THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
CANKRAL770;
NLX095
Plaintiff(s)
v.
EctopIex, a Representative;
BANK OF ECTO, a Sole Proprietorship;
ACZERO_VERXA, a Supervisor;
RICKYPEDINA, a Business Owner;
DAUDSR, an Alternate Account of EctopIex
Defendant(s)
Case No. N/A
CIVIL COMPLAINT
Presiding Judge: N/A
Plaintiffs, by and through their undersigned counsel, hereby brings this civil action and
for their allegations against the Defendants, it is alleged as follows:
PARTIES
1. Plaintiff Cankral770 is a citizen of the United States of America, who resides in the State
of Ridgeway, Ridgeway County.
2. Plaintiff Nlx095 is a citizen of the United States of America, who resides in the State of
Ridgeway, Ridgeway County.
3. Defendant Bank of Ecto is a registered business in the State of Ridgeway, classified
under the Ridgeway Department of State as a Sole Proprietorship. Defendant operates as
a bank.
4. Defendant EctopIex is a representative of defendant Bank of Ecto, and is a citizen of the
United States of America, who resides in the State of Ridgeway, Ridgeway County.
5. Defendant Aczero_Verxa is a representative of defendant Bank of Ecto, and the Chief
Executive Officer of such, and is a citizen of the United States of America, who resides in
the State of Ridgeway, Ridgeway County.
6. Defendant RickyPedina is the owner of defendant Bank of Ecto, and is a citizen of the
United States of America, who resides in the State of Ridgeway, Ridgeway County.
7. Defendant DaudSr is an alternate account of EctopIex, and is a citizen of the United
States of America, who resides in the State of Ridgeway, Ridgeway County.
JURISDICTION AND VENUE
8. Venue is proper in this Court because the alleged actions took place in-game in the City
of Palmer, State of Ridgeway, which is subject to the laws of Ridgeway County.
9. The Plaintiff has the right to pursue justice and remedy under Article I, Section I of the
constitution.
10. This Court has original jurisdiction for all civil cases and controversies under Article V
Section IV of the constitution.
11. This Court has the power to issue all writs and remedies under Article V, Section III of
the constitution.
FACTS
FROM PLAINTIFF CANKRAL770
12. On the 29th of April, 2024, Plaintiff cankral770 joined the Defendant Bank of Ecto’s
discord server, after seeing an ad posted by Defendant EctopIex.
13. After joining, Plaintiff cankral770 opened a ticket within the discord server, and stated
that he joined to sell a house to the company, previously named Ecto Insurance, listing
the house as Cyrus 3560 Ranger Rd, and asking how much the Defendant would pay to
purchase the house from the Plaintiff.
14. Plaintiff stated that he wanted $70,000 for the house, where Defendant EctopIex stated
“We can do that”, agreeing to purchase the house for $70,000. This is a verbal legally
binding contract, where both parties have an offer, consideration, and verbal acceptance.
15. Due to neither party taking a step forward in the contract yet, Defendant EctopIex
proposed a change to the contract, changing the purchasing price from $70,000 to
$75,000, which was also agreed upon by Plaintiff cankral770.
16. Both parties got in game, after Plaintiff was told to follow Defendant in game.
17. Defendant EctopIex, representing the Bank of Ecto in this transaction, stated “let’s get
ownership done”, wanting to transfer the ownership of Plaintiff’s house to the Defendant
prior to money being paid out, with the agreement of the money being provided after the
house has been switched over.
18. Plaintiff cankral770 vacated their property, allowing Defendant EctopIex to then purchase
the property for $4,250, the in-game price mandatory to obtain the property.
19. After the property had been switched, Defendant EctopIex stated “alr let me get my alt”,
before changing up and saying “wait bflare will take u TO ATM.”, referring to Bflare, an
individual seemingly connected with the business.
20. After this, defendant EctopIex left the game, where plaintiff cankral770 hopped into a car
driven by Bflare at slow speeds around the map for around 60 seconds.
21. While doing so, plaintiff cankral770 noticed defendant EctopIex deleting and removing
messages from his DMs with the plaintiff.
22. Plaintiff, upon noticing what was happening, called Bflare a cheater in game, to which he
responded with "What?", and immediately left the game, leaving Plaintiff alone in the
middle of the road.
23. Defendant Bank of Ecto, according to representative and defendant EctopIex, refused to
pay out the $75,000 duly owed to the plaintiff.
24. Plaintiff was then banned from the discord server connected to defendant Bank of Ecto.
25. Defendants EctopIex and Aczero_Vexra were contacted on the 5th of May with a cease
and desist order, as will be provided, requesting them to reimburse the plaintiff or face
lawsuit.
