STATE OF RIDGEWAY SUPERIOR COURT
Techiey
Plaintiff,
v.
RonaldMorelli
Defendant.
AMENDED CIVIL COMPLAINT
Docket No. RSC-CV-809
Plaintiff, Techiey, files this action against Defendant, seeking all available declaratory judgment
pursuant to Civil Claims Act § 1 as a result of their actions on 14 December, 2022 at The Hub in
Sterling, Ridgeway, causing the death of Plaintiff and the loss of their life and belongings.
PARTIES
1. Mr. Techiey, the Plaintiff, is a citizen and Attorney General of the State of Ridgeway.
2. Mr. RonaldMorelli, the Defendant, is a citizen of the State of Ridgeway.
JURISDICTION AND VENUE
1. Article V, Section IV of the Ridgeway State Constitution empowers this Court to hear
“all civil or criminal cases or controversies”.
2. Venue is proper in this Court because the incident took place within Ridgeway County.
ALLEGATIONS
On or about the date of 14 December, 2022;
1. Plaintiff was peacefully and civilly conducting his business as a citizen of the State of
Ridgeway.
2. Plaintiff entered The Hub in Ridgeway to sell his packaged sugar cane crop as the result
of a successful harvest, the only place in Ridgeway where packaged sugar cane crop is
able to be sold.
3. Plaintiff sold his crops at The Hub for $500, which was deposited in his wallet.
4. Defendant walked into the Hub with his friends immediately after Plaintiff sold his crops
and received his cash.
5. Plaintiff, understanding that many individuals are ambushed at The Hub because of its
exclusive nature as the only buyer of packaged sugar cane in Ridgeway, immediately
attempted to deposit the cash he earned from selling his crop in the Automated Teller
Machine (ATM) inside The Hub.
6. Plaintiff, with this knowledge, was carrying a Cline pistol and two, 20 round boxes, of
9mm ammunition to use with his Cline pistol in self-defense, if needed.
7. Defendant RonaldMorelli shoots and kills Plaintiff with his shotgun while Plaintiff is
depositing his cash in the ATM.
8. Plaintiff was able to successfully deposit his $500 cash in the ATM in the second before
being killed by Defendant RonaldMorelli.
9. Defendant RonaldMorelli, after killing Plaintiff, takes Plaintiff’s dropped 9mm
ammunition from his corpse.
10. Defendant then leaves The Hub after attempting to rob Plaintiff of his hard-earned money
and pilfering his corpse, abandoning Plaintiff’s dead body on the floor of The Hub.
11. Later that same day, Defendant invades the home of Plaintiff.
12. Defendant proceeds to kill Plaintiff with a Solami machine gun and destroy his sugar
cane farm, including 10 plots and 1 juicer.
13. All 10 plots had seeds planted and were actively growing to eventually be harvested.
14. Defendant caused Plaintiff to drop 1 watering jug, 10 packaged cane crops, 1 Cline pistol,
and 1 box of 20 rounds of 9mm ammunition when Plaintiff died.
15. Defendant took all of these items from Plaintiff’s corpse before destroying Plaintiff’s
juicer and 10 growing plots.
FIRST CAUSE OF ACTION
(Battery - 1 R. Stat. § 3102)
1. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
2. Battery is defined in the Civil Claims Act as “Any individual who brings unconsented
harmful or offensive contact against another person is battery and shall be liable for
punitive damages up to $2,500.”
3. Defendant RonaldMorelli brought unconsented, harmful, and offensive contact against
Plaintiff by shooting and killing Plaintiff with Defendant’s shotgun.
SECOND CAUSE OF ACTION
(Assault - 1 R. Stat. § 3103)
4. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
5. Assault is defined in the Civil Claims Act as “Any individual who intentionally and
voluntarily caused reasonable apprehension of an immediate harmful or offensive contact
is assault and shall be liable for punitive damages up to $1,500.”
6. Defendant RonaldMorelli caused reasonable apprehension of an immediate harmful or
offensive contact against Plaintiff by shooting and killing Plaintiff with Defendant’s
shotgun.
THIRD CAUSE OF ACTION
(Wrongful Death - 1 R. Stat. § 3109)
7. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
8. Wrongful Death is defined in the Civil Claims Act as “Any individual who causes the
death of another without legal cause or justification shall be wrongful death and liable for
compensatory damages and punitive damages up to $2,500.”
9. Defendant RonaldMorelli caused the death of Plaintiff without legal cause or justification
by shooting and killing Plaintiff with Defendant’s shotgun.
