STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
TROOPER_NOVICH;
ARTHUR_CHEN,
Plaintiff(s),
v.
TOBYRULLES4568,
Defendant(s).
Case Number: RSC-CV-3102
Presiding: Hon. Arthur_Chen
CIVIL COMPLAINT
CIVIL COMPLAINT
PLAINTIFF, Trooper_Novich and Arthur_Chen, by and through the undersigned
counsel, alleges the following:
JURISDICTION & VENUE
1. The court has jurisdiction to hear “all civil and criminal cases or controversies.”
Ridgeway State Constitution Article V, Section IV.
2. Venue is proper as the tortious actions alleged herein took place in Ridgeway County,
Ridgeway.
PARTIES
3. Trooper_Novich (“Plaintiff”) is a resident of Ridgeway County. He is also a citizen of the
State of Ridgeway—his place of business and personal home address is unknown; but it
is understood that he resides within the applicable jurisdiction as hereinafter referenced
and applied in this case.
4. Arthur_Chen (“Plaintiff”) is a resident of Ridgeway County. He is also a citizen of the
State of Ridgeway—his place of business and personal home address is unknown; but it
is understood that he resides within the applicable jurisdiction as hereinafter referenced
and applied in this case.
5. Tobyrulles4568 (“Defendant”) is a resident of Ridgeway County. He is also a citizen of
the State of Ridgeway—his personal home address is unknown; but it is understood that
he resides within the applicable jurisdiction as hereinafter referenced and applied in this
case. He is the Managing Partner at Toby & Sawyer LLP
FACTS
I. Contract between parties
6. On or about April 24th, 2024, Plaintiff’s engaged in a settlement agreement between
themselves, OhMyEffGees and AviaLyft - through his counsel, the Defendant. This
settlement agreement had a term of confidentiality in paragraph 4.
7. This settlement agreement arose out of conduct from earlier that day involving the parties
named above.
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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8. When the Parties signed this agreement, they agreed to uphold all portions of this
agreement, unless otherwise stated. In paragraph 4, they acknowledged that “parties
reserve the right to initiate litigation on violation of this clause only”.
II. Grand Jury
9. On or about May 8th, 2024, Grand Jury 24-241 subpoenaed Defendant in relation to a
Grand Jury investigation into Plaintiff Trooper_Novich and another individual.
10. In this Grand Jury Investigation, Defendant was asked multiple questions, including,
asking him to describe what happened leading up to an alleged incident that took place.
Defendant provided details to the Grand Jury, including that a settlement was agreed to.
The State Attorney then asked for him to share the agreement. Defendant offered the
agreement to the State attorney on the 13th of May 2024.
FIRST CAUSE OF ACTION
BREACH OF CONTRACT - 1 R. STAT. § 3107
11. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
12. 1 R. Stat. § 3107 states “Any individual who breaches a contract they have signed with
another party shall be a breach of contract”.
13. Plaintiff’s entered into a settlement agreement with Defendant’s client. A term of this
agreement is that this would be confidential and only disclosed when REQUIRED by
law.
14. Defendant disclosed information of this settlement, including the amount paid to
Defendant’s client, and other terms in the agreement. This disclosure was made in a
Grand Jury proceeding, without a subpoena or other lawful court order.
15. Plaintiff’s signed this agreement, knowing that this would be a confidential, sealed
agreement. Defendant broke Plaintiff’s trust by disclosing this to a Grand Jury.
16. As a result of this settlement agreement being broken, Plaintiff’s suffered damage to their
character. In addition to this, the Settlement agreement was evidence in the grand jury
proceedings.
RELIEF
WHEREFORE, Plaintiff requests the court to grant relief to redress the injury as follows:
a. Declaratory relief declaring that Defendant broke contract;
b. Injunctive relief ordering Defendant to apologize to Plaintiff for breaching contract;
c. Grant Punitive Damages in the amount of $5,000 per Plaintiff.
d. Granting Plaintiff such other further relief as the court finds just and proper.
June 10, 2024 Respectfully submitted,
MatthewSandringham
Counsel of Record
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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Clarke, Feelings & Associates, LLP.
Managing Partner
R. Bar. No. 16103
Attorney for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
TROOPER_NOVICH;
ARTHUR_CHEN,
Plaintiff(s),
v.
TOBYRULLES4568,
Defendant(s).
Case Number: RSC-CV-0000
Presiding: Hon.
INITIAL DISCLOSURE
INITIAL DISCLOSURE
PLAINTIFF, Trooper_Novich and Arthur_Chen, 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.
INITIAL DISCOVERY
Plaintiff submits the following articles as initial discovery as to the tortious claims listed within
the civil complaint, pursuant to Rid. Civ. P. 19:
a. Exhibit A - Grand Jury Disclosures.
June 10, 2024 Respectfully submitted,
MatthewSandringham
Counsel of Record
Clarke, Feelings & Associates, LLP.
Managing Partner
R. Bar. No. 16103
Attorney for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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