Lawsuit filed at Superior Court of Santa Cruz for criminal offenses against Scott STOCKER,

Lawsuit filed at Superior Court of Santa Cruz for criminal offenses against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA, « De Laveaga Motors Inc. », Nathan VASQUEZ, Kevin VOGEL, Lynn ROBINSON, Mayor Don LANE, Patty HAYMOND,

Complaint for
1. – EMBEZZLEMENT and UNLAWFUL WITHHOLDING of OFFICIAL DOCUMENTS
2. – ROBBERY of OFFICIAL DOCUMENTS
3. – INVOICE FRAUD
4. – UNLAWFUL FAKE and NONEXISTENT INVOICE
5. – EMBEZZLEMENT AND MISAPPROPRIATION OF PROPERTY
6. – BLACKMAILS, THREATS, ACTS of INTIMIDATIONS, PERSECUTION and INTENTIONAL INFLICTIONS OF EMOTIONAL DISTRESS
7. – SCAMS, LIES, BAD FAITH
8. – EXTORTION
9. – ROBBERY and UNLAWFUL FAKE WITHHOLDING OF PROPERTY
10. – DELIBERATE LACKS OF RESPECT FOR THE ESSENTIAL PROFESSIONAL OBLIGATIONS IN THE GOAL OF DISHONEST AND UNLAWFUL PURPOSES
11. – DELIBERATE BREACHES OF CONTRACT
12. – CORRUPTION, COLLUSION, OBSTRUCTION OF JUSTICE BY OFFICER
13. – PROFITABLE AND USEFUL PASSIVE COMPLICITY of CRIMINAL OFFENSES and of CORRUPTION, COLLUSION and OBSTRUCTION of JUSTICE, LACK OF NEUTRALITY

Against

Scott STOCKER, Andrew WHITMAN, Joey MOCCIA, « De Laveaga Motors Inc. », Nathan VASQUEZ, Kevin VOGEL, Lynn ROBINSON, Mayor Don LANE, Patty HAYMOND,



Plaintiff, Laurent GRANIER (hereinafter « Plaintiff » or « GRANIER ») alleges and pleads as follows:

The original case.
Plaintiff Laurent GRANIER wanted to sell his PORSCHE 911 (vin WP0CB2969LS472037) convertible of 1990. He found the dealership De Laveaga Motors Inc. located at 1215 Water St., Santa Cruz, CA 95062DE on internet, by their website http://www.delamotors.com/.
Their staff is composed by the manager and owner Scott STOCKER, and the sellers Andrew WHITMAN and Joey MOCCIA.
They were, and are, proposing to take cars under consignment, with the terms “risk free”.
According their website, letting the car for sale is “risk free”, on the “consignment page”: “Let De Laveaga Motors sell your vehicle hassle and risk free – we’ll do that as quickly as possible and for the best price! BENEFITS OF CONSIGNMENT: EXPOSURE Our showcase has 28,000 drive bys daily. Advertising includes print, internet and a national dealer and customer network. Over 80% of consigned vehicles are sold within 30 days. FINANCE The majority of cars sold are financed-we offer competitive finance and lease options to buyers. TRADES Over 70% of buyers have trade-ins. We offer competitive prices. Let De Laveaga Motors sell your vehicle hassle and risk free – we’ll do that as quickly as possible and for the best price!”
Laurent GRANIER went two times to this dealership, in order to meet the manager, so-called expert in Porsche. The 11th of august 2014, they signed an agreement to sell the car at $20.000 plus $2000 of commission. Laurent GRANIER accepted to put the price of the car below the market, in order first, to sell it quickly, and second, to do easier the task of the dealership. When they signed, Scott STOCKER maliciously kept the title of the car, and gave another paper to sign, but he did not give a double, a copy of it, like he did for the original agreement.
Laurent GRANIER discovered later that Scott STOCKER had hidden to have kept the title, and he had to go back several times, meeting the sellers Andrew WHITMAN and Joey MOCCIA, to get back, but unsuccessfully.
Laurent GRANIER discovered later that Scott STOCKER put the price ofr sale at $39.990, so the double of the price asked by Laurent GRANIER to sell it quickly, but worse, a price above the market, and impossible to sell.
Laurent GRANIER discovered that Scott STOCKER used plaintiff’s time and money to make more money without him knowing and agreement. Worse, summer time being the best time to sell a convertible has been wasted by Scott STOCKER’s dishonest behaviour.
When Laurent GRANIER wanted to have his car back, in september 2014, Andrew WHITMAN told to plaintiff that Scott STOCKER was able to buy the car, and he had just to pass by the office to take the check. In fact, it was a strategy to make lose time and energy to Laurent GRANIER because when plaintiff came to take the check, Scott STOCKER was not there to do it. Laurent GRANIER came back another time and that time, Scott STOCKER was not there and Andrew WHITMAN told to plaintiff that Scott STOCKER was not able to buy the car at this price, and if he wanted to get his car back, he has to pay $1000. As it was blackmail, robbery and scam, Laurent GRANIER refused.
Laurent GRANIER still saw the ad about his car, posted by the band Scott STOCKER, Andrew WHITMAN and Joey MOCCIA at the price of $34990 on craigslist.
Laurent GRANIER came back to the dealership twice, meeting first, the of october 2014, Andrew WHITMAN who told to plaintiff to pay $1000 to get his car back, doing unlawful withholding and using blackmail, and a second time, on monday 13th of october 2014, Scott STOCKER who was continuing to blackmail plaintiff by theatrening him to put a security bond on the title, even threatening him by wanting to hit plaintiff. Scott STOCKER stopped only when Laurent GRANIER told him he was recording. Scott STOCKER warned Plaintiff he was able to call Police. Laurent GRANIER understood that something wrong was present in this small city like corruption of authorities when a criminal dares to call the Police against his victim, or when a person is able to commit several criminal offenses with no fear of justice, and continuing to do more, being not afraid by authorities, as being sure to be protected by a kind of impunity. Something unlawful like corruption. Plaintiff has had the confirmayion of his doubts of corruption when he tried to file a criminal complaint to the Police of Santa Cruz.
In addition, following the blackmail and the threats made by Scott STOCKER on Laurent GRANIER, plaintiff went the same day, monday 13th of october 14, to Police Station of Santa Cruz to deposit a criminal complaint for blackmail, threat, scam and robbery against Scott Stocker and Andrew Whitman.
A police officer, Nathan VASQUEZ met Plaintiff with nothing in hand, no paper, no no pen, no laptop.
Nathan VASQUEZ did not care about the case, the situation of the Plaintiff, as he had yet in mind not to report it, as he knew yet it, as he had in mind to make Plaintiff give it up, as he will not write anything against the criminals, as he wanted to help the criminals by obstruction of justice. In fact, he was busy by his sticking plaster (Band-Aid) at one of his finger, telling Plaintiff he can’t write anything, canning not to hold a pen…
At once, Plaintiff came to Mayor’s office to warn her about corruption behaviour and obstruction of justice made by a police officer under her responsibility.
People was good at the different offices of the City Hall until the time Plaintiff wanted to file a complaint. Kristina SANTANA at the front desk refused to give him a receipt, a certificate about his filing case, what is against the Law. Otherwise, the internal affairs of the city, « Risk Management Office » takes 45 days to study each case, letting criminals to do what they want and they need.

