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Lawsuit filed at Superior Court of Santa Cruz for criminal offenses against Jack LADD
Lawsuit filed at Superior Court of Santa Cruz for criminal offenses against Jack LADD, Lyle WOLLERT, Ryan YORK, Phil WOWAK;
Complaint filed at Superior Court of Santa Cruz the 30th of october 2014 asking for a jury trial.
For
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
2. – FORGED INVOICE AND FRAUD
3. – ROBBERY
4. -COMPLICITY OF ROBBERY
5.- DELIBERATE OBSTRUCTION OF JUSTICE
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
Complaint filed at Superior Court of Santa Cruz the 30th of october 2014 asking for a jury trial.
For
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
2. – FORGED INVOICE AND FRAUD
3. – ROBBERY
4. -COMPLICITY OF ROBBERY
5.- DELIBERATE OBSTRUCTION OF JUSTICE
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
Complaint filed at Superior Court of Santa Cruz the 30th of october 2014 asking for a jury trial.
For
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
2. – FORGED INVOICE AND FRAUD
3. – ROBBERY
4. -COMPLICITY OF ROBBERY
5.- DELIBERATE OBSTRUCTION OF JUSTICE
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
Against
- Jack LADD of « LADD’S Auto Body & Towing »
- Lyle WOLLERT, of « LADD’S Auto Body & Towing »
- Ryan YORK, Deputy Sheriff representing Sheriff-Coroner Phil WOWAK;
- Phil WOWAK, Sheriff-Coroner;
Plaintiff, Laurent GRANIER (hereinafter « Plaintiff » or « GRANIER ») alleges and pleads as follows:
The original case.
Plaintiff, Laurent GRANIER has had a car accident when driving his car, a classic british one, a 53 MG, the afternoon of the 09th of october 2014, around 3 pm, on the highway 9 in the direction from FELTON to BOULDER CREEK. Another car, a SUBARU, driven by PERRI NOELLE MONTGOMERY arrived behind him fast. She was unable to stop, and even to avoid Laurent GRANIER’s car, and she hit it in the right side of the back. She is 100% responsible.
Neighbors having heard the collision, went outside and called 911. Ambulance arrived first, and Police later. Because Plaintiff, Laurent GRANIER had pain in his back, left shoulder, his neck and his left bottom, he has been brought by an ambulance to the Hospital of Santa Cruz (Dominican). By this time, Police officer who did the report, called a company, « LADD’s » from FELTON, agreed by « AAA », to tow the two cars.
Before to be brought by the ambulance to hospital, Laurent GRANIER gave to the Police Officer a copy of his « AAA » membership (« Premier », which is the highest grade) in order to do the work under his own privilege.
Jack LADD, owner of « LADD’S Auto Body & Towing », and Lyle WOLLERT, manager of « LADD’S Auto Body & Towing » have the responsibility to keep the car for the owner, Plaintiff.
For the following days, Plaintiff, Laurent GRANIER being victim, has had to manage his body pain, and his property damages, in order to avoid an increase of them, and the creation of new ones in his private and professional lifes, caused by all the hassle coming from the accident.
During this difficult time, Laurent GRANIER was alone, being not helped by his own insurance company, « PROGRESSIVE/DRIVE », and let alone by the insurance of the other driver, in order to settle his expenses, his losses, like an hotel because he had to stay in this area to settle the problems caused by the accident.
Yet, the day after the accident, he filed the claim to his insurance. But, he has had no help, no assistance, no advise like the simple fact how and what to do.
Fortunately, his insurance broker helped Laurent GRANIER by explaining him that, as victim, and as the other person who caused the accident was identified, and insured, he had to do everything by himself, his own insurance company having not to take care of his situation anymore.
And so, he even had to contact directly the insurance of the driver who victimized him…
The following monday, having no help, no assistance from his own insurance, to know what to do, Plaintiff has had to get information about the other driver and her insurance, by going to Police station.
The insurance company of the adverse party sent on monday 20th of october 2014, an expert to LADD’S Auto Body & Towing in FELTON.
Laurent GRANIER, Plaintiff, that his car was estimated at the strange and low price of $17,086.20, despite the fact, that two days before, Laurent GRANIER sent to claims manager of the insurance company of the adverse party, an ad for the same car, 53 MG TD, in the same condition but not the same color, for sale by a professional at $39,990.
There was in this offer, the repayment for the tow and the storage at « LADD’s » for $ 1485.00
Tow and Storage $180 tow
15 days at 75 p/day $1,305.00
At once, Plaintiff sent to Defendants, CJ. LUCAS and her manager, Cynthia VELASCO, several emails under the title of « Re: Claim: 011665727 FORMAL NOTICE of CRIMINAL COMPLAINT and CIVIL LAWSUIT FOR CRIMINAL OFFENSES » to ask them proofs about this fanciful estimate of his car -expertise report-, and by the same time, all legal information about the company she worked for and spoke and decided in its name, and the name of its highest responsibles. None of them replied, but CJ. LUCAS took care, to send three times the same email from a prior email, so with only the title « Claim: 011665727 », and so, in order to avoid to give to Plaintiff the proof she had received his FORMAL REQUEST. For information, copy of each FORMAL NOTICE sent by Plaintiff to CJ. LUCAS, has been sent to Cynthia VELASCO, Steve DOUGLAS, the company the latter works for, « Property Damages Appraisers, Inc. » , and Daniel WARNICK, Claims Manager at « PROGRESSIVE/DRIVE », his insurance company.
Laurent GRANIER, as yet victim, and being screwed, facing ingratitude, disrespect, dishonesty, bad faith from the representatives of the insurance company which has to pay him, decided not to give up anything anymore, and asked for all his losses.
So, in each FORMAL NOTICE, he claimed :
$40,000 for the value of his car ( few evaluations on internet give a price up to 50,000);
$5,000 for the sentimental value about the loss;
$5,000 for the additional value of his car having black original plates of State of California;
$4,400 for tax and registration;
$5,000 for his future personal expenses to find a new car like this one, expecting at least 3 months;
$5,000 to travel and to check the car before to buy it, because most of time pictures in ads are not the reality and we go for nothing;
$100 daily for the loss of pleasure to use his car because it is not a commuting car but a pleasure, what is proved by its nature, classic car, but also by the fact it is a convertible, and it is declared at his insurance as a pleasure car, so starting from the day of the accident until the day he’ll find one exactly the same, condition and color;
$100 daily to rent a car until the date he’ll find a new one to replace it;
$350 for the rental car of the first week ;
$1,300 for the two weeks at hotel which is not finished at the day of the complaint ;
So, a total of $72,050 for property damages and expenses, without the damages caused by their deliberate dirty and unlawful behaviour on his health, on his life and on his work.
Being CEO of a corporation in California, and of a Company in London, from one side, and author, inventor, theoretician, master philosopher, from another one, all those troubles, all those hassle disturbed his mind, his main tool, and so his lifes, professional and private, and so, Plaintiff is asking $500,000.
Plaintiff, Laurent GRANIER filed a complaint to California Department of Insurance (CDI) for the lacks and misconducts of some responsibles of the insurance company, self-named « AAA SOUTHERN CALIFORNIA INSURANCE ».
Plaintiff filed the 28th of october 2014, a complaint at Superior Court of Santa Cruz for a jury trial, against several responsibles of the insurance company of teh adverse party.
Facts and acts regardings Defendants.
Morning, the 29th of october 2014 around 9, Plaintiff went to Ladd’s, to see his car. He discovered that it was not there. First, Lyle WOLLERT told him that someone picked it up the day before, saying by the insurance company, but without mentioning its name. Plaintiff asked him to give him a copy of the document from the person who took the car, as he has to ask when he releases a car.
