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- Jun 30, 2024
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Kendall Hamilton, Plaintiff
v.
Azalea Isles, Defendant
Civil Complaint:
The Plaintiff opened a ticket with the Ministry of Urban Development on February 2nd, to paste in his build across b048, b050, and b051. Plaintiff requested the build be tendered on March 15th. It has been more than two months since this initial request was made, and the Ministry of Economic Affairs has failed to do the cost calculation and tendering to allow the build to be pasted in, including publicly stating the refusal had to do with the Plaintiff being on LoA.
This failure by the Ministry of Economic Affairs to do the tenders is a violation of the Government fulfilling their responsibilities, and has cost the Plaintiff significant revenue that he would have otherwise received from rents, shops, and planned projects in the build.
Parties:
Plaintiff - Kendall Hamilton
Plaintiff's Counsel - Lysander Lyon
Defendant - Azalea Isles
Factual Allegations:
(1) Plaintiff opened his first ticket to request the paste on February 2nd (Exhibit B).
(2) Plaintiff made a request for his build to be tendered on March 15th, confirmed by the MUD Minister Nanicholls Nanicholls (Exhibit B).
(3) Plaintiff’s paste was not tendered.
(4) Plaintiff’s ticket was closed by the Ministry of Urban Development during reorganizing and review under a new MUD Minister, Octavian Russell (Exhibit B).
(5) Plaintiff opened the correct new ticket on April 29th (Exhibit D).
(6) The MUD Minister gave the MEA the block list that same day (Exhibit D).
(7) The paste has still not been tendered, or even cost calculated.
(8) The Minister of Economic Affairs has publicly stated he is “Not tendering for someone who doesnt play and is on loa for 2 more months.” (Exhibit A)
(9) There is no MEA policy about leaves of absence affecting the paste tender process.
(10) The cost calculation/tender process has been the duty of the Minister of Economic Affairs for the duration of multiple MUD and MEA Ministers’ terms, as is explictly assigned to the MEA under Section 7(a)viii of the Governing Structure Act.
(11) Another citizen, Iturgen Bolir, is not on a Leave of Absence, and has had his cost calculation done and tenders posted (Exhibit E).
(12) Plaintiff was unable to use his plots for planned store rentals, apartments, and a casino, and has lost significant revenue as a result.
(13) To demonstrate this revenue loss, Plaintiff hosted one of his planned casino games that has been delayed by this project on the evening of May 21st. Plaintiff made approximately $56,000 in cash profit and also won four plots, which were accepted as bets, offered at $45,000 each, on this one night he hosted the game (Exhibit F).
Legal Claims:
(1) Citizens have a reasonable expectation that Ministries will fulfill their legally assigned obligations, particularly where it impacts citizen services facilitated by the Government, and failure by a Ministry to do so creates standing for claims. A citizen's pastes being held up by a Ministry, particularly where the law clearly dictates responsibilities to the Ministry it is not fulfilling, creates a clear claim and standing.
(2) Regardless of the specific amount of time that should be considered reasonable or timely, the Plaintiff’s wait cannot be considered either.
(3) The MEA’s extended failure to provide Plaintiff the cost calculation and tendering violates Article I of the Constitution, in light of the Minister’s claim that Plaintiff’s Leave of Absence means he will not have tenders or cost calculating done. There is no MEA policy that declares this, and as such, Plaintiff is unconstitutionally being treated as different from other citizens who had their pastes processed.
(4) The extended failure to provide cost calculation and tendering not only creates standing for this claim, but also for damages. Plaintiff has been unable to utilize his plots, which could otherwise have been actively receiving rent, selling items, or taking in revenue from Plaintiff’s planned projects.
This is clearly demonstrated by Plaintiff’s one singular test night, which earned him $236,000 in profit, counting the plots. Over sixty days (allowing 8-9 days for tendering), that would be $14,160,000 in earned revenue. Now, the Plaintiff recognizes not every single day would make that much. Instead, for the sake of reasonable compensation, the Plaintiff is asking for just 5% of that single day’s figure to be considered reasonable daily revenue from the casino, $11,800 per day, which still comes out to $708,000.
We understand this is a significant sum, but Plaintiff’s test for just one single night and one single game clearly proves that he has lost revenue well into the six figures because of the Government's, and specifically the Ministry of Economic Affairs', failure to complete their legal responsibility of tendering his plots. We ask Your Honor to factor that in when reviewing the Prayer for Relief.
Prayer For Relief:
(1) Compensatory damages in the amount of at least $1,000 per week the case goes on, in accordance with Section 2(a) of the Damages Reform Act.
(2) Compensatory damages in the amount of up to $15,000 for lost rental revenues, accounting for the Plaintiff’s inability to use his plots and earn revenue from planned shop and apartment rentals.
(3) Compensatory damages in the amount of up to $708,000 for lost business revenues, to account for an extremely low valuation of Plaintiff’s lost revenue from his planned casino business for the plots.
(4) Punitive damages in the amount of $25,000, to account for constitutional violations in how the Plaintiff was treated, and for the significant length of time Plaintiff has waited without the process being done.
(5) A Writ of Mandamus compelling the Ministry of Economic Affairs to complete and return the cost calculation to the Plaintiff within seven calendar days of a verdict being returned in favor of the Plaintiff.
(6) A Writ of Mandamus compelling the Ministry of Economic Affairs to complete the tendering process in entirety, including collecting items, within fourteen calendar days of the Plaintiff responding to the MEA-provided cost calculation with approval to tender, or a specific subset of blocks to tender.
Verification:
I, Lysander Lyon, 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.
Evidence:
All Exhibits should be attached to this filing. There should be 6 - two images and four PDFs. Please let me know if any are not open-able. Exhibit E can also be found here - https://cityrp.org/threads/i021-paste.3483/
v.