At the end, Laurent GRANIER lost, first the opportunity to sell his car in summer, second to save money, third to get money, fourth his car and fifth the opportunity to sell his car to clients who wanted to buy it at the right price.
FIRST CAUSE OF ACTION
1. – EMBEZZLEMENT and UNLAWFUL WITHHOLDING of OFFICIAL DOCUMENTS
against Scott STOCKER and DOES 1-50
Maliciously, Scott STOCKER deliberately did keep unlawfully the title in order to get more power and advantage on Plaintiff. He did this since the beginning, showing his dishonest purpose and his aforetought unlawful goal, far and out of his professional duties, to screw Plaintiff. Scott STOCKER deliberately did this against the interest of his client, Laurent GRANIER, but also for his own interest, in a dishonesty, unfair, unlawful and criminal purpose, to get the car cheaper, even for free. In addition, the fact to keep the title gives to Scott STOCKER an unfair increase of the inequality for his benefit, having the car and his title. Scott STOCKER embezzled it unbeknown to Plaintiff who discovered later that his title was missing, and he did not succeed to get it back.

In conclusion, being against the Law by having kept illegally the title of the owner, Plaintiff, their client, in order to get advantage later on him, Scott STOCKER did commit the OFFENSE of UNLAWFUL WITHHOLDING of OFFICIAL DOCUMENTS.

Defendant used deceits, lies, ruses and omissions to Plaintiff who was his client and who trusted him.
Plaintiff suffered stress, anxiety, worries, loss of trust which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several 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. – ROBBERY of OFFICIAL DOCUMENTS
against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA and DOES 1-50
Maliciously, Scott STOCKER deliberately did keep unlawfully the title in order to get more power and advantage on Plaintiff. He did this since the beginning, showing his dishonest purpose and his aforetought unlawful goal, far and out of his professional duties, to screw Plaintiff. Scott STOCKER deliberately did this against the interest of his client, Laurent GRANIER, but also for his own interest, in a dishonesty, unfair, unlawful and criminal purpose, to get the car cheaper, even for free. In addition, the fact to keep the title gives to Scott STOCKER an unfair increase of the inequality for his benefit, having the car and his title. Scott STOCKER embezzled it unbeknown to Plaintiff who discovered later that his title was missing. When Laurent GRANIER discovered that Scott STOCKER had kept his title, Plaintiff tried to get it back since the first week he let his car. But after to have gone to the dealership several times, to have met Scott STOCKER, Andrew WHITMAN and Joey MOCCIA, Plaintiff has not succeeded to get back his title.
The fact not to give back an official document is above a simple withholding because at this time, the dispute to get the car back was not started. The title was stolen indeed for future purposes, dishonest purposes from the band Scott STOCKER, Andrew WHITMAN and Joey MOCCIA.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER by the fact they knew, they know, they are aware of what and how happen « things » in this business, and they stay, still working, still getting advantage even by taking part and contributing, without denouncing those criminal offenses to authorities and justice.

In conclusion, being against the Law by refusing to give back an official document to his owner, Plaintiff, their client, with no reason than a hidden personal future dishonest purpose, in addition to have it embezzled it unbeknown to his owner, so against his will and agreement, and under the aggravating circumstances of deliberate and with intent illegal acts that is not anymore a « simple » unlawful withholding, Scott STOCKER, Andrew WHITMAN and Joey MOCCIA did commit the OFFENSE of ROBBERY of an OFFICIAL DOCUMENT.

