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RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
PATOTHE1ST,
Plaintiff,
v.
ROBERTSEVIGNE,
Defendant.
CIVIL ACTION
COMPLAINT
Plaintiff patothe1st (“Plaintiff”), by and through the undersigned counsel, seeking
all available relief, in their complaint against Defendant RobertSevigne (“Defendant”),
alleges the following:
INTRODUCTION
1. On or about the 28th of July, 2025, Plaintiff had lawfully entered the Pizza
Shack restaurant in Palmer, to collect cash as part of their official duties as an employee
with RCU Corporate Security.
2. As Plaintiff entered inside, they observed the Defendant, armed with a
submachine, sitting on a stool .
3. Within 5 seconds, Defendant stood up and pulled out the submachine gun,
aiming it directly at Plaintiff, who was unarmed.
4. Plaintiff attempted to run away, back to the shelter of their armored truck as
they feared for their safety.
5. Defendant followed Plaintiff, shooting them repeatedly in the back and
causing their death.
6. After Plaintiff was shot and killed, Defendant put away their submachine
gun, and walked back inside the restaurant.
JURISDICTION
7. This court has original jurisdiction over “all civil and criminal cases or
controversies." Rid. Const. art. 5, § 4.
8. Venue is proper in this court because the actions and omissions alleged in
this complaint took place in the State of Ridgeway.
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PARTIES
9. patothe1st (“Plaintiff”) is an individual, resident, and citizen of the State of
Ridgeway. Plaintiff is an employee with RCU Corporate Security and a Delivery Driver
with StudsPerSecond. Plaintiff brings forth this suit as an individual.
10. RobertSevigne (“Defendant”) is an individual, resident, and citizen of the
State of Ridgeway. Defendant is an employee with RCU Corporate Security. Defendant is
sued in their individual capacity.
FIRST CAUSE OF ACTION
Wrongful Death - 1 R. Stat. § 3109
11. All prior paragraphs within this complaint are incorporated as if they were
fully set forth herein.
12. Under 1 R. Stat. § 3109, any individual who causes the death of another
without legal cause or justification is liable for wrongful death.1
13. Defendant, without legal cause or justification, intentionally discharged a
firearm at Plaintiff, causing Plaintiff’s death.
14. Defendant’s conduct directly caused the wrongful death of Plaintiff.
15. As a result of Defendant’s actions, Plaintiff suffered compensable damages
including, but not limited to, suffering and loss of life.
RELIEF
WHEREFORE, Plaintiff prays that the court enter judgment in their favor and
against Defendant as follows:
a. A finding that Defendant is liable for Wrongful Death under 1. R. Stat. §
3109;
b. An award of compensatory to be determined at trial;
c. An award of punitive damages not to exceed the statutory limit of $5,000;
d. Any further relief that the Court deems just and proper.
Dated: August 3rd, 2025
Respectfully submitted,
Detachment_Result
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Detachment_Result (State Bar No. 11103)
Counsel of Record
Nicklaus, Popplewell & Associates LLP
Lander Civic Center, Suite 324
Lander, Mayflower 19000
Tel: (212) 558-4000
Fax: (212) 558-3588
Email: [email protected]
Attorney for Plaintiff
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