RIDGEWAY ADMINISTRATIVE COURT
GRAMMA12221,
Plaintiff,
v.
PALMER POLICE DEPARTMENT;
COMMISSIONER_JASON, in their
official capacity as the Chief of Police
of the Palmer Police Department;
ROOTENTRY, in their official capacity
as a Captain of the Palmer Police
Department; ALLYCORETTI, in their
official capacity as an Acting Lieutenant
of the Palmer Police Department,
Defendants.
Case No. RSC-AD-
CIVIL COMPLAINT
CIVIL COMPLAINT
PLAINTIFF, for their complaint against the Palmer Police Department, et al.., allege as
follows:
PARTIES
1. Gramma12221 is a resident of the State of Ridgeway and a Corporal in the Palmer Police
Department’s Public Affairs Unit.
2. The Palmer Police Department is an official subsidiary of the State of Ridgeway.
3. Commissioner_Jason is a resident of the State of Ridgeway and Chief of Police of the
Palmer Police Department.
4. RootEntry is a resident of the State of Ridgeway and a Captain of the Palmer Police
Department.
5. AllyCoretti is a resident of the State of Ridgeway and an Acting Lieutenant of the Palmer
Police Department.
JURISDICTION
6. This court has original jurisdiction to hear “all civil claims involving administrative
action, or policy, or rules of governing agencies.” 2 R. Stat. § 3305.
7. This court may also grant “equitable remedy necessary to ensure proper enforcement of
the law.” 2 R. Stat. § 3307.
8. No claim raised is barred by sovereign immunity because each cause of action has been
“explicitly created” against the government. 1 R. Stat. § 3203.
GENERAL ALLEGATIONS
I. Leave of Absence
9. On June 4th , 2024, gramma12221, a Sergeant of the Public Affairs Unit at the time,
requested a leave of absence to begin on June 11th and end on August 15th.
10. This request was processed by Acting Lieutenant AllyCoretti of the Palmer Police
Department on June 11th, 2024, and he was placed on a leave of absence until August
15th.
II. Blatant Harassment, Oppression, Obstruction, Abuse, and Coercion
11. Starting in the beginning of June 2024, the plaintiff has been a subject of targeting,
harassment, coercion, obstruction, and abuse by Acting Lieutenant AllyCoretti.
12. The Acting Lieutenant has micromanaged the Public Affairs Unit and disallowed the
plaintiff to speak his thoughts without oppression, obstructing him from his duties.
13. Gramma12221, a Sergeant at the time, has had many ideas for the Palmer Police
Department’s Public Affairs Unit–the unit which he commands–and has given these ideas
to his Acting Lieutenant, AllyCoretti.
14. Instead of trying to work out some of the plaintiff’s ideas, Acting Lieutenant AllyCoretti
has threatened him with dismissal if he doesn’t “fix [his] mindset”.
15. Indeed, the Acting Lieutenant has gone even further. In one instance, the Acting
Lieutenant wanted to immediately speak to the plaintiff about his unit. The plaintiff stated
he was unavailable at the time. Instead of finding a time where they both were available,
the Acting Lieutenant decided to spam voice call the plaintiff more than 8 times.
16. In another instance, the plaintiff was speaking to the Acting Lieutenant about the Palmer
Police Department’s Officer of the Month program. The plaintiff and Acting Lieutenant
had some disagreements over it, and instead of the Acting Lieutenant resolving them
civilly, he decided to call the plaintiff “FUCKING DELUSIONAL AND
INSUBORDINATE” and proceeded to insult him again, saying “WHO ARE YOU”.
17. The Acting Lieutenant’s actions have severely hindered the plaintiff from speaking his
thoughts freely without forthcoming harassment, hindering his abilities to work as an
employee of the Palmer Police Department.
III. Demotion from Sergeant to Corporal
18. On June 24th, 2024, while the plaintiff was on his leave of absence, he was messaged by
his Acting Lieutenant, AllyCoretti, and notified that he would be demoting the plaintiff to
the rank of Senior Patrol Officer.