Defendants used deceits, lies, ruses and omissions to Plaintiff who was her client and who trusted them.
Plaintiff suffered stress, anxiety, worries, loss of trust which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several 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. – INVOICE FRAUD
against Scott STOCKER, Andrew WHITMAN and DOES 1-50
Scott STOCKER deliberately put a price of the Plaintiff’s car above the market, twice the price of the plaintiff sale price, which has led to an impossibility to sell it. By this time, two months in summer, Plaintiff saw several Porsche for sale, cheaper than it, and which has been sold.
Maliciously, Scott STOCKER kept unlawfully the title in order to get more power and advantage on plaintiff, and still maliciously, Scott STOCKER put a price for sale so high that any would-be buyer did not want to consider it, in order to put in an awkward position Plaintiff. Scott STOCKER had in mind his dishonest and unlawful purpose since the beginning, in order to screw Plaintiff. Scott STOCKER deliberately did this against the interest of the plaintiff, but also for his own interest, in a dishonesty, unfair, unlawful and criminal purpose.
Scott STOCKER and Andrew WHITMAN asked for $1000 to give back his vehicle to Plaintiff. The amount is not based on nothing, but a sheet of paper that Plaintiff did not remember to have signed, but worse, a document that he had no copy, and so, he had not the opportunity to read and to evaluate the legal value. The asked amount is a fraud, based on no one invoice, no justification.
We could not recognize a kind of security to be paid by « keeping » illegally and against the will of the owner, made Scott STOCKER because first, the amount is not justified, not agreed but contested by Plaintiff, and must be a subject of legal evaluation and discussion, and second and above all, because the amont so-called due and claimed is 20 times less than the value of the car. In this case, it is an extortion of money, either of property.

In conclusion, being against the Law by asking money without no proof, no justification, no invoice, to Plaintiff, their client, Scott STOCKER and Andrew WHITMAN did commit the OFFENSE of INVOICE FRAUD.

Defendant used deceits, lies, ruses, bad faith and omissions against Plaintiff who was his client and who trusted him.
Defendant did use and increased the Plaintiff’s distress of his situation being already victim of numerous serious criminal offenses.
Plaintiff suffered stress, anxiety, worries, loss of trust which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several 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. – UNLAWFUL FAKE and NONEXISTENT INVOICE
against Scott STOCKER, Andrew WHITMAN and DOES 1-50
Scott STOCKER deliberately put a price of the Plaintiff’s car above the market, twice the price of the plaintiff sale price, which has led to an impossibility to sell it. By this time, two months in summer, Plaintiff saw several Porsche for sale, cheaper than it, and which has been sold.
Maliciously, Scott STOCKER kept unlawfully the title in order to get more power and advantage on plaintiff, and still maliciously, Scott STOCKER put a price for sale so high that any would-be buyer did not want to consider it, in order to put in an awkward position Plaintiff. Scott STOCKER had in mind his dishonest and unlawful purpose since the beginning, in order to screw Plaintiff. Scott STOCKER deliberately did this against the interest of the plaintiff, but also for his own interest, in a dishonesty, unfair, unlawful and criminal purpose.
Scott STOCKER and Andrew WHITMAN asked for $1000 to give back his vehicle to Plaintiff. The amount is not based on nothing, but a sheet of paper that Plaintiff did not remember to have signed, but worse, a document that he had no copy, and so, he had not the opportunity to read and to evaluate the legal value. The asked amount is a fraud, based on no real and legal justification.
We could not recognize a kind of security to be paid by « keeping » illegally and against the will of the owner, made Scott STOCKER because first, the amount is not justified, not agreed but contested by Plaintiff, and must be a subject of legal evaluation and discussion, and second and above all, because the amont so-called due and claimed is 20 times less than the value of the car. In this case, it is an extortion of money, either of property.