26. Defendant EctopIex stated that the farm house, previously owned by plaintiff cankral770,
had already been sold for $200,000, and refused to cooperate in reobtaining the house.
27. Despite plaintiff cankral770 already transferring ownership of the house to defendant
EctopIex, Plaintiff never received the $75,000 promised by the defendant.
FROM PLAINTIFF NLX095
28. On May 5th, 2024, plaintiff Nlx095 approached Defendant EctopIex in his direct
messages, asking for where the farmhouse is located and asking how much it would cost.
29. Plaintiff would also ask if it has a car spawner, and for a picture of it, to which the
answers of these DMs were obviously deleted, highlighted by the surrounding DMs.
30. Plaintiff and defendant EctopIex, with EctopIex acting as an employee of the Bank of
Ecto, agreed to sell Nlx095 the house, and they agreed to meet in the smallest server, with
the defendant stating "coming."
31. Defendant EctopIex sent a screenshot of the house, with them standing in front of it, and
told the plaintiff to send EctopIex around $35,000, and that they would be joining on
their alt, and to send DaudSr $45,000.
32. Once done, defendant EctopIex said "Go to the farmhouse fast", to which the plaintiff
noticed that it was already owned by EctopIex, with an unidentified man at the house.
33. Upon making this observation, defendant EctopIex quickly deleted all of his messages
from the Plaintiff’s direct discord messages, and blocked the plaintiff, highlighted by the
message not going through when the plaintiff asked the defendant why messages were
being deleted.
34. Plaintiff was then banned from the Bank of Ecto discord server.
35. Plaintiff, after reaching out to defendant EctopIex in the main Ridgeway discord server,
asked the Defendant why he deleted all of his messages and banned him from the server,
with the Defendant claiming that he was never in the server, despite concrete proof of
him being in it.
36. Plaintiff Nlx095 was unaware, at the time, that the Farmhouse that he intended the
purchase was not lawfully obtained by the defense, and made all reasonable precautions
to assert this.
BOTH PLAINTIFFS
37. After both plaintiffs were scammed by defendant EctopIex, who acted in the name of the
business and defendant Bank of Ecto, through posting advertisements on the main
Ridgeway discord and operating primarily through the business discord, the Chief
Executive Officer, Aczero_Vexra, the highest ranking individual made publicly available
to the business, was contacted.
38. Defendant Rickypedina was also sent a cease and desist order, albeit later, and failed to
act upon it, not commenting at all.
39. Despite being sent a cease and desist order, outlining the employee’s violations and bad
practices, Defendant replied with “shush” and failed to react or continue further.
40. Both deals made by both Plaintiffs were done through defendant Bank of Ecto, and while
plaintiff Nlx095 primarily communicated through direct messages with an employee
acting in their capacity, it was still through the business.
41. Defendants Rickypedina and Aczero_Vexra are both in supervisory positions within the
defendant Bank of Ecto.
42. Both defendants have the power to oversee and manage employees, as well as to create
regulation for good business practices.
43. Both defendants were made well aware of the accusations and facts surrounding the
matter, yet failed to act and vehemently denied all allegations, conducting themselves
inconsistently with normal business operators.
44. Both defendants are liable for the actions of defendant EctopIex, who acted in the
company’s name, with their oversight and management, under respondeat superior
doctrine.
45. Defendant Bank of Ecto is also liable for all actions of defendant EctopIex, as they are
the body used to carry out these actions, and also provided an umbrella and reputation
necessary to garner clients.
46. Defendant DaudSr acted as an accomplice with defendant EctopIex in scamming Plaintiff
Nlx095 out of his money.
47. Defendant EctopIex verbally stated that DaudSr was his alternate account, and combined
with the account’s appearance, quick reaction time to join game, and the storing of money
on the account, establishes this account as an alternate account, and a clear accomplice.
FIRST CAUSE OF ACTION
Breach of Contract (1 R. Stat. § 3107)
As to defendant EctopIex
48. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
49. Breach of contract is defined by 1 R. Stat. § 3107 as “Any individual who breaches a
contract they have signed with another party shall be a breach of contract.”
50. While the statute requires a contract “they have signed”, common law has held, through
centuries, that verbal agreements, especially textual contracts over discord, are valid
contracts, even though no traditional pen-and-paper contract with cursive signatures
affixed below.
51. This is supported in Ogden v. Saunders 25 U.S. 213 (1827) (“A great mass of human
transactions depends upon implied contracts; upon contracts which are not written, but
which grow out of the acts of the parties.”)
