Case: Pending Vontobel v. Ministry of Urban Development (2025) CV 07

[MilkCrack]

Vontobel, Plaintiff
v.
Ministry of Urban Development, Defendant

Civil Complaint:​

Plaintiff Vontobel brings this action against the Ministry of Urban Development (MUD) for the unlawful and unauthorized seizure of plots registered under Omegabiebel's name.

The plaintiff has a clear right to be secure against unreasonable searches and seizures. MUD's actions constitute an infringement on this right.

Parties:​

• Plaintiff: Vontobel ("Volt"), a financial institution with an active security interest in the disputed land plots.
• Defendant: Ministry of Urban Development.

Factual Allegations:​

1. Omegabiebel had registered under their name plots B107, B108, B128 and B129. As part of a loan agreement including Vontobel.
2. On or about the 24th of May, The Ministry of Urban Development seized plots B107, B108, B128 and B129.
3. The plots were seized citing the following reason: "Because you currently are in possession of plots which are contractually required to be held by Raze"
4. Omegabiebel opened, a ticket with the Ministry of Urban Development asking for clarification, and his plots back.
5. The Minister of Urban Development at the time (Fergie_Foo) cited the reason why the plots were seized as "Raze was the company, owned by Wetc, who developed the land and illegally sold it to you. The plots were not theirs to sell, and so they have been reclaimed by the government."
6. On or about the 6th of June, The new MUD minister OCG stated "And by verifying you are not part of Raze “After completion of the development, the Ministry of Urban Development agrees to allow Raze Development to retain ownership of the ceded land outlined previously.” when wetc hit the 30 day inactivity limit, the plot was seized. Volt was not given permission to hold the land via the contract, only raze"
7. On or about the 7th of June, the same minister stated "If the land was handed to Wetc, he would have had to open a ticket to register it. But instead the contract which is in MUD records and signed by a minister, states the business owns the land and who operates the business."
8. On or about the 10th of June the Prime Minister stated: "At no time did any third party have ownership of the plots. Them being provided as collateral does not suddenly change their actual owner, nor was there any update to their registration as a business plot. We have no record of the plots being registered under Vontobel."
9. The Ministry of Urban Development has been repeatedly asked to return the plots and go through the proper channels but has refused to do so. Stating "By all means, I look forward to your lawsuit."
10. The seizure of the plots was done unilaterally by the Ministry of Urban Development, without a court warrant.

Legal Claims:
(1) Unlawful seizure. The defendant unlawfully seized property in which Plaintiff held a valid security interest, with no legal cause. As per The Contract Establishment Act, the legal remedy for a breach of contract is to file a lawsuit against the offending party. The Ministry of Urban Development did not file a lawsuit and chose to just seize the plots using the power of the state instead. Violating not only statutory law but also constitutional law prohibiting such unlawful seizures.
(2) Government Overreach. The seizure occurred without any hearing, warning, or adjudicative process, in breach of principles of procedural fairness. And constitutes a government overreach of powers.
(3) Tortious Interference. By seizing the collateral without justification, and taking up so much of the plaintiff's time the Ministry interfered with Vontobel’s financial agreement and damaged the enforceability of its secured interest. Leading to financial losses.

Prayer for Relief:​

Plaintiff respectfully requests that the Court:
(1) Order the Ministry of Urban Development to immediately restore possession of the plots to Omegabiebel;
(2) Enjoin the Ministry from further unlawful interference with Vontobel’s collateral or security rights;
(3) Award compensatory damages for any loss suffered due to the Ministry’s actions; Amounting to $1699.50 per day since the 10th of June for lossed earnings. And $5,000 total for time spend dealing with the ministers actions.
(4) Award legal fees and costs to the Plaintiff; Amounting to $1,000 per week from the start of this courtcase.
(5) Award punitive damages. Amounting to $10,000.
(6) Grant such other relief as the Court deems just and proper under the circumstances.
(7) Place an Emergency injunction to return the plots to the plaintiff immediatly so they can continue with their bussines activities.

Verification:​

I, Milkcrack, hereby affirm that the allegations in the complaint AND all subsequent statements made in court are true and correct to the best of the plaintiff's knowledge, information, and belief and that any falsehoods may bring the penalty of perjury.


Attached, are pictures of the ticket transcript presented as evidence. Due to forum, size limits and discord limitations, they are formatted in reverse. Unfortunatly we do not have permission in the discord to get a transcript of the ticket from the bot.

 

[Westray]

Before the Court issues a summons, please amend your complaint to include a number of how much compensation the Plaintiff would require in their prayer in relief. This may include calculated estimates, based on past precedent, or on lawful standards.

 

[MilkCrack]

You honour, the complaint has been amended.