In conclusion, being against the Law by asking money without no proof, no justification, no invoice, to Plaintiff, their client, Scott STOCKER and Andrew WHITMAN did commit the OFFENSE of UNLAWFUL FAKE and NONEXISTENT INVOICE.
Defendant used deceits, lies, ruses, bad faith and omissions against Plaintiff who was his client and who trusted him.
Defendant did use and increased the Plaintiff’s distress of his situation being already victim of numerous serious criminal offenses.
Plaintiff suffered stress, anxiety, worries, loss of trust which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several 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. – EMBEZZLEMENT AND MISAPPROPRIATION OF PROPERTY
against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA and DOES 1-50
Scott STOCKER deliberately put a price of the Plaintiff’s car above the market, twice the price of the plaintiff sale price, which has led to an impossibility to sell it. By this time, two months in summer, Plaintiff saw several Porsche for sale, cheaper than it, and which has been sold.
Maliciously, Scott STOCKER kept unlawfully the title in order to get more power and advantage on plaintiff, and still maliciously, Scott STOCKER put a price for sale so high that any would-be buyer did not want to consider it, in order to put in an awkward position Plaintiff. Scott STOCKER had in mind his dishonest and unlawful purpose since the beginning, in order to screw Plaintiff.
Scott STOCKER and Andrew WHITMAN asked for $1000 to give back his vehicle to Plaintiff. The amount is not based on nothing, but a sheet of paper that Plaintiff did not remember to have signed, but worse, a document that he had no copy, and so, he had not the opportunity to read and to evaluate the legal value. The asked amount is a fraud, based on no real and legal justification.
Andrew WHITMAN promised several time to Laurent GRANIER to sell the car in the following days, « having a client », and so, to give a check in the following days, and even the car was not sold, he told to Plaintiff that Scott STOCKER was able to buy it. But indeed, Andrew WHITMAN lied to Laurent GRANIER, and when it comes time to give the check, Scott STOCKER was not there, and Andrew WHITMAN asked Plaintiff to come back, causing expenses to Laurent GRANIER, being not in Santa Cruz area all the time. Scott STOCKER knew this from Andrew WHITMAN who took advantage of this weakness of the Plaintiff not to be present all the time in this area, in order to discourage, to putt off, and so to buy the car cheaper, or to get iy for free, following his dishonest plan since the beginning.
Scott STOCKER and Andrew WHITMAN deliberately did this against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose.
We could not recognize a kind of security to be paid by « keeping » illegally and against the will of the owner, made Scott STOCKER because first, the amount is not justified, not agreed but contested by Plaintiff, and must be a subject of legal evaluation and discussion, and second and above all, because the amont so-called due and claimed is 20 times less than the value of the car.
In this case, it is not an extortion of money, either of property, it is an embezzlement and misappropriation of property.
Andrew WHITMAN is fully accomplice by having commission on sales, and so on company income. Andrew WHITMAN is fully accomplice of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN is fully accomplice of the criminal offenses committed by Scott STOCKER by the fact he knew, he knows, he is aware of what and how happen « things » in this business, and he stay, still working, still getting advantage by taking part and contributing, without denouncing thoss criminal offenses to authorities and justice.

In conclusion, being against the Law by having kept illegally first the title of the owner, Plaintiff, their client, and second the car with no real and legal rights, Scott STOCKER and Andrew WHITMAN did commit the OFFENSE of EMBEZZLEMENT AND MISAPPROPRIATION OF PROPERTY.

Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who was their client and who trusted them.
Defendants did use and increased the Plaintiff’s distress of his situation being already victim of numerous serious criminal offenses.
Plaintiff suffered stress, anxiety, worries, loss of trust which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.
SIXTH CAUSE OF ACTION
6. – BLACKMAILS, THREATS, ACTS of INTIMIDATIONS, PERSECUTION and INTENTIONAL INFLICTIONS OF EMOTIONAL DISTRESS
against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA and DOES 1-50
Maliciously, Scott STOCKER deliberately did act unlawfully since the beginning to get power and advantage on his client, Plaintiff, but not by a professional, normal, fair and honest way. Maliciously, first, he kept the title, second, he refused to give it back to his owner, third, he put a price of the car above the market, fourth, he put a price twice the price of the plaintiff sale price, which has led to an impossibility to sell it, wasting and using only the time and investment of the owner, Plaintiff. Indeed, Scott STOCKER’s dishonest behaviour, which started since the beginning, showing his premeditated dishonest and unlawful purpose, was to discourage Plaintiff, and so, to buy it at a fraction pf the value, if not for free.
So, Scott STOCKER used first, blackmail to get illegal, unfair, unlawful and fanciful amount of $1000, because Plaintiff refused to sell him the car cheaper, second, threats on him, by registering a fanciful security on his title (which shows his connection in administration by corruption), third, acts of intimidations by having the help of the police and by threatening to hit him.
In addition, Scott STOCKER and Andrew WHITMAN were intentionally creating, using and increasing a persecution and an emotional distress to Plaintiff.
He did this since the beginning, showing his dishonest purpose and his goal, far and out of his professional duties, to screw Plaintiff. Scott STOCKER and Andrew WHITMAN deliberately did this against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose.
We could not recognize a kind of security to be paid by « keeping » illegally and against the will of the owner, made Scott STOCKER because first, the amount is not justified, not agreed but contested by Plaintiff, and must be a subject of legal evaluation and discussion, and second and above all, because the amont so-called due and claimed is 20 times less than the value of the car. In this case, it is an extortion of money, either of property.
Otherwise, the « Risk Free » claimed in the website is indeed a lie, a misleading advertising, a trickery in order to catch people to scam them, at least.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER by the fact they knew, they know, they are aware of what and how happen « things » in this business, and they stay, still working, still getting advantage even by taking part and contributing, without denouncing those criminal offenses to authorities and justice.

In conclusion, being against the Law by having kept illegally first the title of the owner, and second the car with no real and legal rights, Scott STOCKER and Andrew WHITMAN did commit the OFFENSE of EMBEZZLEMENT AND MISAPPROPRIATION OF PROPERTY.
In conclusion, being against the Law by having kept illegally the title of the owner, Plaintiff, their client, in order to get advantage later on him, Scott STOCKER, Andrew WHITMAN and Joey MOCCIA did an OFFENSE of BLACKMAILS, THREATS, INTIMIDATIONS, PERSECUTION and INTENTIONAL INFLICTIONS OF EMOTIONAL DISTRESS.