He did not know, and told to Plaintiff to see with the owner, Jack LADD. Jack LADD gave, in fact a copy of a kind of invoice he did himself because his invoice, and showing an amount the person who took the car had paid to him, a round sum of $1750.
His explanation was unclear and nebulous, and more, Jack LADD laughed when Plaintiff told him he was going to sue him for his misconduct, replying only « Godd Luck ».
The insurance company of Laurent GRANIER is « PROGRESSIVE », has not to take his car for any reason because it has not to pay for anything about this accident, and the responsibles do not even know here was the car.
At once, Laurent GRANIER went to Sheriff’s office in FELTON. He was well comen, but he wait half an hour for the deputy Ryan YORK, to take his complaint. Ryan YORK is Deputy Sheriff representing Sheriff-Coroner Phil WOWAK. He asked to Laurent GRANIER ONE question about where was the car, but he seemed to have yet an idea, a position to take. He went to his office and called Jack LADD in private. Few minutes later, Ryan YORK told to Laurent GRANIER that his car had been picked it up by the insurance company, a so-called « CAA » and so, it was a civil case, and not a crimInal one, the car was not stolen.
Indeed, ryan YORK said all that Jack LADD told him, even his judgement or legal advises. Laurent GRANIER replied that he did not agree because first, « CAA » is not an insurance company, second, he never gave the authorization to anyone to pick up his car, third, his insurance company is « PROGRESSIVE » and not « CAA », and none had the right to take it, and so, it was not a cvil case but a criminal one. Laurent GRANIER insisted to file a report, but Ryan YORK refused, and Laurent GRANIER asked him to give him a report about his conversation with Jack LADD. He refused too.
Plaintiff, victim of an accident in the course of which he missed to be killed, or very seriously injured, thanks to his good reflexe and his lucky star, lost his car, a part of data of his laptop, money, time, energy, health, and opportunities. In addition, the insurance company of the adverse party which has to reduce his problems, his troubles, took advantage on him by increasing them, and even by creating new ones.
At the time when this complaint is filed, none of problems caused by the accident is solved, none about property, none about body injury. And in addtion, new ones occured by the fault of the insurance company of the adverse party.
In addition, Jack LADD and Lyle WOLLERT deliberately did act wrongly, unlawfully, in order to take advantage on their client, Laurent GRANIER, and to commit with impunity criminal acts against his interests, with the protection of one person representing authority.
FIRST CAUSE OF ACTION
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
against Jack LADD, Lyle WOLLERT, and DOES 1-50
Jack LADD and Lyle WOLLERT towed Laurent GRANIER’s car after an accident because they have been called by a police officer of CHP, and because they are agreed to do it.
Their duty is to keep the car, and to release to the owner. Only its owner.
They towed it the 09th of october 2014, and since this date, they kept the car under the will of his owner, Plaintiff. Laurent GRANIER wanted to keep his car in a neutral location, to avoid any scam, cheatery, bad faith from the insurance company of the adverse party, which had to repair it, or to pay it at its replacement value.
At this time, Laurent GRANIER, Plaintiff, is the owner of the 53 MG TD, VIN XPAGTD224825 under the CA title « LXX474 ». He has his title and even its registration card until 06/14/2015.
When Laurent GRANIER went to « Ladd’s Tow » the morning of the 29th of october 2014 to see his car, he discovered that it was not there. First, Lyle WOLLERT, the manager, told him that someone picked it up the day before, by the insurance company, but without mentioning its name.
Plaintiff asked him to give him a copy of the document from the person who took the car, as he has to ask when he releases a car. He did not know, and told to Plaintiff to see with the owner, Jack LADD. Jack LADD gave in fact a copy of a kind of invoice he did himself because his invoice about its tow and storage, saying that it was paid by the person who took the car, but he did not know what was his identity.
His explanation was unclear and nebulous, and more, Jack LADD laughed when Plaintiff told him he was going to sue him for his unacceptable misconduct. He only replied « Good Luck ».
Any person who has the responsibility to keep a property, has to release it only to its owner, or to a person who has the authorization from the owner, and a document. None professional has the right to release to anyone, a property for which he has the responsibility to its owner, and it is true without any proof and document, any certificate and proof of identity of the person who requests it if he is not the owner but an authorized one by the owner. In addition, the responsible has to keep all documents, or at least, copies.
For information, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». It has never picked up the car. And Plaintiff is not a client of any else insurance company.
In conclusion, by releasing a car which is under their responsibilities, to an unknown person, to a person who is not the owner, Plaintiff, to a person who has not any authorization from the owner, Plaintiff, Defendants Jack LADD and Lyle WOLLERT did commit the offense of DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS towards Plaintiff.
Each defendant did not respect the duty they have to do according the Law, and is fully responsible of those offenses towards Plaintiff, and caused to him more and new financial and health damages.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
SECOND CAUSE OF ACTION
2. – FORGED INVOICE AND FRAUD
against Jack LADD, Lyle WOLLERT, and DOES 1-50
When Laurent GRANIER went to « Ladd’s Tow » the morning of the 29th of october 2014 to see his car, he discovered that it was not there. First, Lyle WOLLERT told him that someone picked it up the day before, by the insurance company, but without mentioning its name. Plaintiff asked him to give him a copy of the document from the person who took the car, as he has to ask when he releases a car. He did not know, and told to Plaintiff to see with the owner, Jack LADD.
Maliciously, Jack LADD gave in fact a copy of a kind of invoice he did himself because his invoice regarding its tow and storage, saying that it was paid by the person who took the car, but he did not know what was his identity. His explanation was unclear and nebulous, and more, Jack LADD laughed when Plaintiff told him he was going to sue him for his unacceptable misconduct. He only replied « Good Luck ».
Defendants Jack LADD and Lyle WOLLERT were deliberately unclear, nebulous when they have to give to the owner, Plaintiff, an explanation for their misconduct and information about the identity of the person to whom they gave Plaintiff’s car without any document, any authorization, seeming as if they have made the mistake to fail the respect of their main professional duty according the Law.
The kind of invoice edited and provided by Jack LADD is indeed a fake, a forgery, first because it is at the name of Laurent GRANIER, who has not asked for it, who did not know its existence, and which presents a wrong address about him, and second because Plaintiff has not paid it, has not authorized anyone to pay it, and third because its payment has been done with a bank card which is not one of Laurent GRANIER’s one, and let alone a bank card provided by Laurent GRANIER himself, or with a bank card by an identified authorized person by Laurent GRANIER.
Otherwise, and it is very interesting, the amount, the price paid by the unidentifed so-called person representing a so-called company, if he really exists, in order to take the car, is a round number, which includes tax. Normally, the claimed price was $75 daily and $180 for the tow, and of course because we are in USA, the price is without tax, a way which leads for most of time to a price to pay, far to be a round one. The amount of the kind of invoice is $1750, an arranged price.
How a person can make a round and arranged price to a person he does not know, or with whom he has not any advantage, any benfit, any partnership…
As a reminder, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». It has never picked up the car, and has not to pay anything for this accident. And Plaintiff is not a client of any else insurance company.
In conclusion, by editing an invoice to a name of a person, Plaintiff, who is not aware of its existence, by editing an invoice with a wrong address about the person billed, Plaintiff, by being paid by another unidentifed person than the person billed, Plaintiff, by being paid by an unauthorized person by the billed person, Plaintiff, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offense of FORGED INVOICE AND FRAUD towards Plaintiff.
