COMPLAINT

COMES NOW Plaintiff DOROTHY PIERCE, with this complaint against the Defendants, CLEMENTS ELECTRICAL, INC; ALTON FREDERICK CLEMENTS JR; JANET GAY CLEMENTS; JASON ALTON CLEMENTS; NICHOLAS BEHRINGER; BRANDON J. DURHAM; JEFFERY PILGRIM; SHERRY L. BURGESS; NICHOLSON JERRY; FRANCISCO MAJIA ARMANDO; MELISSA C. CHASTAIN; RICHARD HUNT MCDUFF; MORRELL, JAHN & MCDUFF, PA; JARED ADAM PIERCE: SANDRA PHILIPS PIERCE; OCONEE COUNTY SHERIFF DEPARTMENT and MICHAEL L CRENSHAW as follows: 

PARTIES

1. Plaintiff, DOROTHY PIERCE of address 708 Mourning Dove Lane, Seneca, SC. 29678 is the owner of American Pharma Machinery, a limited liability company organized under the laws of the State of South Carolina
2. Defendant, CLEMENTS ELECTRICAL, INC aka Contractor’s electric. is an electrical company of address 802 Friendship Rd, Seneca, SC. 29678.
3. Defendant ALTON FREDRICK CLEMENTS aka Alton Clements, Alton F Clements, Alton F Clements Jr, Alton Frederick Clements, Alton Fredrick Clements Jr, of address 418 Gassaway St Central, SC 29630 is the owner of Clements Electrical, Inc.
4. Defendant JANET GAY CLEMENTS aka ( Janet Clements, J Clements, Janet A Clements, Janet G Clements, Jason Clements, Janet Clements, Janet G Wheeler, Janet Clemens, Joyce Clements, Clements Janet, Justine Clements, Jennifer Clements) of address 418 Gassaway St Central, SC 29630    is the president at Clements Electricals, Inc.
5. Defendant, JASON ALTON CLEMENTS aka (Jason Clements, Jason A Clements, Jason A Clements, Jason Alton Clements, Alton Clements, of address 440 Gassaway St Central, SC 29630 is the employee/ manager at Clements Electrical Inc.
6. Defendant, NICHOLAS BEHRINGER aka (Nick Behringer, Nicholas A Behringer, Nick Berhringer), of address 516 Horseshoe Dr. Seneca, SC 29678 is the assistant Project manager and estimator at Clements Electrical, Inc
7. BRANDON J. DURHAM, of address 126 Wood Creek Dr. Piedmont, SC 29673 is an employee of Clements Electrical Inc.
8. JEFF PILGRIM aka: Jeffrey Pilgrim, Jeffrey Ray Pilgrim, Jeffrey R Pilgrim of address 206 Francis St Central, SC 29630 is an employee of Clements Electrical, Inc
9. Defendant, RICHARD HUNT MCDUFF aka/ RICK H MCDUFF, of address 401 Pointe East Dr. Seneca, SC 29672 is an Attorney licensed to practice law in South Carolina. 
10. Defendant MERRELL, JAHN, & MCDUFF, PA, of address 119 Professional Park Dr, Seneca, SC 29678 is a law firm owned by Defendant Richard McDuff. Plaintiff includes this Defendant in this suit under the doctrine of vicarious liability.
11. Defendant, SHERRY L. BURGESS aka. (Sherry Burgess, Sherry Vansteenburg, Sherry Ortega, Sherry Burgess Ortega, Sherry L Ortega, Sherry Burgess Vansteenburg, Sherry L Burgess, Sherry S Burgess, Sheir Ortega, Sherry B Ortega, Sherry B Vansteenburg, Sherry L Ortega) of address 301 Zion Hill Rd. Seneca, SC.29678 is a former employee of Plaintiff’s Company. 
12. Defendant, NICHOLSON JERRY of address 220 Vinyard Lane, Salem SC,29676
13. Defendant, FRANCISCO MAJIA aka ARMANDO FRANK ——————–is a former employee of Plaintiff’s Company. 
14.  Defendant, MELISSA C. CHASTAIN aka. (Melisa Chastain, Melisa Chastai, Melisa C Chastain, Melisa Clark Chastain, Melissa F. Chastain, Melissa Chastain, Melissa C Chastain, Melisa F Clark, Melissa F Clark, Melisa Faye Clark, Melissa Faye Chastain, Melisa Clark Chastain, Melissa Clark, Lisa Clark) of address 410 John Okelley Dr, Seneca, SC 29678, is a former employee of Plaintiff’s Company. 
15. Defendant JARED ADAM PIERCE aka/ Adam Pierce, Jared Pierce, Jared A Pierce, Jared Adam Pierce, Jarred Adam Pierce) of address 404 N Church St Walhalla, SC 29691 (106 Blackbottom Rd Liberty, SC 29657) is the Plaintiff in Plaintiff’s Probate case. (Case No: 2020ES3700532).
16. Defendant SANDRA PHILIPS PIERCE aka. Sandra Pierce, Sandra P Culbertson, Sandra J. Culbertson, Sandra J Pierce, Sandra Jean Culbertson, Sandra J Pierce, Sandra J Culbertson, Sandr J Culbertson, Sandy Pierce, S Pierce, sandy Phillips Pierce, Sandy Philips of is the Wife to JARED ADAM PIERCE, the Plaintiff in Plaintiff’s Probate case. (Case No: 2020ES3700532). 
17. Defendant, OCONEE COUNTY SHERIFF DEPARTMENT of address 300 S Church St. Walhalla, SC 29691 is a government agency.
18. Defendant, MICHAEL L CRENSHAW aka (Michael Crenshaw, Mike Crenshaw, Mike Creashaw, Michale L Crenshaw, Michael Leon Crenshaw, Mike Crenshaw, Michael Crenshaw Michael Mykesha Crenshaw.) of address, 1912 Queen Dr. Walhalla, SC 29691 is the Sheriff of Oconee County Police Department.

