Suhila Cassini vs Mark Rotenberg -Complaint

 

UNITED STATES DISTRICT COURT

6th JUDICIAL CIRCUIT

OAKLAND COUNTY

 

SUHILA CASSINI 

 

Plaintiff,

 

V.

 

MARK ROTENBERG

 

Defendant

 

DOCKET NO.:

 

PETITION

 

Suhila Cassini hereby alleges upon personal knowledge and belief as to their own acts, and upon information and belief as to all other matters, as to which allegations Plaintiff believe substantial evidentiary support exists or will exist after a reasonable opportunity for further investigation and discovery of evidence, as follows:

• NATURE OF THE ACTION

1. This is an action for relief from unwanted, unsolicited, uninvited actions and conduct directed at Plaintiff by Defendant blocking, restricting, interfering and otherwise threatening Plaintiff’s personal safety. 
2. Plaintiff is a resident of 4370 Strathdale Ln, West Bloomfield, MI 48323, where upon he resides together with his family.
3. Plaintiff alleges Defendant threat to personal and family safety occasioned by Defendant’s unwanted, unsolicited, uninvited actions and conduct.
4. Plaintiff alleges that Defendant has acted and conducted self in a manner suggestive of Stalking as defined by MCL 750.411h and MCL 750.411i. 
5. Plaintiff further allege Defendant has published illicit messages through use of mediums of communication.
6. Plaintiff alleges Defendant’s actions have caused him to grow fearful and anxious for his own safety and the safety of his family.
7. Plaintiff seek Personal Protection Order against Defendant. 

• THE PARTIES

• Plaintiff Suhila Cassini is an adult male residing with his family at 4370 Strathdale Ln, West Bloomfield, MI 48323.

1. Upon information and belief, Defendant is an adult male of sound mind residing at 4380 Strathdale Ln, West Bloomfield, MI 48323.

 

• JURISDICTION AND VENUE

• This Court has jurisdiction of Plaintiff’ claims pursuant to MCL 600.2950a (1). 

• Venue is proper in, and Defendant are subject to the personal jurisdiction of, this Court because Defendant maintain operations in this District, and all or most of the events giving rise to this action occurred in this District. 

