Griever/Plaintiff's Position Statement - Revision history

Woozle at 23:08, 11 September 2025

2025-09-11T23:08:48Z

← Older revision		Revision as of 23:08, 11 September 2025
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	===Accounting / Debt===		===Accounting / Debt===
	Please state any disagreements you may have with any of the following attached [[~~SvsG:Accounting~~\|accountings]]:		Please state any disagreements you may have with any of the following attached [[Griever/accounting\|accountings]]:

	<center>		<center>
	{{~~SvsG: Accounting Links~~}}		{{Nav/Griever/accountings}}
	</center>		</center>

	Please indicate specific transactions or calculations you believe to be in error or to have been omitted. For each transaction involved, please identify specifically by naming date, payer, payee, method of transaction (check, credit card, etc.) and check number where applicable.		Please indicate specific transactions or calculations you believe to be in error or to have been omitted. For each transaction involved, please identify specifically by naming date, payer, payee, method of transaction (check, credit card, etc.) and check number where applicable.

Woozle: internal link updates

2025-09-11T23:06:10Z

internal link updates

← Older revision		Revision as of 23:06, 11 September 2025
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	==Introduction==		==Introduction==
	I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask (~~[[SvsG:Plaintiffs' First Requests to RDA~~\|~~Plaintiffs~~' First Requests to RDA]], ~~[[SvsG:Plaintiffs' First Fact Requests to Bubba~~\|~~Plaintiffs~~' First Fact Requests to Bubba]], and ~~[[SvsG:Plaintiffs' First Fact Requests to Lynne~~\|~~Plaintiffs~~' First Fact Requests to Lynne]]). I am now revising it to be essentially an overview of my complaints against the Grievers.		I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask ({{l/same\|Plaintiff's First Requests to RDA}}, {{l/same\|Plaintiff's First Fact Requests to Bubba}}, and {{l/same\|Plaintiff's First Fact Requests to Lynne}}). I am now revising it to be essentially an overview of my complaints against the Grievers.

	An archive of the original "interrogatory" version is [[/archive\|here]].		An archive of the original "interrogatory" version is [[/archive\|here]].

Woozle: updated links and templates

2015-08-15T17:41:22Z

updated links and templates

← Older revision		Revision as of 17:41, 15 August 2015
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	[[category:Griever]]		[[category:Griever]]
	[[category:Griever/~~legal~~]]		[[category:Griever/docs]]
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	==Introduction==		==Introduction==
	I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask (~~{{l/same~~\|~~Plaintiff~~'s First Requests to RDA}}, ~~{{l/same~~\|~~Plaintiff~~'s First Fact Requests to Bubba}}, and ~~{{l/same~~\|~~Plaintiff~~'s First Fact Requests to Lynne}}). I am now revising it to be essentially an overview of my complaints against the Grievers.		I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask ([[SvsG:Plaintiffs' First Requests to RDA\|Plaintiffs' First Requests to RDA]], [[SvsG:Plaintiffs' First Fact Requests to Bubba\|Plaintiffs' First Fact Requests to Bubba]], and [[SvsG:Plaintiffs' First Fact Requests to Lynne\|Plaintiffs' First Fact Requests to Lynne]]). I am now revising it to be essentially an overview of my complaints against the Grievers.

	An archive of the original "interrogatory" version is [[/archive\|here]].		An archive of the original "interrogatory" version is [[/archive\|here]].

