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UNITED STATED DISTRICT COURTDISTRICT OF RHODE ISLAND
Plaintiff
Melinda Laucks 2D Bonniecrest GardensNewport RI 02840401 846 1898
v. COMPLAINT
Defendants:
Mark McVayc/o Adult Correctional Institution, 40 Howard Street, Cranston RI 02920
John Deacon Jr. Esq. 72 Pine Street, Providence RI 02903 W. Mark Russo, as individual and in his capacity as RI Superior Court Special Master55 Pine Street, Providence RI 02903
John A. Dorsey, as individual and in his capacity as RI Superior Court Special Master55 Pine Street, Providence RI 02903
Seth Schalowc/o 55 Pine Street, Providence RI 02903
Michael A. Silverstein, as individual and in his capacity as RI Superior Court Judge250 Benefit Street, Courtroom Room 17, Providence, RI 02903
Benjamin Cutchshaw, Esq.695 Town Center Drive 17th Floor Costa Mesa, CA 92626. Phone: +1 714 668 6200
1 At all times mentioned hereafter, except as noted, the Plaintiff is and remains a resident of the State of Rhode Island.
1
2 Defendant Mark McVay is a resident of the State of Rhode Island currently incarcerated at the Adult Correctional Institute in Cranston, RI
3 Defendant John Deacon Jr. Esq. resides and practices law in the State of Rhode Island
4 Defendant W. Mark Russo Esq. resides and practices law in the State of Rhode Island and
acts as Court Appointed Special Master to the business US Textile Inc.
5 Defendant John A. Dorsey Esq. practices law in the State of Rhode Island and acts as
Court Appointed Special Master to the business US Textile Inc.
6 Defendant Seth Schalow resides in the State of Rhode Island and maintains operations of
US Textile Inc. under the direction of the Special Master.
7 Defendant Michael A. Silverstein resides and acts in the capacity of Rhode Island
Superior Court Associate Justice, Providence County
8 Defendant Benjamin Cutchshaw Esq. resides and practices law in the State of California
and is attorney for Kolon Industries, the client of US Textile Inc.
9 The Jurisdiction of this Court is invoked pursuant to: RICO Act 91-452, Foreign and
Interstate Commerce Clause, Antitrust, violations of civil rights 42 U.S.C. § 1983
Diversity of Citizenship 28 U.S.C. § 1332,
SUMMARY OF CASE
10 Comes Now, the Plaintiff having been wrongfully denied rightful ownership and access
2
to her business, US Textile Inc. in conjunction to crimes of physical violence upon her on two
occasions within a ten year period, first in 2005 for a period of nearly one year, and again in
2013 by Mr. Mark McVay, her former business partner, who pleaded no lo contendere to crimes
of vandalism, domestic disturbance and also committed assault with a deadly weapon upon her,
and issued other threats of bodily harm, extortion, embezzlement, conversion and used business
funds for the purchase and reckless consumption of improperly acquired controlled substances
including cocaine, marijuana, and adderall; and other personal items beyond a reasonable
allowance.
11 Mr. McVay has been aided and abetted wholly or in part by the remaining Defendants
who have, through abuse of authority, color of office, extortion, intimidation or other means of
collaboration have wrongfully converted the business US Textile Inc. to their own control with
the intention to manipulate the Judicial System to retain ownership permanently.
12 The collective activities of the Defendants have cause the wrongful and permanent denial
of Melinda Laucks to her rightful ownership of US Textile Inc. a business that she spent 13 years
building from nothing. The Defendants have also interfered with her Federally protected
activities including her First Amendment right to petition and participate in a public concern;
they have interfered with her right to associate with persons in her industry, gain rightful
employment in her industry, and have caused permanent defamation of her professional
reputation. Their actions have caused financial devastation and such severe emotional trauma as
to require two instances of hospitalization for anxiety, panic attacks and despair.