19. The reasons for this demotion was, at first, noted to be due to the plaintiff being on a
leave of absence accompanied by an 8 hour time zone difference, making it, in the Acting
Lieutenant’s opinion, a hindrance on the unit.
20. Shortly later, the demotion was later changed from going to the rank of Senior Patrol
Officer to going to the rank of Corporal. Instead of getting knocked 2 ranks down to
Senior Patrol Officer, the Acting Lieutenant stated that he would only be getting knocked
down one to Corporal.
21. A bit later, at 4:07 PM Central Standard Time, the plaintiff was demoted to Corporal of
the Public Affairs Unit by Captain RootEntry, citing that Acting Lieutenant AllyCoretti
would take command of the unit.
22. The reasoning for the plaintiff’s demotion was then changed by Captain RootEntry to a
reform of the Public Affairs Unit.
23. Acting Lieutenant AllyCoretti and Captain RootEntry jointly demoted the plaintiff from
the rank of Sergeant to Corporal in the Public Affairs Unit.
IV. Threats and Oppression from the Chief of Police
24. Acting Lieutenant AllyCoretti was served a cease and desist letter for the aforementioned
behavior of harassment, oppression, obstruction, abuse, and coercion.
25. This letter demanded that Acting Lieutenant AllyCoretti cease this behavior, and reinstate
the plaintiff back to his position of Sergeant of the Public Affairs Unit.
26. This letter was forwarded to the Chief of Police by the Acting Lieutenant, who oppressed
the plaintiff for seeking legal counsel.
27. The Chief of Police threatened to issue an at-will termination to the plaintiff for seeking
legal counsel who issued a cease and desist, an action which is retaliatory and prohibited
by law.
28. Furthermore, because of the plaintiff’s actions, the Chief of Police informed him that he
is “effectively relieved of [his] command”, and noted that it was “initially for the duration
of the [Leave of Absence]” but “after this stunt” is “permanent”.
29. The Chief of Police calls the plaintiff’s actions of seeking counsel and sending a cease
and desist to deter the aforementioned behavior as a “stunt”, and has unlawfully retaliated
against the plaintiff and permanently issued him a demotion to Corporal, with a clear
message that there is no chance of getting back to his original rank of Sergeant.
FIRST CAUSE OF ACTION
(Disciplinary Action While On an Extended Leave of Absence - 2 R. Stat. § 3403)
30. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
31. Pursuant to 2 R. Stat. § 3403, the plaintiff is, inter alia, “entitled to an extended leave of
more than seven days but not lasting more than fourteen without fear of termination,
retribution, or other forms of disciplinary action.”
32. The plaintiff’s extended leave of absence that he is entitled to would end on June 26th,
2024, however he was disciplined on June 25th.
33. The plaintiff’s disciplinary action and punishment of demotion from Sergeant to Corporal
in the Public Affairs Unit is unlawful and arbitrary because he has been disciplined while
on an extended leave of absence.
SECOND CAUSE OF ACTION
(Disciplinary Action While On an Extended Leave of Absence - 2 R. Stat. § 3403)
34. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
35. The plaintiff, while on an extended leave of absence, was issued an unjust, unlawful, and
retaliatory permanent demotion by Chief of Police Commissioner_Jason for seeking
counsel and taking legal action against the department.
36. The plaintiff’s extended leave of absence that he is entitled to would end on June 26th,
2024, however he was issued the permanent demotion on June 25th.
37. The plaintiff’s disciplinary action of permanent demotion is unlawful and arbitrary
because he has been disciplined while on an extended leave of absence.
THIRD CAUSE OF ACTION
(Fear of Disciplinary Action While On an Extended Leave of Absence - 2 R. Stat. § 3403)
38. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
39. The plaintiff, while on an extended leave of absence, was put in fear of an unjust,
unlawful, and retaliatory at-will termination by Chief of Police Commissioner_Jason for
seeking counsel and taking legal action against the department.
40. The plaintiff’s extended leave of absence that he is entitled to would end on June 26th,
2024, however he was put in fear of termination on June 25th.