As concerning criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect, and who trusted them.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
THIRD CAUSE OF ACTION
3. – ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
Maliciously, Defendants Jack LADD and Lyle WOLLERT were deliberately unclear, nebulous in order to give to Plaintiff an explanation for their professional misconduct and information about the identity of the person to whom they gave Plaintiff’s car without any right, any authorization, seeming as if they have made the mistake to fail the respect of their main professional duty according the Law.
Indeed, if they have no proof of the release, about the identity of the person who took the car, if they did not ask him any document in order to release the car to another pseron than the owner, Plaintiff, it is only because they have themselves stolen Plaintiff’s car, who was their client.
To agree with this fact, we can see that they were not afraid by the local authorities, having yet a relationship with them, thanks to their job, and having yet a strategy by some already prepared legal answers, but indeed totally wrong because false.
Jack LADD claimed to the easy, with him, Deputy Sheriff, Ryan YORK, that it was a civil case with the insurance company, named « CAA ».
But, yet, none insurance company named « CAA » is registered at the State of California, and second, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». In addition, his insurance company did not care about his car for this accident because he was not responsible, and so, it had not to pick it up, and in addition, it even did not know where was his car. And Plaintiff is not a client of any else insurance company.
Because its owner, Plaintiff never asked to pick it up, never asked to change its location, and as owner, he does not know who took his property, and even where it is, and above all, he can not see it, or take care of it, or use it, or simply enjoy of the total freedom that any owner has the right to keep about his own property, Plaintiff’s car has been stolen.
Anyway, even if we admit, if it is true that Jack LADD and Lyle WOLLERT gave the car to anyone else, we have to consider that Jack LADD and Lyle WOLLER have stolen first the car to Plaintiff, to give them to anyone else. Insurance company, or not, it remains an act of robbery from its origin, even they have not the car anymore.
In conclusion, under the facts that Plaintiff never gave any authorization to anyone to pick up his car, that Plaintiff does not know who took it, who gets it, and where it is, that Plaintiff has no possibility to use all advantages, benefits, privileges and freedom as any owner of property has the absolute and exclusive right to claim and to keep, and by the fact that Defendants had the full access and the full means to his property, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offense of ROBBERY towards Plaintiff.
As concerning criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect, and who trusted them.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
FOURTH CAUSE OF ACTION
4. – COMPLICITY OF ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
If we could accept the fact that the car has not been really stolen by Jack LADD and Lyle WOLLERT, it remains it has been stolen, because its owner, Plaintiff never asked to pick it up, never asked to change its location, and as owner, he does not know who took it, who gets it, and even where it is. In addition, and above all, he can not see it, or use the total freedom that any owner has the absolute and exclusive right to claim and to keep.
So, it remains to be a robbery, Plaintiff’s car has been stolen.
And if Jack LADD and Lyle WOLLERT are not the robbers, they are at least, the accomplices of the robbers.
Anyway, their first motive and benefit is about the payment of the so-called invoice billed to Plaintiff’s name with a wrong address, a fake invoice, which is a fraud too, because paid by an unidentified unauthorized person, and for a strange sum, with a round arranged number, higher than the previous official one.
If it was a breach of their professional duties, meaning non deliberate, it should remain difficult to understand, and to accept as true, for people working in this domain since a while, and agreed by Law, for which they have to know their duty, and their obligation.
As a reminder, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». It has never picked up the car. And Plaintiff is not a client of any else insurance company.
In conclusion, if it was the case, by releasing a car which is under their responsibilities to an unknown person, to a person who is not the owner, Plaintiff, to a person who has not any authorization from the owner, Plaintiff, and as the car has to be considered as stolen, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offense of COMPLICITY OF ROBBERY towards Plaintiff.
As concerning criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
FIFTH CAUSE OF ACTION
5. – DELIBERATE OBSTRUCTION OF JUSTICE
against Jack LADD, Lyle WOLLERT, and DOES 1-50
If the car were not stolen by them, or by any else, why Jack LADD and Lyle WOLLERT did not anything to help Plaintiff, their client, who became victim. Quite the opposite, they declared wrong and fake legal arguments, they protected the interest of the person who picked it up the car, the robber, they were not able to identify him, they claims that it was the insurance company « CAA » , which does not exist, they claims that it was a civil problem, that is not.
First, the problem between Plaintiff and the insurance company of the adverse party is aside the fact that Jack LADD and Lyle WOLLERT gave the car to anyone else than the owner, Plaintiff.
Second, the problem between Plaintiff and the insurance company of the adverse party is about criminal offenses committed by several persons of the insurance company, Plaintiff having yet filed a complaint to California Department of Insurance, and to Superior Court of Santa Cruz for a jury trial.
Third, the situation between Plaintiff and the insurance company of the adverse party is not the business of Jack LADD and Lyle WOLLERT.
Fourth, Plaintiff was the client of Jack LADD and Lyle WOLLERT, so the latter had a contract with him, and so, professional duties and obligations.
Indeed, they were outside their duties, their obligations, and so, their rights. They have stolen the car.
Jack LADD claimed to Deputy Sheriff, Ryan YORK that the insurance company took it, but he did not give any proof of his declaration. If it was true, he should have documents, as any professional requests to release a property. And other wise,
Otherwise, it claimed to Deputy Sheriff, Ryan YORK that it was a civil case. Not at all.
First, if there was a civil case, it was between Plaintiff and the insurance company, not between Plaintiff and Jack LADD and Lyle WOLLERT, which is a different case because they committed criminal offenses, anyway there was or not a dispute with the insurance company.
Second, Jack LADD and Lyle WOLLERT have no right to be a judge, and to determine if the problem between Plaintiff and the insurance company of the adverse party is civil, criminal, or both.
He was not part of it, and he had not to give some information, some legal advise. It is against the Law. His behaviour shows without any doubt his collusion with the insurance company who agreed him, who pay him all the year. It is a pure corruption.
Third, and it is very important, none insurance company has the right to take a property from his owner, without his authorization, without any right. And in the present case, if there was dispute between Plaintiff and an insurance company, it is not with his own insurance company, so with a company from which he is not client, has never signed of contract, has never asked anything other than to be paid for the damages about the status of victim caused by one of their client.
Even if the robbery were committed by the insurance company, meaning the one of the adverse party, it remains that Jack LADD and Lyle WOLLERT protected them, made and makes money with them, having a contract with them, and acted unlawfully against the interest of Plaintiff who was their client.
So, if it is proven that indeed, it was the insurance company of the adverse party which took unlawfully the car from them, the act remains a criminal one, so Plaintiff’s property has been stolen, at least with the complicity of Jack LADD and Lyle WOLLERT, if we don’t consider that the latter have stolen first the car from their client, Plaintiff. In this case, Jack LADD and Lyle WOLLERT should be associated with the defendants listed in the civil complaint filed the 28th of october 2014 at Superior Court of Santa Cruz by Plaintiff, against the insurance company of the adverse party, and so, as accomplices of the criminal offenses, at least of blackmails, scams, lies, trickeries, attempted extortion and intentional inflictions of emotional distress.
Even if we agreed that Jack LADD and Lyle WOLLERT did a serious mistake, and it should be difficult to put their act, their behaviour under the status of non deliberate, non partnership with a company which pays him all the year, they did not help at all their client, Plaintiff. Quite the oposite, Jack LADD laughed and replied « Good Luck » to Plaintiff when he told him he was going to sue him.