JURISDICITON AND VENUE

1. This court has subject matter jurisdiction pursuant to SC Code § 14-5-350 (2016).
2. Venue is proper in this court as Plaintiff and the Defendants are subject to personal jurisdiction in this state. Notably, Plaintiff and some/all of the Defendants live within the jurisdiction of this Court. Besides, a substantial part of the acts and omissions forming the basis of these claims occurred in this County.  

FACTS

• On or about May 2019, Plaintiff established a business to deal in manufacturing and packaging machines.
• In 2020 when COVID-19 hit, the plaintiff imported face masks manufacturing machines worth $ 920,000 and Face Mask Materials worth $54,590 to start a face mask production facility in Seneca, South Carolina.
• On or about September 2020, Plaintiff hired Sherry L. Burgess (hereinafter “Sherry”) to manage Plaintiff’s new business facility.        
• Sherry then insisted and employed Nicholson Jerry- her father; and Francisco MeJia aka. Armando Frank- her friend.
• Upon the recommendation of Sherry, Plaintiff engaged the services of Clement Electrical (hereinafter “the Company”) to install part of the machines that Plaintiff had acquired.
• In the Month of October 2021, Clements electrical sent their employees, Jason Alton Clements; Nicholas Behringer; Brandon J. Durham, and Jeffery Pilgrim to the plaintiff’s facility to start the process of installation of the plaintiff’s machines which dragged for several weeks due to the company’s incompetence.
• On or about ———————————-the Plaintiff paid the Company $ 6,200 for the first invoice that the company sent to Plaintiff for partial installation of the machines. It should be noted that the services were exaggerated and Overpriced.
• In the month of December 2020, the employees of Clements electrical Inc. namely Nicholas Behringer; Brandon J. Durham, Jeffery Pilgrim Showed up occasionally at the Plaintiff’s facility to install the rest of the 3 Phase machines. The invoice of $5,800, which was due on or about January 27, 2021, was emailed to Plaintiff on or about January 4, 2021.
• The plaintiff also enrolled, Sherry Burgess, Armando Frank and Nicholson Frank to TSheets, a QuickBooks time tracking app with automatic login and log out to manage payroll but Sherry Did not allow any of the two employees she hired to activate their accounts. The plaintiff had to enter their time manually every Friday to post payroll.
• On or about December 18, 2020, Plaintiff left for Africa for holidays and personal matters.
• On or about December 22, 2020, the plaintiff released all employees for holidays.
• Plaintiff kept in contact with NICK BEHRINGER the assistant Project manager and estimator at Clements Electrical Inc. via emails and text messages about installation of a transformer and a power panel at the facility until about January 5^th, 2021, when the plaintiff’s last email was not responded to by the individual.
• Before leaving for Africa, The Plaintiff paid a total of $4,126.00 to Seneca Light and water to dig a line from the nearest transformer belonging to BP Western Hotel to the Plaintiff’s facility to prepare for the Installation of the Transformer being ordered by Clements electrical. This money went to waste when Clements electrical Inc. uninstalled all the machines in the plaintiff’s facility.
• It is also worth noting that at this time, Plaintiff had made all due payments to all her staff, and since it was the holiday period, nobody was at work.
• On or about January 4^th, 2021, Sherry L. Burgess demanded that she wanted a meeting with Plaintiff before she and the rest of the employees could return to work.  Plaintiff found the suggestion very strange because Sherry already knew that Plaintiff was away and would not come back until January 20^th, 2021. After a series of back-and-forth texting, Sherry made it clear that she and the rest of the employees whom she hired were not going back to work and had therefore quit.   
• It appears Sherry also spoke to another of Plaintiff’s employees, Melissa C. Chastain (hereinafter “Melissa”), who was working at another facility that belonged to Plaintiff and Jewels Morris Nekitta.  Melissa also told Plaintiff that she would not get back to work until she met Plaintiff.
