 26, 2015). 2

40. As for damages, DLP Healthcare contends that Healthcare Foundation may

yet receive the purchase price that it seeks and therefore has not been injured. But

Healthcare Foundation alleges that BDO would have issued its final appraisal long

ago absent DLP Partner’s interference, that the closing would also have occurred, and

that the ongoing delay has kept Healthcare Foundation from receiving $55 million in

proceeds and enjoying the benefits of the put option that it bargained for. That is

more than enough to allege injury.

41. Accordingly, the Court denies the motion to dismiss the claims for breach of

fiduciary duty and aiding and abetting the breach.

C. Tortious Interference

42. The final claim is a derivative claim for tortious interference with contract.

This claim is also based on the allegation that DLP Partner improperly directed BDO

not to issue the final appraisal in July 2025, thus tortiously interfering with the

appraisal agreement between BDO and Wilson Holding.

43. Once more, the Court applies Delaware law, as urged by the parties. See

Bluebird, 188 N.C. App. at 680–81 (discussing “internal affairs doctrine”).

2 In connection with this issue, DLP Partner points out that DLP Healthcare is its subsidiary

and that a subsidiary, by definition, cannot direct its parent’s actions. Perhaps so. But the element of knowing participation requires substantial assistance, not puppeteer-like direction.

44. A claim for tortious interference with contract arises when a person induces

a third party to breach an existing contract with the plaintiff. Under Delaware law,

“[t]here must be (1) a contract, (2) about which defendant knew and (3) an intentional

act that is a significant factor in causing the breach of such contract (4) without

justification (5) which causes injury.” Aspen Advisors LLC v. United Artists Theatre

Co., 861 A.2d 1251, 1265–66 (Del. 2004) (citation and quotation marks omitted). In

other words, Healthcare Foundation must allege that DLP Partner induced BDO to

breach the appraisal agreement, causing harm to Wilson Holding.

45. The amended complaint states that DLP Partner caused “BDO to refrain

from issuing the” final appraisal and thereby “caused BDO to breach the Appraisal

Agreement.” (V. Am. Compl. ¶ 143.) At no point, though, does the amended

complaint allege facts sufficient to show that BDO’s delay is a breach of the appraisal

agreement, particularly given the express allegation that BDO withheld its final

appraisal at the request of an agent (DLP Partner) of the other contractual party

(Wilson Holding). (See, e.g., V. Am. Compl. ¶¶ 91, 100.) Moreover, although

Healthcare Foundation may have suffered harm from the delay, it is difficult to see

what harm Wilson Holding has suffered. The only allegation of harm is conclusory

and therefore insufficient to support the claim. (See V. Am. Compl. ¶ 145.)

46. Accordingly, the Court grants the motion to dismiss this claim. Because

Healthcare Foundation has already amended its complaint, the Court dismisses this

claim with prejudice. See First Fed. Bank v. Aldridge, 230 N.C. App. 187, 191 (2013) (“The decision to dismiss an action with or without prejudice is in the discretion of

the trial court . . . .”).

IV.

CONCLUSION

47. For all these reasons, the Court GRANTS the motion to dismiss the

derivative claim against DLP Partner for tortious interference with contract. This

claim is dismissed with prejudice. The Court DENIES the motion to dismiss in all

other respects.

SO ORDERED, this the 23rd day of June, 2026.

/s/ Adam M. Conrad

Adam M. Conrad

Special Superior Court Judge

for Complex Business Cases