3
13 The Defendants used extortion, blackmail and intimidation by public official, color of
office and abuse of the RI Judiciary System to their own financial gain and for the sole intention
of permanent conversion of the business to their own property. Their wrongful expulsion of the
Plaintiff was in complete disregard to the abundant evidence filed by the Plaintiff of Mr. McVay's
breach of fiduciary duty, his attempted embezzlement, and pleadings of no lo contendere to
multiple crimes of physical violence.
14 The business US Textile Inc. is incorporated in the State of Rhode Island but its only
client, Kolon Industries is located in South Korea and all of its customers are located outside of
the State of Rhode Island, thus the Defendants interfered with the Plaintiff's activities and rights
in respect to foreign and interstate commerce.
Factual Background
15 From summer of 2001, Ms. Laucks and Mr. McVay started, as an un-incorporated
partnership, concurrently to their full time jobs, a part-time company, US Textile, as a textile
sales agent in New York City.
16 In January of 2002, Mr. McVay and Ms. Laucks met Kolon Industries, and became
4
Kolon's textile agent in North America. Kolon became the business's only client.
17 In September 2002, the business relocated to Newport, RI, and business partners shared
an apartment as roommates. US Textile's contract with Kolon did not provide reimbursement for
expenses and Ms. Laucks financed the business expenses and both partner's living expenses with
credit cards and loans from family members and friends.
18 In 2004, US Textile brokered an MOU creating 10-year supply agreement between Kolon
Industries and Milliken of South Carolina. Both Ms. Laucks and Mr. McVay travelled often to
bring this deal together. Mr. McVay was using cocaine in addition to drinking heavily during this
time and the two stopped sharing an apartment when a vacant one became available in the same
building. The business started to become profitable for the first time.
19 In April of 2005, Ms. Laucks discovered that Mr. McVay, with attorney Mark Bardorf,
incorporated himself as sole shareholder of US Textile Inc. two months earlier, in February of
2005. Mr. McVay's drug and alcohol use increased.
20 In May of 2005, Mr. McVay ransacked Ms. Laucks’s apartment rendering it
uninhabitable, including destroying her computer. Mr. McVay was arrested and required to pay
restitution for vandalism of $1,983.75 and the Newport District Court placed a No Contact order
upon him. Ms Laucks was compelled to move as Mr. McVay lived in an apartment directly
above. Mr McVay, when confronted by Ms Laucks for her share of proceeds from the business,
5
he said “Get a lawyer, bitch”.
21 Ms. Laucks was shut off the access to the business and its assets were redirected to a
client account held by Bardorf & Bardorf, attorneys in Newport RI. Ms. Laucks was compelled
to seek relief in Federal Bankruptcy Court. The Federal Court discharged her debt of
approximately $56,000 in October of 2005.
22 During the period, May 2005 through approximately February or March 2006, Ms.
Laucks was completely shut out from operations and access to the business and all profits. An
attempt to settle between Ms. Laucks and Mr. McVay was brokered through lawyers and Ms.
Laucks accepted Mr. McVay's offer of $16,000 but he never paid it.
23 In 2006, following the loss of his driver's license due to a drug related arrest, Mr. McVay
sought out Ms. Laucks and entreated her to return to US Textile as a full 50% partner claiming
that he could not run it without her. Mr. McVay indicated his intention to change the
Incorporation to reflect this partnership but never did, instead the Incorporation become revoked
in 2007 due to lack of filing with the Secretary of State.
24 In December 2006, while Ms. Laucks was away for holidays, Mr. McVay was arrested for
video voyeurism of Ms. Laucks's roommate, breaking and entering, and possession of crack
cocaine. After Ms. Laucks' return in January 2007, she was obliged to vacate this apartment due
to his arrest there. In 2009, Mr. McVay was found guilty by judge of Breaking and Entering and
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Possession.