• On or about January 4, the plaintiff sent Melissa a text after getting a confirmation from Sherry that they won’t be going back to work and asked how she would get her keys to the warehouse, Melissa Promised to personally return the keys to the plaintiff and the plaintiff alone.
• Sherry L. Burgess and Francisco Mejia had the keys to Plaintiff’s face mask facility. Sherry promised to keep the key until Plaintiff returned.
• However, Plaintiff realized that on or about January 12, 2021, Sherry had told the electrical company, Clements Electrical, Inc.  that Plaintiff’s company had gone bankrupt, and that Plaintiff had run away to Africa; and she would not come back.
• The plaintiff had created a new bank account for the Facility and opened a debit card with a spending limit of $100.00 which was in the custody of Sherry. It is important to note that upon sherry’s refusal to go back to work, the Plaintiff immediately Blocked the card. To justify her claim, sherry attempted to make a payment of the amount in the invoice of $5,800 which was declined.
•  Without consultation with the plaintiff, the Employees of Clements Electrical Inc. who had installed the machines namely: Jason Alton Clements; Nicholas Behringer; Brandon J. Durham, Jeffery Pilgrim illegally entered the Plaintiff’s facility, and uninstalled Plaintiff’s machines that they had already installed. It is instrumental to note that the Company’s employees in cohorts with Sherry L. Burgess, Melissa C Chastain, Nicholson Jerry, and Francesco Majia Armando, uninstalled machines, whose installation Plaintiff had already paid for in the first invoice of $ 6,200. They also uninstalled all the 3 phase machines they had installed for $ 5,800 comprised in the invoice no__________ which was only due on January 27^th, 2021.
• On or about January 12^th, 2021, while Clements Electrical uninstalled the machines, the Plaintiff also realized that the Company Clements electrical Inc. and its employees Jason Alton Clements; Nicholas Behringer; Brandon J. Durham, Jeffery Pilgrim, in cohorts with Sherry L. Burgess, Melissa C Chastain, Nicholson Jerry and Francesco Majia Armando, stole a brand-new air compressor, which Plaintiff had bought for $ 2,900, used 15 gallon air compressor. Besides, other materials were taken including 5 brand new office chairs: 5 brand new desktop computers, the pallet jack, 6 office Telephones, Office Printer and supplies worth over $5,800.
• Upon Return from Africa, the plaintiff contacted Sherry L. Burgess and Melissa C. Chastain for the keys to her Facilities but was unprepared for the shock of her life. All the keys to her facilities were handed over to the sheriff’s department.
• According to Melissa C. Chastain, she was instructed by Sheriff Crenshaw of the Oconee County Sheriff Department to give the keys to the plaintiff’s warehouse at 708 Mourning Dove Lane to Jared Adam Pierce and Sandy Phillips Pierce, who were involved in a bitter legal matter over the Last Will and testament of the plaintiff’s deceased husband Doyle Elton Pierce.
• The plaintiff contacted Jared Adam Pierce via text message and threatened to report the unauthorized entry into her facility to law enforcement if the keys were not returned as soon as possible, Jared Adam Pierce dropped the Plaintiff’s key at the Sheriff Department. Plaintiff had to use her Attorney to get the keys back.
• Plaintiff realized that the said parties had accessed her warehouse, went through her private documents; took pictures of the warehouse; and deleted that day’s recording of the security camera. She also found that some items were missing in the warehouse
• Sherry L. Burgess on the other hand told the plaintiff that on the advice of the attorney, she and Francesco Mejia Armando dropped all the keys to the plaintiff’s facility at 513 Bypass 123 to the Oconee County sheriff department. Plaintiff’s lawyer later got the keys from the Sheriff department.
• When the plaintiff finally recovered the keys to her facility from the defendants. Almost all movable items were stolen.
