The plaintiff alleges:
The defendant Christopher Wright aka mistabay997 is, and at all times herein mentioned was, and is a resident of Fremont, CA in Alameda County, California.
The plaintiff is ignorant of the true names and capacities of the defendants sued herein as DOES I-25, inclusive, and therefore sues these defendants by such fictitious names. The plaintiff will amend this complaint to allege their true names and capacities when ascertained. (The plaintiff is informed and believes and thereon alleges that each of the fictitiously named defendants is responsible in some manner for the occurrences herein alleged, and that the plaintiff's damages as herein alleged were proximately caused by their conduct.)
On or about February 16, 2010, defendant Christopher Wright, made the following representation(s) to the plaintiff:that as a result of his name being thrown around on siccness.net/vb, his record sales would increase.
The representations made by the defendant were in fact false. The true facts were he is a tweaker.
When the defendant made these representations, he/she/it knew them to be false and made these representations with the intention to [deceive and defraud the plaintiff and to] induce the plaintiff to act in reliance on these representations in the manner hereafter alleged, or with the expectation that the plaintiff would so act.
The plaintiff, at the time these representations were made by the defendant and at the time the plaintiff took the actions herein alleged, was ignorant of the falsity of the defendant's representations and believed them to be true. In reliance on these representations, the plaintiff was induced to and did ask to ban plaintiff.The plaintiff's reliance on the defendant's representations was justified because he is a white guy that uses the word "nigga".
The aforementioned conduct of the defendant(s) was an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant(s) with the intention on the part of the defendant(s) of thereby depriving the plaintiff of property or legal rights or otherwise causing injury, and was despicable conduct that subjected the plaintiff to a cruel and unjust hardship in conscious disregard of the plaintiff's rights, so as to justify an award of exemplary and punitive damages.
WHEREFORE, the plaintiff prays judgment as follows:
BAN THIS FAGGOT!
I, radiostationrep am the plaintiff in this action. I have read the foregoing complaint and know the contents thereof. The same is true of my own knowledge, except as to those matters that are therein stated on information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury under the laws of the State of Cal. that the foregoing is true and correct.
The defendant Christopher Wright aka mistabay997 is, and at all times herein mentioned was, and is a resident of Fremont, CA in Alameda County, California.
The plaintiff is ignorant of the true names and capacities of the defendants sued herein as DOES I-25, inclusive, and therefore sues these defendants by such fictitious names. The plaintiff will amend this complaint to allege their true names and capacities when ascertained. (The plaintiff is informed and believes and thereon alleges that each of the fictitiously named defendants is responsible in some manner for the occurrences herein alleged, and that the plaintiff's damages as herein alleged were proximately caused by their conduct.)
On or about February 16, 2010, defendant Christopher Wright, made the following representation(s) to the plaintiff:that as a result of his name being thrown around on siccness.net/vb, his record sales would increase.
The representations made by the defendant were in fact false. The true facts were he is a tweaker.
When the defendant made these representations, he/she/it knew them to be false and made these representations with the intention to [deceive and defraud the plaintiff and to] induce the plaintiff to act in reliance on these representations in the manner hereafter alleged, or with the expectation that the plaintiff would so act.
The plaintiff, at the time these representations were made by the defendant and at the time the plaintiff took the actions herein alleged, was ignorant of the falsity of the defendant's representations and believed them to be true. In reliance on these representations, the plaintiff was induced to and did ask to ban plaintiff.The plaintiff's reliance on the defendant's representations was justified because he is a white guy that uses the word "nigga".
The aforementioned conduct of the defendant(s) was an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant(s) with the intention on the part of the defendant(s) of thereby depriving the plaintiff of property or legal rights or otherwise causing injury, and was despicable conduct that subjected the plaintiff to a cruel and unjust hardship in conscious disregard of the plaintiff's rights, so as to justify an award of exemplary and punitive damages.
WHEREFORE, the plaintiff prays judgment as follows:
BAN THIS FAGGOT!
I, radiostationrep am the plaintiff in this action. I have read the foregoing complaint and know the contents thereof. The same is true of my own knowledge, except as to those matters that are therein stated on information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury under the laws of the State of Cal. that the foregoing is true and correct.
