Case: Pending Liam Wolfe v. Chris West (2025) CV 05

[xXLordLyonXx]

Liam Wolfe, Plaintiff

v.

Chris West, Defendant



Civil Complaint:

On March 25th, the Defendant was seen using blue concrete to block off the Plaintiff's rented space in the Defendant's store. The Defendant has since threatened legal action against the Plaintiff, although no discernable reason why has been presented. The Defendant is the one, however, that has committed wrongdoing. According to Section 2a of the Protection of Tenants Act, "Landlords are unable to obstruct, destroy, or otherwise modify rented regions without prior consent." The usage of blue concrete to block off access to the rented property from all directions but one, when the rented properly was previously a freely accessible, open-air plot, counts as obstruction, and violates this Act. This case is brought forward to restore the Plaintiff's full access to his plot, and gain restitution owed by the Defendant under the Protection of Tenants Act.


Parties:
Plaintiff - Liam Wolfe, represented by Lysander Lyon
Defendant - Chris West


Factual Allegations:
1) The Plaintiff's rented plot was previously completely unobstructed and fully accessible, as seen in Exhibit A.
2) The Defendant used blue concrete to obstruct all sides of the rented plot, leaving a 1x2 hole, as seen in Exhibits B, C, D, and E.
3) Obstruction of a rented plot is against the Protection of Tenants Act if it is not done with consent, as stated under Section 2a.

Legal Claims:
1) The Defendant's obstruction of the Plaintiff's rented plot violates Section 2a of the Protection of Tenants Act.

Prayer For Relief:
1) A permanent injunction against the Defendant, requiring the removal of the obstruction of the Plaintiff's plot and forbidding the Defendant from acting to obstruct the Defendant's plot again.
2) Payment of a $250 fine for violating the Protection of Tenants Act.
3) Payment of any and all court fees incurred by the Plaintiff for the duration of this case.
4) Payment of $5,000 in special damages to cover the legal fees incurred by the Plaintiff as a result of the Defendant's actions.

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.

 

[xXLordLyonXx]

As the exhibits do not appear to have uploaded in the initial filing, I have attached them here.

 

[Westray]

Writ of Summons

Azalea Isles Civil Court (CR)

Case No. CV-25-05

Plaintiff: Liam Wolfe (ocg)
Defendant: Chris West (ChAkselsen1450)

The Defendant is required to appear before the court in the case of Liam Wolfe (ocg) v. Chris West (ChAkselsen1450). 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.
​

Signed,
Hon. Justice Raymond West

​

 

[ChAkselsen1450]

Ye ye I’m here

 

[Westray]

Ye ye I’m here

Thank you for indicating your presence. Please provide an answer to the complaint. You or your counsel must do so within 48 hours from now.

 

[ChAkselsen1450]

Response to complaint
The plaintiff claims the plot is obstructed. It remains fully accessible through a door made. The law the plaintiff is referencing does not include partial obstruction or change of surrounding property unless done so in a way where it would obstruct the access of the plot. Which it does not here as it is still accessible.

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FACTUAL RESPONSE

1. The Plaintiff claims that their rented plot was "completely unobstructed and fully accessible" prior to the Defendant’s actions. However, the Defendant, as the owner and landlord of the property, has the right to regulate his own property.
2. The Defendant acknowledges placing blue concrete around parts of the Plaintiff’s rented space but asserts that the Plaintiff was still provided reasonable access to the plot through an available entrance (1x2 hole). The placement of blue concrete was neither destructive nor a permanent obstruction.
3. The Defendant did not violate Section 2a of the Protection of Tenants Act, as the modifications made were neither destructive nor unlawful. The Act does not specify that a rented plot must remain in an "open-air" state, nor does it prohibit landlords from managing the layout of their property.

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LEGAL DEFENSES

1. No Violation of the Protection of Tenants Act
   • Section 2a of the Protection of Tenants Act states that "Landlords are unable to obstruct, destroy, or otherwise modify rented regions without prior consent." The Defendant’s actions do not meet the threshold for obstruction as defined by law. The Plaintiff still had reasonable access to the rented space.
   • The Act does not prevent landlords from implementing structural changes for practical property management purposes, provided they do not entirely restrict the tenant's access. The Plaintiff still had an entry point and was not deprived of their ability to use the rented plot.
2. Landlord’s Right to Manage Property
   • As per the Landlord Protection Act, the Defendant retains the right to manage and oversee the rental property to ensure proper organization and usage of the space.
   • The Defendant’s actions were executed in a manner that did not evict or remove the Plaintiff from their rented plot, nor were they intended to infringe upon the Plaintiff’s rights.
3. No Demonstrable Harm or Damages
   • The Plaintiff has failed to provide evidence of financial harm or damages directly caused by the Defendant’s actions.
   • The claim for $5,000 in special damages for legal fees is excessive, unsubstantiated, and not directly linked to the Defendant’s conduct.
   • The Plaintiff also claims a $250 fine is owed under the Protection of Tenants Act; however, the Defendant’s actions do not constitute a violation of said Act.

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REQUEST FOR RELIEF
Based on the above arguments, the Defendant respectfully requests the following relief:

1. Dismissal of all claims with prejudice, as no legal violation has occurred.
2. Denial of the Plaintiff’s request for an injunction, as the Defendant’s actions do not constitute obstruction under the law.
3. Denial of the Plaintiff’s monetary demands, as there is no demonstrable harm.
4. Court costs and attorney fees to be awarded to the Defendant for defending against an unsubstantiated claim.