In conclusion, by deliberately withholding information about criminals acts towards Plaintiff, by deliberately withholding the real identity of the person having committed a criminal offense towards Plaintiff, by deliberately taking part and protecting the interest of a criminal who acted towards Plaintiff, by being yet involoved by their own criminal offenses towards Plaintiff, by deliberately declaring fake and wrong assertions to authorities towards Plaintiff, by deliberately giving fake and wrong interpretations and understanding of the Law towards Plaintiff, by deliberately giving a kind of judgement towards Plaintiff, by deliberately giving legal advises which are wrong in order to lead authorities in the wrong direction and decision towards Plaintiff, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offenses of DELIBERATE OBSTRUCTION OF JUSTICE towards Plaintiff.
As concerning deliberate offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
SIXTH CAUSE OF ACTION
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
against Ryan YORK, Phil WOWAK, and DOES 1-50
Plaintiff re-alleges herein by this reference each and every allegation previously contained in the present complaint.
Ryan YORK is Deputy Sheriff at Sheriff-Coroner’s office, 701 Ocean Street, Room 340, Santa Cruz. He is representing Phil WOWAK, Sheriff-Coroner, but Plaintiff met him at Sheriff’s office in FELTON, the morning of 29th of october 2014, following the discovery of the robery of his car from where it was parked, at « LADD’S Auto Body & Towing ».
Indeed, Plaintiff has understood that the steal of his car had been committed by Jack LADD and Lyle WOLLERT, or at least they were accomplice of the robbery, or at least they were responsibles.
At once, Laurent GRANIER went to Sheriff’s office in FELTON. He was well comen, but he wait half an hour for the deputy Ryan YORK, in order to file the report of the criminal offense.
First, Ryan YORK asked to Laurent GRANIER one question about where was the car, but he seemed to have yet the answer, or at least get an idea, a position to take. He went to his own office and called Jack LADD in private. Few minutes later, Ryan YORK came back and told to Laurent GRANIER that his car had been picked it up by the insurance company, a so-called « CAA » and so, it was a civil case, and not a criminal one, declaring that the car was not stolen.
Indeed, he said all that Jack LADD told him, even his personal judgement and wrong legal advise.
Plaintiff asked to Ryan YORK to write that Jack LADD told him, but he refused.
Laurent GRANIER replied that he did not agree because first, « CAA » is not a registered insurance company, second, he never gave the authorization to anyone to pick up the car, third, his insurance company is « PROGRESSIVE » and not « CAA », and so none had the right to take it, and so, it was never a cvil case but a criminal one. In addition, Plaintiff told to Ryan YORK that nevertheless it was a civil case between him and an insurance company, it remains that the behaviours and acts committed by Jack LADD and Lyle WOLLERT towards Plaintiff were criminal offenses, and so, he was there to file a report against Jack LADD and Lyle WOLLERT, no matter about an insurance company or not. Jack LADD and Lyle WOLLERT did criminal offenses, that’s it.
Laurent GRANIER insisted to file a report, but Ryan YORK refused, and Laurent GRANIER asked him again to give him a report about his conversation with Jack LADD. He refused too, again. Indeed, Ryan YORK listened exclusively to Jack LADD, his declarations, and his legal advises, and his legal consultation and even his judgement which was by saying it was only a civil case. By the same time, Ryan YORK deliberately did not want to listen the victim of Jack LADD and Lyle WOLLERT, Plaintiff’s declarations, legal claims. Indeed, Ryan YORK listened to the criminal, but not to the victim of the criminal. Even, when Plaintiff insisted to file a complaint, he refused.
First, Ryan YORK is not a lawyer, and let alone a judge, and he has not to decide, to declare what is an act, or not.
Second, if a victim comes to file a report, a complaint for a criminal act, a police officer has not the right to refuse to do it. If there are laws to punish false declarations, false complaints, false alerts, it is not for nothing, it is to avoid to get useless work. So, with the existence of a punishment in case of irrelevant declarations, the will of people wanting to file a complaint for any criminal act has to be taken seriously by people representing authorities and having the duty to report it.
Third, a person representing the authority has to be neutral, and has to listen to each party by the same manner.
Fourth, a person representing the authority has the obligation to write a report and to investigate.
Only the result of an investigation is a proof, a way to determine if a complaint is real or not, if it is criminal or not.
In conclusion, by deliberately failing all points of his main duty against the interest and the situation of Plaintiff, and for the exclusive benefit of the criminals, Jack LADD and Lyle WOLLERT, Defendants Ryan YORK did commit the criminal offenses of COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY towards Plaintiff.
As concerning deliberate and criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, he did not respect the duty he has to do according the Law.
Defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendant used deceits, lies, ruses and/or omissions to Plaintiff who was victim and who deserved to get considered as is, with respect, and, and in addtion who trusted him as person representing authority.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
PRAYER FOR RELIEF
On the FIRST CAUSE OF ACTION
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For an order declaring that Defendants owe to Plaintiff the sum of $72,050 for property damages and expenses ;
5. For actual damages to Plaintiff in an amount according to proof at trial;
6. For interest thereon at the maximum legally permissible rate;
7. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
8. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the SECOND CAUSE OF ACTION
2. – FORGED INVOICE AND FRAUD
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For actual damages to Plaintiff in an amount according to proof at trial;
5. For interest thereon at the maximum legally permissible rate;
6. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
7. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
8. For all costs of suit incurred herein; and
For such other and further relief as deemed just and proper.
On the THIRD CAUSE OF ACTION
3. – ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For an order declaring that Defendants owe to Plaintiff the sum of $72,050 for property damages and expenses ;
5. For actual damages to Plaintiff in an amount according to proof at trial;
6. For interest thereon at the maximum legally permissible rate;
7. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
8. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the FOURTH CAUSE OF ACTION
4. – COMPLICITY OF ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For an order declaring that Defendants owe to Plaintiff the sum of $72,050 for property damages and expenses ;
5. For actual damages to Plaintiff in an amount according to proof at trial;
6. For interest thereon at the maximum legally permissible rate;
7. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
8. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the FIFTH CAUSE OF ACTION
5. – DELIBERATE OBSTRUCTION OF JUSTICE
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
5. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
6. For retributory damages in a amount of $10.000.000, according pain and suffering Defendants did on Plaintiff, with the aggravating factor that Defendants took advantage by his professional position and have deliberately failed their main duty ;
7. For actual damages to Plaintiff in an amount according to proof at trial;
8. For interest thereon at the maximum legally permissible rate;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the SIXTH CAUSE OF ACTION
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
against Ryan YORK, Phil WOWAK, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses, and so an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of authority ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts ;
5. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
6. For retributory damages in a amount of $10.000.000, according pain and suffering Defendants did on Plaintiff, with the aggravating factor that Defendants took advantage by his professional position and have deliberately failed their main duty ;
7. For actual damages to Plaintiff in an amount according to proof at trial;
8. For interest thereon at the maximum legally permissible rate;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On all Causes of Action :
1. For attorney’s fees according to proof ;
2. For spent personal time and expenses according the status of representing self ;
3. For costs of suit incurred herein ; and
4. For such other and further relief as the Court may deem just and proper.
DEMAND FOR JURY TRIAL
Plaintiff, Laurent GRANIER, hereby demands a trial by jury.
The 30th of october 2014.