25 In 2008, Milliken withdrew from the sales agreement causing an immediate and drastic
financial hardship to US Textile. Ms. Laucks and Mr. McVay moved to and shared the two
bedroom apartment at 2D Bonniecrest Gardens where they resided as business partners and
worked at other jobs to support the business. Due to being on probation, Mr. McVay refrained
from cocaine use but continued to consume marijuana and alcohol profusely.
26 Mr. McVay and Ms. Laucks worked together to re-establish Kolon in the automotive
market going directly to the OEMs, ultimately landing a meeting with GM in 2010 that proved
productive and began bringing in profit to US Textile in the Spring of 2012. Due to Mr. McVay's
lack of credit card and driver's license, Ms. Laucks facilitated all travel and meetings to
customers with and, more often, without, Mr. McVay.
27 From 2006 until 2013 the partners used the US Textile Inc business account nearly
exclusively for both personal and business transactions. Mr. McVay converted a larger than 50%
of the profits of US Textile for personal items including past child support and attorney fees for
his various criminal charges. He purchased an outboard 14' dinghy; and a ride on an America's
Cup series catamaran for $4,900. He used funds from US Textile to travel for his pleasure to San
Francisco to volunteer for the America's Cup and intended to travel to Italy as well, paying for
ten days of hotel rooms in Naples that were never used or refunded. Mr. McVay and Ms. Laucks
had an agreement that in exchange for “reasonable” personal items, the business would buy her
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an automobile and it did provide down-payment and monthly payments starting in October of
2012. However, Mr McVay also used business funds for unreasonable personal use (bar bills,
entertainment and cash for marijuana) causing Ms. Laucks and Mr. McVay to argue constantly.
28 In early January of 2013, Mr. McVay began abusing the prescription drug Adderall (a
stimulant) which he obtained without prescription. His behavior became increasingly erratic and
irascible.
29 In February 2013 Melinda Laucks was asked by three separate customers why Mr.
McVay was not responding to their emails and phone calls; she discovered that Mr McVay was
not visiting friends but had absconded, checked into a hotel with all of the business's operating
capital of about $3,200 and caused overdraft fees of $390. Mr. McVay had set up a secret email
address "[email protected]" with which he asked Kolon Industries to transfer
commission payments to a new personal bank account. He wrote an email, on February 17, and
stated “Be sure not to copy my ustextile.us address because if Melinda finds out she will be even
more ballistic than she already is”. (Ms Laucks having been angered by the bank withdrawals
and overdraft fees). Mr McVay also stated his intention to end the partnership by writing “The
money I save by switching Melinda from partner to employee will allow me to hire 3 more
people.” He told Kolon that he had an Incorporation with himself as sole shareholder allowing
him to do this. Mr. Ryan Im at Kolon responded by writing “Regarding the bank account,
Melinda is following up all of your business now. So I can imagine how people think about
changing account to another one with you out of the loop. You really should speak to her and fix
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things first.” Kolon Industries showed this email to Ms. Laucks, and both Ms. Laucks and Kolon
Industries interpreted Mr. McVay's email as intention of embezzlement as well as an intention to
end the partnership.
30 On February 21, 2013, Mr. McVay took, without approval, Ms. Laucks' car with her
wallet in it. Ms. Laucks required the Newport Police to intervene to prevent damage to the
vehicle and to keep Mr. McVay from using her cash and credit card. The Newport Police arrested
Mr. McVay and returned the car Ms Laucks. (The charge of driving a motor vehicle without
permission was dropped by Ms. Laucks several weeks later.)
31 On February 23, Mr. McVay sent an email to Ms. Laucks' stepfather stating that he was
sole shareholder of US Textile. That evening, Mr. McVay's lawyer, Mr. Kevin Hagan called Ms.
Laucks and told her that Mr. McVay was sole shareholder of US Textile and that she had no
rights to the business. Ms Laucks agreed to that the partnership to be was over.