	==Loose Ends==		==Loose Ends==
	* As far as I can tell, we have never received a response to {{l/same\|Plaintiff's First Requests to RDA}}.		* As far as I can tell, we have never received a response to {{l/same\|Plaintiff's First Requests to RDA}}; presumably, Bubba's and Lynne's responses to their individual Requests documents served that function.
	==Claims==		==Claims==
	I haven't yet gone over this with my lawyer to make sure this is what we're actually asking for, but my understanding of what we are claiming is:		I haven't yet gone over this with my lawyer to make sure this is what we're actually asking for, but my understanding of what we are claiming is:
	* damages for all amounts borrowed, including unpaid rental on the Benz, currently totalling almost $40,000 (see ~~[[Griever~~/accounting/summary~~\|accounting summary]]~~).		* damages for all amounts borrowed, including unpaid rental on the Benz, currently totalling almost $40,000 (see {{l/same\|accounting/summary}}).
	* either:		* either:
	** return of all Red House Store merchandise left with the Grievers, in new/saleable condition, or		** return of all Red House Store merchandise left with the Grievers, in new/saleable condition, or
	** return of all Red House Store merchandise currently in the Grievers' possession, regardless of condition, plus payment ~~equaling~~ the resale value of any items not returned in resaleable condition		** return of all Red House Store merchandise currently in the Grievers' possession, regardless of condition, plus payment equalling the resale value of any items not returned in resaleable condition

	==Overview==		==Overview==
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	* I worked with them to expand my online store, but as they gradually increased the scope of their involvement while rejecting the idea of a written contract or recorded hours, it was ultimately impossible to reach an agreement over what their compensation for this work should be		* I worked with them to expand my online store, but as they gradually increased the scope of their involvement while rejecting the idea of a written contract or recorded hours, it was ultimately impossible to reach an agreement over what their compensation for this work should be
	* I paid for all items purchased for sale by The Red House Store, much of which they later kept and refused to return.		* I paid for all items purchased for sale by The Red House Store, much of which they later kept and refused to return.
	* They rented my ~~1983~~ Mercedes Benz for over two and a half years, never paid more than the first week's rent, allowed the car to become damaged and undriveable, and ultimately refused to return it.		* They rented my [[Janis Jalopy\|1982 Mercedes Benz]] for over two and a half years, never paid more than the first week's rent, allowed the car to become damaged and undriveable, and ultimately refused to return it.
	* They allowed the storage unit for which I was paying them $100/month to be hauled off with no notice, before or after, sustaining considerable damage to the contents and forcing me to abandon many of my personal belongings.		* They allowed the storage unit for which I was paying them $100/month to be hauled off with no notice, before or after, sustaining considerable damage to the contents and forcing me to abandon many of my personal belongings.
	===Borrowing===		===Borrowing===
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	===Benz Rental===		===Benz Rental===
	# The Plaintiffs agreed to rent the Benz to Defendant Norma Lynne Griever starting at the rate of $100 per week. (This much does not seem to be in dispute; see "{{l/same\|Defendants' Admission}} ~~of Facts to Plaintiffs~~" #18)		# The Plaintiffs agreed to rent the Benz to Defendant Norma Lynne Griever starting at the rate of $100 per week. (This much does not seem to be in dispute; see "{{l/same\|Defendants' Admission}}" #18)