Laurent GRANIER, Plaintiff, self-represented
For
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
2. – FORGED INVOICE AND FRAUD
3. – ROBBERY
4. -COMPLICITY OF ROBBERY
5.- DELIBERATE OBSTRUCTION OF JUSTICE
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
Against
- Jack LADD of « LADD’S Auto Body & Towing »
- Lyle WOLLERT, of « LADD’S Auto Body & Towing »
- Ryan YORK, Deputy Sheriff representing Sheriff-Coroner Phil WOWAK;
- Phil WOWAK, Sheriff-Coroner;
Plaintiff, Laurent GRANIER (hereinafter « Plaintiff » or « GRANIER ») alleges and pleads as follows:
The original case.
Plaintiff, Laurent GRANIER has had a car accident when driving his car, a classic british one, a 53 MG, the afternoon of the 09th of october 2014, around 3 pm, on the highway 9 in the direction from FELTON to BOULDER CREEK. Another car, a SUBARU, driven by PERRI NOELLE MONTGOMERY arrived behind him fast. She was unable to stop, and even to avoid Laurent GRANIER’s car, and she hit it in the right side of the back. She is 100% responsible.
Neighbors having heard the collision, went outside and called 911. Ambulance arrived first, and Police later. Because Plaintiff, Laurent GRANIER had pain in his back, left shoulder, his neck and his left bottom, he has been brought by an ambulance to the Hospital of Santa Cruz (Dominican). By this time, Police officer who did the report, called a company, « LADD’s » from FELTON, agreed by « AAA », to tow the two cars.
Before to be brought by the ambulance to hospital, Laurent GRANIER gave to the Police Officer a copy of his « AAA » membership (« Premier », which is the highest grade) in order to do the work under his own privilege.
Jack LADD, owner of « LADD’S Auto Body & Towing », and Lyle WOLLERT, manager of « LADD’S Auto Body & Towing » have the responsibility to keep the car for the owner, Plaintiff.
For the following days, Plaintiff, Laurent GRANIER being victim, has had to manage his body pain, and his property damages, in order to avoid an increase of them, and the creation of new ones in his private and professional lifes, caused by all the hassle coming from the accident.
During this difficult time, Laurent GRANIER was alone, being not helped by his own insurance company, « PROGRESSIVE/DRIVE », and let alone by the insurance of the other driver, in order to settle his expenses, his losses, like an hotel because he had to stay in this area to settle the problems caused by the accident.
Yet, the day after the accident, he filed the claim to his insurance. But, he has had no help, no assistance, no advise like the simple fact how and what to do.
Fortunately, his insurance broker helped Laurent GRANIER by explaining him that, as victim, and as the other person who caused the accident was identified, and insured, he had to do everything by himself, his own insurance company having not to take care of his situation anymore.
And so, he even had to contact directly the insurance of the driver who victimized him…
The following monday, having no help, no assistance from his own insurance, to know what to do, Plaintiff has had to get information about the other driver and her insurance, by going to Police station.
The insurance company of the adverse party sent on monday 20th of october 2014, an expert to LADD’S Auto Body & Towing in FELTON.
Laurent GRANIER, Plaintiff, that his car was estimated at the strange and low price of $17,086.20, despite the fact, that two days before, Laurent GRANIER sent to claims manager of the insurance company of the adverse party, an ad for the same car, 53 MG TD, in the same condition but not the same color, for sale by a professional at $39,990.
There was in this offer, the repayment for the tow and the storage at « LADD’s » for $ 1485.00
Tow and Storage $180 tow
15 days at 75 p/day $1,305.00
At once, Plaintiff sent to Defendants, CJ. LUCAS and her manager, Cynthia VELASCO, several emails under the title of « Re: Claim: 011665727 FORMAL NOTICE of CRIMINAL COMPLAINT and CIVIL LAWSUIT FOR CRIMINAL OFFENSES » to ask them proofs about this fanciful estimate of his car -expertise report-, and by the same time, all legal information about the company she worked for and spoke and decided in its name, and the name of its highest responsibles. None of them replied, but CJ. LUCAS took care, to send three times the same email from a prior email, so with only the title « Claim: 011665727 », and so, in order to avoid to give to Plaintiff the proof she had received his FORMAL REQUEST. For information, copy of each FORMAL NOTICE sent by Plaintiff to CJ. LUCAS, has been sent to Cynthia VELASCO, Steve DOUGLAS, the company the latter works for, « Property Damages Appraisers, Inc. » , and Daniel WARNICK, Claims Manager at « PROGRESSIVE/DRIVE », his insurance company.
Laurent GRANIER, as yet victim, and being screwed, facing ingratitude, disrespect, dishonesty, bad faith from the representatives of the insurance company which has to pay him, decided not to give up anything anymore, and asked for all his losses.
So, in each FORMAL NOTICE, he claimed :
$40,000 for the value of his car ( few evaluations on internet give a price up to 50,000);
$5,000 for the sentimental value about the loss;
$5,000 for the additional value of his car having black original plates of State of California;
$4,400 for tax and registration;
$5,000 for his future personal expenses to find a new car like this one, expecting at least 3 months;
$5,000 to travel and to check the car before to buy it, because most of time pictures in ads are not the reality and we go for nothing;
$100 daily for the loss of pleasure to use his car because it is not a commuting car but a pleasure, what is proved by its nature, classic car, but also by the fact it is a convertible, and it is declared at his insurance as a pleasure car, so starting from the day of the accident until the day he’ll find one exactly the same, condition and color;
$100 daily to rent a car until the date he’ll find a new one to replace it;
$350 for the rental car of the first week ;
$1,300 for the two weeks at hotel which is not finished at the day of the complaint ;
So, a total of $72,050 for property damages and expenses, without the damages caused by their deliberate dirty and unlawful behaviour on his health, on his life and on his work.
Being CEO of a corporation in California, and of a Company in London, from one side, and author, inventor, theoretician, master philosopher, from another one, all those troubles, all those hassle disturbed his mind, his main tool, and so his lifes, professional and private, and so, Plaintiff is asking $500,000.
Plaintiff, Laurent GRANIER filed a complaint to California Department of Insurance (CDI) for the lacks and misconducts of some responsibles of the insurance company, self-named « AAA SOUTHERN CALIFORNIA INSURANCE ».
Plaintiff filed the 28th of october 2014, a complaint at Superior Court of Santa Cruz for a jury trial, against several responsibles of the insurance company of teh adverse party.
Facts and acts regardings Defendants.
Morning, the 29th of october 2014 around 9, Plaintiff went to Ladd’s, to see his car. He discovered that it was not there. First, Lyle WOLLERT told him that someone picked it up the day before, saying by the insurance company, but without mentioning its name. Plaintiff asked him to give him a copy of the document from the person who took the car, as he has to ask when he releases a car.
He did not know, and told to Plaintiff to see with the owner, Jack LADD. Jack LADD gave, in fact a copy of a kind of invoice he did himself because his invoice, and showing an amount the person who took the car had paid to him, a round sum of $1750.
His explanation was unclear and nebulous, and more, Jack LADD laughed when Plaintiff told him he was going to sue him for his misconduct, replying only « Godd Luck ».
The insurance company of Laurent GRANIER is « PROGRESSIVE », has not to take his car for any reason because it has not to pay for anything about this accident, and the responsibles do not even know here was the car.
At once, Laurent GRANIER went to Sheriff’s office in FELTON. He was well comen, but he wait half an hour for the deputy Ryan YORK, to take his complaint. Ryan YORK is Deputy Sheriff representing Sheriff-Coroner Phil WOWAK. He asked to Laurent GRANIER ONE question about where was the car, but he seemed to have yet an idea, a position to take. He went to his office and called Jack LADD in private. Few minutes later, Ryan YORK told to Laurent GRANIER that his car had been picked it up by the insurance company, a so-called « CAA » and so, it was a civil case, and not a crimInal one, the car was not stolen.