32 By examining the Rhode Island Secretary of State website, Ms. Laucks determined that
the Incorporation for US Textile Inc. had in fact been revoked since 2007. On February 23, 2013,
Ms. Laucks paid $235 and incorporated her half of the now dissolved partnership as US Textile
Inc. Ms. Laucks notified by email Mr. McVay of her Incorporation on February 25, 2013.
33 In March of 2013, Mr. McVay agreed to stop abusing prescription drugs and return the
business money. With acknowledgement of the Incorporation, Mr. McVay returned to US Textile
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and the residence at 2D Bonniecrest Gardens but with no official or written agreement to the
status or nature of the business relationship.
34 From March to June of 2013, Mark McVay attended counseling with a psychiatrist but
also continued drug abuse. Ms Laucks attended two counseling sessions with Mr. McVay and Dr.
Gollinger in the attempt to improve the situation. In spite of this, Mr. McVay's behavior became
increasingly erratic, contentious, irascible, and delusional. He engaged in frequent manic rages
wherein he would rant uncontrollably for prolonged periods shouting obscenities and abusive
language. His behavior included prolonged sexual perversion. During this time period the
Newport Police were called to the apartment to intervene in domestic conflicts on at least three
separate occasions. On the last occasion, the police threatened to arrest both parties if they were
called another time.
35 Mr McVay resumed excessive and reckless spending, intentionally overdrawing the
business bank account. He made numerous bank transfers to his personal account, and the
accounts of his family members and excessive cash withdrawals and charges via his debit card.
His behavior caused overdraft charges of $1,3678.82. Mr. McVay willfully created conditions in
incur cause for charges of Fraud/Writing Bad Checks upon Ms Laucks. Mr McVay's egregious
spending prevented Ms Laucks from mailing normal bank checks and during this time she was
compelled, upon notification of a deposit, to rush to the bank and buy cashiers checks in order to
keep the business running and to prevent insufficient funds on mailed checks. When Mr. McVay
found out about Ms. Laucks issuing cashier's checks to creditors including to the landlord, Mr.
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McVay became irate.
36 Mr. McVay's destructive behavior was not limited to Ms. Laucks and the US Textile bank
account. Mr McVay's behavior as volunteer for SailNewport Youth regatta was so extreme that
three other volunteers requested to never be on a boat with Mr. McVay again. He was terminated
from his volunteer position with the Clagett Regatta when the director discovered empty rum
bottles on her personal boat after Mr. McVay used it without her permission.
37 Mr. McVay, by his own volition, destroyed his interest in US Textile business by using
abusive and threatening language to US Textile's only client, Kolon Industries in both emails and
phone calls. Mr McVay entirely alienated, threatened to sue directly, and threatened to provide
“evidence” against Kolon in their litigation with DuPont. By June 23, 2013 Kolon Industries
refused communicate or work with Mr McVay entirely. Ms. Laucks was the sole communicator
between US Textile and Kolon.
38 In the morning of June 26, 2013, Plaintiff McVay assaulted Ms. Laucks as she sat in her
bedroom emailing business customers. Initially Mr. McVay attempted to barricade and nail shut
her bedroom door which she managed to undo and then retrieve her laptop, she retreated to her
bedroom and locked the door. Mr. McVay then removed the door from its hinges, wrested her
laptop computer and her wallet from her arms. In doing so he ripped her clothing and smashed
her hip with a large hammer. He caused bruising on her arms and hip. He destroyed the laptop by
hurling it from a second-story deck into the driveway. Ms. Laucks, in shock, drove, barefoot and
11
in a ripped dress, to a safer location and parked behind a nearby school. There, she called the
personal cell number of an officer of Newport Police, whom she hoped could help her get Mr.
McVay in a rehab facility. While Ms. Laucks waited to hear back from the officer she saw the
Plaintiff ride away on his bicycle. Ms. Laucks returned to the apartment to dress and secure her
things. While Ms. Laucks was preparing to leave, Mr. McVay returned to the property and
continued his assault on Ms. Laucks. Ms. Laucks had locked the front door to prevent his entry
and Mr McVay climbed the fire escape and forced his way in. When Ms Laucks ran to her car,
Mr. McVay chased her and positioned himself in front of the car, preventing her from driving.