	# As it was known to both parties that there was considerable uncertainty about the balance of prior transactions between Plaintiffs and Defendants (that is, it was uncertain whether calculations would ultimately show a debt owed by Plaintiffs to Defendants or instead a debt owed by Defendants to Plaintiffs), it was agreed that the Benz rental would be kept as a separate matter from any other transactions unless otherwise explicitly and specifically agreed between the two parties – in other words, that any amounts due from either party to the other as a result of the storage rental agreement would not be presumed to be negated by any debt, pre-existing or otherwise, from the latter to the former, without mutual agreement to such.		# As it was known to both parties that there was considerable uncertainty about the balance of prior transactions between Plaintiffs and Defendants (that is, it was uncertain whether calculations would ultimately show a debt owed by Plaintiffs to Defendants or instead a debt owed by Defendants to Plaintiffs), it was agreed that the Benz rental would be kept as a separate matter from any other transactions unless otherwise explicitly and specifically agreed between the two parties – in other words, that any amounts due from either party to the other as a result of the storage rental agreement would not be presumed to be negated by any debt, pre-existing or otherwise, from the latter to the former, without mutual agreement to such.
	# The Plaintiffs agreed to allow the cost of necessary maintenance (specifically, an oil change and repairs) to be deducted from the rent due (see "~~[[S vs G:~~ Defendants' Admission~~]] of Facts to Plaintiffs~~" #19)		# The Plaintiffs agreed to allow the cost of necessary maintenance (specifically, an oil change and repairs) to be deducted from the rent due (see "{{l/same\|Defendants' Admission}}" #19)
	# The Plaintiffs agreed to consider changing the rental from weekly to per-mile		# The Plaintiffs agreed to consider changing the rental from weekly to per-mile
	#Defendants contend:		# Defendants contend:
	#* the per-week rental rate was for the months of November and December of 2001 only		#* the per-week rental rate was for the months of November and December of 2001 only
	#* the new per-mile rental basis was to be negotiated just after January 1, 2002		#* the new per-mile rental basis was to be negotiated just after January 1, 2002
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	====Conclusions====		====Conclusions====
	# As Defendants agreed to pay $100 per week for rental on the Benz, with no time-limitation specified at the time of the agreement, and as no subsequent agreement was reached between Defendants and Plaintiff which would have altered or superceded these terms, and as the vehicle remained in the possession of the Defendants, and as the Defendants refused to respond to Plaintiff Nick's efforts to arrange retrieval of the vehicle, Defendants are liable for rental charges on the Benz during the time it was in their possession.		# As Defendants agreed to pay $100 per week for rental on the Benz, with no time-limitation specified at the time of the agreement, and as no subsequent agreement was reached between Defendants and Plaintiff which would have altered or superceded these terms, and as the vehicle remained in the possession of the Defendants, and as the Defendants refused to respond to Plaintiff Nick's efforts to arrange retrieval of the vehicle, Defendants are liable for rental charges on the Benz during the time it was in their possession.
	# As Defendants refused to return the Benz upon request, and it was shown [[~~S vs~~. G: Magistrate Court Order 2\|in court]] that they had no just cause for retaining it, they are additionally liable for court and legal costs incurred in the process of recovering it.		# As Defendants refused to return the Benz upon request, and it was shown [[../documents/legal/2004-02-09 Magistrate Court Order\|in court]] that they had no just cause for retaining it, they are additionally liable for court and legal costs incurred in the process of recovering it.
	# As Defendants did not return the Benz to Plaintiff as soon as it became non-functional, and – by leaving it in the open without running it or subjecting it to any kind of maintenance for well over a year – allowed it to deteriorate further to the point where major repairs were required in order to return it to working condition, they are also liable for the cost of such repairs.		# As Defendants did not return the Benz to Plaintiff as soon as it became non-functional, and – by leaving it in the open without running it or subjecting it to any kind of maintenance for well over a year – allowed it to deteriorate further to the point where major repairs were required in order to return it to working condition, they are also liable for the cost of such repairs.