Defendants did not offer and guarantee to Plaintiff peace of mind quite the contrary, defendant increased deliberately the difficulty of the Plaintiff’s situation.
Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who was their client and who trusted them.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.
SEVENTH CAUSE OF ACTION
7. -SCAMS, LIES, BAD FAITH
against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA and DOES 1-50
Maliciously, Scott STOCKER deliberately did act unlawfully since the beginning to get power and advantage on his client, Plaintiff, but not by a professional, normal, fair and honest way. Maliciously, first, he kept the title, second, he refused to give it back to his owner, third, he put a price of the car above the market, fourth, he put a price twice the price of the plaintiff sale price, which has led to an impossibility to sell it, wasting and using only the time and investment of the owner, Plaintiff. Indeed, Scott STOCKER’s dishonest behaviour, which started since the beginning, showing his premeditated dishonest and unlawful purpose, was to discourage Plaintiff, and so, to buy it at a fraction pf the value, if not for free.
So, Scott STOCKER used first, blackmail to get illegal, unfair, unlawful and fanciful amount of $1000, because Plaintiff refused to sell him the car cheaper, second, threats on him, by registering a fanciful security on his title (which shows his connection in administration by corruption), third, acts of intimidations by having the help of the police and by threatening to hit him.
In addition, Scott STOCKER and Andrew WHITMAN were intentionally creating, using and increasing a persecution and an emotional distress to Plaintiff.
He did this since the beginning, showing his dishonest purpose and his goal, far and out of his professional duties, to screw Plaintiff. Scott STOCKER and Andrew WHITMAN deliberately did this against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose.
We could not recognize a kind of security to be paid by « keeping » illegally and against the will of the owner, made Scott STOCKER because first, the amount is not justified, not agreed but contested by Plaintiff, and must be a subject of legal evaluation and discussion, and second and above all, because the amont so-called due and claimed is 20 times less than the value of the car. In this case, it is an extortion of money, either of property.
Otherwise, the « Risk Free » claimed in the website is indeed a lie, a misleading advertising, a trickery in order to catch people to scam them, at least.
So, the purpose of Scott STOCKER since the beginning was to screw Plaintiff, if it was not to steal his car by fake official ways, thanks to his « connections » who give him impunity. Scott STOCKER got the help and the assistance from Andrew WHITMAN who was deeply involved by taking part of his unlawful acts, being fully aware of the numerous ciminal offenses did by Scott STOCKER but also by himself, both using lies and bad faith.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER by the fact they knew, they know, they are aware of what and how happen « things » in this business, and they stay, still working, still getting advantage even by taking part and contributing, without denouncing those criminal offenses to authorities and justice.

In conclusion, being against the Law by having kept illegally first the title of the owner, and second the car with no real and legal rights, by using lies and bad faith to Plaintiff, their client, in order to get advantage later on him, Scott STOCKER, Andrew WHITMAN and Joey MOCCIA did commit the OFFENSE of SCAMS, LIES, BAD FAITH.

Defendants did not offer and guarantee to Plaintiff peace of mind quite the contrary, defendant increased deliberately the difficulty of the Plaintiff’s situation.
Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who was their client and who trusted them.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.
EIGHT CAUSE OF ACTION
8. – EXTORTION
against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA and DOES 1-50
Maliciously, Scott STOCKER deliberately did act unlawfully since the beginning to get power and advantage on his client, Plaintiff, but not by a professional, normal, fair and honest way. Maliciously, first, he kept the title, second, he refused to give it back to his owner, third, he put a price of the car above the market, fourth, he put a price twice the price of the plaintiff sale price, which has led to an impossibility to sell it, wasting and using only the time and investment of the owner, Plaintiff. Indeed, Scott STOCKER’s dishonest behaviour, which started since the beginning, showing his premeditated dishonest and unlawful purpose, was to discourage Plaintiff, and so, to buy it at a fraction pf the value, if not for free.
So, Scott STOCKER used first, blackmail to get illegal, unfair, unlawful and fanciful amount of $1000, because Plaintiff refused to sell him the car cheaper, second, threats on him, by registering a fanciful security on his title (which shows his connection in administration by corruption), third, acts of intimidations by having the help of the police and by threatening to hit him.
In addition, Scott STOCKER and Andrew WHITMAN were intentionally creating, using and increasing a persecution and an emotional distress to Plaintiff.
He did this since the beginning, showing his dishonest purpose and his goal, far and out of his professional duties, to screw Plaintiff. Scott STOCKER and Andrew WHITMAN deliberately did this against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose.
We could not recognize a kind of security to be paid by « keeping » illegally and against the will of the owner, made Scott STOCKER because first, the amount is not justified, not agreed but contested by Plaintiff, and must be a subject of legal evaluation and discussion, and second and above all, because the amont so-called due and claimed is 20 times less than the value of the car.
Otherwise, the « Risk Free » claimed in the website is indeed a lie, a misleading advertising, a trickery in order to catch people to scam them, at least.
In this case, it is an extortion of money, either of property.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER by the fact they knew, they know, they are aware of what and how happen « things » in this business, and they stay, still working, still getting advantage even by taking part and contributing, without denouncing those criminal offenses to authorities and justice.
In conclusion, being against the Law by having kept illegally first the title of the owner, and second the car with no real and legal rights, and by asking to Plaintiff, their client, a fanciful amount which is a ransom, Scott STOCKER, Andrew WHITMAN and Joey MOCCIA did commit the OFFENSE of EXTORTION.