Indeed, ryan YORK said all that Jack LADD told him, even his judgement or legal advises. Laurent GRANIER replied that he did not agree because first, « CAA » is not an insurance company, second, he never gave the authorization to anyone to pick up his car, third, his insurance company is « PROGRESSIVE » and not « CAA », and none had the right to take it, and so, it was not a cvil case but a criminal one. Laurent GRANIER insisted to file a report, but Ryan YORK refused, and Laurent GRANIER asked him to give him a report about his conversation with Jack LADD. He refused too.
Plaintiff, victim of an accident in the course of which he missed to be killed, or very seriously injured, thanks to his good reflexe and his lucky star, lost his car, a part of data of his laptop, money, time, energy, health, and opportunities. In addition, the insurance company of the adverse party which has to reduce his problems, his troubles, took advantage on him by increasing them, and even by creating new ones.
At the time when this complaint is filed, none of problems caused by the accident is solved, none about property, none about body injury. And in addtion, new ones occured by the fault of the insurance company of the adverse party.
In addition, Jack LADD and Lyle WOLLERT deliberately did act wrongly, unlawfully, in order to take advantage on their client, Laurent GRANIER, and to commit with impunity criminal acts against his interests, with the protection of one person representing authority.
FIRST CAUSE OF ACTION
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
against Jack LADD, Lyle WOLLERT, and DOES 1-50
Jack LADD and Lyle WOLLERT towed Laurent GRANIER’s car after an accident because they have been called by a police officer of CHP, and because they are agreed to do it.
Their duty is to keep the car, and to release to the owner. Only its owner.
They towed it the 09th of october 2014, and since this date, they kept the car under the will of his owner, Plaintiff. Laurent GRANIER wanted to keep his car in a neutral location, to avoid any scam, cheatery, bad faith from the insurance company of the adverse party, which had to repair it, or to pay it at its replacement value.
At this time, Laurent GRANIER, Plaintiff, is the owner of the 53 MG TD, VIN XPAGTD224825 under the CA title « LXX474 ». He has his title and even its registration card until 06/14/2015.
When Laurent GRANIER went to « Ladd’s Tow » the morning of the 29th of october 2014 to see his car, he discovered that it was not there. First, Lyle WOLLERT, the manager, told him that someone picked it up the day before, by the insurance company, but without mentioning its name.
Plaintiff asked him to give him a copy of the document from the person who took the car, as he has to ask when he releases a car. He did not know, and told to Plaintiff to see with the owner, Jack LADD. Jack LADD gave in fact a copy of a kind of invoice he did himself because his invoice about its tow and storage, saying that it was paid by the person who took the car, but he did not know what was his identity.
His explanation was unclear and nebulous, and more, Jack LADD laughed when Plaintiff told him he was going to sue him for his unacceptable misconduct. He only replied « Good Luck ».
Any person who has the responsibility to keep a property, has to release it only to its owner, or to a person who has the authorization from the owner, and a document. None professional has the right to release to anyone, a property for which he has the responsibility to its owner, and it is true without any proof and document, any certificate and proof of identity of the person who requests it if he is not the owner but an authorized one by the owner. In addition, the responsible has to keep all documents, or at least, copies.
For information, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». It has never picked up the car. And Plaintiff is not a client of any else insurance company.
In conclusion, by releasing a car which is under their responsibilities, to an unknown person, to a person who is not the owner, Plaintiff, to a person who has not any authorization from the owner, Plaintiff, Defendants Jack LADD and Lyle WOLLERT did commit the offense of DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS towards Plaintiff.
Each defendant did not respect the duty they have to do according the Law, and is fully responsible of those offenses towards Plaintiff, and caused to him more and new financial and health damages.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
SECOND CAUSE OF ACTION
2. – FORGED INVOICE AND FRAUD
against Jack LADD, Lyle WOLLERT, and DOES 1-50
When Laurent GRANIER went to « Ladd’s Tow » the morning of the 29th of october 2014 to see his car, he discovered that it was not there. First, Lyle WOLLERT told him that someone picked it up the day before, by the insurance company, but without mentioning its name. Plaintiff asked him to give him a copy of the document from the person who took the car, as he has to ask when he releases a car. He did not know, and told to Plaintiff to see with the owner, Jack LADD.
Maliciously, Jack LADD gave in fact a copy of a kind of invoice he did himself because his invoice regarding its tow and storage, saying that it was paid by the person who took the car, but he did not know what was his identity. His explanation was unclear and nebulous, and more, Jack LADD laughed when Plaintiff told him he was going to sue him for his unacceptable misconduct. He only replied « Good Luck ».
Defendants Jack LADD and Lyle WOLLERT were deliberately unclear, nebulous when they have to give to the owner, Plaintiff, an explanation for their misconduct and information about the identity of the person to whom they gave Plaintiff’s car without any document, any authorization, seeming as if they have made the mistake to fail the respect of their main professional duty according the Law.
The kind of invoice edited and provided by Jack LADD is indeed a fake, a forgery, first because it is at the name of Laurent GRANIER, who has not asked for it, who did not know its existence, and which presents a wrong address about him, and second because Plaintiff has not paid it, has not authorized anyone to pay it, and third because its payment has been done with a bank card which is not one of Laurent GRANIER’s one, and let alone a bank card provided by Laurent GRANIER himself, or with a bank card by an identified authorized person by Laurent GRANIER.
Otherwise, and it is very interesting, the amount, the price paid by the unidentifed so-called person representing a so-called company, if he really exists, in order to take the car, is a round number, which includes tax. Normally, the claimed price was $75 daily and $180 for the tow, and of course because we are in USA, the price is without tax, a way which leads for most of time to a price to pay, far to be a round one. The amount of the kind of invoice is $1750, an arranged price.
How a person can make a round and arranged price to a person he does not know, or with whom he has not any advantage, any benfit, any partnership…
As a reminder, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». It has never picked up the car, and has not to pay anything for this accident. And Plaintiff is not a client of any else insurance company.
In conclusion, by editing an invoice to a name of a person, Plaintiff, who is not aware of its existence, by editing an invoice with a wrong address about the person billed, Plaintiff, by being paid by another unidentifed person than the person billed, Plaintiff, by being paid by an unauthorized person by the billed person, Plaintiff, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offense of FORGED INVOICE AND FRAUD towards Plaintiff.
As concerning criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect, and who trusted them.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
THIRD CAUSE OF ACTION
3. – ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
Maliciously, Defendants Jack LADD and Lyle WOLLERT were deliberately unclear, nebulous in order to give to Plaintiff an explanation for their professional misconduct and information about the identity of the person to whom they gave Plaintiff’s car without any right, any authorization, seeming as if they have made the mistake to fail the respect of their main professional duty according the Law.
Indeed, if they have no proof of the release, about the identity of the person who took the car, if they did not ask him any document in order to release the car to another pseron than the owner, Plaintiff, it is only because they have themselves stolen Plaintiff’s car, who was their client.
To agree with this fact, we can see that they were not afraid by the local authorities, having yet a relationship with them, thanks to their job, and having yet a strategy by some already prepared legal answers, but indeed totally wrong because false.
Jack LADD claimed to the easy, with him, Deputy Sheriff, Ryan YORK, that it was a civil case with the insurance company, named « CAA ».
But, yet, none insurance company named « CAA » is registered at the State of California, and second, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». In addition, his insurance company did not care about his car for this accident because he was not responsible, and so, it had not to pick it up, and in addition, it even did not know where was his car. And Plaintiff is not a client of any else insurance company.