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	# The items which Nick had moved into the other trailer became inaccessible for a time, due to obstruction by other items not belonging to Plaintiffs.		# The items which Nick had moved into the other trailer became inaccessible for a time, due to obstruction by other items not belonging to Plaintiffs.
	# Plaintiff Nick later recovered these items. To the best knowledge of Defendants, all of Plaintiffs' belongings were recovered from that other trailer.		# Plaintiff Nick later recovered these items. To the best knowledge of Defendants, all of Plaintiffs' belongings were recovered from that other trailer.
	# Defendants were at that time renting the three trailers from Neff at a combined cost of no more than $259.00 per month (see RDA checks #[[:Image:2002-07-18 rda ck3087 Neff Rental.jpg\|3087]], #[[:Image:2002-11-20 rda ck3202 Neff Rental.jpg\|3202]], # [[:Image:2002-12-27 rda ck3423 Neff Rental.jpg\|3423]], # [[:Image:2003-03-27 rda ck3545 Neff Rental.jpg\|3545]], #[[:Image:2003-04-21 rda ck3566 Neff Rental.jpg\|3566]]).		# Defendants were at that time renting the three trailers from Neff at a combined cost of no more than $259.00 per month (see RDA checks #[[:Image:2002-07-18 rda ck3087 Neff Rental.jpg\|3087]], #[[:Image:2002-11-20 rda ck3202 Neff Rental.jpg\|3202]], # [[:Image:2002-12-27 rda ck3423 Neff Rental.jpg\|3423]], #[[:Image:2003-03-27 rda ck3545 Neff Rental.jpg\|3545]], #[[:Image:2003-04-21 rda ck3566 Neff Rental.jpg\|3566]]).
	# Defendants later discontinued renting the other two trailers from Neff, at which point Neff's rental charge for the one Trailer was no more than $108.75 per month (see RDA checks #[[:Image:2003-05-05 rda ck3586 Neff Rental.jpg\|3586]], #[[:Image:2003-06-02 rda ck3248 Neff Rental.jpg\|3248]])		# Defendants later discontinued renting the other two trailers from Neff, at which point Neff's rental charge for the one Trailer was no more than $108.75 per month (see RDA checks #[[:Image:2003-05-05 rda ck3586 Neff Rental.jpg\|3586]], #[[:Image:2003-06-02 rda ck3248 Neff Rental.jpg\|3248]])
	# By October, 2002, Plaintiff(s) had finished moving their belongings into Trailer #3.		# By October, 2002, Plaintiff(s) had finished moving their belongings into Trailer #3.
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	# In October, 2002, Defendants began charging Plaintiffs $70 per month for the non-merchandise portion of storage (approximately half the available space)		# In October, 2002, Defendants began charging Plaintiffs $70 per month for the non-merchandise portion of storage (approximately half the available space)
	# The remaining cost of storage in Trailer #3 was covered by Defendants, as the merchandise occupying that space was at that time presumed to be the property of Defendants, and storage of same was therefore presumed to be Defendants' responsibility.		# The remaining cost of storage in Trailer #3 was covered by Defendants, as the merchandise occupying that space was at that time presumed to be the property of Defendants, and storage of same was therefore presumed to be Defendants' responsibility.
	# By verbal agreement between Plaintiff Nick and Defendant Bubba, this $70 was to be paid in two parts: $40 was to be paid by cash or check, and $30 was to be deducted from the amount due for Defendants' rental of Plaintiff Nick's Mercedes Benz (see [[~~SvsG:~~Benz ~~Rental Accounting~~\|Benz ~~Rental Accounting~~]]).		# By verbal agreement between Plaintiff Nick and Defendant Bubba, this $70 was to be paid in two parts: $40 was to be paid by cash or check, and $30 was to be deducted from the amount due for Defendants' rental of Plaintiff Nick's Mercedes Benz (see [[../accounting/Benz\|Benz rental accounting]]).
	# For the period of October 1, 2002, through March 31, 2003, Plaintiffs paid these charges in full and adjusted the Mercedes Benz accounting as agreed.		# For the period of October 1, 2002, through March 31, 2003, Plaintiffs paid these charges in full and adjusted the Mercedes Benz accounting as agreed.
	# As it was known to both parties that there was considerable uncertainty about the balance of prior transactions between Plaintiffs and Defendants (that is, it was uncertain whether calculations would ultimately show a debt owed by Plaintiffs to Defendants or instead a debt owed by Defendants to Plaintiffs), it was agreed that the storage rental would be kept as a separate matter from any other transactions except as explicitly specified in the above arrangement (i.e. deducting $30 per month from the Benz Rental amount due) – in other words, that any amounts due from either party to the other as a result of the storage rental agreement would not be presumed to be negated by any debt, pre-existing or otherwise, from the latter to the former.		# As it was known to both parties that there was considerable uncertainty about the balance of prior transactions between Plaintiffs and Defendants (that is, it was uncertain whether calculations would ultimately show a debt owed by Plaintiffs to Defendants or instead a debt owed by Defendants to Plaintiffs), it was agreed that the storage rental would be kept as a separate matter from any other transactions except as explicitly specified in the above arrangement (i.e. deducting $30 per month from the Benz Rental amount due) – in other words, that any amounts due from either party to the other as a result of the storage rental agreement would not be presumed to be negated by any debt, pre-existing or otherwise, from the latter to the former.
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	===Accounting / Debt===		===Accounting / Debt===
	Please state any disagreements you may have with any of the following attached ~~{{l/same~~\|~~accounting}}s~~:		Please state any disagreements you may have with any of the following attached [[SvsG:Accounting\|accountings]]:

	<center>		<center>
	{{~~nav/Griever/accountings~~}}		{{SvsG: Accounting Links}}
	</center>		</center>

	Please indicate specific transactions or calculations you believe to be in error or to have been omitted. For each transaction involved, please identify specifically by naming date, payer, payee, method of transaction (check, credit card, etc.) and check number where applicable.		Please indicate specific transactions or calculations you believe to be in error or to have been omitted. For each transaction involved, please identify specifically by naming date, payer, payee, method of transaction (check, credit card, etc.) and check number where applicable.

Woozle: updated categories; removed navbar

2015-08-15T16:10:28Z

updated categories; removed navbar

← Older revision		Revision as of 16:10, 15 August 2015
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			[[category:Griever]]
			[[category:Griever/legal]]
	<span class=noPrint>		<span class=noPrint>
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	~~=={{hide\|Navigation}}==~~
	~~[[Category:SvsG Documents]]~~
	~~[[Staddon vs. Griever]]: [[SvsG:Plaintiffs' Position Statement\|Plaintiffs' Position Statement]]~~
	==Introduction==		==Introduction==
	I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask (~~[[SvsG:Plaintiffs' First Requests to RDA~~\|~~Plaintiffs~~' First Requests to RDA]], ~~[[SvsG:Plaintiffs' First Fact Requests to Bubba~~\|~~Plaintiffs~~' First Fact Requests to Bubba]], and ~~[[SvsG:Plaintiffs' First Fact Requests to Lynne~~\|~~Plaintiffs~~' First Fact Requests to Lynne]]). I am now revising it to be essentially an overview of my complaints against the Grievers.		I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask ({{l/same\|Plaintiff's First Requests to RDA}}, {{l/same\|Plaintiff's First Fact Requests to Bubba}}, and {{l/same\|Plaintiff's First Fact Requests to Lynne}}). I am now revising it to be essentially an overview of my complaints against the Grievers.

	An archive of the original "interrogatory" version is [[~~SvsG:Plaintiffs' Position Statement~~/archive\|here]].		An archive of the original "interrogatory" version is [[/archive\|here]].

	==Loose Ends==		==Loose Ends==
	* As far as I can tell, we have never received a response to ~~[[SvsG:Plaintiffs' First Requests to RDA~~\|~~Plaintiffs~~' First Requests to RDA]]		* As far as I can tell, we have never received a response to {{l/same\|Plaintiff's First Requests to RDA}}.
	==Claims==		==Claims==
	I haven't yet gone over this with my lawyer to make sure this is what we're actually asking for, but my understanding of what we are claiming is:		I haven't yet gone over this with my lawyer to make sure this is what we're actually asking for, but my understanding of what we are claiming is:
	* damages for all amounts borrowed, including unpaid rental on the Benz, currently totalling almost $40,000 (see [[~~SvsG:Accounting Summary~~\|~~Accounting Summary~~]]).		* damages for all amounts borrowed, including unpaid rental on the Benz, currently totalling almost $40,000 (see [[Griever/accounting/summary\|accounting summary]]).
	* either:		* either:
	** return of all Red House Store merchandise left with the Grievers, in new/saleable condition, or		** return of all Red House Store merchandise left with the Grievers, in new/saleable condition, or
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	They then refused to return the car to me until ordered to do so by the Magistrate Court. During the time the car was in their possession it stopped working. They allowed it to deteriorate to the point where it ultimately required over $2000 in repairs in order to be driveable. It also sustained additional cosmetic damage while in their possession. Unpaid rent plus damages minus some maintenance they did on it comes to over $13,000.		They then refused to return the car to me until ordered to do so by the Magistrate Court. During the time the car was in their possession it stopped working. They allowed it to deteriorate to the point where it ultimately required over $2000 in repairs in order to be driveable. It also sustained additional cosmetic damage while in their possession. Unpaid rent plus damages minus some maintenance they did on it comes to over $13,000.