Ms Laucks backed up to avoid him and the neighbor came outside of her home. Mr. McVay
climbed up onto the hood of Ms Laucks's vehicle gouged a deep 40” scratch in the hood of her
car with a key. The neighbor called the police. Ms. Laucks drove straight to the Newport Police
department. Mr. McVay was arrested for Domestic Disturbance, and Vandalism of personal and
business property, and Assault with a Deadly Weapon. Newport District Court imposed a No
Contact order placed upon Plaintiff McVay. This Court Order made all communication, for
business and otherwise, unlawful between Mr. McVay and Ms. Laucks.
39 On June 27, 2013, Melinda Laucks terminated Mr. McVay from his association with US
Textile Inc. due to this specific incident, his reckless use of business funds, illicit drug use and
unprofessional conduct; and removed him from the US Textile Citizen's Bank Account under the
guidelines established by Citizens Bank's corporate policy and Rhode Island Law.
40 Ms. Laucks discovered that Mr. McVay had ordered a gun safe and spy cameras in the
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shape of coat hooks that he had shipped in care of the neighbor to, presumably, conduct video
voyeurism as he had done in 2006.
41 After the termination of Mr. McVay, Defendant Ms. Laucks frequently traveled to
maintain the operation of US Textile, improve relationships with customers and the client Kolon
Industries. She increased the business's operations and its profitability significantly. Ms. Laucks
successfully guided the business through many serious color and quality issues at GM and GM's
suppliers. Ms Laucks paid back the business loans to family members and friends they had given
ten years prior. Kolon wrote emails stating that they were impressed with how things were going
without Mark.
42 During the summer and fall of 2013,Mark McVay, in violation of his No Contact Order
continued to send emails to Ms. Laucks alternating from apologetic to very threatening. In
August of 2013, Mr. McVay threatened a manager at Citizen's Bank.
43 In September of 2013, Mr John Deacon, Jr., attorney for Mr. McVay sent a demanding
and harassing letter to Ms. Laucks, insisting that she resume a business relationship with Mr.
McVay. Ms. Laucks responded with a letter describing the assault and that a No Contact Order
prevented any communication; and that Kolon no longer wanted Mark with US Textile either, a
sentiment that Kolon had made very clear. Mr. Deacon immediately issued a Subpoena and
Summons with Verified Complaint. Kolon Industries requested that Ms. Laucks shut down the
business and re-incorporate under a different name but Kolon's counsel, Mr. Ben Cutchshaw later
13
advised against that.
44 In December 2013 Ms. Laucks provided as discovery thousands of documents and emails
relating to the operations of the business.
45 In February, while Ms. Laucks was attending business meetings in Michigan with Kolon
and GM, the Court placed the business in Mastership. On February 21, Special Master, Mr. w.
Mark Russo proceeded to seize the business's bank account with no notice or advance warning.
Ms. Laucks had gone to Texas briefly for a family obligation and was stranded in there with only
$47 in cash and a single credit card with a very low limit (as result of the prior bankruptcy). The
lawyer representing Ms. Laucks immediately quit.
46 On February 27, 2014, the Plaintiff Mark McVay pleaded guilty (no lo contendere) to
Vandalism and Domestic Disturbance, was sentenced to No Contact, Probation, Restitution and
Domestic Violence Classes. Ms Laucks discovered that the Newport police mishandled the
evidence causing the Assault with a Deadly Weapon charge to be dismissed. The evidence
incorrectly labeled the neighbor who called the police as the victim in this charge.
47 In February 2014, Mr. McVay wrote an email to a business supplier, Mr. Kurt Con cannon
in which he made false allegations and defamed her character, instead of reprimanding Mr.