52. Defendant made a contract with plaintiff Cankral770 to pay him a sum of $75,000, once
he transfers ownership of his farmhouse.
53. Both the Defendant and the Plaintiff agreed to carry this out in text, forming an active
contract.
54. Plaintiff completed their end of the deal by transferring ownership of the farmhouse over
to the Defendant, via vacating the property with the Defendant right next to it, claiming it
immediately, a common form of realty in the State of Ridgeway.
55. Defendant failed to uphold their end of the deal, never transferring Plaintiff their $75,000
as promised. This constituted a breach of their contract.
SECOND CAUSE OF ACTION
Fraud (1 R. Stat. § 3108)
As to defendant EctopIex
56. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
57. Fraud is defined by 1 R. Stat. § 3108 as “Any individual who intentionally deceives
another party to secure unfair or unlawful gain, or deprives a victim of a legal right.”
58. Defendant made a contract with plaintiff Cankral770 to pay him a sum of $75,000, once
he transfers ownership of his farmhouse, as described in the first cause of action.
59. Plaintiff completed their end of the deal by transferring ownership of the farmhouse over
to the Defendant, via vacating the property with the Defendant right next to it, claiming it
immediately, a common form of realty in the State of Ridgeway.
60. Defendant failed to uphold their end of the deal, never transferring Plaintiff their $75,000
as promised.
61. The Defendant’s actions unlawfully and unfairly secured a financial and proprietary gain
for them, resulting in the obtaining of a farmhouse, a property, through breach of
contract.
62. Defendant’s actions in deleting discord messages are very indicative of fraudulent
activity, and the intent to cover their tracks, and shows the intent to deceive.
THIRD CAUSE OF ACTION
Negligence (1 R. Stat. § 3105)
As to defendant EctopIex
63. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
64. Negligence is defined by 1 R. Stat. § 3105 as “Any individual who owes a duty of care to
another individual, and that other individual suffers injury as a result of a breach of that
duty to care is negligence.”
65. The Defendant is owed a duty to uphold their contracts and not to deceive citizens out of
their money, established by the aforementioned causes of actions’ statutes.
66. The Defendant breached this duty by failing to uphold the contract and deceiving the
Plaintiff out of $75,000, that he was under the pretense that he would obtain.
67. The Defendant’s breach of this duty directly resulted in the Plaintiff being out of their
house, the farmhouse, and not obtaining their $75,000 as promised; the Defendant’s
actions are the proximate cause for the Plaintiff’s damages and suffering.
FOURTH CAUSE OF ACTION
Breach of Contract (1 R. Stat. § 3107)
As to defendant EctopIex
68. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
69. Breach of contract is defined by 1 R. Stat. § 3107 as “Any individual who breaches a
contract they have signed with another party shall be a breach of contract.”
70. While the statute requires a contract “they have signed”, common law has held, through
centuries, that verbal agreements, especially textual contracts over discord, are valid
contracts, even though no traditional pen-and-paper contract with cursive signatures
affixed below.
71. This is supported in Ogden v. Saunders 25 U.S. 213 (1827) (“A great mass of human
transactions depends upon implied contracts; upon contracts which are not written, but
which grow out of the acts of the parties.”)
72. Defendant made a contract with plaintiff Nlx095 to transfer him over the farmhouse,
which was in his possession, although illegally, but unbeknownst to the Plaintiff.
73. Plaintiff and Defendant both agreed to transfer the farmhouse over to the Plaintiff, after a
total of $80,000 was paid to the Defendant.
74. Plaintiff paid $80,000 to the Defendant, via sending $35,000 to defendant EctopIex and
$45,000 to defendant DaudSr, at the request of the defendant. Plaintiff did this through 2
accounts, but under his name and authority.
75. After the payment was received by EctopIex and DaudSr, EctopIex, the property owner,
refused to hand over the property, and blocked the plaintiff on discord and banned him
from the Bank of Ecto discord server, preventing contact.
76. Even though Plaintiff upheld his end of the contract, Defendant failed to uphold theirs,
breaching the contract.
FIFTH CAUSE OF ACTION
Fraud (1 R. Stat. § 3108)
As to defendant EctopIex
77. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
78. Fraud is defined by 1 R. Stat. § 3108 as “Any individual who intentionally deceives
another party to secure unfair or unlawful gain, or deprives a victim of a legal right.”
79. Defendant made a contract with plaintiff Nlx095 to transfer over a farmhouse, upon the
receiving of $80,000.