	''(Other notes on the Benz rental are [[~~SvsG:~~Benz Rental\|here]].)''		''(Other notes on the Benz rental are [[Griever/Benz Rental\|here]].)''

	===Storage Unit===		===Storage Unit===
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	===Benz Rental===		===Benz Rental===
	#The Plaintiffs agreed to rent the Benz to Defendant Norma Lynne Griever starting at the rate of $100 per week. (This much does not seem to be in dispute; see "~~[[S vs G:~~ Defendants' Admission]] of Facts to Plaintiffs" #18)		# The Plaintiffs agreed to rent the Benz to Defendant Norma Lynne Griever starting at the rate of $100 per week. (This much does not seem to be in dispute; see "{{l/same\|Defendants' Admission}} of Facts to Plaintiffs" #18)
	#As it was known to both parties that there was considerable uncertainty about the balance of prior transactions between Plaintiffs and Defendants (that is, it was uncertain whether calculations would ultimately show a debt owed by Plaintiffs to Defendants or instead a debt owed by Defendants to Plaintiffs), it was agreed that the Benz rental would be kept as a separate matter from any other transactions unless otherwise explicitly and specifically agreed between the two parties – in other words, that any amounts due from either party to the other as a result of the storage rental agreement would not be presumed to be negated by any debt, pre-existing or otherwise, from the latter to the former, without mutual agreement to such.		# As it was known to both parties that there was considerable uncertainty about the balance of prior transactions between Plaintiffs and Defendants (that is, it was uncertain whether calculations would ultimately show a debt owed by Plaintiffs to Defendants or instead a debt owed by Defendants to Plaintiffs), it was agreed that the Benz rental would be kept as a separate matter from any other transactions unless otherwise explicitly and specifically agreed between the two parties – in other words, that any amounts due from either party to the other as a result of the storage rental agreement would not be presumed to be negated by any debt, pre-existing or otherwise, from the latter to the former, without mutual agreement to such.
	#The Plaintiffs agreed to allow the cost of necessary maintenance (specifically, an oil change and repairs) to be deducted from the rent due (see "[[S vs G: Defendants' Admission]] of Facts to Plaintiffs" #19)		# The Plaintiffs agreed to allow the cost of necessary maintenance (specifically, an oil change and repairs) to be deducted from the rent due (see "[[S vs G: Defendants' Admission]] of Facts to Plaintiffs" #19)
	#The Plaintiffs agreed to consider changing the rental from weekly to per-mile		# The Plaintiffs agreed to consider changing the rental from weekly to per-mile
	#Defendants contend:		#Defendants contend:
	#*the per-week rental rate was for the months of November and December of 2001 only		#* the per-week rental rate was for the months of November and December of 2001 only
	#*the new per-mile rental basis was to be negotiated just after January 1, 2002		#* the new per-mile rental basis was to be negotiated just after January 1, 2002
	#Plaintiffs contend:		# Plaintiffs contend:
	#*No date was set for said negotiations		#* No date was set for said negotiations
	#*No such negotiations ever took place		#* No such negotiations ever took place
	#*The rental was to continue per-week until a new agreement was reached or Defendants terminated the agreement by returning the Benz		#* The rental was to continue per-week until a new agreement was reached or Defendants terminated the agreement by returning the Benz
	#In 2002-3, the Plaintiffs asked, in several different emails, for details regarding retrieving the (disabled) Benz and its keys		# In 2002-3, the Plaintiffs asked, in several different emails, for details regarding retrieving the (disabled) Benz and its keys
	#Such details would have been helpful in the process of retrieving the Benz		# Such details would have been helpful in the process of retrieving the Benz
	#Defendants never provided any such details		# Defendants never provided any such details
	====Conclusions====		====Conclusions====
	#As Defendants agreed to pay $100 per week for rental on the Benz, with no time-limitation specified at the time of the agreement, and as no subsequent agreement was reached between Defendants and Plaintiff which would have altered or superceded these terms, and as the vehicle remained in the possession of the Defendants, and as the Defendants refused to respond to Plaintiff Nick's efforts to arrange retrieval of the vehicle, Defendants are liable for rental charges on the Benz during the time it was in their possession.		# As Defendants agreed to pay $100 per week for rental on the Benz, with no time-limitation specified at the time of the agreement, and as no subsequent agreement was reached between Defendants and Plaintiff which would have altered or superceded these terms, and as the vehicle remained in the possession of the Defendants, and as the Defendants refused to respond to Plaintiff Nick's efforts to arrange retrieval of the vehicle, Defendants are liable for rental charges on the Benz during the time it was in their possession.
	#As Defendants refused to return the Benz upon request, and it was shown [[S vs. G: Magistrate Court Order 2\|in court]] that they had no just cause for retaining it, they are additionally liable for court and legal costs incurred in the process of recovering it.		# As Defendants refused to return the Benz upon request, and it was shown [[S vs. G: Magistrate Court Order 2\|in court]] that they had no just cause for retaining it, they are additionally liable for court and legal costs incurred in the process of recovering it.
	#As Defendants did not return the Benz to Plaintiff as soon as it became non-functional, and – by leaving it in the open without running it or subjecting it to any kind of maintenance for well over a year – allowed it to deteriorate further to the point where major repairs were required in order to return it to working condition, they are also liable for the cost of such repairs.		# As Defendants did not return the Benz to Plaintiff as soon as it became non-functional, and – by leaving it in the open without running it or subjecting it to any kind of maintenance for well over a year – allowed it to deteriorate further to the point where major repairs were required in order to return it to working condition, they are also liable for the cost of such repairs.