McVay, Mr. Russo was hostile and derogatory to Ms. Laucks for defending herself from this
egregious libel and did this with Mr. Concannon cc:d in the email thus Mr. Russo began to
14
willfully and maliciously defame the Defendant's professional reputation.
48 In March of 2014, the Special Master (consisting of W. Mark Russo and John Dorsey)
refused to allow Ms. Laucks to operate her business even though it was her wish to do so, the
wishes of Kolon and the wishes of the customers. Mr. Benjamin Cutchshaw, Kolon's counsel,
explicitly told Ms. Laucks that Kolon would absolutely insist that she be maintained in the
running of the business.
49 However, Mr. Russo refused to provide any type of payment for her work or
reimbursement of business travel expenses and was upset because she sent an email to his office
after business hours. Mr. Russo demanded that Ms. Laucks return to Rhode Island even though
she did not feel safe there and he would not pay her travel expenses to do so.
50 Ms. Laucks was told by her attorney, before he quit, that the Mastership was appointed
for the purpose of "Finding of Fact" and reducing litigation, yet Mr Russo and Mr. Dorsey
refused to acknowledge the evidence submitted to them by Ms. Laucks, refused to acknowledge
Mr. McVay's guilty pleading on criminal charges and refused to acknowledge evidence that was
available to them through Kolon Industries (who immediately demanded to NOT work with Mr.
McVay) or evidence obtainable in the bank statements for the account that they seized two weeks
prior. The Mastership willfully ignored the evidence and proceeded with the case in an
extraordinarily hostile manner toward Ms. Laucks, including having her harassed in her home on
multiple occasions.
15
49 Immediately upon being appointed Permanent Special Master, in March 2014, Mr. Russo
and Mr. Dorsey caused Mr. Seth Schalow to run the day to day operations of the business. Mr.
Seth Schalow has a Linked-in Page online that indicates that he has been involved with the
business from as early as December 2013, coinciding to when discovery was presented, thus
providing evidence of collusion, conspiracy and intend to defraud by the Mastership.
50 Mr. McVay continued to harass Ms. Laucks by email, and through contact with her
family, in violation of the No Contact Order. Mr McVay was arrested for this on April 7, 2014.
51 During the course of this litigation, the Mastership, as assisted by Attorney John Deacon
Jr and Superior Court Judge Michael A. Stern destroyed Ms. Laucks's relationships with her
clients and customers causing defamation to her professional reputation and her esteem in her
industry. The Court ordered to forbid Ms. Laucks contact with all persons and associations in her
industry; she has been unlawfully prevented from seeking employment in her industry, taking a
job offered in her industry, and maintaining her personal relationships.
52 The restraining order denied Ms. Laucks her right to participate in interstate and foreign
commerce, and violated Strategic Litigation against Public Participation by prohibiting her from
contacting her associated for materials, statements and witnesses for her legal defense.
53 The activity of the Mastership, by wrongfully denying any income to Ms. Laucks, and
16
refusing the return of personal funds in the account, has prevented her from obtaining counsel
which abridges her ability to properly petition and present her legal defense.
54 In April 2014, Judge Silverstein made false allegations of a felony against Ms. Laucks,
that she embezzled $13,000 from a customer. Neither the client nor the customer supported this
accusation. This act of extortion by public official was attested, while under oath, by Mr. Russo
in Kent County Courtroom 4e in the presence of Judge Brian Stern.
54 The loss of income has caused severe hardship to Ms. Laucks, she is getting government
assistance (SNAPS) and despite a low-paying hourly rate job, she is depleting a small IRA
simply for living expenses.
55 During the course of the litigation Mr. Deacon, Mr. Russo and Mr. Dorsey filed and
threatened multiple charges of contempt of court on very flimsy and exaggerated circumstances,
circumstances that they used entrapment tactics to obtain. These contempt accusations were used
to intimidate and threaten Ms. Laucks from appearing in Court. Judge Silverstein threatened to
have the bailiff "lock her up."