• After the employees stole Plaintiff’s materials, the Attorney advised the aforesaid parties to leave Plaintiff’s keys with the Sheriff.  The Sheriff department failed to make an inventory of what was left in the Plaintiff’s facility. They only took the keys and kept it without conducting further check on the facility and keeping record count or pictures of the items left at the facility whose keys they took.
• Plaintiff filed a complaint with the Sheriff department but did not get her issue investigated. The Sheriff department only asked her to provide evidence that her items were stolen. Plaintiff therefore produced every receipt of all items that were missing in the facility. The Sheriff department did not further step.
• The Plaintiff asked the Investigator assigned to her case to look into the cameras of the landlord who is within the proximity of the plaintiff’s facility for the dates of January 12^th and 13^th 2021 but the investigator hesitated and claim that it was a hard task to look into the camera records.
• Plaintiff has suffered numerous expenses as a result of the Defendants’ actions and/or inactions as alleged herein. For instance, Plaintiff had paid $ 4,126 to the city, to have the city dig a power line to provide power to Plaintiff’s facility. This expense went to waste when the Company uninstalled all machines it had installed in the facility. Besides, Plaintiff lost profit that she would have made in the event her business was operational, in light of the booming face masks business. Notably, Plaintiff had to relocate and find a new building in which to start over her business, thus incurring further costs. Plaintiff spent $ 14,400 to pay lease for a new building, and over $11,600 to hire trucks and personnel to move her heavy equipment from one warehouse to a new one. It also cost a lot of time to reinstall and establish the facility afresh. It took up to July 2021, for Plaintiff’s business to start its operations. Plaintiff also went through Severe emotional distress as a result of the Defendants’ actions and/or inactions as alleged herein.
• The Oconee County Sheriff Department did not make an effort to take inventory of the items at the plaintiffs’ facilities before accepting the keys from the defendants. In addition, there was no record of any official document/ report showing that a case was reported or opened to warrant the parties to either drop the plaintiff’s keys to the Sheriff Department or hand the keys to third parties.
•  Besides, it was public knowledge that the plaintiff was represented by an attorney and yet the Sheriff department did not inform the plaintiff’s attorney about all the dealings with the defendants.  Michael Crenshaw, the Oconee County sheriff department did not have any right whatsoever to authorize the transfer of the plaintiff’s warehouse facility to Jared Adam Pierce and Sandra Philips Pierce.
• The plaintiff attempted to have a direct conversation with the employees of the Clements electricals Inc, Jason Alton Clements, and Nicholas Behringer but they did not want anything to do with the plaintiff and refused to talk.
• On February 2021, the plaintiff visited the Company’s Office at 802 Friendship Rd, Seneca, SC 29678 to attempt to resolve the issue, but Jason Alton Clements sent the plaintiff away and threated to have the plaintiff arrested if she continued to ask questions about the whereabouts of her stolen items or her money back. Jason Alton Clements arrogantly told the Plaintiff to get lawyer and SUE their company instead.
• Most of the goings on were influenced by Richard McDuff (hereinafter “the Attorney”), who was the Plaintiff’s Attorney in Plaintiff’s Probate Case. (Case No: 2020ES3700532). The Attorney represented the plaintiff in the Complainant Probate Case at the Probate Court, County of Oconee, SC.  (Case No: 2020ES3700532).
• Before taking the case against the complainant in a probate case N0: 2020ES3700532, the attorney had several back-and-forth emails with her while brokering the lease agreement between the landlord and the complainant. Notably, the attorney was the Attorney for the Landlord whose building the complainant had leased.
• Without an official contract, the attorney had series of communications with the Complainant’s employees and influenced them to terminate their employment with the Complainant/ company and leave the keys with the Oconee County sheriff’s department.
