API tools faq
paste
Guest User

Untitled

a guest
Aug 15th, 2018
274
0
Never
Add comment
Not a member of Pastebin yet? Sign Up, it unlocks many cool features!
Clone C++ 6.99 KB | None | 0 0
raw download clone embed print report
  1. HONORABLE JUDGE JAMES R. HELER  
  2. ( Note: the judges name is actuall HELLER, with 2 "L"s....)
  3.  
  4.  
  5. IN THE DISTRICT COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE
  6.  
  7.  
  8. CHASSIDY F. LUCAS
  9. Plaintiff,
  10.         Plaintiffs
  11.  
  12. v.
  13.  
  14. JOE CAMACHO
  15.  
  16.         Defendants.
  17.    
  18.  
  19.  
  20.               Case NO. 762152
  21.  
  22.  
  23.  
  24.             Motion to AMMEND COMPLAINT               for Cause
  25.  
  26.            
  27.  
  28.          
  29.        
  30.  
  31. COMES NOW THE PLAINTIFF, in order to SHOW CAUSE FOR TRIAL and AMMEND COMPLAINT no. 762152.
  32. HISTORY
  33.  
  34. In 2007 Honorable  Judge James R. Heller dismissed Lucas vs. Camacho case  no. 762152 WITHOUT PREJUDICE binding the terms of a stipulated and numbered “Agreement”.
  35.  
  36. COMPLAINT
  37.  Lucas Plaintiff alleges (Camacho party) currently has violated “Agreement” including but not limited to the following causes so forth;
  38.  
  39. BREACH OF COURT ORDER, MATERIAL BREACH AND FORFEITURE, BREACH OF AGREEMENT, LIQUIDATED DAMAGES SUFFERED BY NON-VIOLATING PARTY, DEFAULT BY VIOLATING PARTY, BREACH OF A NO CONTACT ORDER, THIRD PARTY DAMAGES.
  40.  
  41. Plaintiff alleges the (Camacho party) has broken agreement in regard to third party damages, specifically WHEREAS in 2007 the DEFENDANT party was previously provided proof of PLAINTIFF extensive environmental/regulatory history background and Credentials, WHEREAS the DEFENDANT parties were informed of the PLAINTIFF intellectual properties and proprietary interests, WHEREAS the DEFENDANT parties have NOW willfully violated, including third party associates as recited in “Agreement”. (see Agreement Recitals 1,5,6,7)
  42.  
  43. The PLAINTIFF asserts that the (Camacho Party) has willfully violated agreement and has now suffered multiple damages caused by breach and third party damages which were to be prohibited.(see Incorporation of Recitals. #1)
  44.  
  45. The PLAINTIFF claims that Joe Camacho has now violated the “AGREEMENT” and has developed sub- founding companies, including but not limited to “Drakkar Industries” and has violated no contact order by means of internet misusage. The parties have engaged in internet commentaries, libel and slander hosted by third party and associate Michael T. Halligan. The Third parties have attacked, harassed and diluted the plaintiff party reputation, while interfering with CUSTOMER RELATIONSHIPS, TRADE METHODS, SOLUTIONS, AND PROPRIETARY INTERESTS. ( see Parties #2 a., b. )
  46.  
  47. The Plaintiff asserts that Camacho parties have willfully broken the “AGREEMENT”, and have harassed the Lucas party publicly, while interfering in NEW projects including but not limited to Public Book Release, and harassment to our children, children’s environmental projects and to the “Lucas” reputation.
  48. Lucas is a Public Figure and for this the damages are higher.
  49.  
  50. Lucas asserts that the Camacho party has willfully imposed on patent, trademark, and copyrights owned by Lucas in which was to be protected in 2007 “AGREEMENT” including Camacho third parties for TIME PERIOD WITHOUT PREJUDICE AFTER FEBRUARY 28, 2007. (see Waivers and Releases. A.), (4. Consideration c., d, g) , (6. Availability of Legal Advice and Warranty of Comprehension and Authority to Sign Agreement and Non-Assignment of Claim: ) , (7. Entire Agreement and changes to Agreement:) , ( Execution of Agreement & Additional Documents: ) , (10. Presumption Regarding Drafting) , (12. No Assignment)
  51.  