80. Defendant had already obtained the house illegally, via frauding the first plaintiff,
Cankral770, out of the farmhouse and not paying him.
81. After Plaintiff transferred over the money to EctopIex, he was not given the farmhouse he
was intended to get, and was deceived for the monetary gain of the Defendant.
82. Defendant failed to uphold their end of the deal, never transferring over the house.
83. The Defendant’s actions unlawfully and unfairly secured a financial gain for them,
resulting in the obtainment of $80,000.
84. Defendant’s actions in deleting discord messages are very indicative of fraudulent
activity, and the intent to cover their tracks, and shows the intent to deceive.
SIXTH CAUSE OF ACTION
Negligence (1 R. Stat. § 3105)
As to defendant EctopIex
85. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
86. Negligence is defined by 1 R. Stat. § 3105 as “Any individual who owes a duty of care to
another individual, and that other individual suffers injury as a result of a breach of that
duty to care is negligence.”
87. The Defendant is owed a duty to uphold their contracts and not to deceive citizens out of
their money, established by the aforementioned causes of actions’ statutes.
88. The Defendant breached this duty by failing to uphold the contract and deceiving the
Plaintiff out of a farmhouse, that he was under the pretense that he would obtain.
89. The Defendant’s breach of this duty directly resulted in the Plaintiff being out of $80,000
and not obtaining their farmhouse as promised; the Defendant’s actions are the proximate
cause for the Plaintiff’s damages and suffering.
SEVENTH CAUSE OF ACTION
Breach of Contract (1 R. Stat. § 3107)
As to defendant Bank of Ecto
90. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
91. Breach of contract is defined by 1 R. Stat. § 3107 as “Any individual who breaches a
contract they have signed with another party shall be a breach of contract.”
92. Defendant EctopIex was acting in his official capacity as a member of the Defendant, a
business, while conducting business in the sale and purchasing of property, and while
breaching the aforementioned contract with Plaintiff Cankral770.
93. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
94. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
EIGHTH CAUSE OF ACTION
Fraud (1 R. Stat. § 3108)
As to defendant Bank of Ecto
95. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
96. Fraud is defined by 1 R. Stat. § 3108 as “Any individual who intentionally deceives
another party to secure unfair or unlawful gain, or deprives a victim of a legal right.”
97. Defendant EctopIex was acting in his official capacity as a member of the Defendant, a
business, while conducting business in the sale and purchasing of property, and while
frauding Plaintiff Cankral770 out of his farmhouse, without paying him.
98. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
99. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
NINTH CAUSE OF ACTION
Negligence (1 R. Stat. § 3105)
As to defendant Bank of Ecto
100. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
101. Negligence is defined by 1 R. Stat. § 3105 as “Any individual who owes a duty of
care to another individual, and that other individual suffers injury as a result of a breach
of that duty to care is negligence.”
102. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Cankral770.
103. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
104. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
TENTH CAUSE OF ACTION
Breach of Contract (1 R. Stat. § 3107)
As to defendant Bank of Ecto
105. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
106. Breach of contract is defined by 1 R. Stat. § 3107 as “Any individual who breaches a
contract they have signed with another party shall be a breach of contract.”
107. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
breaching the aforementioned contract with Plaintiff Nlx095.
108. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
109. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
ELEVENTH CAUSE OF ACTION
Fraud (1 R. Stat. § 3108)
As to defendant Bank of Ecto
110. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
111. Fraud is defined by 1 R. Stat. § 3108 as “Any individual who intentionally deceives
another party to secure unfair or unlawful gain, or deprives a victim of a legal right.”
112. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
frauding Plaintiff Nlx095 out of $80,000, without transferring over a farmhouse.
113. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
114. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
TWELFTH CAUSE OF ACTION
Negligence (1 R. Stat. § 3105)
As to defendant Bank of Ecto
115. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
116. Negligence is defined by 1 R. Stat. § 3105 as “Any individual who owes a duty of
care to another individual, and that other individual suffers injury as a result of a breach
of that duty to care is negligence.”
117. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Cankral770.
118. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
119. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
THIRTEENTH CAUSE OF ACTION
Civil Conspiracy (1 R. Stat. § 3111)
As to defendant Bank of Ecto
120. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
121. Civil Conspiracy is defined by 1 R. Stat. § 3111 as “Any 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.”
122. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Cankral770.
123. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
124. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
125. Defendant EctopIex, their supervisor, and the business owner all knew of the illegal
activities, and are currently whitelisted on the property, proving this, yet failed to take
any action to mediate or stop the illegal acts from occurring.