41. The Chief of Police’s actions of putting the plaintiff in fear of termination is unlawful
because he has done so while the plaintiff was on an extended leave of absence.
FOURTH CAUSE OF ACTION
(Oppression, Coercion, or Obstruction During Employment - 2 R. Stat. § 4102)
42. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
43. Pursuant to 2 R. Stat. § 3305, the plaintiff has “the right to be free from oppression,
coercion, or obstruction during the course of their employment.”
44. When statutory terms are undefined, or in other words, not given a specific definition,
they are given their “ordinary meaning”. See Taniguchi v. Kan Pac. Saipan, Ltd., 566
U.S. 560, 2006 (2012) (concluding that undefined statutory terms are given their
“ordinary meaning”).
45. The ordinary meaning of oppression is “prolonged cruel or unjust treatment or control.”
Oxford English Dictionary.
46. The plaintiff has been a subject of oppression by Acting Lieutenant AllyCoretti when he,
since April, has taken full control of his unit, not allowed him to express his thoughts
without harassment, unjustly insulting the plaintiff multiple times, and harassing the
plaintiff by spam calling him, all actions which were done in a cruel or unjust manner.
47. The ordinary meaning of obstruct is “to hinder from passage, action, or operation” .1
48. The plaintiff has been a subject of obstruction by the Acting Lieutenant when he has
unjustly and unlawfully committed oppression and harassment against the plaintiff,
causing a hindrance on the plaintiff from action and operation of the Public Affairs Unit.
49. The ordinary meaning of coercion is “the practice of persuading someone to do
something by using force or threats.” Oxford English Dictionary.
50. The plaintiff has been a subject of coercion by the Acting Lieutenant when he was
threatened by the Acting Lieutenant that he would lose his position of Sergeant of the
Public Affairs Unit if he didn’t “fix [his] mindset” about the Palmer Police Department’s
Officer of the Month Program.
FIFTH CAUSE OF ACTION
(Oppression, Coercion, or Obstruction During Employment - 2 R. Stat. § 4102)
51. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
52. Pursuant to 2 R. Stat. § 3305, the plaintiff has “the right to be free from oppression,
coercion, or obstruction during the course of their employment.”
53. Another, yet similar, definition of oppression is an “unjust or cruel exercise of authority
or power” .2
54. Commissioner_Jason, the Chief of Police of the Palmer Police Department, has unjustly
and cruelly exercised his authority and power that is given to his office and unjustly
treated and oppressed the plaintiff by disciplining him by threatening him with an at-will
termination and issuing him a permanent demotion for seeking counsel and taking legal
action against the department.
SIXTH CAUSE OF ACTION
(Arbitrary Demotion & Punishment - 2 R. Stat. §§ 3105, 3135)
55. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
2 “Oppression.” Merriam-Webster.com Dictionary, Merriam-Webster,
https://www.merriam-webster.com/dictionary/oppression. Accessed 27 Jun. 2024.
1 “Obstruct.” Merriam-Webster.com Dictionary, Merriam-Webster,
https://www.merriam-webster.com/dictionary/obstruct. Accessed 27 Jun. 2024.
56. Pursuant to 2 R. Stat. § 3105, “it is unlawful to”, inter alia, “arbitrarily, or without due
observation of law, demote someone from a non-staff position.”
57. The basis for the plaintiff’s punishment of demotion was, as aforementioned, due to his
“leave of absence, accompanied by [an] 8 hour time difference” which, in the Acting
Lieutenant’s opinion, has made it “a hindrance on [the plaintiff’s] communication
abilities” which “is not healthy for the unit.”
58. Pursuant to 2 R. Stat. § 3135, punishment is considered arbitrary when it is:
a. Punishment that has no backing in regulation, policy, or law; or
b. Punishment whose policy, law, or regulation prescribing it is ambiguous, or
unclear, or a violation of a constitutional right or privilege or statutory enactment;
or
c. Punishment outside or beyond what is explicitly prescribed in policy; or
d. Punishment that takes no accounting of mitigating factors, circumstances, or
liabilities.
