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This 3 page Class Notes was uploaded by Akinyemn on Wednesday January 6, 2016. The Class Notes belongs to 28199 at Grand Valley State University taught by Renee E. Stamper in Fall 2016. Since its upload, it has received 26 views. For similar materials see Courts Process in Criminology and Criminal Justice at Grand Valley State University.
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Date Created: 01/06/16
Nicole Akinyemi Straight Outta Law School, LLP COMPLAINT AND PLAINTIFF DEMANDS TRIAL BY JURY Plaintiff Adam Jackson complains against Defendants Mostly Honest Rentals, LLC and Richard Roberts. Jurisdictional Allegation 1. Jurisdiction in this case is in state court in the state of Michigan. The appropriate venue for this action should be in 61 District Court, 180 Ottawa Avenue NW. Count I – Illegal Entry (against defendant Richard Roberts) 1. Mr and Mrs Jackson signed a one-year lease to rent a duplex at 1818 Fuller, Grand Rapids, MI from Mostly Honest Rentals, LLC. 2. The lease started on January 1 2014 and rent was at $1000.00 a month. 3. On June 15, 2014, Mr Roberts entered home of Adam Jackson without notice of his arrival. 4. Mr Jackson saw someone walking around his home and became afraid as he believed there was an intruder inside his home. 5. Soon after, he realised it was Mr Roberts. Count II – Assault (against defendant Richard Roberts) 6. Mr Roberts was belligerent and became aggressive towards Mr Jackson after being told to leave Mr Jackson’s home and to come back with reasonable notice. 7. Mr Roberts refused and upon doing so, stormed towards Mr Jackson and proceeded to shove him. 8. Mr Jackson fell through the doorway into the basement stairs. He further stumbled down the stairs, hitting the wall at the landing, which continued till he landed in the basement. 9. At this point, Mr Robert left the house. Count III – Medical Bills (against defendant Richard Roberts) 10. Mr Jackson could not stand up after his fall and began to yell for help. His neighbour, Sandy heard him and called the ambulance. 11. At the hospital, Mr Jackson was diagnosed with a fractured femur, and a dislocated shoulder. 12. He had to stay in the hospital for a week. Count IIII – Loss of Income Nicole Akinyemi (against defendant Richard Roberts) 13. As a result of Mr Jackson’s injuries, he was unable to work for over four months. Count V – Pain and Suffering (against defendant Richard Roberts) 14. In October, when Mr Jackson was able to go back to work, he could not walk without a limp and was in constant pain. 15. He has lost his athletic abilities and can no longer enjoy activities such as skiing or cycling. Count VI – Negligence (against defendant Mostly Honest Rentals, LLC) 16. In the spring of 2014, Mr Jackson noticed that the hot water heater wasn’t working very well. His wife, Alisa called Mr Roberts several times regarding the issue, but Mr Roberts didn’t respond. As Mr Roberts is the landlord, he had a duty of care to keep the premise in repair. 17. In May of 2014, Alisa texted Mr Roberts, and he replied after some time stating he would stop by on some morning. 18. On June 15 2014, Mr Roberts entered the home of Mr Jackson without permission or notice with the intention to fix the hot water. 19. The hot water was not fixed on this day. Mr Roberts breached his duty of care as the repair remained unfixed. 20. Mr and Mrs Jackson were unable to enjoy constant, working hot water for over six months of their lease, which caused them discomfort. 21. In the fall 2014, Mr and Mrs Jackson paid $400.00 to a friend to fix the hot water. This was the duty of the landlord and not the tenants, which resulted in Mr Jackson losing $400.00. Count VII – Cost of Moving (against defendant Richard Roberts) 22. At the end of August, Mr and Mrs Jackson moved out of the duplex and moved into another one, which had all the rooms on the same floor 23. The new lease started September 1 2014. The rent is $1200.00 a month. PRAYER OF RELIEF WHEREFORE, plaintiff Adam Jackson demands judgment against defendants Richard Roberts and Mostly Honest Rentals, LLC for: Nicole Akinyemi A. Injuries sustained by the assault; B. Medical bills; C. Pain and suffering; D. Loss of incomes; E. The cost to fix the hot water; F. The cost to move including U-Haul fees; G. Attorneys fees and costs to the extent allowed by law; H. Such further and other reliefs as this Court deems just and proper. Dated: September 30 2015 Nicole Akinyemi Attorney for Plaintiff Straight Outta Law School, LLP 123 Sugar Drive New York, NY 32103 (616) 926-5492
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