Transmontaigne Operating Company L.P. v. Iwc Oil & Refinery, Llc

TransMontaigne brings this Complaint against IWC for breach of a January 12,

2022, Terminaling Services Agreement between the parties (the “TSA”), under which

TransMontaigne agreed to receive, handle, store, blend, and distribute a minimum volume of

IWC’s Fungible, Mexican great Ultra-Low Sulfur Diesel (“Product”) for an agreed-upon amount

plus fees and costs.1

As set forth in detail below, despite TransMontaigne’s continued performance

under the TSA, IWC failed to terminal the contractual minimum volume of Product and failed to

make necessary payments for the same after just four months.

As a result of IWC’s breaches of the TSA, TransMontaigne has suffered

irreparable harm and has sustained, and will continue to sustain, damages as a result of IWC’s

willful and intentional breaches.

1

Terminaling means the services performed by a facility providing storage and redelivery of petroleum products,

crude oil, chemicals, fertilizers, or other liquid products.