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STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
AYOJERRYYY; R_OAM,
Plaintiffs,
v.
ECTOPIEX; TRUMPTHEBUIIDER; and
WILDERNVUSS,
Defendants.
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IN THE SUPERIOR COURT OF
RIDGEWAY COUNTY
Civil Action No.
SUMMONS
TO THE ABOVE NAME DEFENDANT:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action,
a copy of which is attached hereto and herewith served upon you, and to serve a copy of your
answer within five (5) days after the service of same, exclusive of the day of such service. If you
fail to answer the Complaint within the time aforesaid, the Plaintiffs in this action will apply to the
Court for the relief demanded in the Complaint and judgment will be taken against you be default.
Respectfully Submitted.
/s/ S. Stickza
Stickza, Esq.
Counsel of Record
Cohn, Cicero, & Goodrich LLC
Suite 1B, Palmer Suites
Palmer, RW 27841
(111) 222-3333
[email protected]
Attorney for Plaintiffs
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STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
AYOJERYYY; R_OAM,
Plaintiffs,
v.
ECTOPIEX; TRUMPTHEBUIIDER; and
WILDERNVUSS,
Defendants.
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IN THE SUPERIOR COURT OF
RIDGEWAY COUNTY
Civil Action No.
JURISIDCTION AND VENUE
1. This Court has jurisdiction pursuant to Article V, Section IV of the Constitution
of the State of Ridgeway.
2. Venue is proper in this Court because the incidents set forth below took place
within Ridgeway County, State of Ridgeway.
PARTIES
I. Plaintiffs
3. Plaintiff AyoJerryyy (“Jerry”) is a citizen of the state of Ridgeway.
4. Plaintiff R_oam is a citizen of the state of Ridgeway.
II. Defendants
5. Defendant Ectoplex (“Plex”) is a citizen of the state of Ridgeway.
6. Defendant TrumpTheBuiIder (“Trump”) is a citizen of the state of Ridgeway.
7. Defendant Wildernvuss (“Wilder”) is a citizen of the state of Ridgeway.
FACTUAL ALLEGATIONS
8. Plaintiffs are hard-working citizens—they farm goods and sell them to the public
and take on odd jobs to earn a quick buck.
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9. With their money, Plaintiffs purchase items they need to make a living, including
but not limited to farming equipment, sugarcane, transportation, and housing.
10. For the past week, Defendants have repeatedly harassed Plaintiffs, blowing up their
cars, breaking into their homes, and even killing them.
11. Plaintiffs have lost thousands of dollars’ worth of equipment and vehicles as a result
of Defendants’ reckless and intentional acts.
I. The Ecto Insurance Scam
12. Ecto Insurance is a registered sole proprietorship owned by RickyPedina. Ecto
Insurance offers various policies, including home and vehicle coverage.
13. Defendant Ectoplex is the named “CEO” of Ecto Insurance.
14. Defendants have advertised Ecto Insurance to Plaintiffs, ordering them to “get Ecto
Insurance” after they destroy items of value—or, in other words, extortion.
15. Throughout the past week, Ectoplex has shared numerous images of criminals
blowing up vehicles and ordering victims to “get ecto insurance.”
16. Ectoplex has also harassed members of the community, threatening them so that
they get car insurance through his company.
17. If an individual refuses to get the insurance, Ectoplex threatens them, noting that
“it’ll be a shame if some1 blew up ur cars.”
18. Defendants have done this several times as well. Defendant Wildernvuss, for
instance, killed Plaintiff r_oam and said, “I would’ve gotten insured by Ecto Insurance to have
prevented these kinds of problems!”
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19. Through a preponderance of evidence, Ecto Insurance—represented by
Defendants—is a corrupt and criminal organization facilitating the extortion plot against Plaintiffs
and several other members of the community.
II. Defendants’ Acts of Harm Against Plaintiffs
A. Plaintiff AyoJerryyy
20. On or about February 10, 2024, Defendant TrumpTheBuilder approached Plaintiff
AyoJerryy with a police-grade firearm in his hand.
21. Without a rhyme or reason, Defendant Trump discharged his illegal firearm, killing
Plaintiff. Furthermore, Defendant Trump blew up his car.
22. After killing Plaintiff AyoJerryyy, Defendant Trump said “Get ecto insurance.”
23. At the time Defendant Trump blew up his vehicle, Plaintiff had $1,000.00 worth of
sugarcane packs (including equipment), a licensed M1, and the car itself.
24. Defendant Ectoplex has admitted that this is a common practice of Ecto Insurance,
and he has threatened people by stating that he would “send [Blue] to destroy ur cars again.”
B. Plaintiff R_oam
25. On or about February 10, 2024, Defendants Ectoplex and Wildernvuss were
active within the county, promoting their extortion to plot to innocent people.
26. Defendants Ectoplex and Wildernvuss stationed themselves outside of Plaintiff
R_oam’s house, asking to come in.
27. When he refused to let them in the house, Defendants Ectoplex and Wildernvuss
went to the front of the building, pulled out their firearms, and destroyed Plaintiff R_oam’s car.
28. After they blew up his vehicle, Extoplex, by way of forced entry, broke into
Plaintiff R_oam’s home, refusing to leave.