	===Storage Rental===		===Storage Rental===
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	# The items which Nick had moved into the other trailer became inaccessible for a time, due to obstruction by other items not belonging to Plaintiffs.		# The items which Nick had moved into the other trailer became inaccessible for a time, due to obstruction by other items not belonging to Plaintiffs.
	# Plaintiff Nick later recovered these items. To the best knowledge of Defendants, all of Plaintiffs' belongings were recovered from that other trailer.		# Plaintiff Nick later recovered these items. To the best knowledge of Defendants, all of Plaintiffs' belongings were recovered from that other trailer.
	# Defendants were at that time renting the three trailers from Neff at a combined cost of no more than $259.00 per month (see RDA checks #[[:Image:2002-07-18 rda ck3087 Neff Rental.jpg\|3087]], #[[:Image:2002-11-20 rda ck3202 Neff Rental.jpg\|3202]], # [[:Image:2002-12-27 rda ck3423 Neff Rental.jpg\|3423]], #[[:Image:2003-03-27 rda ck3545 Neff Rental.jpg\|3545]], #[[:Image:2003-04-21 rda ck3566 Neff Rental.jpg\|3566]]).		# Defendants were at that time renting the three trailers from Neff at a combined cost of no more than $259.00 per month (see RDA checks #[[:Image:2002-07-18 rda ck3087 Neff Rental.jpg\|3087]], #[[:Image:2002-11-20 rda ck3202 Neff Rental.jpg\|3202]], # [[:Image:2002-12-27 rda ck3423 Neff Rental.jpg\|3423]], # [[:Image:2003-03-27 rda ck3545 Neff Rental.jpg\|3545]], #[[:Image:2003-04-21 rda ck3566 Neff Rental.jpg\|3566]]).
	# Defendants later discontinued renting the other two trailers from Neff, at which point Neff's rental charge for the one Trailer was no more than $108.75 per month (see RDA checks #[[:Image:2003-05-05 rda ck3586 Neff Rental.jpg\|3586]], #[[:Image:2003-06-02 rda ck3248 Neff Rental.jpg\|3248]])		# Defendants later discontinued renting the other two trailers from Neff, at which point Neff's rental charge for the one Trailer was no more than $108.75 per month (see RDA checks #[[:Image:2003-05-05 rda ck3586 Neff Rental.jpg\|3586]], #[[:Image:2003-06-02 rda ck3248 Neff Rental.jpg\|3248]])
	# By October, 2002, Plaintiff(s) had finished moving their belongings into Trailer #3.		# By October, 2002, Plaintiff(s) had finished moving their belongings into Trailer #3.
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	===Accounting / Debt===		===Accounting / Debt===
	Please state any disagreements you may have with any of the following attached ~~[[SvsG:Accounting~~\|~~accountings]]~~:		Please state any disagreements you may have with any of the following attached {{l/same\|accounting}}s:

	<center>		<center>
	{{~~SvsG: Accounting Links~~}}		{{nav/Griever/accountings}}
	</center>		</center>

	Please indicate specific transactions or calculations you believe to be in error or to have been omitted. For each transaction involved, please identify specifically by naming date, payer, payee, method of transaction (check, credit card, etc.) and check number where applicable.		Please indicate specific transactions or calculations you believe to be in error or to have been omitted. For each transaction involved, please identify specifically by naming date, payer, payee, method of transaction (check, credit card, etc.) and check number where applicable.

Woozle: Woozle moved page SvsG:Plaintiffs' Position Statement to Griever/Plaintiff's Position Statement: reorganizing

2015-08-15T01:15:49Z

Woozle moved page SvsG:Plaintiffs' Position Statement to Griever/Plaintiff's Position Statement: reorganizing

← Older revision	Revision as of 01:15, 15 August 2015
(No difference)

Woozle: /* Introduction */ link to archive

2006-10-25T23:49:54Z

Introduction: link to archive

← Older revision		Revision as of 23:49, 25 October 2006
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	==Introduction==		==Introduction==
	I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask ([[SvsG:Plaintiffs' First Requests to RDA\|Plaintiffs' First Requests to RDA]], [[SvsG:Plaintiffs' First Fact Requests to Bubba\|Plaintiffs' First Fact Requests to Bubba]], and [[SvsG:Plaintiffs' First Fact Requests to Lynne\|Plaintiffs' First Fact Requests to Lynne]]). I am now revising it to be essentially an overview of my complaints against the Grievers.		I had originally planned to submit this document to the Defendants for response as an Interrogatory, but apparently I am only permitted one set of Interrogatories; had I known that, I would certainly have asked a similar set of questions along with the questions we did actually ask ([[SvsG:Plaintiffs' First Requests to RDA\|Plaintiffs' First Requests to RDA]], [[SvsG:Plaintiffs' First Fact Requests to Bubba\|Plaintiffs' First Fact Requests to Bubba]], and [[SvsG:Plaintiffs' First Fact Requests to Lynne\|Plaintiffs' First Fact Requests to Lynne]]). I am now revising it to be essentially an overview of my complaints against the Grievers.

			An archive of the original "interrogatory" version is [[SvsG:Plaintiffs' Position Statement/archive\|here]].

	==Loose Ends==		==Loose Ends==
	* As far as I can tell, we have never received a response to [[SvsG:Plaintiffs' First Requests to RDA\|Plaintiffs' First Requests to RDA]]		* As far as I can tell, we have never received a response to [[SvsG:Plaintiffs' First Requests to RDA\|Plaintiffs' First Requests to RDA]]

Woozle: edited wrong document yet again... restoring to proper location

2006-10-25T23:46:05Z

edited wrong document yet again... restoring to proper location

Show changes

Woozle: SvsG:Plaintiffs' Position Statement moved to SvsG:Plaintiffs' Position Statement/archive: archiving this version for easy reference

2006-10-25T14:45:05Z

SvsG:Plaintiffs' Position Statement moved to SvsG:Plaintiffs' Position Statement/archive: archiving this version for easy reference

New page

#redirect [[SvsG:Plaintiffs' Position Statement/archive]]