 

[Westray]

Writ of Summons

Azalea Isles Civil Court (CR)

Case No. CV-25-067
​

Plaintiff: Vontobel ("Volt")
Defendant: Ministry of Urban Development

​

The Defendant is required to appear before the court in the case of Vontobel v. Ministry of Urban Development. Failure to respond within 48 hours may result in a default judgement. Both parties are ask to familiarize themselves with the relevant court documents, including proper formats, as well as the laws referenced in the complaint. Ensure that you comply with any court orders.

If you wish to hold this trial at the Azalea Courthouse in-person, please note that in your response. The Court will try to work with both parties to hold live hearings at convenient times.

​

Signed,
Hon. Chief Justice Raymond West

 

[Westray]

On the matter of the emergency injunction, as specified in the Plaintiff's Prayer for Relief §7, the Court will rule on this matter once the Defendant has had the opportunity to respond to this case. It is advised that the Defendant provides their arguments on the injunction in their answer to the complaint.

 

[xXLordLyonXx]

Your Honor, given that this weekend is Father's Day weekend, I am requesting an additional 48 hours extension. I recognize this is a significant extension, but given that many celebrate today and some celebrate tomorrow, coordination is nearly impossible until the week begins.

 

[Westray]

The extension of 48 hours is granted given the holiday. Once this extension has passed, the Court shall rule on the emergency injunction.

In the meantime until the emergency injunction is ruled on, the Court will be asking that the Ministry of Urban Development refrains from selling, removing, giving away, or otherwise modifying the status of b107, b108, b128 and b129.

 

[xXLordLyonXx]

Motion To Dismiss

Your Honor, the Plaintiff in this case is named as Vontobel. However, Vontobel has no standing to sue. This is simply a matter of fact. The Plaintiff claims the plots are Vontobel's property, and that the government has illegally seized this property of Vontobel, yet they were never registered as such with MUD. In order for the plots to legally be owned by Vontobel, the business, the plots would have had to have been registered with MUD as business plots. The plots have never been registered to their name with MUD, and not only was this registration never done, it was never even attempted, nor has the Plaintiff provided any evidence to indicate otherwise, so again - Vontobel cannot have legal standing here.

 

[Westray]

The Plaintiff has 48 hours to provide a response to the motion to dismiss before the Court rules on it.

 

[MilkCrack]

Your Honour,

The Defendant unlawfully seized property registered under the name of an agent acting on behalf of my client. As a result of this improper seizure, my client has suffered financial damages, this is sufficient grounds to establish standing.

Furthermore, no law grants the Ministry of Urban Development final authority to determine plot ownership and citizens should be thankful for that. The Ministry has repeatedly failed to maintain a consistent position on who owns the plots in question.

At various times, the Ministry has claimed the plots belonged to Wetc, then to Raze Development, then to Omegabiebel or Vontobel, and back again cycling through explanations with little regard for clarity or consistency.

Putting an end to this confusing and arbitrary bureaucratic behaviour is precisely what this case is about.

In fact, the Defendant said it best in their motion to dismiss: "This is simply a matter of fact."

And matters of fact should be litigated during trial, not a motion to dismiss.

If the Defendant wishes to establish ownership or lack thereof, they should present evidence and arguments before the Court during trial. That is why I respectfully ask that this case be allowed to proceed and that the motion to dismiss be denied.

 

[xXLordLyonXx]

Motion to Strike

Your Honor, businesses are clearly required to register their plots with the Ministry of Urban Development under Section 2 of the Plot Regulation Act. The Plaintiff claims that "no law grants the Ministry of Urban Development final authority to determine plot ownership." The Plot Regulation Act specifically states that "Businesses shall release the following information to the ministry upon decision to designate a plot an asset to a business," and then lists the required information. While I can go on about how process was never completed and the Plaintiff hasn't proved that it was, which means it cannot be a plot owned by a business, the point here is that the Plaintiff's claim is completely and utterly false. There is a law on the books that directly disproves the Plaintiff's statement, and thus we would ask it be excluded from his response.


Hearsay Objection

The Plaintiff claims that the Ministry of Urban Development has said, at some unknown time, that the plots belong to Omegabiebel or Vontobel. The Plaintiff has not provided/pointed to evidence of this, and it is in fact in direct contradiction of the evidence he provided the court in his filings, in which MUD has been clear these plots are owned by Wetc/Raze Holdings (which are legally not separate entities under Azalean law). Even if one wished to argue for a distinction between those two, MUD did not ever acknowledge Vontobel's ownership in the provided evidence, nor could the Ministry given Vontobel never even attempted to register the plots, and so any Wetc/Raze arguments are irrelevant. This claim is hearsay for the purposes of the arguments on the motion and should not be considered.