126. The Defendant, Bank of Ecto, as a whole, failed to take action on anything, and
knowingly assisted the Defendants with their illegal and fraudulent activities to harm
Plaintiff Cankral770.
127. Defendant knew that their business could be used for its reputation and license, as an
established business is reputable and attracts clients, and fraudulently induced these
actions.
FOURTEENTH CAUSE OF ACTION
Civil Conspiracy (1 R. Stat. § 3111)
As to defendant Bank of Ecto
128. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
129. Civil Conspiracy is defined by 1 R. Stat. § 3111 as “Any 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.”
130. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Nlx095.
131. Defendant Bank of Ecto is responsible for the actions of their employees, under
respondeat superior doctrine.
132. Defendant Bank of Ecto was contacted and notified of the illegal and criminal acts of
their employees, yet failed to act.
133. Defendant EctopIex, their supervisor, and the business owner all knew of the illegal
activities, and are currently whitelisted on the property, proving this, yet failed to take
any action to mediate or stop the illegal acts from occurring.
134. The Defendant, Bank of Ecto, as a whole, failed to take action on anything, and
knowingly assisted the Defendants with their illegal and fraudulent activities to harm
Plaintiff Nlx095.
135. Defendant knew that their business could be used for its reputation and license, as an
established business is reputable and attracts clients, and fraudulently induced these
actions.
FIFTEENTH CAUSE OF ACTION
Negligence Per Se (1 R. Stat. § 3106)
As to defendant Bank of Ecto
136. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
137. Negligence Per Se is defined by 1 R. Stat. § 3106 as “Any individual who is
prescribed a duty by statute or administrative policy, and that individual breached such
statute or administrative policy resulting in injury against another individual is negligence
per se.”
138. Defendant is prescribed a duty by the Department of State Expansion Act not to
engage in criminal activity while operating as a business, according to Section 2.2(f)(iv).
139. This is further elaborated and dictated upon by Section 1 to say "No business shall
use resources granted to said business to facilitate a crime", in Section 2, "No business
shall knowingly continue to employ individuals who use resources granted to said
business to facilitate a crime", and most importantly, in Section 3 "No business shall
knowingly continue to employ individuals who, on behalf of the business, systematically
violate state law."
140. The Defendant license’s license grants reputability and trust, as well as access to the
business updates channel in the State of Ridgeway discord, in which they can advertise
their business to all citizens of Ridgeway on a public forum, restricted to business
owners.
141. The Defendant knowingly used this resource to violate the law and fraudulently tricky
and deprive the Plaintiff, Cankral770, out of his farmhouse, where he transferred
ownership of his house prior to receiving the money, acting first, due to the business
being reputable, and appearing trustworthy.
142. The Defendant’s violation of this resource resulted in severe injury to the Plaintiff,
conning them out of both a house and their rightful $75,000.
SIXTEENTH CAUSE OF ACTION
Negligence Per Se (1 R. Stat. § 3106)
As to defendant Bank of Ecto
143. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
144. Negligence Per Se is defined by 1 R. Stat. § 3106 as “Any individual who is
prescribed a duty by statute or administrative policy, and that individual breached such
statute or administrative policy resulting in injury against another individual is negligence
per se.”
145. Defendant is prescribed a duty by the Department of State Expansion Act not to
engage in criminal activity while operating as a business, according to Section 2.2(f)(iv).
146. This is further elaborated and dictated upon by Section 1 to say "No business shall
use resources granted to said business to facilitate a crime", in Section 2, "No business
shall knowingly continue to employ individuals who use resources granted to said
business to facilitate a crime", and most importantly, in Section 3 "No business shall
knowingly continue to employ individuals who, on behalf of the business, systematically
violate state law."
147. The Defendant license’s license grants reputability and trust, as well as access to the
business updates channel in the State of Ridgeway discord, in which they can advertise
their business to all citizens of Ridgeway on a public forum, restricted to business
owners.
148. The Defendant knowingly used this resource to violate the law and fraudulently tricky
and deprive the Plaintiff, Nlx095, out of $80,000, after transferring over the money,
intending to receive the house, and acting first in the transaction, due to the business
being reputable, and appearing trustworthy.
149. The Defendant’s violation of this resource resulted in severe injury to the Plaintiff,
conning them out of $80,000 and the farmhouse.
SEVENTEENTH CAUSE OF ACTION
Negligence Per Se (1 R. Stat. § 3106)
As to defendant Bank of Ecto
150. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
151. Negligence Per Se is defined by 1 R. Stat. § 3106 as “Any individual who is
prescribed a duty by statute or administrative policy, and that individual breached such
statute or administrative policy resulting in injury against another individual is negligence
per se.”