• Richard McDuff and his client Jared Adam Pierce manipulated the employees of the plaintiff using malicious, damaging, and defamatory claims to get information about the plaintiff’s business and customers, an action that damaged the reputation of the plaintiff and cause irreparable emotion damage to the Plaintiff.
• Consequently, when the employees terminated their employment with the Complainant/ company, they stole several items from the Complainant’s facility including but not limited to a used air compressor, brand new air compressor, which the complainant had bought for $ 2,900 from Grainger; 5 brand new office chairs; 5 brand new desktop computers, brand new pallet jack, Hp printer, office supplies worth $2,990.00 plus many more items.
• On January 2021, the attorney contacted defendants’ clients exhorting them to file complaints against the defendant both in court and with the police in a bid to make his client’s Fraudulent Probate contest case stronger. Two clients of the defendant filed cases of breach of trust with the sheriff department under the request of the attorney Richard McDuff, but the sheriff later closed their cases. Another Client was advised to file a fraudulent lawsuit instead.
• The attorney persistently emailed the judge in the probate case No: 2020ES3700532 about his arrangement with the Plaintiff’s employees. In the Emails, the attorney admitted that he had employee witnesses to testify that the plaintiff had not paid them wages and are pursuing action with the Department of Labor. This was proof that he was in cohorts with the employees of the plaintiff.
• In another communication, the attorney wrote “Judge John’s, Sheriff Michael Crenshaw has confirmed through the Department of Homeland Security that the PR, Dorothy Pierce, has fled the country and is in Uganda. Accordingly, the plaintiff believes that it’s because of this that the employees were urged to steal the Plaintiff’s assets because of the assurance from the attorney and the Oconee County sheriff department that the Plaintiff had fled the country and would not be returning.
• Also, under the influence of the Attorney, Jared Adam Pierce (hereinafter “Adam”), the Respondent in the aforesaid Probate Case, claimed ownership of Complainant’s business in Anderson city, South Carolina. Using false information supplied by the attorney, Jared lied to the employee that the complainant had fled the country. He instructed the employee to quit her Job and take the complainant’s Dell Latitude 5500 (8^th generation), all the cash in the cash drawer, microwave and to hand over the complainant’s store keys to the sheriff department. The Complainant had to close her dietary store as a result.
•  On or about January 25^th, 2021, The Complainant requested for termination of her lease with her landlord of the face mask Manufacturing facility (513 Bypass 123) when the attorney’s violations became eminent; she moved her business to a new facility and reinstalled the machines.
•  It was until July 2021 When the complainant’s business was partially ready to market her products, The complainant engaged the services of a local Newspaper company to advertise her products.
• Consequently, the Attorney called the Newspaper Company that had begun advertising Complainant’s business and falsely informed them that Complainant had been defeated in a case for fraud. This was after the complainant had filed a notice of appeal with the circuit court which automatically stayed any order or judgment by the lower court until the appeal could be ruled on. Accordingly, the newspaper company sent Complainant an Email citing the Judgment and immediately stopped advertising Complainant’s business. Complainant could not market her products and therefore could not sell her products leading to severe loss of revenue.
• Clements electrical and the defendants uninstalled the machines and unprofessionally removed electrical wires and damaged a full line of Automatic 3-Ply disposable face mask Machine and left the machine not functioning.
• The company also left series of damages, cuts and dents on the plaintiff’s brand-new machine rendering the equipment old with less value