Azalea Isles, Defendant
Civil Complaint:
The Plaintiff opened a ticket with the Ministry of Urban Development on February 2nd, to paste in his build across b048, b050, and b051. Plaintiff requested the build be tendered on March 15th. It has been more than two months since this initial request was made, and the Ministry of Economic Affairs has failed to do the cost calculation and tendering to allow the build to be pasted in, including publicly stating the refusal had to do with the Plaintiff being on LoA.
This failure by the Ministry of Economic Affairs to do the tenders is a violation of the Government fulfilling their responsibilities, and has cost the Plaintiff significant revenue that he would have otherwise received from rents, shops, and planned projects in the build.
Parties:
Plaintiff - Kendall Hamilton
Plaintiff's Counsel - Lysander Lyon
Defendant - Azalea Isles
Factual Allegations:
(1) Plaintiff opened his first ticket to request the paste on February 2nd (Exhibit B).
(2) Plaintiff made a request for his build to be tendered on March 15th, confirmed by the MUD Minister Nanicholls Nanicholls (Exhibit B).
(3) Plaintiff’s paste was not tendered.
(4) Plaintiff’s ticket was closed by the Ministry of Urban Development during reorganizing and review under a new MUD Minister, Octavian Russell (Exhibit B).
(5) Plaintiff opened the correct new ticket on April 29th (Exhibit D).
(6) The MUD Minister gave the MEA the block list that same day (Exhibit D).
(7) The paste has still not been tendered, or even cost calculated.
(8) The Minister of Economic Affairs has publicly stated he is “Not tendering for someone who doesnt play and is on loa for 2 more months.” (Exhibit A)
(9) There is no MEA policy about leaves of absence affecting the paste tender process.
(10) The cost calculation/tender process has been the duty of the Minister of Economic Affairs for the duration of multiple MUD and MEA Ministers’ terms, as is explictly assigned to the MEA under Section 7(a)viii of the Governing Structure Act.
(11) Another citizen, Iturgen Bolir, is not on a Leave of Absence, and has had his cost calculation done and tenders posted (Exhibit E).
(12) Plaintiff was unable to use his plots for planned store rentals, apartments, and a casino, and has lost significant revenue as a result.
(13) To demonstrate this revenue loss, Plaintiff hosted one of his planned casino games that has been delayed by this project on the evening of May 21st. Plaintiff made approximately $56,000 in cash profit and also won four plots, which were accepted as bets, offered at $45,000 each, on this one night he hosted the game (Exhibit F).
Legal Claims:
(1) Citizens have a reasonable expectation that Ministries will fulfill their legally assigned obligations, particularly where it impacts citizen services facilitated by the Government, and failure by a Ministry to do so creates standing for claims. A citizen's pastes being held up by a Ministry, particularly where the law clearly dictates responsibilities to the Ministry it is not fulfilling, creates a clear claim and standing.
(2) Regardless of the specific amount of time that should be considered reasonable or timely, the Plaintiff’s wait cannot be considered either.
(3) The MEA’s extended failure to provide Plaintiff the cost calculation and tendering violates Article I of the Constitution, in light of the Minister’s claim that Plaintiff’s Leave of Absence means he will not have tenders or cost calculating done. There is no MEA policy that declares this, and as such, Plaintiff is unconstitutionally being treated as different from other citizens who had their pastes processed.
(4) The extended failure to provide cost calculation and tendering not only creates standing for this claim, but also for damages. Plaintiff has been unable to utilize his plots, which could otherwise have been actively receiving rent, selling items, or taking in revenue from Plaintiff’s planned projects.
This is clearly demonstrated by Plaintiff’s one singular test night, which earned him $236,000 in profit, counting the plots. Over sixty days (allowing 8-9 days for tendering), that would be $14,160,000 in earned revenue. Now, the Plaintiff recognizes not every single day would make that much. Instead, for the sake of reasonable compensation, the Plaintiff is asking for just 5% of that single day’s figure to be considered reasonable daily revenue from the casino, $11,800 per day, which still comes out to $708,000.
We understand this is a significant sum, but Plaintiff’s test for just one single night and one single game clearly proves that he has lost revenue well into the six figures because of the Government's, and specifically the Ministry of Economic Affairs', failure to complete their legal responsibility of tendering his plots. We ask Your Honor to factor that in when reviewing the Prayer for Relief.
Prayer For Relief:
(1) Compensatory damages in the amount of at least $1,000 per week the case goes on, in accordance with Section 2(a) of the Damages Reform Act.
(2) Compensatory damages in the amount of up to $15,000 for lost rental revenues, accounting for the Plaintiff’s inability to use his plots and earn revenue from planned shop and apartment rentals.
(3) Compensatory damages in the amount of up to $708,000 for lost business revenues, to account for an extremely low valuation of Plaintiff’s lost revenue from his planned casino business for the plots.
(4) Punitive damages in the amount of $25,000, to account for constitutional violations in how the Plaintiff was treated, and for the significant length of time Plaintiff has waited without the process being done.
(5) A Writ of Mandamus compelling the Ministry of Economic Affairs to complete and return the cost calculation to the Plaintiff within seven calendar days of a verdict being returned in favor of the Plaintiff.
(6) A Writ of Mandamus compelling the Ministry of Economic Affairs to complete the tendering process in entirety, including collecting items, within fourteen calendar days of the Plaintiff responding to the MEA-provided cost calculation with approval to tender, or a specific subset of blocks to tender.
Verification:
I, Lysander Lyon, 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.
Evidence:
All Exhibits should be attached to this filing. There should be 6 - two images and four PDFs. Please let me know if any are not open-able. Exhibit E can also be found here - https://cityrp.org/threads/i021-paste.3483/