• FACTUAL ALLEGATIONS

1. On or about March 20th, 2020, in front of Plaintiff’s house, Defendant engaged in activities and conducted himself in manner that violated Plaintiff.
2. Immediately after having a friendly conversation, Defendant contacted the Oakland Police Department and reported Plaintiff on allegations of illegal occupation of my house. The Department dispatched police officers to the residence of Plaintiff. 
3. Upon arriving at Plaintiff’s residence, Plaintiff explained to the police that the house had been vacant for over 5 years. Plaintiff came into possession through redemption while it was vacant. Plaintiff demonstrated that he paid tax obligations on the house for a period of at least twelve (12) months in accordance with the General Property Tax Act section 211.79a. Plaintiff further demonstrated he obtained a valid building permit, and attempts to obtain a title deed.
4. The police saw no grounds to arrest/evict Plaintiff as Plaintiff had to their knowledge violated no laws or committed any crime. Despite this outcome, Defendant continued to initiate several complaints against Plaintiff with the police department.
5. The Defendant openly and without shame disclosed to Plaintiff that Defendant is the one who has been filing reports with the police department.
6. Sometimes later, Defendant contacted the Municipality Inspector, who came to Plaintiff’s house and posted a note stating that Plaintiff’s residence had no running water.
7. On several occasions Plaintiff’s mail has gone missing. On one instance, Plaintiff did not receive registered deed title which was sent to him via registered mail. Plaintiff being distressed was constrained to apply to be issued with a new registered deed title.
8.  As a direct result of the missing title deed, Defendant has on several occasions accused Plaintiff of fraud. Plaintiff has gone further to verbally abuse Plaintiff, referring to him as “trash”.
9. On March 21st at around midnight, someone knocked on Plaintiffs door and demanded that he and his family evacuate the house. For fear of danger, the following morning Plaintiff began to gather his belongings with the intention of fleeing to safety. 
10. While removing belongings from his house, Plaintiff was greeted by Defendant’s son. Immediately after, Defendant began to scream yell in a loud voice towards the Plaintiff claiming that “everyone hates you [Plaintiff]”, “you are a fraud”, “you are trash”, “that is not your house”.
11. Plaintiff attempted to explain his missing mail and second attempt to register for a new title deed over his property. Plaintiff also attempted to explain that running water to his house will only be turned on once Plaintiff has presented a valid title deed. Unfortunately, this information fell on deaf ears.
12. Plaintiff alleges Defendant has interfered with Plaintiff’s right to enjoyment of property. Plaintiff’s children attended school within walking distance and due to Defendant’s actions, 
13. Plaintiff redeemed the house with intention of living in the house with his family. To that end, Plaintiff has invested a lot of money and time into the house. Plaintiff even took out a building permit for the property.
14. Defendant attacked Plaintiff verbally, and also through third parties (i.e. Police and municipality Inspector). Plaintiff has attempted to justify himself to Defendant without success. Plaintiff believes that Defendant’s hostility is likely to escalate whereupon Defendant may take matters into his own hands.
15. At some point, Defendant began to place his trash cans at the end of Plaintiff’s drive way. The Plaintiff innocently attempted to remove the trash cans from the drive way to place them in their appropriate location. 
16. Defendant did not approve of this action and walked out of the house, and into the street where the Plaintiff was. This entire time Defendant verbally abused Plaintiff while approaching him. Plaintiff realized the growing danger from Defendant’s aggression and chose to lock himself inside his car which was in the driveway. 
17. Plaintiff acquired the property free from any debt/liability. Plaintiff has made plans to install a well on the property. Plaintiff has also met with municipality inspector to receive building permits and temporary occupancy permit.
18. Plaintiff has done nothing to cause Defendant to act in such a manner. Plaintiff is a victim to the Defendant’s whims and abuses. 
19. Defendant has no justifiable reason to 

CAUSE OF ACTION

1. Plaintiff alleges Defendant has engaged in actions equal or similar to stalking as defined by MCL 750.411h and MCL 750.411i, which includes but is not limited to:
   1. Following Plaintiff or appearing within Plaintiff sight;
   2. Appearing at Plaintiff’s workplace or residence;
   3. Approaching or confronting Plaintiff in a public place or on private property;
   4. Entering onto or remaining on property owned, leased, or occupied by Plaintiff;
   5. Sending mail or other communications to Plaintiff;
   6. Contacting Plaintiff by telephone;
   7. Placing an object on or delivering an object to property owned, leased, or occupied by Plaintiff;
   8. Threatening to kill or physically injure Plaintiff; and
   9. Purchasing or possessing a firearm.
2. Posting messages through the use of any medium of communication, including the internet or computer or any electronic medium, pursuant to MCL 750.411s.

 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff pray for relief as follows:

1. For a declaration that Defendant’ actions as alleged herein are unlawful;
2. For Personal Protection Order in favor of Plaintiff and against Defendant;
3. For compensatory damages for Plaintiff’ emotional pain and suffering, in an amount to be proven at trial;
4. For punitive damages in an amount to be determined at trial;
5. For interest on compensation and damages, including pre- and post-judgment interest and an upward adjustment for inflation;
6. For an order enjoining Defendant from engaging in the unlawful acts complained of herein;
7. For reasonable fees and costs of suit; and
8. For such other and further relief as this Court deems just and proper.

 

Dated:  ____________________	Respectfully submitted,
By:
Suhila Cassini 4370 Strathdale Ln, West Bloomfield, MI 48323	SUHILA CASSINI Pro Se

 

DEMAND FOR JURY TRIAL

Plaintiff demand a jury trial on all causes of action and claims to which they have a right to a jury trial.

 

Dated: _____________________

Respectfully submitted,

 

By:
	SUHILA CASSINI

 

Suhila Cassini

4370 Strathdale Ln,

West Bloomfield, MI 48323

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