CLAIMS FOR RELIEF

COUNT 1

UNJUST ENRICHMENT

 (Clement Electrical; Sherry Burgess; Jerry; Amanda Franco; Melissa Clark; Adam Pierce; Alton fredrick clements; Janet gay clements; Jason alton clements; Nicholas behringer; Brandon; J. Durham; Jeff pilgrim; and Nicholson Jerry)

• Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
• The said Defendants unjustly enriched themselves by taking Plaintiff’s items from Plaintiff’s facility. Also, Clement Electrical Unjustly enriched itself by uninstalling machines, which services Plaintiff had already paid for. Therefore, Plaintiff’s is entitled to a refund of her payment. 
• As a result of Defendants’ actions alleged herein, Plaintiff has lost brand new air compressor, which Plaintiff had bought for $ 2,900; 5 brand new office chairs; 4 brand new desktop computers and laptops; and the pallet jack.
• Plaintiff is therefore entitled to recover the said losses from the Defendants.

COUNT 2

NEGLIGENCE

(Against the Oconee County Sheriff Department; and Michael L Crenshaw)

• Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
• The Sheriff Department owed to the Plaintiff a duty of care.
• The Sheriff is duty bound to maintain law and Order. Part of the duties of the Sheriff department is to conduct investigations. 
• The Sheriff Department breached the aforesaid duty by failing conduct an investigation in Plaintiff’s case. The Department only received Plaintiff’s keys and did not care to check what was left inside Plaintiff’s facility.
• As a direct and proximate result hereof, the Plaintiff has Plaintiff has lost brand new air compressor, which Plaintiff had bought for $ 2,900; 5 brand new office chairs; 4 brand new desktop computers and laptops; and the pallet jack.
• The acts and/or omissions of the Defendant were deliberate, knowing, willful, and/or reckless.

COUNT 3

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(Against all Defendants)

• Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
• The conducts of the Defendants as set forth above were extreme, and outrageous.
• Defendants ought to have reasonably known that their actions and/or inactions would cause severe harm on Plaintiff.
• The Defendants failed to consider the adverse effects of their actions and/or inactions on Plaintiff.
• As a result of the Defendants’ acts as alleged above, Plaintiff has incurred massive costs. First, Plaintiff has incurred cost in form of wasted expenses in setting up the facility only to have work done uninstalled; Plaintiff lost profit that she would have made in the event her business was operational, in light of the booming face masks business; Plaintiff incurring further costs by spending around $ 14,000 in relocating and re-establishing her business; it also cost a lot of time to reinstall and establish the facility afresh; and lastly, Plaintiff went through emotional distress as a result of the Defendants’ actions and/or inactions as alleged herein.

COUNT 4

BREACH OF CONTRACT

(Against Clement Electricals; Sherry Burgess; Jerry; Amanda Franco; Melissa Clark; and Francisco Majia)

• Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
• A contract existed between Plaintiff’s Company and Clement Electricals. As the owner of her company, Plaintiff suffered directly from the Defendants’ breach of the Contract.
• Under the contract Clement Electricals was obligated to provide electrical installation services for Plaintiff.
• Clement Electricals breached the contract by stopping their services and uninstalling the machines they had already installed at Plaintiff’s facility.
• There also existed a Contract of Employment between Plaintiff and the Defendants whereby the said Defendants were obligated to perform their respective services in Plaintiff’s business.
• The employees breached the agreement(s) by terminating the employment without reasonable notice and without reasons to the Plaintiff.
• As a result of the Defendants’ acts as alleged above, Plaintiff has incurred massive costs. First, Plaintiff  has incurred cost in form of wasted expenses in setting up the facility only to have work done uninstalled; Plaintiff lost profit that she would have made in the event her business was operational, in light of the booming face masks business; Plaintiff incurring further costs by spending around $ 14,000 in relocating and re-establishing her business; it also cost a lot of time to reinstall and establish the facility afresh; and lastly, Plaintiff went through emotional distress as a result of the Defendants’ actions and/or inactions as alleged herein.

COUNT 5

TORTIOUS INTERFERENCE WITH CONTRACT

(Against Sherry Burgess; Richard McDuff; Merrell, Jahn, & Mcduff; Adam Pierce; and Sandra Philips Pierce)

• Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
• Plaintiff had a reasonable expectation that she would obtain the benefits from the services of Clement Electrical to her company; and that her employees would abide by the terms in their contract of employment.
• The said Defendants interfered with the reasonable expectation by influencing the breach of the said contracts.
• Notably, Sherry told the electrical company that Plaintiff’s company had gone bankrupt and that Plaintiff had run away to Africa; and she would not come back.
• Sherry also spoke to Melissa, who told Plaintiff that she would not get back to work until she met Plaintiff.  
• Adam spoke ill about Plaintiff to Plaintiff’s employees, making them terminate their employment.
• Attorney McDuff influenced Adam to perform all the conduct alleged in this Complaint. Besides, McDuff interfered with Plaintiff’s employees and played a role in their termination of their contracts of employment. Notably, he mobilized Plaintiff’s employees against Plaintiff, and told them that Plaintiff had fled to Africa. He also coordinated with Plaintiff’s employees to have them leave the facility’s keys at the Sheriff’s office.
• As a result of the Defendants’ acts as alleged above, Plaintiff has incurred massive costs. First, Plaintiff has incurred cost in form of wasted expenses in setting up the facility only to have work done uninstalled; Plaintiff lost profit that she would have made in the event her business was operational, in light of the booming face masks business; Plaintiff incurring further costs by spending around $ 14,000 in relocating and re-establishing her business; it also cost a lot of time to reinstall and establish the facility afresh; and lastly, Plaintiff went through emotional distress as a result of the Defendants’ actions and/or inactions as alleged herein.

COUNT 7

BREACH OF IMPLIED DUTY OF GOOD FAITH AND FAIR DEALING

(Against Clement Electricals; Sherry Burgess; Jerry; Amanda Franco; Melissa Clark; and Francisco Majia)

1. Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
2. The said Defendants had an implied duty of good faith and fair dealing out of the contractual relationship that existed between the parties.
3. The doctrine of good faith and fair dealing bound the Defendants to ensure they offered all services in good faith.
4. The actions and/or inactions of the Defendants as alleged hereinabove amounted to a violation of the implied duty of good faith and fair dealing.
5. As a result of the Defendant’s acts as alleged above, Plaintiff has incurred massive costs. First, Plaintiff has incurred cost in form of wasted expenses in setting up the facility only to have work done uninstalled; Plaintiff lost profit that she would have made in the event her business was operational, in light of the booming face masks business; Plaintiff incurring further costs by spending around $ 14,000 in relocating and re-establishing her business; it also cost a lot of time to reinstall and establish the facility afresh; and lastly, Plaintiff went through emotional distress as a result of the Defendants’ actions and/or inactions as alleged herein.

COUNT 8

CONVERSION

(Against Clement Electrical; Sherry Burgess; Jerry; Armando Franco; Melissa Clark; Adam Pierce; Alton fredrick clements; Janet gay clements; Jason alton clements; Nicholas behringer; Brandon; J. Durham; Jeff pilgrim; and Nicholson Jerry)

1. Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
2. The Plaintiff owned the facility and all property within the facility.
3. The said Defendants obtained unlawful possession of the items they took from the facility without Plaintiff’s consent.
4. The aforesaid conduct was inconsistent with Plaintiff’s property rights thereof.

COUNT 9

DEFAMATION

(Against Richard McDuff; and Merrell, Jahn, & Mcduff)

1. Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
2. The said Defendant made false statements purporting them to be facts. Notably, he told the newspaper company that Plaintiff was a criminal. He also presented false information about Plaintiff to the Judge. He told the Judge that Plaintiff’s employees were ready to testify that Plaintiff had not paid them. In reality, Plaintiff had settled all due payments to her employees.
3. The Defendant’s statements caused injury to the Plaintiff. For instance, the Newspaper Company stopped advertising Plaintiff’s products. Plaintiff could therefore not market her products, leading to Plaintiff’s loss in sales.
4. Also, the statements to the Judge reasonably and objectively painted a negative image of the Plaintiff in the Judge’s eyes, thus impeding Plaintiff’s access to justice.
5. The statements made by the said Defendant were false. Notably, Plaintiff has no criminal conviction against her.
6. Besides, the statements made by the Defendant are not privileged. The Defendant cannot therefore claim privileged information, as a defense.

PRAYER FOR RELIEF

WHEREFORE, the Plaintiff is entitled to damages from the Defendants, and she hereby prays that judgment be entered in his favor and against the Defendants as follows:

Complainant seeks the following remedies:

1. That the Court orders damages amounting to $99,600,000.
2. That the Court orders a refund of any and all moneys already paid to Clement Electrical.
3. Interest as provided by law;
4. An award of fees and costs;
5. That the Court issues any other order that this institution deems just.

Respectfully submitted:

Dated: __________

CERTIFICATE OF MAILING

I, [ENTER NAME], certified on this ______day of ________ 2021, I deposited a true copy of the above to the Defendants by placing the documents with prepaid postage in the United States mailbox address.

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