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CONCLUSION
The Plaintiff has failed to prove that the Defendant violated the Protection of Tenants Act or caused any harm warranting legal or financial restitution. The Defendant acted within their legal rights as a landlord and provided continued access to the Plaintiff’s rented plot. This case should be dismissed in its entirety.

Respectfully submitted,
Chris West

 

[Westray]

The Plaintiff has 48 hours to present their opening statement.

 

[xXLordLyonXx]

Opening Statement

Your Honor,

This case will clearly prove the Defendant's violation of the Protection of Tenants Act.

Language is important. Obstruction can be used to refer to partial blockages, rather than a complete block. Hindering access to a plot is clearly obstruction. Context is also important. This is not a situation where the Plaintiff had three access points and now only has two. The Plaintiff's plot was fully accessible and fully visible, and now both are obstructed to just one access point. In this context, obstruction is more than clear - the Plaintiff rented a plot that was freely visible and accessible, which has now been reduced down to just one doorway. That marks a clear obstruction of the Plaintiff's access to his rented property.

Moreover, this was not the accidental obstruction of access that comes with "managing" one's property - it was an intentional act to obstruct the view of what was on the Plaintiff's property.

The Defendant's legal defenses are broad interpretations of law to favor his views in a situation that is actually quite clear. The claim that the Plaintiff still has "reasonable access" to his plot is farcical - no reasonable individual would consider constricting an open-air plot into a one by one access point "reasonable." Beyond this, the claim has no legal basis - the law does not say "Landlords are unable to obstruct, destroy, or otherwise modify rented regions without prior consent, unless such action maintains reasonable access." It says that, flat-out, landlords may not obstruct, destroy, or modify rented regions without consent.

The other claim to avoid being guilty under the Protection of Tenants Act is just as clearly wrong. Let's break that out into two parts. "The Act does not prevent landlords from implementing structural changes for practical property management purposes, provided they do not entirely restrict the tenant's access." Your Honor, you'd be hard pressed to find this in the Protection of Tenants Act, because there isn't a line in the Act that says it. It's a false interpretation intended to strengthen landlords from a bill that specifically acts to empower renters.

The second part of this claim is just as egregious. "The Plaintiff still had an entry point and was not deprived of their ability to use the rented plot." Individuals have many uses for plots. Someone renting a billboard could have just one block placed in front of said billboard, and that one block would clearly obstruct access and deprive the owner/renter of their ability to use the plot. The Plaintiff rented an open air plot, and the Defendant's actions clearly deprive the Plaintiff of his ability to use the plot as he wants.

The Plaintiff's plot was intentionally obstructed in a major way, which makes the Defendant guilty of violating the Protection of Tenants Act.

This will only be further proven throughout this trial.

 

[Westray]

Thank you. The Defendant has 48 hours to present their opening statement.

 

[ChAkselsen1450]

Closing statement.
I will not be responding to this trial anymore following this statement. Out of respect of the judges time I thought I'd let the court know so no extra time is spent waiting for my response.

My arguements from my answer to the complaint still stands equal to what they were.

The law referenced by the defense states obstruct/obstruction but does not entail anything regarding partial obstruction. This would be a grey area and best left up to parliament to clarify in an amendment

This also finds standing in the guiding principals

A Person’s House is One’s Own Castle:

The exception being where the law takes away such ability. Now the tenants protection against takes away the ability to obstruct a renters region. That being restrict access. But should ruling fall in the plaintiffs favour that opens up for not allowing construction around any rent regions that would partially obstruct them. As far as even new developments of land around could be argued against since it would in some % way obstruct the renters view, access or whatever.

The defense agrees that the law could benefit from an amendment to better clarify partial obstruction but as the law stands now it says only the definitive term of obstruction. This not being a qualifier of such as access remains. There is no such thing as partial access or complete access. The plaintiff can access their rent region fully through the doorway kept for the plaintiff.

The defense has followed the law to the letter and if the renter is unhappy with the amendment the defense is willing to offer reimbursement of the full rent period. Price sits at 10$ per interval.

The plaintiff also requested special damages.

Special damages is awarded where a cost is directly from a harm caused by the defendent. The defendent had nothing to do with the hiring of an expensive attorny for the plaintiff and thus by the opinion of the defense does not qualify as reasoning for special damages.
The rent region costs 10$ and thus is the only realistic damage that could be asked for. The plaintiff use of special damages here is an attempt to make the case over costly for the defense.

Should the plaintiff be awarded special damages as reqested anyone can hire a lawyer and get that lawyer to charge a 100k for their work over any minor dispute to financially target and harm citizens and would be a poor use of this.

As an example of how the defense would argue special damages be used instead is damage for slander in the loss of intended sales for example

Signed
Chris West

 

[Westray]

While the Court acknowledges the Defendant's attempt to summarize his case in a closing remark and note to the Court his anticipated lack of response, unfortunately it is not sufficient enough to address the proper procedures of this court. If the Defendant is unable to respond to the case for a period of time, they may hire counsel to represent them or request an extension.

Given that the Defendant has indicated a "closing statement" in his opening statement, Court will ask the Plaintiff if they wish to agree to a motion for an expedited hearing (closing statements and then verdict, pursuant to the Motions and Objections forum), or if they wish to continue the trial as is. If they wish to continue the trial in its regular format, then witnesses will be called next, and the Defendant will be expected to continue to respond to this case.

 

[xXLordLyonXx]

The Plaintiff is amenable to expediting the hearing. We would request that this statement only be counted for either the opening or the closing statement, however, rather than being allowed to stand in for both.