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29. On that same day, Defendant Wildernvuss killed Plaintiff R_oam, repeating the
phrase set forth in Paragraph 18, pressuring him to get Ecto Insurance.
30. Defendants Ectoplex and Wildernvuss are transparent about their involvement in
the acts against Plaintiff R_oam and have refused to compensate him for his losses.
COUNT I
1 R. Stat. § 3102 – Battery
(Against Defendants Wildernvuss and TrumpTheBuilder)
31. Plaintiff incorporates the allegations within all prior paragraphs of this Complaint
as if they were fully set forth herein.
32. Under state law, “[a]ny individual who brings unconsented harmful or offensive
contact against another person is battery and shall be liable for punitive damages up to $2,500.” 1
R. Stat. § 3102.
33. On or about February 10, 2024, Defendant Wildernvuss shot Plaintiff R_oam, an
act that was brought against him without consent, with the purpose of extorting him to purchase
coverage through Ecto Insurance.
a. Defendant Wildernvuss is therefore liable for Battery and subject to the
damages set forth above for the same.
34. On or about February 10, 2024, Defendant TrumpTheBuilder got out of his vehicle
and shot Plaintiff AyoJerryyy, an act that was brought against him without his consent, with the
purpose of extorting him to purchase coverage through Ecto Insurance.
a. Defendant TrumpTheBuilder is therefore liable for Battery and subject to the
damages set forth above for the same.
WHEREFORE, Plaintiff prays for relief as hereinafter set forth.
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COUNT II
1 R. Stat. § 3113 – Trover
(Against Defendants Ectoplex and Wildernvuss)
35. Plaintiff incorporates the allegations within all prior paragraphs of this Complaint
as if they were fully set forth herein.
36. Under state law, “[a]ny 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.” 1 R. Stat. § 3113.
37. Defendants Ectoplex and Wildernvuss, without reason or justification, blew up
Plaintiff’s vehicle, resulting in a significant loss of property—farming equipment and
commodities—and the unlawful taking of his personal property.
a. Defendant Ectoplex and Wildernvuss are therefore liable for Trover and subject
to the damages set forth above for the same.
WHEREFORE, Plaintiff prays for relief as hereinafter set forth.
COUNT III
1 R. Stat. § 3109 – Wrongful Death
(Against Defendants TrumpTheBuilder and Wildernvuss)
38. Plaintiff incorporates the allegations within all prior paragraphs of this Complaint
as if they were fully set forth herein.
39. Under state law, “[a]ny 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.” 1 R. Stat. § 3109.
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40. On or about February 10, 2024, Defendant Wildernvuss shot and killed Plaintiff
R_oam. Defendant Wildernvuss had no legal cause or justification, including self-defense, to cause
the death of Plaintiff R_oam.
a. Defendant Wildernvuss is therefore liable for Wrongful Death and subject to
the damages set forth above for the same.
41. On or about February 10, 2024, Defendant TrumpTheBuilder shot and killed
Plaintiff AyoJerryyy in the street. Defendant TrumpTheBuilder had no legal cause or justification,
including self-defense, to cause the death of Plaintiff AyoJerryyy.
a. Defendant Wildernvuss is therefore liable for Wrongful Death and subject to
the damages set forth above for the same.
WHEREFORE, Plaintiff prays for relief as hereinafter set forth.
COUNT IV
1 R. Stat. § 3111– Civil Conspiracy
(Against All Defendants)
42. Plaintiff incorporates the allegations within all prior paragraphs of this Complaint
as if they were fully set forth herein.
43. Under state law, “[a]ny individual who conspires or colludes between one or more
parties to deprive a third party of a legal right or deceive a third party to obtain an illegal objective
shall be civil conspiracy and liable for compensatory damages for each offending party, injunctive
relief, and $3,000 in punitive damages for each offending party.” 1 R. Stat. § 3111.
44. Defendants, in conspiring with each other and on behalf of Ecto Insurance to
promote violence and extortion tactics to turn profit, in knowingly recognizing that such acts are
with an illegal objective, and in pursuing these acts with the intent to deprive Plaintiffs of their
legal rights, are liable for Civil Conspiracy and subject to the damages set forth above.
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PRAYERS FOR RELIEF
b. WHEREFORE, Plaintiffs demand:
a. That this Court enter judgment in favor of the Plaintiff and against Defendants
on Counts One to Four of this Complaint;
b. That this Court enter judgment against Defendants for compensatory damages
in an amount to be determined at trial;
c. That this Court enter judgment against Defendants for punitive damages in an
amount sufficient to punish and penalize Defendants and to deter Defendants
from repeating their unlawful conduct;
d. That this Court award the Plaintiff of attorneys’ fees and costs; and
e. That this Court grant such other and further relief deemed appropriate.
Respectfully Submitted.
/s/ S. Stickza
Stickza, Esq.
Counsel of Record
Cohn, Cicero, & Goodrich LLC
Suite 1B, Palmer Suites
Palmer, RW 27841
(111) 222-3333
[email protected]
Attorney for Plaintiffs
Document record
File size
144.2 KB
Uploaded
Feb 12, 2024 12:00 PM
Filed
Feb 12, 2024 12:00 PM
Filing code
COMPLAINT
Uploaded by
ayojerryyy
Notes
Complaint-Ecto.pdf — archived from the Trello docket (https://trello.com/c/YFGFFXXe)