  52. AMMENDMENT OF PARTIES
  53. To include additional members to current parties as stipulated per “AGREEMENT”;
  54. 1.  “Lucas” party to include her current spouse Bianca Lucas, and associate CB Stormwater whom have also been injured by breach.
  55.  
  56. To include additional members to current parties as stipulated per “AGREEMENT”;
  57. 2.  “Camacho” party to include any sub- businesses and / or sub-founding business and to also include now the following associates per “AGREEMENT” stipulations; Angela Stephenson, Drakkar Industries, Pape Materials Handling, Enpac, Michael T. Halligan, Barakas Martin and Tomlinson, Aric Bomsztyk, Camacho Services, and other affiliates to also include; Dana McGuire, Joe Lara, Dolores Lara, Holroyd Co., Watermans, Eco SWPPP, Jeff Pool, Kerry Lawrence, Norcal, Pati Lois all of which have commented together on public forums manufacturing and deforming commentaries with intent to harm.
  58.  
  59.  
  60.  
  61. RELIEF THE PLAINTIFF IS SEEKING
  62. The PLAINTIFF has suffered multiple damages, and is now Requesting that the Courts compensate Chassidy Lucas for (Camacho parties) first material breach in the amount of $5,000.00 in liquidated damages per “AGREEMENT” violation terms.
  63.  
  64. Including but not limited to any further damages in the ACTUAL amount for which is due per “AGREEMENT” on account thereof.
  65.  
  66. The Plaintiff further seeks compensation for court time and costs, for the interruption in which shall be tried again for causes to include third party damages; including but not limited to LIBEL, SLANDER, ECONOMIC TORTS, INVASION OF PRIVACY, COMPUTER MISUSE, AGGRAVATION, SEXUAL HARRASSMENT, HARRASSMENT TO OUT CHILDREN, VIOLATION OF CIVIL AND CONSTITUTIONAL RIGHTS AS AN MINORITY, WOMEN OWNED, AND OPERATED COMPANY , BREACH OF CONTRACTUAL “AGREEMENT” STIPULATIONS.
  67. Lucas seeks declaration that ALL prior Counts be reinstated per original Complaint filed in 2007 to include but not limit as forth;
  68. COUNT 1-CONVERSION, COUNT 2 – UNJUST ENRICHMENT, COUNT 3-INTERFERANCE WITH BUSINESS RELATIONSHIPS.
  69.                    
  70. Lucas also seeks declaration that associates and /or sub – founders and/ or affiliates include  Drakkar Industries, George Parker, Lori Parker and Michael T. Halligan to update stipulated agreement under Camacho party and shall bind the parties from further breach of “Agreement” and that should any of the parties violate breach, the non-violator shall be award in the amount of $5,000.00 and any further damages due in the actual amount should breach occur, including but not limited no contact stipulation.
  71.  
  72. Lucas also seeks incarceration charges for damages caused by the violating parties.
  73.  
  74. CONCLUSION
  75. Currently Camacho DEFENDANTS including; Joe Camacho, Angela Stephenson, Deborah Camacho, George Parker and Lori Parker and PLAINTIFF shall be bifurcating case no. 11-cv-05350 in regards to United States Patent and Trademark issues in which has proceeded since the dismissal of case no. 762152 WITHOUT PREJUDICE pending future issues.
  76. In addition the Plaintiff is re-representing herself now as “pro se” and has request for “preliminary injunction” enjoining the DEFENDANTS per USPTO patent and trademark related issues currently held in Supreme Court presiding Honorable Benjamin H. Settle in which shall be overseeing the discovery of the intellectual property issues. Case no. 11-cv-05350 is in precedence to previous case, although shall be addressed as a separate issue.
  77.  
  78. RESPECTFULLY SUBMITTED this 05th day of November, 2011.
  79.  
  80.  
  81.  
  82. By:   /s/ Chassidy Lucas
  83.                     Power of Attorney, pro se
  84.                     For Chassidy Lucas
  85.                                                       508 Le Lou Wa Pl.
  86.                                                       Tacoma, WA 98422
  87.                             P. (855) 787-6787
Add Comment
Please, Sign In to add comment
Public Pastes
We use cookies for various purposes including analytics. By continuing to use Pastebin, you agree to our use of cookies as described in the Cookies Policy.  OK, I Understand
Not a member of Pastebin yet?
Sign Up, it unlocks many cool features!