FOURTH CAUSE OF ACTION
(Trover - 1 R. Stat. § 3113)
10. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
11. Trover is defined in the Civil Claims Act as “Any individual who wrongfully takes
another's personal property without legal reason or justification is trover and shall be
liable up to compensatory damages and $2,000 in punitive damages.”
12. Defendant RonaldMorelli caused the death of Plaintiff without legal cause or justification
by shooting and killing Plaintiff with Defendant’s Solami.
FIFTH CAUSE OF ACTION
(Battery - 1 R. Stat. § 3102)
13. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
14. Battery is defined in the Civil Claims Act as “Any individual who brings unconsented
harmful or offensive contact against another person is battery and shall be liable for
punitive damages up to $2,500.”
15. Defendant RonaldMorelli brought unconsented, harmful, and offensive contact against
Plaintiff by shooting and killing Plaintiff with Defendant’s Solami.
SIXTH CAUSE OF ACTION
(Assault - 1 R. Stat. § 3103)
16. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
17. Assault is defined in the Civil Claims Act as “Any individual who intentionally and
voluntarily caused reasonable apprehension of an immediate harmful or offensive contact
is assault and shall be liable for punitive damages up to $1,500.”
18. Defendant RonaldMorelli caused reasonable apprehension of an immediate harmful or
offensive contact against Plaintiff by shooting and killing Plaintiff with Defendant’s
Solami.
SEVENTH CAUSE OF ACTION
(Wrongful Death - 1 R. Stat. § 3109)
19. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
20. Wrongful Death is defined in the Civil Claims Act as “Any individual who causes the
death of another without legal cause or justification shall be wrongful death and liable for
compensatory damages and punitive damages up to $2,500.”
21. Defendant RonaldMorelli caused the death of Plaintiff without legal cause or justification
by shooting and killing Plaintiff with Defendant’s Solami.
EIGHTH CAUSE OF ACTION
(Trover - 1 R. Stat. § 3113)
22. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
23. Trover is defined in the Civil Claims Act as “Any individual who wrongfully takes
another's personal property without legal reason or justification is trover and shall be
liable up to compensatory damages and $2,000 in punitive damages.”
24. Defendant RonaldMorelli caused the death of Plaintiff without legal cause or justification
by shooting and killing Plaintiff with Defendant’s Solami.
EIGHTH CAUSE OF ACTION
(Trespass - 1 R. Stat. § 3101)
25. Plaintiff realleges and incorporates by reference all of the allegations contained in all of
the preceding paragraphs.
26. Trespass is defined in the Civil Claims Act as “Any individual who unlawfully enters the
land of another individual without lawful excuse is trespassing and shall be liable for
punitive damages up to $1,000”.
27. Defendant RonaldMorelli unlawfully and without lawful excuse or permission entered
the home of Plaintiff.
PRAYERS FOR RELIEF
1. Plaintiff prays the Court find Defendant liable for the aforementioned torts.
2. Plaintiff seeks monetary relief amounting to $9,500 in both redress and punitive damages
and $5,500 in compensatory damages.
a. $2,500 for 1 R. Stat. § 3102 - Battery
b. $1,500 for 1 R. Stat. § 3103 - Assault
c. $2,500 for 1 R. Stat. § 3109 - Wrongful Death
d. $2,000 for 1 R. Stat. § 3113 - Trover
e. $1,000 for 1 R. Stat. § 3101 - Trespass
f. $506 for Plaintiff’s two lost Cline pistols
g. $105 for Plaintiff’s lost 3 boxes of 9mm ammunition
h. $213 for Plaintiff’s destroyed Cane Juicer
i. $980 for Plaintiff’s destroyed 10 fertilized dirt plots
j. $58 for Plaintiff’s lost watering can
k. $180 for Plaintiff’s lost cane seeds
l. $500 for Plaintiff’s lost packaged cane sugar
m. $125 for Plaintiff’s court filing fees
n. $2,833 for Plaintiff’s pain and suffering and related costs of replacing Plaintiff’s
possessions lost as a result of Defendant’s actions
3. Plaintiff also seeks any additional relief as deemed appropriate by the Court that is not
requested herein.
EVIDENCE
1. Exhibit A - Defendant killing Plaintiff at The Hub.
2. Exhibit B - Screenshot of Plaintiff’s corpse and Defendant stealing the dropped items in
Plaintiff’s home.
3. Exhibit C - Screenshot of notification that Defendant had destroyed Plaintiff’s cane
juicer.
Date: December 14th, 2022
Respectfully submitted,
TECHIEY
ATTORNEY GENERAL
DEPARTMENT OF JUSTICE
Government Annex, 2nd Floor
Palmer, RW 33328
RSB 17140
COUNSEL OF RECORD
