Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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THE STATE OF RIDGEWAY RIDGEWAY SUPERIOR COURT Ronnie2347, Plaintiff. v. Proceed101, Defendant. Case No. RSC-CV-812 CIVIL COMPLAINT Presiding Judge: AlexJCabot Ronnie2347, proceeding with counsel, hereby brings this civil action and for their allegations against Defendant Proceed101, it is alleged as follows: STATEMENT OF FACTS On or around the day of December 18th, 2022: 1. Plaintiff was peacefully and civilly conducting his business as a citizen of the State of Ridgeway. 2. Plaintiff was operating a motor vehicle in Sterling Heights, directly outside of the Sterling Heights Gun Club. 3. Plaintiff’s motor vehicle was obstructed and cordoned by Defendant. 4. Defendant began to strike Plaintiff’s motor vehicle with a Fire Axe, causing significant property damage and bodily injury. 5. Plaintiff exited his vehicle in hopes of escaping the threat, but Defendant began to run after and pursue him. 6. Defendant began to strike Plaintiff with a Fire Axe, causing significant bodily harm to the Plaintiff and injuring him. 7. Plaintiff, on multiple occasions, attempted to regain entry into his vehicle, but was obstructed by Defendant who was chasing after him with a Fire Axe, attempting to cause severe bodily harm. 8. Defendant continuously and repeatedly bludgeoned Plaintiff with a Fire Axe. 9. Defendant pursued Plaintiff on foot, striking him several times, and upon Plaintiff falling to the ground, Defendant struck him several more times, killing him and causing his loss of life. 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 as the incident took place within Ridgeway County. PARTIES 1. Ronnie2347, the Plaintiff, is a citizen of the State of Ridgeway. 2. Proceed101, the Defendant, is a citizen of the State of Ridgeway. FIRST CAUSE OF ACTION (Wrongful Death - 1 R. Stat. § 3109) 1. Plaintiff realleges and incorporates by reference all of the allegations contained in all of the preceding paragraphs. 2. 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.” 3. Defendant Proceed101 caused the death of Plaintiff without legal cause or justification by stabbing, bludgeoning, and killing Plaintiff with Defendant’s Fire Axe. SECOND 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 Proceed101 brought unconsented, harmful, and offensive contact against Plaintiff by stabbing, bludgeoning, and killing Plaintiff with Defendant’s Fire Axe. THIRD CAUSE OF ACTION (Assault - 1 R. Stat. § 3103) 1. Plaintiff realleges and incorporates by reference all of the allegations contained in all of the preceding paragraphs. 2. 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.” 3. Defendant Proceeed101 caused reasonable apprehension of an immediate harmful or offensive contact against Plaintiff by stabbing, bludgeoning, and killing Plaintiff with Defendant’s Fire Axe. PRAYERS FOR RELIEF 1. Plaintiff prays the Court find Defendant liable for the aforementioned torts. 2. Plaintiff seeks monetary relief amounting to $6,550 in both redress and punitive damages. a. $2,500 for 1. R. Stat. § 3102 - Battery b. $2,500 for 1 R. Stat. § 3109 - Wrongful Death c. $1,500 for 1 R. Stat § 3103 - Assault d. $50 for Plaintiff’s related costs of replacing Plaintiff’s vehicle window that was destroyed. 3. Plaintiff also seeks any additional relief as deemed appropriate by the Court that is not requested herein. EVIDENCE 1. Exhibit A - Defendant wrongfully killing Plaintiff at or around the area of the Sterling Heights Gun Club. DATED: December 19th, 2022 Respectfully submitted, ELLOM8HOWAREYOU Senior Associate COHN, CICERO, & GOODRICH, LLC Suite 3B, Palmer Apartments Palmer, RW 33328 D: ello !#2023 E: [email protected] COUNSEL OF RECORD Ronnie2347 Plaintiff /s/ Ronnie2347

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