152. Defendant is prescribed a duty by the Department of State Expansion Act not to
engage in criminal activity while operating as a business, according to Section 2.2(f)(iv).
153. This is further elaborated and dictated upon by Section 1 to say "No business shall
use resources granted to said business to facilitate a crime", in Section 2, "No business
shall knowingly continue to employ individuals who use resources granted to said
business to facilitate a crime", and most importantly, in Section 3 "No business shall
knowingly continue to employ individuals who, on behalf of the business, systematically
violate state law."
154. The Defendant was notified about their employees’ breaches of law, via
representative and supervisor Aczero_Verxa and business owner Rickypedina, yet
continued to employ EctopIex and failed to act in anyway, allowing them to continue
misusing the company’s reputable name, a resource granted via the Department of State
license, to injure others, especially the Plaintiff.
155. Defendant EctopIex continues to systematically violate the law, frauding out citizens
of both their houses and money, acting in the name of the business, and the Defendant
Bank of Ecto consistently fails to act.
156. The Defendant’s continuation of employment of EctopIex after the damage of
Plaintiff Cankral770 resulted in the damage to Plaintiff Nlx095, which could have been
completely avoided by abiding by statute, and not continuing to employ defendant
EctopIex.
EIGHTEENTH CAUSE OF ACTION
Civil Conspiracy (1 R. Stat. § 3111)
As to defendant Aczero_Verxa
157. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
158. Civil Conspiracy is defined by 1 R. Stat. § 3111 as “Any 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.”
159. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Cankral770.
160. Defendant Aczero_Verxa is the Chief Executive Officer for the Bank of Ecto, and
acts as a high level supervisor directly under the business owner, with direct oversight
over defendant EctopIex.
161. Defendant Aczero_Verxa was notified of Defendant EctopIex’s illegal and fraudulent
activity via a cease and desist order, yet failed to act, and continued to conspire with
Defendant EctopIex to cover his tracks and silence victims.
162. Defendant Aczero_Verxa knew of these illegal practices and made no attempt to
remedy these issues and continued operating the business in spite of this.
163. Defendant, upon receipt of the cease and desist order, would continue engaging in
illegal activities and conspiring with both the Bank of Ecto and EctopIex to deceive and
fraud citizens, saying “shush” upon receipt of the cease and desist order.
NINETEENTH CAUSE OF ACTION
Civil Conspiracy (1 R. Stat. § 3111)
As to defendant Aczero_Verxa
164. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
165. Civil Conspiracy is defined by 1 R. Stat. § 3111 as “Any 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.”
166. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Nlx095.
167. Defendant Aczero_Verxa is the Chief Executive Officer for the Bank of Ecto, and
acts as a high level supervisor directly under the business owner, with direct oversight
over defendant EctopIex.
168. Defendant Aczero_Verxa was notified of Defendant EctopIex’s illegal and fraudulent
activity via a cease and desist order, yet failed to act, and continued to conspire with
Defendant EctopIex to cover his tracks and silence victims.
169. Defendant Aczero_Verxa knew of these illegal practices, even agreeing that Plaintiff
Nlx095 attempted to buy the farmhouse, yet didn’t receive it. Defendant made no attempt
to remedy these issues and continued operating the business in spite of this.
170. Defendant, upon receipt of the cease and desist order, would continue engaging in
illegal activities and conspiring with both the Bank of Ecto and EctopIex to deceive and
fraud citizens, saying “shush” upon receipt of the cease and desist order.
TWENTIETH CAUSE OF ACTION
Civil Conspiracy (1 R. Stat. § 3111)
As to defendant Rickypedina
171. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
172. Civil Conspiracy is defined by 1 R. Stat. § 3111 as “Any 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.”
173. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Cankral770.
174. Defendant Aczero_Verxa is the Chief Executive Officer for the Bank of Ecto, and
acts as a high level supervisor directly under the business owner, with direct oversight
over defendant EctopIex.
175. Defendant Aczero_Verxa was notified of Defendant EctopIex’s illegal and fraudulent
activity via a cease and desist order, yet failed to act, and continued to conspire with
Defendant EctopIex to cover his tracks and silence victims.
176. Defendant Aczero_Verxa knew of these illegal practices and made no attempt to
remedy these issues and continued operating the business in spite of this.
177. Defendant Aczero_Verxa is even whitelisted for the farmhouse property, the very
same property that has had 2 fraudulent actions occur within it: the fraudulent obtainment
and the failed sale.
