RIDGEWAY SUPERIOR COURT
Tobyrulles4568,
Plaintiff,
v.
Arthur_Chen, Trooper_Novich,
Defendant(s).
COUNTERCLAIM
RSC-CV-3102
Hon. Notsfeelings
COUNTERCLAIM
Plaintiff, by and through the undersigned counsel, does file this counterclaim against the
Defendants alleging at all times:
1. The Plaintiff does, by reference, incorporate all paragraphs one through ten of the
civil complaint filed by the defenses in the case RSC-CV-3102 and all responses made
to those paragraphs filed in the response to the civil complaint in the above-
referenced case to serve as the basis for this counterclaim.
FIRST CAUSE OF ACTION
Abuse of Process (1 R. Stat. § 3112)
2. Paragraph one in incorporated, by reference, for the purposes of giving sufficient
factual background to this cause.
3. Plaintiff voluntarily agreed to testify to the Grand Jury regarding the conduct of the
Defendent(s). Plaintiff was, however, issued a subpoena mandated his attendance
and testimony to the Grand Jury.
4. The Plaintiff did comply with this subpoena, as was required by law, and was,
consequently, in full compliance with the terms of the settlement contract.
5. In their civil complaint, the Defendants claim that “This disclosure was made in a
Grand Jury proceeding, without a subpoena or other lawful court order,” a clearly false
statement, given the existence of the Plaintiff’s subpoena.
6. Defendants are either negligently or willfully oblivious to this fact, as evinced by the
civil complaint and its hasty filing.
7. Consequently, Defendants are liable for abuse of process as defined in 1 R. Stat. § 3112
as they did file a vexatious and frivolous complaint to this Court, irrespective of the
true facts of the case, with the intention of getting the Plaintiff in trouble.
REQUESTS FOR RELIEF
WHEREFORE, the Plaintiff requests the following relief to be granted to amend the injuries
alleged:
1. Issue injunctive relief against the Defendants enjoining further litigation of the case
at hand;
2. Award punitive damages in the amount of three-thousand per defendant to
effectively punish the defendants for their conduct and to deter the defendants from
engaging in future vexatious litigating;
3. Attorney’s fees and costs; and
4. Any other relief the court deems proper.
Respectfully Submitted, 6/23/24
Holy R. Ryan
Counsel of Record
Attorney at Law
Bar #17105
