Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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Josef13344, RSB No. 21109 LAW OFFICE OF JOSEF SULIVAN (An incorporated entity) Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Tel.: (430) 946-8594 Fax: (753) 632-2442 E-mail: [email protected] Attorney for Plaintiff COMPLAINT - 1 - Josef Sullivan Esq. Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Phone: (430) 946-8594 Fax: (753) 632-2442 IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY COUNTY OF RIDGEWAY TIGER_GAMERQ, an individual, Plaintiff, v. LANCEJADE09123, an individual, Defendant. : : : : : : : : : : : : : : : : Case No. RSC-CV-2493 Judge: Hon. EnforcementBeyond ⠀ COMPLAINT FOR MONETARY DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF CIVIL COMPLAINT _____0. __Plaintiff Tiger_gamerq (“Plaintiff”), by and through his undersigned attorney, brings this Civil Complaint (“Complaint”) against Defendant Lancejade09123 (“Defendant”) and in support thereof alleges upon personal information and belief as follows: JURISDICTION AND VENUE _____1. __The Ridgeway Constitution vests this Court with original jurisdiction over all civil and criminal cases or controversies including this Complaint. See Rid. Const. Art. IV, Sec. IV (“There shall be a Superior court which shall exercise original jurisdiction for all civil and criminal cases or controversies […]”) _____2. __Venue is proper in this Court for this Complaint and all its claims brought under the Civil Claims Act (1 R. Stat. § 3101, et seq.) COMPLAINT - 1 - Josef Sullivan Esq. Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Phone: (430) 946-8594 Fax: (753) 632-2442 PARTIES _____3. __Plaintiff Tiger_gamerq is a citizen of the State of Ridgeway and resident of Ridgeway County and an individual. _____4. __Defendant Lancejade09123 is an alien and an individual. STATEMENT OF FACTS _____5. __On or about March 18, 2024, Plaintiff Tiger_gamerq was legally operating his vehicle near Oakland, Ridgeway County. _____6. __As Plaintiff reached Intersection West in his vehicle near Oakland, Ridgeway County, Defendant Lancejade09123 illegally drove his vehicle toward Plaintiff on the wrong lane of the same road. Defendant’s vehicle thereafter collided with Plaintiff’s vehicle. _____7. __The collision was proximately caused by Defendant. _____8. __The collision caused an unconsented harmful or offensive contact against Plaintiff and his vehicle. _____9. __Following the collision, Defendant exited his vehicle and approached Plaintiff while he was still in his vehicle. _____10. __Defendant told Plaintiff “u just bro[k]e my car” and “u hit me” before returning to his vehicle and parking it on the side of the road. _____11. __Defendant exited his vehicle once more and approached Plaintiff. _____12. __Plaintiff told Defendant “YOU WERE DRIVING ON THE OPPOSI[T]E LANE.” _____13. __Defendant suddenly and without warning brandished a firearm and pointed it toward Plaintiff at point-blank range. _____14. __This act caused Plaintiff to reasonably apprehend an immediate harmful or offensive COMPLAINT - 2 - Josef Sullivan, Esq. Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Phone: (430) 946-8594 Fax: (753) 632-2442 contact to his person. Plaintiff quickly ran behind his own vehicle for cover. _____15. __Defendant thereafter said “lol ... i have no ammo chill” and “u hit me.” _____16. __Defendant continued to accuse Plaintiff of hitting him. _____17. __Defendant demanded that Plaintiff pay him $70 for damage to his vehicle’s “bumper” and said “no need for court u need to pay me and we all done.” _____18. __Plaintiff denied any wrongdoing and refused to pay Defendant the money. _____19. __Defendant brandished a firearm again and pointed it toward Plaintiff and said “pay atleast 10 bucks bro.” _____20. __This act caused Plaintiff to reasonably apprehend an immediate harmful or offensive contact to his person. _____21. __ErosBosi1234, a resident of Ridgeway County, was present at the scene. _____22. __ErosBosi1234 brandished a firearm and pointed it toward Defendant in an effort to prevent him from harming Plaintiff. _____23. __As a result of Defendant’s threatening conduct as alleged herein, Plaintiff suffered emotional distress and anxiety including, but not limited to, fear for his life and property and reasonable apprehensions of harm to his person. _____24. __At all times relevant herein, Defendant acted with callous or reckless disregard of Plaintiff’s safety. _____25. __At all times relevant herein, Defendant acted intentionally and voluntarily. COUNT I Battery Violation of 1 R. Stat. § 3102 _____26. __Plaintiff realleges the allegations contained in all prior paragraphs and includes them COMPLAINT - 3 - Josef Sullivan, Esq. Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Phone: (430) 946-8594 Fax: (753) 632-2442 in this count as though fully restated herein. _____27. __The tort of “battery” is defined as bringing "unconsented harmful or offensive contact against another person.” See 1 R. Stat. § 3102. A person who commits battery is liable for “punitive damages up to $2,500.” See ibid. _____28. __Defendant Lancejade09123 caused his vehicle to crash into Plaintiff’s vehicle and brought unconsented harmful or offensive contact against Plaintiff. _____29. __Defendant acted with callous or reckless disregard of Plaintiff’s safety. _____30. __As a proximate result of Defendant’s actions and omissions as alleged herein, Plaintiff suffered emotional distress and harmful or offensive contact to his person. COUNT II Assault Violation of 1 R. Stat. § 3103 _____31. __Plaintiff realleges the allegations contained in all prior paragraphs and includes them in this count as though fully restated herein. _____32. __The tort of “assault” is defined as “intentionally and voluntarily causing reasonable apprehension of an immediate harmful or offensive contact ” See 1 R. Stat. § 3103. A person who commits assault is liable for “punitive damages up to $1,500.” See ibid. _____33. __Defendant Lancejade09123 brandished and pointed a firearm toward Plaintiff and caused Plaintiff to reasonably apprehend an immediate harmful or offensive contact to his person. _____34. __Defendant acted intentionally and voluntarily. _____35. __As a proximate result of Defendant’s actions and omissions as alleged herein, Plaintiff suffered emotional distress and anxiety. COMPLAINT - 4 - Josef Sullivan, Esq. Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Phone: (430) 946-8594 Fax: (753) 632-2442 COUNT III Assault Violation of 1 R. Stat. § 3103 _____36. __Plaintiff realleges the allegations contained in all prior paragraphs and includes them in this count as though fully restated herein. _____37. __The tort of “assault” is defined as “intentionally and voluntarily causing reasonable apprehension of an immediate harmful or offensive contact ” See 1 R. Stat. § 3103. A person who commits assault is liable for “punitive damages up to $1,500.” See ibid. _____38. __After the events mentioned in Count II, Defendant Lancejade09123 once more brandished and pointed a firearm toward Plaintiff and caused Plaintiff to reasonably apprehend an immediate harmful or offensive contact to his person. _____39. __Defendant acted intentionally and voluntarily. _____40. __As a proximate result of Defendant’s actions and omissions as alleged herein, Plaintiff suffered emotional distress and anxiety. COUNT IV False Imprisonment Violation of 1 R. Stat. § 3104 _____41. __Plaintiff realleges the allegations contained in all prior paragraphs and includes them in this count as though fully restated herein. _____42. __The tort of “false imprisonment” is defined as an act “without legal authority or justification” that “restrains or restricts a person's movement within an area.” See 1 R. Stat. § 3104. A person who commits false imprisonment is liable for “punitive damages up to $3,500.” _____43. __Defendant illegally drove his vehicle on the wrong lane of the road and collided with Plaintiff’s vehicle. This caused Plaintiff’s vehicle to drastically stop. Defendant as a result COMPLAINT - 5 - Josef Sullivan, Esq. Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Phone: (430) 946-8594 Fax: (753) 632-2442 restricted or restrained Plaintiff’s movement without legal authority or justification. _____44. __As a proximate result of Defendant’s actions and omissions as alleged herein, Plaintiff suffered emotional distress and anxiety. PRAYER FOR RELIEF _____45. __WHEREFORE, Plaintiff prays as follows: _____46. __For punitive damages in the amount of $9,000 or in an amount to be determined according to proof; _____47. __For a declaratory judgment that Defendant’s conduct as alleged herein is wrongful under the Civil Claims Act; _____48. __For an order directing Defendant to apologize in open court for his conduct as alleged herein; _____49. __For awardment of attorney’s fees and costs in an amount to be computed and specified before the Court at a later date; _____50. __For such other and further relief as the Court deems just and proper. DATED: March 19, 2024 JOSEF SULLIVAN, ESQ. /s/Josef13344 - Josef13344 Ridgeway Bar No. 21109 Counsel of Record Palmer Apartments, Suite 5B Palmer, Ridgeway Tel.: (430) 946-8594 Fax: (753) 632-2442 E-mail: [email protected] Attorney for Plaintiff COMPLAINT - 6 - Josef Sullivan, Esq. Palmer Apartments, Suite 5B Palmer, Ridgeway 33369 Phone: (430) 946-8594 Fax: (753) 632-2442

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