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Old November 27th 09, 12:11 AM posted to rec.games.chess.politics
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Default draft of lawsuit 2

UNITED STATES DISTRICT COURT
WESTERN DISTRCIT of TEXAS
EL PASO DIVISON

Marcus Wayne Roberts, a citizen of the United States of America and
Ambassador of the Federation of Saint Christopher and Nevis

V. CASE NO _________________________

Rio Grand Electric Cooperative, Inc., a Texas Corporation
Dan Laws, General Manager/CEO, Rio Grande Electric Cooperative, Inc.
Cerro Alto Development, Inc., a Texas Corporation
John E. Turner, President, Cerro Alton Development, Inc. and Constable
Of Hudspeth County, Texas, District 3

COMPLAINT

PARITIES TO LAWSUIT
1 Plaintiff, Marcus Wayne Roberts, physical address 19308 France Silva
Avenue, El Paso, Texas 79996 mailing address PO BOX 961029, El Paso,
Texas 79996.
2. Rio Grande Electric Cooperative, Inc., Highway 90 & SH 131,
Brackettville, Texas 78832
3. Dan Laws, Highway 90 & SH 131, Brackettville, Texas, 78832
4. Cerro Alto Development, Inc.11900 Montana Avenue, El Paso, Texas,
79936
5. John E. Turner, 11900 Montana Avenue, El Paso, Texas, 79936
JURISDICTION
6. This action is a federal question primarily for three reasons:
7. Rio Grande Electric Cooperative, Inc. is the recipient of Federal
financial assistance from the U.S. Department of Agriculture (USDA).
The USDA prohibits discrimination in all its programs and activities
on the basis of race, color, national origin, age, disability, and
where applicable, sex, marital status, familial status, parental
status, religion, sexual orientation, genetic information, political
beliefs, reprisal, or because all or part of an individual’s income is
derived from any public assistance program.
8. United States Constitution, Amendment V (1791)
No person shall be held to answer for a capital, or otherwise infamous
crime, unless on a presentment or indictment of a grand jury, except
in cases arising in the land or naval forces, or in the militia, when
in actual service in time of war or public danger; nor shall any
person be subject for the same offense to be twice put in jeopardy of
life or limb; nor shall be compelled in any criminal case to be a
witness against himself, nor be deprived of life, liberty, or
property, without due process of law; nor shall private property be
taken for public use, without just compensation.
9. United States Constitution, Amendment XIV (1868) Section 1
All persons born or naturalized in the United States, and subject to
the jurisdiction thereof, are citizens of the United States and of the
state wherein they reside. No state shall make or enforce any law
which shall abridge the privileges or immunities of citizens of the
United States; nor shall any state deprive any person of life,
liberty, or property, without due process of law; nor deny to any
person within its jurisdiction the equal protection of the laws.
VENUE
10. Property owned by the Plaintiff sits in Hudspeth County, Texas, in
the Western Federal District of Texas. Defendants with Rio Grande
Electric, Inc. do business in the western district of Texas, and
signed a PEACE bond before Justice of the Peace Juanita Callier, in
Hudspeth County, Texas. Defendant Cerro Alto Development, Inc., and
Constable John Turner sold property to plaintiff in Hudspeth County,
Texas. (See exhibit “A”).

COUNT 1: REFUSAL TO CONNECT POWER
11. Dan Laws, CEO of Rio Grand Electric Cooperative, refuses to
connect power to TWO LOTS adjacent my homestead for RV use. I need two
200 amp poles. In an email dated November 24, 2009. Mr. Law refuses to
establish power along the same lines as the lawsuit filed by me
against Rio Grande Electric Cooperative, Inc. et.al. (EP09CV0403) on
November 9, 2009. Plaintiff seeks unspecified damages for TWO RV
rental sites. Appropriate sewage facilities and water supplies have
been constructed.
COUNT II: EXTORTION
12. Plaintiff has been charged with a class “B” misdemeanor relating
to the power hookup request. Mr. Laws, again, attempts to extort a
confession. Plaintiff seeks unspecified damages and punitive damages
for EXTORTION in email dated Tuesday, November 24, 2009.
COUNT III: BREECH OF CONTRACT
13. Constable Turner guaranteed by contract power was readily
available. Plaintiff seeks unspecified damages.
COUNT IV: DECEPTIVE TRADE PRATICES
14. Plaintiff seeks depictive seeks TRIPLE damages against defendant
Turner and Cerro Alto Development Company, Inc for hotel costs.
Plaintiff seeks TRIPLE damages because Rio Grand Power company charged
Plaintiff approximately 2,500 dollars cash on his VISA credit card for
access to electricity. Costs of electric connection are supposed to be
FREE for home connection, due to board policy. Defendant Turner knew
of neighbors in Deer Mountain being refused power connections and
refused to disclose fact to Plaintiff prior to sale of property.
COUNT V: FALSE ADVERTISING
15. Defendant Turner and his company openly advertises ELECTRICITY
AVIABLE by sign at entrance to subdivision off Montana Avenue for Deer
Mountain, in which Plaintiff paid Defendant approximately 30,000
dollars for 3 lots. No electricity is available.

COUNT V: MENTAL ANGISH AND PUNATIVE DAMAGES
16. Plaintiff seeks punitive damages for mental anguish. Plaintiff is
unable to get heat in his home. Plaintiff has heart condition, and
can’t stay warm on his property in new mobile home or in RV’s.
PLANTIFF IS COLD! This damage claim overlaps claims for damages made
by plaintiff for the first lot. Plaintiff did not claim MENTAL ANGUISH
in first lawsuit.
17. Plaintiff seeks service of process feels and filing costs of 350
dollars and all other remedies at law from this HONORABLE COURT.

__________________________________________________ __
Marcus Wayne Roberts mailing address: PO BOX 961029
PRO SE El Paso, Texas 79996
Sunday November 29, 2009
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