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RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
NICKLAUS_S,
Plaintiff,
v.
VXFPRRR,
Defendant.
Action No.
COMPLAINT
Plaintiff Nicklaus_s (“Plaintiff”), by and through the undersigned counsel, seeking
all available relief, in his complaint against Defendant vxfprrr (“Defendant”), alleges as
follows:
JURISDICTION
1. The Ridgeway Superior Court has original jurisdiction over “all civil and
criminal cases or controversies.” RID. CONST. art. 5, § 4.
2. Venue is proper as the acts and omissions which give rise to this complaint
occurred in the State of Ridgeway.
PARTIES
3. Plaintiff is an individual, resident, and citizen of the State of Ridgeway.
4. Defendant is an individual, resident, and citizen of the State of Ridgeway.
FACTS
5. On or about February 23, 2026, Plaintiff was at the Sterling Heights Gun
Club in Sterling Heights, Ridgeway.
6. Plaintiff sought to purchase an automatic firearm.
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7. Plaintiff parked his vehicle in the parking lot of the Sterling Heights Gun
Club, exited his vehicle, and began walking towards the door of the Sterling Heights Gun
Club.
8. While Plaintiff was walking towards the door, Defendant drove into the
parking lot in a black automobile.
9. Plaintiff was shot in the back several times after opening the primary door
of the Sterling Heights Gun Club.
10. Plaintiff ran inside the Sterling Heights Gun Club and hid behind a
merchandise shelf.
11. Plaintiff attempted to look outside to find his attacker.
12. Plaintiff then ran to and entered a small interior room inside the Sterling
Heights Gun Club.
13. Defendant ran into the room with his firearm drawn, pointing it at Plaintiff.
14. Plaintiff then ran out of the room, with Defendant following him with his
firearm still drawn and pointing at Plaintiff.
15. Seeking to hide from Defendant, Plaintiff entered back into the room.
16. Shortly after, Defendant also entered back into the room with his gun slung
around his torso.
17. Plaintiff sought to purchase a gun to protect himself from Defendant, but
did not have enough money in his wallet.
18. Plaintiff ran out of the room and exited the Sterling Heights Gun Club,
seeking to use the automated teller machine.
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19. Defendant followed Plaintiff outside, drew his firearm, and shot Plaintiff
several times.
20. As a result of being shot by Defendant, Plaintiff died.
21. At all times during the encounter, Plaintiff was unarmed and defenseless.
22. At all times during the encounter, Plaintiff was not a threat.
FIRST CAUSE OF ACTION
(Assault – 1 R. Stat. § 3103)
23. All prior paragraphs within this complaint are incorporated as if they were
fully set forth herein.
24. Defendant intentionally and voluntarily approached Plaintiff with his gun
drawn.
25. Defendant intentionally and voluntarily shot Plaintiff.
26. Defendant caused Plaintiff to be in reasonable fear of an immediate harmful
or offensive contact with his body, particularly by Defendant shooting him.
27. The fear was reasonable because Defendant attempted to make contact with
Plaintiff in a harmful and offensive manner by pointing a firearm at Plaintiff and because
Defendant did make contact with Plaintiff in a harmful and offensive manner by shooting
him.
SECOND CAUSE OF ACTION
(Battery – 1 R. Stat. § 3102)
28. All prior paragraphs within this complaint are incorporated as if they were
fully set forth herein.
29. Defendant shot Plaintiff with a firearm.
30. Plaintiff did not consent to being shot.
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31. The contact was harmful and offensive to the Plaintiff because it directly
caused him injury, caused him to lose health, and caused him to die.
THIRD CAUSE OF ACTION
(Wrongful Death – 1 R. Stat. § 3109)
32. All prior paragraphs within this complaint are incorporated as if they were
fully set forth herein.
33. Defendant caused the death of Plaintiff by shooting him.
34. The death was wrongful because Defendant acted without legal
justification.
FOURTH CAUSE OF ACTION
(Negligence – 1 R. Stat. § 3105)
35. All prior paragraphs within this complaint are incorporated as if they were
fully set forth herein.
36. Defendant owed Plaintiff a duty of reasonable care under statutory and
common law.
37. Defendant breached that duty of care during his interaction with Plaintiff.
Defendant was negligent in one or more of the following respects:
a. In failing to act as a reasonably prudent person;
b. In failing to seek help or assistance from a licensed professional;
c. In failing to refrain from threatening Plaintiff;
d. In failing to refrain from shooting Plaintiff;
e. In failing to refrain from killing Plaintiff.
38. As a direct and proximate result of his negligence, Plaintiff sustained
injuries and harm, all of which were reasonably foreseeable:
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a. Loss of health and death;
b. Inconvenience and interference with usual and everyday activities.
39. As a direct result of the outrageous conduct complained of herein, Plaintiff
suffered inconvenience and interference with his ordinary and everyday activities. For
example, Plaintiff was unable to purchase a firearm as intended and was required to make
unnecessary and repeated trips to Sterling Heights Gun Club.
40. Defendant acted willfully, wantonly, and with actual malice or, at
minimum, a conscious and reckless disregard for human life when he unjustifiably shot
and killed an unarmed and defenseless civilian who posed no threat to anyone.
RELIEF
WHEREFORE, Plaintiff prays that the court enter judgment in his favor and
against Defendant as follows:
a. Awarding compensatory damages to Plaintiff in an amount to be
determined at trial;
b. Awarding punitive damages to Plaintiff not to exceed the statutory limit;
c. Awarding pre- and post-judgment interest;
d. Awarding the costs of this action, including attorney fees, to Plaintiff;
e. Such further relief as the court deems just and proper.
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Dated: February 23, 2026
Palmer, Ridgeway Respectfully submitted,
/s/ Nicklaus_s
Nicklaus_s (Bar No. 10241)
Counsel of Record
Nicklaus & Associates LLP
250 Farley Street
Palmer, Ridgeway 90025
(123) 456-7890
[email protected]
Attorney for Plaintiff
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