59. The plaintiff’s punishment of demotion from Sergeant to Corporal in the Palmer Police
Department is arbitrary because it is in violation of a statutory enactment, that being the
S1-023 | Right to Leave Act.
60. The plaintiff’s punishment of demotion from Sergeant to Corporal in the Palmer Police
Department is furthermore arbitrary because there is no policy, law, or regulation that
permits the Palmer Police Department to demote the plaintiff due to reforms.3
61. The plaintiff’s punishment of demotion from Sergeant to Corporal in the Palmer Police
Department is furthermore arbitrary because it has not properly taken into account
mitigating factors and circumstances including but not limited to the fact that the plaintiff
is on a leave of absence and out of country.
62. The plaintiff’s demotion from Sergeant to Corporal of the Public Affairs Unit was done
without due observance of law, rendering it arbitrary.
SEVENTH CAUSE OF ACTION
(Arbitrary Demotion & Punishment - 2 R. Stat. §§ 3105, 3135)
63. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
64. The plaintiff, while on an extended leave of absence, was issued a permanent, retaliatory,
and arbitrary demotion from the Chief of Police Commissioner_Jason for pulling a
“stunt” by seeking legal counsel.
65. This punishment of permanent demotion is arbitrary because it is in violation of a
statutory enactment, that being S1-023 | Right to Leave Act.
3 Palmer Police Department Standard Operating Procedures
https://docs.google.com/document/d/1l0WjdFezOW4YmzTwHJmZ0eLeal9p-cF4ibUcKhTHycE/edit
66. The plaintiff’s punishment of permanent demotion is furthermore arbitrary because there
is no policy, law, or regulation that permits a permanent demotion due to seeking counsel
and taking legal action against the department
67. The plaintiff’s punishment of permanent demotion is furthermore arbitrary because to
discipline someone for seeking legal counsel against your department is inherently
retaliatory
68. The plaintiff’s punishment of permanent demotion from Sergeant to Corporal has been
done without due observance of law, rendering it arbitrary.
EIGHTH CAUSE OF ACTION
(Issuance of a Shadow Blacklist - 2 R. Stat. § 4110)
69. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
70. Pursuant to 2 R. Stat. § 4110, plaintiff has “the right to be free from shadow-blacklists.”
(internal quotation marks omitted).
71. When Commissioner_Jason issued a permanent demotion on the plaintiff from Sergeant
to Corporal for seeking legal counsel in regards to his demotion, he placed a shadow
blacklist—a blacklist that is not formally recorded—on the plaintiff from ever reaching
the rank of Sergeant again.
NINTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant AllyCoretti)
72. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
73. Pursuant to 1 R. Stat. § 3114, “[a]ny individual who is a public servant and commits an
act relating to his office but constitutes an unauthorized exercise of his official functions,
where a reasonable person with his training, expertise, and experiences should know that
such act is unauthorized” is liable for the tort of Official Misconduct.
74. Acting Lieutenant AllyCoretti is an extremely experienced law enforcement officer. He
has had an extensive amount of training, expertise, and experiences.
75. Acting Lieutenant AllyCoretti is a graduate of Class 9 of the Law Enforcement Training
Center, and has been employed in the Palmer Police Department since April 28th, 2022,
and has no disciplinary actions on record.
76. Acting Lieutenant AllyCoretti has received a great amount of experience as an Acting
Lieutenant of the Palmer Police Department. Prior to becoming an Acting Lieutenant and
managing both the Traffic Unit and Public Affairs Unit as the Patrol Group II
Commander, AllyCoretti served as a Sergeant where he managed the Traffic Unit in a
command position, receiving a great amount of experience from that position.
77. AllyCoretti, through this certification and these positions, has received a great amount of
training, expertise, and experience.
78. AllyCoretti, by arbitrarily demoting the plaintiff from Sergeant to Corporal, has
committed an act “relating to his office but” constituting “an unauthorized exercise of his
official functions, where a reasonable person with his training, expertise, and experiences
should know that such act is unauthorized”, making him liable for the tort of Official
Misconduct.
TENTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant AllyCoretti)
79. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
80. AllyCoretti, by committing harassment, obstruction, coercion, and abuse against the
plaintiff are acts committed “relating to his office but” constituting “an unauthorized
exercise of his official functions, where a reasonable person with his training, expertise,
and experiences should know that such act is unauthorized”, making him liable for the
tort of Official Misconduct.
ELEVENTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant RootEntry)
81. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
82. Pursuant to 1 R. Stat. § 3114, “[a]ny individual who is a public servant and commits an
act relating to his office but constitutes an unauthorized exercise of his official functions,
where a reasonable person with his training, expertise, and experiences should know that
such act is unauthorized” is liable for the tort of Official Misconduct.
83. Captain RootEntry is an extremely experienced law enforcement officer. He has had an
extensive amount of training, expertise, and experiences.
84. Captain RootEntry is a graduate of Class 2 of the Law Enforcement Training Center, and
joined the Palmer Police Department on February 2nd, 2021, and has been employed
since his reinstatement on May 20th, 2024, and has no disciplinary actions on record.
85. Captain RootEntry has been a long time high command and command member of the
Palmer Police Department. Captain RootEntry was promoted to the rank of Captain on
April 9th, 2023. Prior to serving as Captain of the Field Operations Division, he served as
a Lieutenant and Commander of Patrol Group I and a Sergeant.
86. Captain RootEntry, through this certification and these positions, has received a great
amount of training, expertise, and experience.
87. Captain RootEntry, by arbitrarily demoting the plaintiff from Sergeant to Corporal, has
committed an act “relating to his office but” constituting “an unauthorized exercise of his
official functions, where a reasonable person with his training, expertise, and experiences
should know that such act is unauthorized”, making RootEntry liable for the tort of
Official Misconduct.
TWELFTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant RootEntry)
88. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
89. Captain RootEntry is Acting Lieutenant AllyCoretti’s direct supervisor and the
Commander of the Palmer Police Department’s Field Operations Bureau. He is
responsible for the Acting Lieutenant’s actions.
90. Captain RootEntry’s actions of committing harassment, oppression, obstruction, abuse,
and coercion unto the plaintiff through Acting Lieutenant AllyCoretti makes him liable
through the doctrine of respondeat superior, and as a result has committed an act “relating
to his office but” constituting “an unauthorized exercise of his official functions, where a
reasonable person with his training, expertise, and experiences should know that such act
is unauthorized”, making RootEntry liable for the tort of Official Misconduct.
THIRTEENTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant Commissioner_Jason)
91. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
92. Pursuant to 1 R. Stat. § 3114, “[a]ny individual who is a public servant and commits an
act relating to his office but constitutes an unauthorized exercise of his official functions,
where a reasonable person with his training, expertise, and experiences should know that
such act is unauthorized” is liable for the tort of Official Misconduct.
93. Chief of Police Commissioner_Jason is an extremely experienced law enforcement
officer. He has had an extensive amount of training, expertise, and experiences.
94. Chief of Police Commissioner_Jason is a graduate of Class 2 of the Law Enforcement
Training Center, and has been employed in the Palmer Police Department since January
31st, 2021, and has no disciplinary actions on record.
95. Chief of Police Commissioner_Jason is a long time member of the Palmer Police
Department’s high command. He has been in the Palmer Police Department’s high
command for nearly 3 years. Prior to serving as the Chief of Police, he served as the
Deputy Chief of Police under Chief of Police LewisMedvedeva.
96. Chief of Police Commissioner_Jason, through this certification and these positions, has
received a great amount of training, expertise, and experience.
97. Chief of Police Commissioner_Jason, having sworn an oath to the Constitution and to
faithfully execute all laws, actions of issuing the plaintiff a permanent, arbitrary, and
retaliatory demotion for seeking counsel and taking legal action against the department,
has made him have committed an act “relating to his office but” constituting “an
unauthorized exercise of his official functions, where a reasonable person with his
training, expertise, and experiences should know that such act is unauthorized”, making
Commissioner_Jason liable for the tort of Official Misconduct.
FOURTEENTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant Commissioner_Jason)
98. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
99. Chief of Police Commissioner_Jason, having sworn an oath to the Constitution and to
faithfully execute all laws, actions of unjustly treating and oppressing the plaintiff by
threatening and putting him at fear with an at-will termination while on an extended leave
of absence has made him have committed an act “relating to his office but” constituting
“an unauthorized exercise of his official functions, where a reasonable person with his
training, expertise, and experiences should know that such act is unauthorized”, making
Commissioner_Jason liable for the tort of Official Misconduct.
FIFTEENTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant Commissioner_Jason)
100. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
101. Chief of Police Commissioner_Jason, having sworn an oath to the Constitution and to
faithfully execute all laws, actions of issuing a shadow-blacklist on the plaintiff has made
him have committed an act “relating to his office but” constituting “an unauthorized
exercise of his official functions, where a reasonable person with his training, expertise,
and experiences should know that such act is unauthorized”, making
Commissioner_Jason liable for the tort of Official Misconduct.
SIXTEENTH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant Commissioner_Jason)
102. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
103. Chief of Police Commissioner_Jason is the department head of the Palmer Police
Department. He is responsible for the actions of his employees.
104. Chief of Police Commissioner_Jason, having sworn an oath to the Constitution and to
faithfully execute all laws, actions of arbitrarily punishing the plaintiff with demotion
through Acting Lieutenant AllyCoretti and Captain RootEntry makes him liable through
the doctrine of respondeat superior, and as a result has committed an act “relating to his
office but” constituting “an unauthorized exercise of his official functions, where a
reasonable person with his training, expertise, and experiences should know that such act
is unauthorized”, making Commissioner_Jason liable for the tort of Official Misconduct.
SEVENTEETH CAUSE OF ACTION
(Official Misconduct - 1 R. Stat. § 3114)
(As to defendant Commissioner_Jason)
105. The allegations in the previous paragraphs are incorporated as reference as if fully set
forth herein.
106. Chief of Police Commissioner_Jason is the department head of the Palmer Police
Department. He is responsible for the actions of his employees.
107. Chief of Police Commissioner_Jason, having sworn an oath to the Constitution and to
faithfully execute all laws, actions of committing harassment, oppression, obstruction,
abuse, and coercion unto the plaintiff through Acting Lieutenant AllyCoretti makes him
liable through the doctrine of respondeat superior, and as a result has committed an act
“relating to his office but” constituting “an unauthorized exercise of his official functions,
where a reasonable person with his training, expertise, and experiences should know that
such act is unauthorized”, making Commissioner_Jason liable for the tort of Official
Misconduct.
PRAYERS FOR RELIEF
108. WHEREFORE, the plaintiff requests that the court grant relief as follows:
A. Declaratory relief, declaring that the defendants are liable for their respective
causes of action as described in this complaint.
B. An injunction, ordering the plaintiff to be reinstated to his previous position as
Sergeant of the Public Affairs Unit.
C. An injunction, reversing the permanent demotion and removing the shadow
blacklist issued by Commissioner_Jason.
D. An injunction, ordering AllyCoretti and Commissioner_Jason to cease the activity
of unlawfully oppression, harassing, obstructing, abusing, and coercing the
plaintiff.
E. An injunction, ordering Commissioner_Jason to not take retaliatory action in the
matter.
F. An injunction, prohibiting the defendants from disciplining the plaintiff further in
the matter.
G. An injunction, ordering the defendants to cease all unlawful activity mentioned in
this complaint.
H. All actual, compensatory, and punitive damages.
I. All attorney costs and fees.
J. Any other relief that is not specifically requested through this complaint that the
Court deems necessary.
Dated: June 30th, 2024 Respectfully submitted.
/s/ JamesGardai
_______________________________
JamesGardai, Esq.
Counsel of Record
Ridgeway Bar No. 24101
Associate Attorney
Clarke, Feelings & Associates, LLP.