178. Defendant, upon receipt of the cease and desist order, would continue engaging in
illegal activities and conspiring with both the Bank of Ecto and EctopIex to deceive and
fraud citizens, saying “shush” upon receipt of the cease and desist order.
TWENTY-FIRST CAUSE OF ACTION
Civil Conspiracy (1 R. Stat. § 3111)
As to defendant Rickypedina
179. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
180. Civil Conspiracy is defined by 1 R. Stat. § 3111 as “Any 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.”
181. Defendant EctopIex was acting in his official capacity as a member of the Defendant,
a business, while conducting business in the sale and purchasing of property, and while
negligently causing harm to Plaintiff Nlx095.
182. Defendant Rickypedina is the business owner for the Bank of Ecto, and is responsible
for the business’ actions under respondeat superior doctrine.
183. The Defendant has the power to rectify issues and resolve conflicts within their
business, yet failed to do so, causing harm to the plaintiffs.
184. Defendant Rickypedina was notified of Defendant EctopIex’s illegal and fraudulent
activity via a cease and desist order, yet failed to act, and continued to conspire with
Defendant EctopIex to cover his tracks and silence victims.
185. Defendant Rickypedina is even whitelisted for the farmhouse property, the very same
property that has had 2 fraudulent actions occur within it: the fraudulent obtainment and
the failed sale.
186. Defendant Rickypedina knew of these illegal practices, even agreeing that Plaintiff
Nlx095 attempted to buy the farmhouse, yet didn’t receive it. Defendant made no attempt
to remedy these issues and continued operating the business in spite of this.
187. Defendant, upon receipt of the cease and desist order, would continue engaging in
illegal activities and conspiring with both the Bank of Ecto and EctopIex to deceive and
fraud citizens, saying “shush” upon receipt of the cease and desist order.
TWENTY-SECOND CAUSE OF ACTION
Breach of Contract (1 R. Stat. § 3107)
As to defendant DaudSr
188. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
189. Breach of contract is defined by 1 R. Stat. § 3107 as “Any individual who breaches a
contract they have signed with another party shall be a breach of contract.”
190. While the statute requires a contract “they have signed”, common law has held,
through centuries, that verbal agreements, especially textual contracts over discord, are
valid contracts, even though no traditional pen-and-paper contract with cursive signatures
affixed below.
191. This is supported in Ogden v. Saunders 25 U.S. 213 (1827) (“A great mass of human
transactions depends upon implied contracts; upon contracts which are not written, but
which grow out of the acts of the parties.”)
192. Defendant DaudSr, an alternate account of Defendant EctopIex, knowingly took
money from Plaintiff Nlx095 totalling $45,000 intended to be for the purchase of a
farmhouse, with the other part of the payment being sent to EctopIex.
193. Defendant DaudSr kept the money, even when Plaintiff Nlx095 was fraudulently
scammed and was not given the house, being an accomplice alongside EctopIex in breach
of contract, and making him liable as an accomplice.
TWENTY-THIRD CAUSE OF ACTION
Fraud (1 R. Stat. § 3108)
As to defendant DaudSr
194. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
195. Fraud is defined by 1 R. Stat. § 3108 as “Any individual who intentionally deceives
another party to secure unfair or unlawful gain, or deprives a victim of a legal right.”
196. Defendant DaudSr, an alternate account of Defendant EctopIex, knowingly took
money from Plaintiff Nlx095 totalling $45,000 intended to be for the purchase of a
farmhouse, with the other part of the payment being sent to EctopIex.
197. Defendant DaudSr kept the money, even when Plaintiff Nlx095 was fraudulently
scammed and was not given the house, being an accomplice alongside EctopIex in breach
of contract, and making him liable as an accomplice.
198. Defendant knowingly assisted Defendant EctopIex in the fraud of Plaintiff Nlx095.
TWENTY-FOURTH CAUSE OF ACTION
Negligence (1 R. Stat. § 3105)
As to defendant DaudSr
199. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
200. Negligence is defined by 1 R. Stat. § 3105 as “Any individual who owes a duty of
care to another individual, and that other individual suffers injury as a result of a breach
of that duty to care is negligence.”
201. Defendant DaudSr, an alternate account of Defendant EctopIex, knowingly took
money from Plaintiff Nlx095 totalling $45,000 intended to be for the purchase of a
farmhouse, with the other part of the payment being sent to EctopIex.
202. Defendant DaudSr kept the money, even when Plaintiff Nlx095 was fraudulently
scammed and was not given the house, being an accomplice alongside EctopIex in breach
of contract, and making him liable as an accomplice.