Defendants did not offer and guarantee to Plaintiff peace of mind quite the contrary, defendant increased deliberately the difficulty of the Plaintiff’s situation.
Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who was their client and who trusted them.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.
NINTH CAUSE OF ACTION
9. – ROBBERY and UNLAWFUL FAKE WITHHOLDING OF PROPERTY
against Scott STOCKER, Andrew WHITMAN and Joey MOCCIA and DOES 1-50
Maliciously, Scott STOCKER deliberately did act unlawfully since the beginning to get power and advantage on his client, Plaintiff, but not by a professional, normal, fair and honest way. Maliciously, first, he kept the title, second, he refused to give it back to his owner, third, he put a price of the car above the market, fourth, he put a price twice the price of the plaintiff sale price, which has led to an impossibility to sell it, wasting and using only the time and investment of the owner, Plaintiff. Indeed, Scott STOCKER’s dishonest behaviour, which started since the beginning, showing his premeditated dishonest and unlawful purpose, was to discourage Plaintiff, and so, to buy it at a fraction pf the value, if not for free.
So, Scott STOCKER used first, blackmail to get illegal, unfair, unlawful and fanciful amount of $1000, because Plaintiff refused to sell him the car cheaper, second, threats on him, by registering a fanciful security on his title (which shows his connection in administration by corruption), third, acts of intimidations by having the help of the police and by threatening to hit him.
In addition, Scott STOCKER and Andrew WHITMAN were intentionally creating, using and increasing a persecution and an emotional distress to Plaintiff.
He did this since the beginning, showing his dishonest purpose and his goal, far and out of his professional duties, to screw Plaintiff. Scott STOCKER and Andrew WHITMAN deliberately did this against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose.
We could not recognize a kind of security to be paid by « keeping » illegally and against the will of the owner, made Scott STOCKER because first, the amount is not justified, not agreed but contested by Plaintiff, and must be a subject of legal evaluation and discussion, and second and above all, because the amont so-called due and claimed is 20 times less than the value of the car. In this case, it is an extortion of money, either of property.
Otherwise, the « Risk Free » claimed in the website is indeed a lie, a misleading advertising, a trickery in order to catch people to scam them, at least.
So, it is not a withholding property anymore, but just a kind of fake justification to get the car as « officially » not stolen. Indeed, the owner can not get it back, car and title, from them without to be forced to pay a ransom. It is a robbery.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER by the fact they knew, they know, they are aware of what and how happen « things » in this business, and they stay, still working, still getting advantage even by taking part and contributing, without denouncing those criminal offenses to authorities and justice.

In conclusion, being against the Law by having kept illegally first the title of the owner, and second the car with no real and legal rights, and by asking to Plaintiff, their client, a fanciful amount which is a ransom, Scott STOCKER, Andrew WHITMAN and Joey MOCCIA did commit the OFFENSE of ROBBERY and UNLAWFUL FAKE WITHHOLDING OF PROPERTY.

Defendants did not offer and guarantee to Plaintiff peace of mind quite the contrary, defendants increased deliberately the difficulty of the Plaintiff’s situation.
Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who was their client and who trusted them.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.
TENTH CAUSE OF ACTION
10. – DELIBERATE LACKS OF RESPECT FOR THE ESSENTIAL PROFESSIONAL OBLIGATIONS IN THE GOAL OF DISHONEST AND UNLAWFUL PURPOSES
against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA and DOES 1-50
Maliciously, Scott STOCKER deliberately did act unlawfully since the beginning to get power and advantage on his client, Plaintiff, but not by a professional, normal, fair and honest way. Maliciously, first, he kept the title, second, he refused to give it back to his owner, third, he put a price of the car above the market, fourth, he put a price twice the price of the plaintiff sale price, which has led to an impossibility to sell it, wasting and using only the time and investment of the owner, Plaintiff. Indeed, Scott STOCKER’s dishonest behaviour, which started since the beginning, showing his premeditated dishonest and unlawful purpose, was to discourage Plaintiff, and so, to buy it at a fraction pf the value, if not for free.
In addition, Scott STOCKER and Andrew WHITMAN were intentionally creating, using and increasing a persecution and an emotional distress to Plaintiff.
Scott STOCKER did this since the beginning, showing his dishonest purpose and his goal, far and out of his professional duties, to screw Plaintiff.
Otherwise, the « Risk Free » claimed in the website is indeed a lie, a misleading advertising, a trickery in order to catch people to scam them, at least.
Scott STOCKER and Andrew WHITMAN deliberately did act against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose.Scott STOCKER and Andrew WHITMAN deliberately did act against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose, by not respecting their professional obligations to sell the car as soon as possible, at the price asked by Plaintiff. They even never gave him any update.
Scott STOCKER and Andrew WHITMAN put a price higher than the market to put in difficulty Plaintiff facing an unsuccessful sale.
Otherwise, if they have succeeded to sell the car at a hihgher price than the one asked by the owner, Plaintiff, they could make more money than the $2000 of commission. Indeed, they were using the time and the investment of Plaintiff, without his agreement, and without his knowledge. Scott STOCKER and Andrew WHITMAN deliberately acted for their own interest, with the property of Plaintiff, and to the exclusive detriment of Plaintiff.
Those acts and behaviours from professionals can not be considered as a respect of terms of agreement for a consigment.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER by the fact they knew, they know, they are aware of what and how happen « things » in this business, and they stay, still working, still getting advantage even by taking part and contributing, without denouncing those criminal offenses to authorities and justice.

