Docket NO:
IN THE SUPERIOR COURT
OF THE STATE OF RIDGEWAY,
COUNTY OF RIDGEWAY
______________________
STEMPIEE,
Plaintiff,
v.
BRUNOMONTIEL1,
Defendant.
______________________
COMPLAINT IN A CIVIL ACTION
Plaintiff Stempiee, proceeding pro se, alleges for her complaint against BrunoMontiel1 as
follows:
PARTIES
1. Plaintiff Stempiee is a resident of the State of Ridgeway.
2. Defendant BrunoMontiel1 is a resident of the State of Ridgeway and the
proprietor of the business known as Maple Ridge Coffee.
JURISDICTION AND VENUE
3. This Court, the Superior Court of the State of Ridgeway, "shall exercise original
jurisdiction for all civil and criminal cases or controversies under the rules as set by the Supreme
Court." Rid. Const. art. V, § IV. By statute, it has original jurisdiction over "all civil claims" and
over "any controversy not otherwise falling within the jurisdiction of the Supreme Court,
Administrative Court, or Magistrate Court as set forth by law." 3 R. Stat. § 131.004(c), (e). This
action asserts civil claims under 7 R. Stat. §§ 121.001 and 121.302; jurisdiction is therefore
proper.
4. This court is the proper venue because civil actions shall only take place in the
county where the controversy occurs. See 7 R. Stat. §§ 131.001–131.003. Since this takes place
within the County of Ridgeway, a county of the State of Ridgeway pursuant to 9 R. Stat.
§ 321.001, venue is proper.
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STATEMENT OF FACTS
5. On or about August 4, 2026 at approximately 22:38 PM, Plaintiff was present
outside Defendant's business, Maple Ridge Coffee, located in the Frederick R. Poole Business
District, Milton.
6. Plaintiff was, at that time, using a fire axe to damage furniture belonging to
Defendant that was situated outside the business premises.
7. Defendant ran towards the business and approached Plaintiff at a run.
8. Defendant discharged his firearm for the first time. At the time of this first
discharge, Plaintiff was in close physical proximity to Defendant.
9. Following the first discharge, the distance between Plaintiff and Defendant
increased, and Plaintiff was no longer in close proximity to Defendant, nor advancing toward
him, nor otherwise engaged in any conduct directed at Defendant's person.
10. Notwithstanding the change in circumstances described in Paragraph 9, Defendant
discharged his firearm a second time.
11. At the time of the second discharge, Plaintiff posed no immediate threat to
Defendant's person, was not within striking distance of Defendant, and had given Defendant no
reason to believe further force was immediately necessary.
12. Both discharges struck the ground and not Plaintiff's person; no rounds struck
Plaintiff.
13. Defendant's second discharge was intentional and voluntary, and was not the
product of accident or mistake.
14. As a direct result of Defendant's second discharge, Plaintiff suffered reasonable
apprehension of immediate harmful or offensive contact, as well as fear for her safety and
emotional distress.
15. Plaintiff acknowledges that her own conduct described in Paragraph 6 may bear
on the reasonableness of Defendant's first discharge, and this complaint accordingly directs its
claims at the second discharge described in Paragraphs 9 through 11.
FIRST CAUSE OF ACTION
7 R. Stat. § 121.001 Assault
16. Plaintiff incorporates the foregoing paragraphs by reference.
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17. Defendant's second discharge of the firearm was an intentional and voluntary act.
18. Defendant's second discharge of the firearm caused Plaintiff reasonable
apprehension of immediate harmful or offensive contact.
19. As a direct result, Plaintiff is entitled to punitive damages pursuant to 7 R. Stat. §
121.001, in an amount not to exceed $4,000.00.
SECOND CAUSE OF ACTION
7 R. Stat. § 121.302 Negligence Per Se
20. Plaintiff incorporates the foregoing paragraphs by reference.
21. R.C.C. § 2.33 prohibits any person from knowingly discharging a firearm within
city limits or in residential areas without legal reason to do so, such as a permit or self-defense.
The statute is intended to prevent the endangerment of, and resulting injury to, persons in
populated areas, which is the injury Plaintiff suffered. The discharge described in Paragraph 10
occurred within the city limits of Milton.
22. Defendant breached this duty by discharging his firearm a second time without
legal reason, as alleged above.
23. As a direct and proximate result of Defendant's breach, Plaintiff suffered injury in
the form of emotional distress.
24. Plaintiff is entitled to compensatory damages, and punitive damages pursuant to 7
R. Stat. § 121.302, in an amount not to exceed $7,500.00.
DEMAND FOR RELIEF
WHEREFORE, Plaintiff demands judgment against Defendant as follows:
a. Compensatory damages in an amount to be determined at trial;
b. Punitive damages of up to $4,000.00 on Count I;
c. Punitive damages of up to $7,500.00 on Count II;
d. Costs of this action; and
e. Such other relief as the Court deems just and proper.
Dated: 09/29/2026 Respectfully submitted:
/s/ STEMPIEE
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Docket NO:
___________________________
Stempiee
Plaintiff pro se
@virridity
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