PLAINTIFFS ORIGINAL COMPLAINT

Name Withheld
Name Withheld Dental, PLLC
Address Withheld
City, State ZIP Withheld
Phone | Fax
Email
Plaintiff in pro per

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF WASHINGTON

Name withheld, Plaintiff,
vs.
Name withheld; Name withheld; and Name withheld, Defendants
Case No.: Number
PLAINTIFF’S ORIGINAL COMPLAINT

NOW COMES Name withheld, Plaintiff, and files this Complaint against Defendants Name withheld, Name withheld, and (Dental Assistant), and for cause, would show this Honorable Court as follows:

PARTIES
Plaintiff Name withheld is a male adult of sound mind and a law-abiding citizen whose address is Name Withheld Dental, Address Withheld.
Defendant Name withheld is a female adult of sound mind whose address is Address Withheld, ID ZIP Withheld.
Defendant Name withheld is a female adult of sound mind whose address is Address Withheld, WA ZIP Withheld.
Defendant Name withheld is a female adult of sound mind whose address is Address Withheld, WA ZIP Withheld.

JURISDICTION AND VENUE
This Court has subject matter jurisdiction under 28 U.S. Code § 1332 (diversity of citizenship). Plaintiff resides in the State of Washington and one Defendant resides in the State of Idaho.

Venue is proper in this Court in accordance with 28 U.S. Code §1391(b) which states that: “A civil action may be brought in – (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred.” The causes of action in this Complaint took place within the Eastern District of Washington.

STATEMENT OF FACTS
Name withheld is the proprietor of Name Withheld Dental, PLLC. He is licensed to practice dentistry in the State of Washington. At all times in this Complaint, Defendants were all employees of Name withheld.

Name withheld was in a relationship with Name withheld. At the same time, Name withheld worked at the dental practice as the Manager of Name Withheld Dental, PLLC.

During her time at the practice, Name withheld used funds belonging to the company for personal use without authorization and did not reimburse the funds.

Name withheld repeatedly defrauded the company by failing to record payments made by clients, causing significant financial losses.

The romantic relationship ended in October 2021, and so did the employment. Name withheld requested the return of business email access and passwords.

The next day, Name withheld changed the passwords, making herself the only one with access to emails containing confidential patient records. She also changed social media account passwords.

Name withheld made multiple respectful requests, but she refused. A report was filed with the cybercrime unit. The Facebook account was left locked. A police report was obtained: Report No. 2021-1015-1979.

Refusal to surrender access credentials led to shutdowns and access resets, causing full closure and paralysis of the practice.

On November 16, 2021, Name withheld intentionally took confidential forms and documents, including a routing slip with patient data.

That same day, she trespassed onto the premises, entered Name withheld’s office, and made false 911 accusations.

A police report was filed against Name withheld and Name withheld for theft and job/patient abandonment. Report No. ________________.

CAUSES OF ACTION

Theft by Conversion
Plaintiff incorporates Paragraphs 7-17.

Defendant retained unauthorized access to accounts after employment ended. Her actions caused the Plaintiff to lose critical access and shut down operations. Defendants are liable.

Unjust Enrichment
Plaintiff incorporates Paragraphs 7-26.

Defendant received financial benefit through misappropriated company funds. Plaintiff’s business closed due to those actions. Defendant is liable.

Defamation
Plaintiff incorporates Paragraphs 7-31.

Defendants falsely accused Plaintiff of malpractice to a regulatory commission. These accusations harmed Plaintiff’s business and led to its closure.

Intentional Interference with Prospective Business Relations
Plaintiff incorporates Paragraphs 7-34.

Defendants’ actions interfered with Plaintiff’s valid business relationships and expectations, causing closure and financial loss.

Trespass
Plaintiff incorporates Paragraphs 4-40.

Defendant knowingly and unlawfully entered the premises and took confidential materials. Defendant is liable.

PRAYER FOR RELIEF
Plaintiff respectfully requests:

Dated this ___ day of December, 2021.

Respectfully Submitted,

Name withheld,
Plaintiff in pro per

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