Because its owner, Plaintiff never asked to pick it up, never asked to change its location, and as owner, he does not know who took his property, and even where it is, and above all, he can not see it, or take care of it, or use it, or simply enjoy of the total freedom that any owner has the right to keep about his own property, Plaintiff’s car has been stolen.
Anyway, even if we admit, if it is true that Jack LADD and Lyle WOLLERT gave the car to anyone else, we have to consider that Jack LADD and Lyle WOLLER have stolen first the car to Plaintiff, to give them to anyone else. Insurance company, or not, it remains an act of robbery from its origin, even they have not the car anymore.
In conclusion, under the facts that Plaintiff never gave any authorization to anyone to pick up his car, that Plaintiff does not know who took it, who gets it, and where it is, that Plaintiff has no possibility to use all advantages, benefits, privileges and freedom as any owner of property has the absolute and exclusive right to claim and to keep, and by the fact that Defendants had the full access and the full means to his property, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offense of ROBBERY towards Plaintiff.
As concerning criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect, and who trusted them.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
FOURTH CAUSE OF ACTION
4. – COMPLICITY OF ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
If we could accept the fact that the car has not been really stolen by Jack LADD and Lyle WOLLERT, it remains it has been stolen, because its owner, Plaintiff never asked to pick it up, never asked to change its location, and as owner, he does not know who took it, who gets it, and even where it is. In addition, and above all, he can not see it, or use the total freedom that any owner has the absolute and exclusive right to claim and to keep.
So, it remains to be a robbery, Plaintiff’s car has been stolen.
And if Jack LADD and Lyle WOLLERT are not the robbers, they are at least, the accomplices of the robbers.
Anyway, their first motive and benefit is about the payment of the so-called invoice billed to Plaintiff’s name with a wrong address, a fake invoice, which is a fraud too, because paid by an unidentified unauthorized person, and for a strange sum, with a round arranged number, higher than the previous official one.
If it was a breach of their professional duties, meaning non deliberate, it should remain difficult to understand, and to accept as true, for people working in this domain since a while, and agreed by Law, for which they have to know their duty, and their obligation.
As a reminder, the insurance company of Plaintiff is « PROGRESSIVE/DRIVE ». It has never picked up the car. And Plaintiff is not a client of any else insurance company.
In conclusion, if it was the case, by releasing a car which is under their responsibilities to an unknown person, to a person who is not the owner, Plaintiff, to a person who has not any authorization from the owner, Plaintiff, and as the car has to be considered as stolen, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offense of COMPLICITY OF ROBBERY towards Plaintiff.
As concerning criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
FIFTH CAUSE OF ACTION
5. – DELIBERATE OBSTRUCTION OF JUSTICE
against Jack LADD, Lyle WOLLERT, and DOES 1-50
If the car were not stolen by them, or by any else, why Jack LADD and Lyle WOLLERT did not anything to help Plaintiff, their client, who became victim. Quite the opposite, they declared wrong and fake legal arguments, they protected the interest of the person who picked it up the car, the robber, they were not able to identify him, they claims that it was the insurance company « CAA » , which does not exist, they claims that it was a civil problem, that is not.
First, the problem between Plaintiff and the insurance company of the adverse party is aside the fact that Jack LADD and Lyle WOLLERT gave the car to anyone else than the owner, Plaintiff.
Second, the problem between Plaintiff and the insurance company of the adverse party is about criminal offenses committed by several persons of the insurance company, Plaintiff having yet filed a complaint to California Department of Insurance, and to Superior Court of Santa Cruz for a jury trial.
Third, the situation between Plaintiff and the insurance company of the adverse party is not the business of Jack LADD and Lyle WOLLERT.
Fourth, Plaintiff was the client of Jack LADD and Lyle WOLLERT, so the latter had a contract with him, and so, professional duties and obligations.
Indeed, they were outside their duties, their obligations, and so, their rights. They have stolen the car.
Jack LADD claimed to Deputy Sheriff, Ryan YORK that the insurance company took it, but he did not give any proof of his declaration. If it was true, he should have documents, as any professional requests to release a property. And other wise,
Otherwise, it claimed to Deputy Sheriff, Ryan YORK that it was a civil case. Not at all.
First, if there was a civil case, it was between Plaintiff and the insurance company, not between Plaintiff and Jack LADD and Lyle WOLLERT, which is a different case because they committed criminal offenses, anyway there was or not a dispute with the insurance company.
Second, Jack LADD and Lyle WOLLERT have no right to be a judge, and to determine if the problem between Plaintiff and the insurance company of the adverse party is civil, criminal, or both.
He was not part of it, and he had not to give some information, some legal advise. It is against the Law. His behaviour shows without any doubt his collusion with the insurance company who agreed him, who pay him all the year. It is a pure corruption.
Third, and it is very important, none insurance company has the right to take a property from his owner, without his authorization, without any right. And in the present case, if there was dispute between Plaintiff and an insurance company, it is not with his own insurance company, so with a company from which he is not client, has never signed of contract, has never asked anything other than to be paid for the damages about the status of victim caused by one of their client.
Even if the robbery were committed by the insurance company, meaning the one of the adverse party, it remains that Jack LADD and Lyle WOLLERT protected them, made and makes money with them, having a contract with them, and acted unlawfully against the interest of Plaintiff who was their client.
So, if it is proven that indeed, it was the insurance company of the adverse party which took unlawfully the car from them, the act remains a criminal one, so Plaintiff’s property has been stolen, at least with the complicity of Jack LADD and Lyle WOLLERT, if we don’t consider that the latter have stolen first the car from their client, Plaintiff. In this case, Jack LADD and Lyle WOLLERT should be associated with the defendants listed in the civil complaint filed the 28th of october 2014 at Superior Court of Santa Cruz by Plaintiff, against the insurance company of the adverse party, and so, as accomplices of the criminal offenses, at least of blackmails, scams, lies, trickeries, attempted extortion and intentional inflictions of emotional distress.
Even if we agreed that Jack LADD and Lyle WOLLERT did a serious mistake, and it should be difficult to put their act, their behaviour under the status of non deliberate, non partnership with a company which pays him all the year, they did not help at all their client, Plaintiff. Quite the oposite, Jack LADD laughed and replied « Good Luck » to Plaintiff when he told him he was going to sue him.
In conclusion, by deliberately withholding information about criminals acts towards Plaintiff, by deliberately withholding the real identity of the person having committed a criminal offense towards Plaintiff, by deliberately taking part and protecting the interest of a criminal who acted towards Plaintiff, by being yet involoved by their own criminal offenses towards Plaintiff, by deliberately declaring fake and wrong assertions to authorities towards Plaintiff, by deliberately giving fake and wrong interpretations and understanding of the Law towards Plaintiff, by deliberately giving a kind of judgement towards Plaintiff, by deliberately giving legal advises which are wrong in order to lead authorities in the wrong direction and decision towards Plaintiff, Defendants Jack LADD and Lyle WOLLERT did commit the criminal offenses of DELIBERATE OBSTRUCTION OF JUSTICE towards Plaintiff.
As concerning deliberate offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, they did not respect the duty they have to do according the Law.
Each defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendants used deceits, lies, ruses and/or omissions to Plaintiff who was victim of their client and who deserved to get considered as is, with respect.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
SIXTH CAUSE OF ACTION
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
against Ryan YORK, Phil WOWAK, and DOES 1-50
Plaintiff re-alleges herein by this reference each and every allegation previously contained in the present complaint.