In conclusion, being against the Law by having deliberately acted against the Law and against the interest of Plaintiff, their client, Scott STOCKER, Andrew WHITMAN and Joey MOCCIA did commit the OFFENSE of DELIBERATE LACKS OF RESPECT FOR THE ESSENTIAL PROFESSIONAL OBLIGATIONS IN THE GOAL OF DISHONEST AND UNLAWFUL PURPOSES.

Defendants did not offer and guarantee to Plaintiff peace of mind quite the contrary, defendants increased deliberately the difficulty of the Plaintiff’s situation.
Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who was their client and who trusted them.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.
ELEVENTH CAUSE OF ACTION
11. – DELIBERATE BREACHES OF CONTRACT
against Scott STOCKER, Andrew WHITMAN, Joey MOCCIA and DOES 1-50
Maliciously, Scott STOCKER deliberately did act unlawfully since the beginning to get power and advantage on his client, Plaintiff, but not by a professional, normal, fair and honest way. Maliciously, first, he kept the title, second, he refused to give it back to his owner, third, he put a price of the car above the market, fourth, he put a price twice the price of the plaintiff sale price, which has led to an impossibility to sell it, wasting and using only the time and investment of the owner, Plaintiff. Indeed, Scott STOCKER’s dishonest behaviour, which started since the beginning, showing his premeditated dishonest and unlawful purpose, was to discourage Plaintiff, and so, to buy it at a fraction pf the value, if not for free.
In addition, Scott STOCKER and Andrew WHITMAN were intentionally creating, using and increasing a persecution and an emotional distress to Plaintiff.
He did this since the beginning, showing his dishonest purpose and his goal, far and out of his professional duties, to screw Plaintiff.
Otherwise, the « Risk Free » claimed in the website is indeed a lie, a misleading advertising, a trickery in order to catch people to scam them, at least.
Scott STOCKER and Andrew WHITMAN deliberately did act against the interest of the plaintiff, but also for their own interest, in a dishonesty, unfair, unlawful and criminal purpose, by not respecting their professional obligations to sell the car as soon as possible, at the price asked by Plaintiff. They even never gave him any update.
Scott STOCKER and Andrew WHITMAN put a price higher than the market to put in difficulty Plaintiff facing an unsuccessful sale.
Otherwise, if they have succeeded to sell the car at a hihgher price than the one asked by the owner, Plaintiff, they could make more money than the $2000 of commission. Indeed, they were using the time and the investment of Plaintiff, without his agreement, and without his knowledge. Scott STOCKER and Andrew WHITMAN deliberately acted for their own interest, with the property of Plaintiff, and to the exclusive detriment of Plaintiff.
Those acts and behaviours from professionals can not be terms of agreement for a consigment.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER in the area of the business of « De Laveaga Motors Inc. », being stakeholder of its benefits, yet as seller having commission on company income.
Andrew WHITMAN and Joey MOCCIA are fully accomplices of the criminal offenses committed by Scott STOCKER by the fact they knew, they know, they are aware of what and how happen « things » in this business, and they stay, still working, still getting advantage even by taking part and contributing, without denouncing those criminal offenses to authorities and justice.

In conclusion, by having deliberately acted against the Law and against the interest of their client, Plaintiff, but for only their own interest, by not respecting normal terms of an agreement for consignment, Scott STOCKER, Andrew WHITMAN and Joey MOCCIA did commit the OFFENSE of DELIBERATE BREACHES OF CONTRACT.

Defendants did not offer and guarantee to Plaintiff peace of mind quite the contrary, defendants increased deliberately the difficulty of the Plaintiff’s situation.
Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who was their client and who trusted them.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.

TWELFTH CAUSE OF ACTION
12. – CORRUPTION, COLLUSION, OBSTRUCTION OF JUSTICE BY OFFICER
against Nathan VASQUEZ and DOES 1-50
Corruption phenomenon is not only an exchange of money, a payment for a « service ». Most of time, it is under the hidden shape of an advantage in nature, in exchange, in return for another service, or a compliance, an obedience to a membership privilege.
Following the blackmail and the threats made by Scott STOCKER on Laurent GRANIER, plaintiff went the same day, monday 13th of october 2014, around 10.30 am, to Police Station of Santa Cruz located at 155 Center St, in order to get assistance and help, but also and above all, to file a criminal complaint for blackmail, threat, extortion, scam and robbery against Scott Stocker and Andrew Whitman.
A police officer, Nathan VASQUEZ met Plaintiff with nothing in hand, no paper, no no pen, no laptop.
Nathan VASQUEZ did not care about the case, the situation of the victim, Plaintiff, as he had yet in mind not to report it, as he knew yet it, as he had in mind to make Plaintiff give it up, as he will not write anything against the criminals, as he wanted to help the criminals by obstruction of justice. In fact, he was busy by his sticking plaster (Band-Aid) at one of his finger, telling Plaintiff he can’t write anything, canning not to hold a pen…
Plaintiff tried to find help and assistance from Police of Santa Cruz, and to file a criminal complaint in order to obtain an official criminal lawsuit made by the prosecutor, but indeed, he found a deliberate fake lazy behaviour from the police officer, a passive unlawful behaviour useful for criminals who can continue to commit criminal offenses with complete impunity, guaranted by authorities. Criminals can continue to do blackmail, threat, extortion, scam and robbery against Laurent GRANIER, Plaintiff, but against other victims, too.
If a little officer is able to do a so serious criminal offense, it is because he is sure to be protected by his hierarchy, so by Kevin VOGEL, Chief of Police of Santa Cruz, becoming accomplice of corruption, collusion and obstruction of justice.