55 July 2, 2014, Mr. McVay was arrested for video voyeurism of a minor which he
photographed under a table up a girls' skirt in a Barrington, RI church and for video voyeurism
in a fitness center women's locker room in Seakonk, MA. and remains incarcerated for violation
of probation.
17
56 In August 2014, Mr. Deacon filed for civil and criminal charges of contempt for 60 days
in jail against the Defendant for simply missing a day in court when no hearings were scheduled
and Mr. McVay, who she is afraid of, was expected to attend. Ms. Laucks had already notified
the Court that this presented unreasonable financial hardship and would be absent. This extreme
and trumped up excessive use of contempt, malicious abuse of the judiciary system and caused
Ms. Laucks so much anxiety and duress that her neighbors worried about her safety and Ms.
Laucks was involuntarily hospitalized for six days under suicide watch. Ms. Laucks has since
been readmitted to the hospital for follow up treatment and has sought outpatient case for her
anxiety, distress and panic attacks caused directly by this litigation.
57 Mr. Deacon caused further harassment and malice by making a false allegation of
Practicing Law without a License upon an associate of Ms. Laucks. This allegation was found to
be entirely false and without merit yet caused a breach in the relationship and her support for Ms.
Laucks and forced the Defendant of the charge to hire a lawyer at her own expense.
58 Despite numerous subpoenas, the Mastership and Seth Schalow have failed to account for
and provide evidence of the alleged start date for Seth Schalow's invovlement. Mr. Schalow said
under oath that he had an email showing that he began on March 6, 2014 but he and the
Mastership have refused to provide this document or any other. This alleged start date of March 6
2014 conflicts with his Linked-in account and with verbal information Ms. Laucks received
from Kolon personnel later that spring.
18
59 The Mastership fails to provide despite subpoena, actual bank statements from Citizens
Bank that would dispel suspicions of bribery and misappropriation of business funds.
60 The Mastership has sought use its influence with Judge Brian Stern to impose a
egregiously unfair settlement document that would enable the Mastership to retain the business
permanently, a document that was initially agreed to by Ms. Laucks under duress and with fouled
expectations and with numerous objectionable issues, including a later, superseding agreement
by the express wish of Mr. McVay, signed and notarized by both Mr. McVay and Ms. Laucks that
returns control of US Textile Inc. to Ms. Laucks.
COUNT IRACKETEERING INFLUENCED CORRUPT ORGANAZATIONS
COUNT IISTRATEGIC LITAGATION AGAINST PUBLIC PARTICIPATION
COUNT IIIVIOLATIONS OF FEDERAL AND CONSTITUTIONAL RIGHTS
TITLE 18, DUE PROCESS
COUNT IVVIOLATION OF COMMERCE CLAUSE
COUNT VCOLLUSION & CONSPIRACY
19
COUNT VIFRAUD
COUNT VIIEXTORTION, BLACKMAIL, INTIMIDATION BY PUBLIC OFFICIAL
COLOR OF OFFICE
COUNT VIIICONVERSION
COUNT IXANTITRUST
COUNT XSLANDER, LIBEL, DEFAMATION
COUNT XIBREACH OF FIDUCIARY DUTY
COUNT XIIINTENTIONAL AFFLICTION OF EMOTIONAL DISTRESS
Wherefore the plaintiff seeks:
Criminal prosecution of the above mentioned Defendants;
the business and its assets and damages for pain and suffering of $2,500,000
or
money damages in the amount of $25,000,000 for loss of income and future income;
20
any further relief the Honorable Court may deem appropriate.
WHEREFORE, Plaintiff demands judgment against Defendants for damages in a sum sufficient to invoke the jurisdiction of this Honorable Court; actual and consequential damages; punitive damages; attorney fees; and interest and costs of suit, together with all other and such relief that this Honorable Court may deem just and proper.
Melinda Laucks, pro se2D Bonniecrest GardensNewport, Rhode Island401 846 1898February 17, 2015
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