Ryan YORK is Deputy Sheriff at Sheriff-Coroner’s office, 701 Ocean Street, Room 340, Santa Cruz. He is representing Phil WOWAK, Sheriff-Coroner, but Plaintiff met him at Sheriff’s office in FELTON, the morning of 29th of october 2014, following the discovery of the robery of his car from where it was parked, at « LADD’S Auto Body & Towing ».
Indeed, Plaintiff has understood that the steal of his car had been committed by Jack LADD and Lyle WOLLERT, or at least they were accomplice of the robbery, or at least they were responsibles.
At once, Laurent GRANIER went to Sheriff’s office in FELTON. He was well comen, but he wait half an hour for the deputy Ryan YORK, in order to file the report of the criminal offense.
First, Ryan YORK asked to Laurent GRANIER one question about where was the car, but he seemed to have yet the answer, or at least get an idea, a position to take. He went to his own office and called Jack LADD in private. Few minutes later, Ryan YORK came back and told to Laurent GRANIER that his car had been picked it up by the insurance company, a so-called « CAA » and so, it was a civil case, and not a criminal one, declaring that the car was not stolen.
Indeed, he said all that Jack LADD told him, even his personal judgement and wrong legal advise.
Plaintiff asked to Ryan YORK to write that Jack LADD told him, but he refused.
Laurent GRANIER replied that he did not agree because first, « CAA » is not a registered insurance company, second, he never gave the authorization to anyone to pick up the car, third, his insurance company is « PROGRESSIVE » and not « CAA », and so none had the right to take it, and so, it was never a cvil case but a criminal one. In addition, Plaintiff told to Ryan YORK that nevertheless it was a civil case between him and an insurance company, it remains that the behaviours and acts committed by Jack LADD and Lyle WOLLERT towards Plaintiff were criminal offenses, and so, he was there to file a report against Jack LADD and Lyle WOLLERT, no matter about an insurance company or not. Jack LADD and Lyle WOLLERT did criminal offenses, that’s it.
Laurent GRANIER insisted to file a report, but Ryan YORK refused, and Laurent GRANIER asked him again to give him a report about his conversation with Jack LADD. He refused too, again. Indeed, Ryan YORK listened exclusively to Jack LADD, his declarations, and his legal advises, and his legal consultation and even his judgement which was by saying it was only a civil case. By the same time, Ryan YORK deliberately did not want to listen the victim of Jack LADD and Lyle WOLLERT, Plaintiff’s declarations, legal claims. Indeed, Ryan YORK listened to the criminal, but not to the victim of the criminal. Even, when Plaintiff insisted to file a complaint, he refused.
First, Ryan YORK is not a lawyer, and let alone a judge, and he has not to decide, to declare what is an act, or not.
Second, if a victim comes to file a report, a complaint for a criminal act, a police officer has not the right to refuse to do it. If there are laws to punish false declarations, false complaints, false alerts, it is not for nothing, it is to avoid to get useless work. So, with the existence of a punishment in case of irrelevant declarations, the will of people wanting to file a complaint for any criminal act has to be taken seriously by people representing authorities and having the duty to report it.
Third, a person representing the authority has to be neutral, and has to listen to each party by the same manner.
Fourth, a person representing the authority has the obligation to write a report and to investigate.
Only the result of an investigation is a proof, a way to determine if a complaint is real or not, if it is criminal or not.
In conclusion, by deliberately failing all points of his main duty against the interest and the situation of Plaintiff, and for the exclusive benefit of the criminals, Jack LADD and Lyle WOLLERT, Defendants Ryan YORK did commit the criminal offenses of COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY towards Plaintiff.
As concerning deliberate and criminal offenses, the shield of the profession can not be applied and have to be attributed to persons. In addition, he did not respect the duty he has to do according the Law.
Defendant is fully responsible of those criminal offenses towards Plaintiff, and caused to him more and new financial and health damages.
Defendant used deceits, lies, ruses and/or omissions to Plaintiff who was victim and who deserved to get considered as is, with respect, and, and in addtion who trusted him as person representing authority.
Yet victim, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
PRAYER FOR RELIEF
On the FIRST CAUSE OF ACTION
1. – DELIBERATE VIOLATION of PROFESSIONAL DUTIES AND OBLIGATIONS
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For an order declaring that Defendants owe to Plaintiff the sum of $72,050 for property damages and expenses ;
5. For actual damages to Plaintiff in an amount according to proof at trial;
6. For interest thereon at the maximum legally permissible rate;
7. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
8. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the SECOND CAUSE OF ACTION
2. – FORGED INVOICE AND FRAUD
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For actual damages to Plaintiff in an amount according to proof at trial;
5. For interest thereon at the maximum legally permissible rate;
6. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
7. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
8. For all costs of suit incurred herein; and
For such other and further relief as deemed just and proper.
On the THIRD CAUSE OF ACTION
3. – ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For an order declaring that Defendants owe to Plaintiff the sum of $72,050 for property damages and expenses ;
5. For actual damages to Plaintiff in an amount according to proof at trial;
6. For interest thereon at the maximum legally permissible rate;
7. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
8. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the FOURTH CAUSE OF ACTION
4. – COMPLICITY OF ROBBERY
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For an order declaring that Defendants owe to Plaintiff the sum of $72,050 for property damages and expenses ;
5. For actual damages to Plaintiff in an amount according to proof at trial;
6. For interest thereon at the maximum legally permissible rate;
7. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
8. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the FIFTH CAUSE OF ACTION
5. – DELIBERATE OBSTRUCTION OF JUSTICE
against Jack LADD, Lyle WOLLERT, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts;
5. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
6. For retributory damages in a amount of $10.000.000, according pain and suffering Defendants did on Plaintiff, with the aggravating factor that Defendants took advantage by his professional position and have deliberately failed their main duty ;
7. For actual damages to Plaintiff in an amount according to proof at trial;
8. For interest thereon at the maximum legally permissible rate;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On the SIXTH CAUSE OF ACTION
6. – COLLUSION, CORRUPTION, LACK OF NEUTRALITY, OBSTRUCTION OF JUSTICE by PERSON HAVING AUTHORITY
against Ryan YORK, Phil WOWAK, and DOES 1-50
1. For an order declaring the offenses committed by each Defendant against Plaintiff ;
2. For an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of same activity than the one under they practiced when they committed those criminal offenses, and so an order declaring that each Defendant must be forbidden to practice, to be involved, to be hired, to work for any kind of authority ;
3. For an order declaring that responsibles must be sued by authorities on the criminal legal ways ;
4. For punitive damages in an amount of not less than $100,000 for each of Defendants’ retaliatory acts ;
5. For pain and suffering about moral exhaustion, nervous prostration and emotional distress caused by Defendant in an amount of not less than $1,000.000 ;
6. For retributory damages in a amount of $10.000.000, according pain and suffering Defendants did on Plaintiff, with the aggravating factor that Defendants took advantage by his professional position and have deliberately failed their main duty ;
7. For actual damages to Plaintiff in an amount according to proof at trial;
8. For interest thereon at the maximum legally permissible rate;
9. For all costs of suit incurred herein; and
10. For such other and further relief as deemed just and proper.
On all Causes of Action :
1. For attorney’s fees according to proof ;
2. For spent personal time and expenses according the status of representing self ;
3. For costs of suit incurred herein ; and
4. For such other and further relief as the Court may deem just and proper.
DEMAND FOR JURY TRIAL
Plaintiff, Laurent GRANIER, hereby demands a trial by jury.
The 30th of october 2014.
Laurent GRANIER, Plaintiff, self-represented
For more information:
http://santacruzcorruption.wordpress.com/
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