In conclusion, being against the Law by giving deliberately leeways in time to criminals, by deliberately not taking in consideration the situation of the victim, Plaintiff, by being deliberately disrespectful towards the victim, Plaintiff, by deliberately increasing damages and situation of the victim, Plaintiff, by deliberately not giving help, assistance and protection to victim, Plaintiff, by ignoring the requests of the victim, Plaintiff, to file a criminal complaint, by being fully passive accomplice of blackmail, threat, extortion, scam and robberyby, Nathan VASQUEZ did commit, under the aggravating circumstances of being a Police Officer, the SERIOUS CRIMINAL OFFENSES of CORRUPTION, COLLUSION, OBSTRUCTION OF JUSTICE by OFFICER.

Defendant used deceits, lies, ruses, bad faith and omissions against Plaintiff who trusted him, being a representative of authorities.
Defendant did use and increased the Plaintiff’s distress of his situation being already victim of numerous serious criminal offenses.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.
THIRTEENTH CAUSE OF ACTION
13. – PROFITABLE AND USEFUL PASSIVE COMPLICITY of CRIMINAL OFFENSES and of CORRUPTION, COLLUSION and OBSTRUCTION of JUSTICE, LACK OF NEUTRALITY
against Lynn ROBINSON, Don LANE, Patty HAYMOND, Nathan VASQUEZ, Kevin VOGEL and DOES 1-50
Plaintiff tried to find help and assistance from Police of Santa Cruz, and to file a criminal complaint in order to obtain an official criminal lawsuit made by the prosecutor, but indeed, he found a deliberate fake lazy behaviour from the police officer, a passive unlawful behaviour useful for criminals who can continue to commit criminal offenses with complete impunity, guaranted by authorities. Criminals can continue to do blackmail, threat, extortion, scam and robbery against Laurent GRANIER, Plaintiff, but against other victims, too.
If a little officer is able to do a so serious criminal offense, it is because he is sure to be protected by his hierarchy, so by Kevin VOGEL, Chief of Police of Santa Cruz, becoming accomplice of corruption, collusion and obstruction of justice.
At once, Plaintiff came to Mayor’s office to warn her about corruption behaviour and obstruction of justice made by a police officer under her responsibility.
People was good at the different offices of the City Hall until the time Plaintiff wanted to file a complaint. Kristina SANTANA at the front desk refused to give him a receipt, a certificate about his filing case, what is against the Law.
Otherwise, the internal affairs of the city, « Risk Management Department » takes 45 days to study each case, letting criminals to do what they want and they need, and by the same time, letting increasing the damages and the difficulty of the situation of the victim. Indeed, this « Risk Management department» is a trickery, because it is not to help victims, it is not to avoid offenses made by city employees, but just a way to win time, in order to analyze the situation if they can be exempted of responsibility, if they could protect themselves from any lawsuit, and so, always for their own benefit, and always to the detriment of victims. Patty HAYMOND is the manager of this office.
Lynn ROBINSON, being Mayor of the city of Santa Cruz and Don LANE being vice-mayor are responsibles for the misconducts of their employees.
Laurent GRANIER, victim, Plaintiff, sent to each of them an email to warn them about the situation. None of them replied. So, in addition of Kevin VOGEL, Lynn ROBINSON, Don LANE and Patty HAYMOND are fully responsible, and are fully accomplice of CORRUPTION, COLLUSION and OBSTRUCTION of JUSTICE, but also, indirectly, of blackmail, threat, extortion, scam and robbery.

In conclusion, being against the Law by giving deliberately leeways in time to criminals, by deliberately not taking in consideration the situation of the victim, Plaintiff, by being deliberately disrespectful towards the victim, Plaintiff, by deliberately increasing damages and situation of the victim, Plaintiff, by deliberately not giving help, assistance and protection to victim, Plaintiff, by ignoring the requests of the victim, Plaintiff, by not doing the necessary to give the possibility to file a criminal complaint about blackmail, threat, extortion, scam and robberyby, Kevin VOGEL, Lynn ROBINSON, Don LANE and Patty HAYMOND did commit, under the aggravating circumstances of being official representative of the authorities, the SERIOUS CRIMINAL OFFENSES of PROFITABLE AND USEFUL PASSIVE COMPLICITY OF CRIMINAL OFFENSES and of CORRUPTION, COLLUSION and OBSTRUCTION of JUSTICE, LACK OF NEUTRALITY.

Defendants used deceits, lies, ruses, bad faith and omissions against Plaintiff who trusted them as the only one and highest authorities.
Defendants did use and increased the Plaintiff’s distress of his situation being already victim of numerous serious criminal offenses.
Plaintiff suffered stress, anxiety, worries, loss of trust in his representative which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting his several projects, in process and/or in development, by disturbing his mind which is his main tool, being inventor, master philosopher, writer, theoretician, designer.
Plaintiff lost opportunities to sell his car, to get money, to use his money for other purposes as investment, and in addition, he can not use his car when he needed it after his accident.

The 10th of september 2014.

Laurent GRANIER, Plaintiff, self-represented