203. Defendant had a duty not to assist and keep the money from Plaintiff Nlx095 after he
was scammed, yet kept it anyway and failed to turn it back over, causing financial
damage to the Plaintiff.
TWENTY-FIFTH CAUSE OF ACTION
Civil Conspiracy (1 R. Stat. § 3111)
As to defendant DaudSr
204. All prior paragraphs within this complaint are incorporated as if they were fully set
forth herein.
205. Civil Conspiracy is defined by 1 R. Stat. § 3111 as “Any 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.”
206. Defendant knowingly engaged in fraudulent and illegal activity alongside EctopIex to
keep and store money on their account for the victims that Defendant EctopIex deceives
and tricks.
207. Defendant deprived Plaintiff Nlx095 out of his money, assisting and colluding with
Defendant EctopIex, making him liable under expressed and accomplice liability.
PRAYERS FOR RELIEF
Wherefore, Plaintiffs prays that the Court:
1. Declare that all defendants are liable for the crimes they have been held liable to;
2. Enjoin the defendants from repeating fraudulent and criminal activity;
3. Recommend, to the Secretaty of State, a revocation of the business license of the Bank of
Ecto, and report the findings of the court;
4. Return Plaintiff Cankral770’s farmhouse back to him;
5. Return Plaintiff Nlx095’s $80,000 back to him
6. Award Plaintiff other actual damages;
7. Award Plaintiff punitive damages;
8. Pay legal and attorney fees for the Plaintiff and their counsel;
9. Grant other relief as the court deems proper.
DATED: May 9th, 2024
Respectfully submitted,
acerxtro, Esq.
R. Bar No. 17137
Counsel of Record
Cohn, Cicero, & Goodrich LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
Counsel for Plaintiff
THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
cankral770 et al.,
Plaintiff(s)
v.
EctopIex et al.,
Defendant(s)
Case No. N/A
Presiding Judge: N/A
INITIAL DISCLOSURE
Plaintiff, by and through the undersigned counsel, submits this document in the
above-entitled matter, pursuant to Rid. Civ. P. 19 and Fed. R. Civ. P. 25. Plaintiff submits the
following articles as initial discovery as to the tortious claims listed within the civil complaint,
pursuant to Rid. Civ. P. 19:
EXHIBITS
A. Exhibit - Defendant EctopIex advertising that the Bank of Ecto buys houses
B. Exhibit - Plaintiff cankral770 offering to sell his house in the Bank of Ecto discord server
C. Exhibit - Negotiations of deal between Plaintiff Cank & Defendant EctopIex
D. Exhibit - Agreement of contract + notice to join game
E. Exhibit - Video of the transfer of house ownership
F. Exhibit - Defendant EctopIex placing Plaintiff Cank’s farmhouse for sale
G. Exhibit - Plaintiff Cank’s money as of 5/9/2024
H. Exhibit - House still being owned by Defendant EctopIex as of 5/9/2024 w/ members of
the Bank of Ecto whitelisted
I. Exhibit - Plaintiff Nlx095 negotiating the purchase of the farmhouse
J. Exhibit - Defendant EctopIex telling Plaintiff Nlx to send DaudSr $45,000 and to send
him $35,000 ($80,000 total)
K. Exhibit - Proof of Plaintiff Nlx paying Defendants EctopIex and DaudSr, as told to
L. Exhibit - Defendant EctopIex deleting DM messages and blocking the plaintiff
M. Exhibit - Proof of Plaintiff Nlx being in the Bank of Ecto discord server, prior to being
banned
N. Exhibit - Proof of the cease and desist order reaching Defendant EctopIex and not being
heeded
O. Exhibit - Proof of the cease and desist order reaching Defendant Aczero_Verxa and not
being heeded
P. Exhibit - Cease and desist order
Q. Exhibit - Registry of Bank of Ecto as a business on the Ridgeway Commerce Registry
trello
WITNESSES
1. EctopIex - Lay Witness
2. Aczero_Verxa - Lay Witness
3. DaudSr - Lay Witness
4. Rickypedina - Lay Witness
5. Bflare - Lay Witness
6. cankral770 - Lay Witness
7. Nlx095 - Lay Witness
8. acerxtro - Lay Witness
9. JasonBourneAxis - Lay & Expert (Business & Regulation) Witness
DATED: May 9th, 2024
Respectfully submitted,
acerxtro, Esq.
R. Bar No. 17137
Counsel of Record
Cohn, Cicero, & Goodrich LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
Counsel for Plaintiff
