Lawsuit: Dismissed Dodrio3 Vs. Dragon Law [2024] DCR 31

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dodrio3

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Dodrio3
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IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

CIVIL ACTION


Dodrio3 (Represented by Titan Law)

Plaintiff


v.


Dragon Law Firm

Defendant


COMPLAINT

The Plaintiff complains against the Defendant as follows:


The Defendant hired the Plaintiff as a Clerk. In accordance with their contract, the Plaintiff's pay was to be $1,000 per week plus a $5,000 signing bonus one month after being hired.


The Plaintiff was not paid for work done, in accordance with their contract. In fact, the Plaintiff was only paid for 1 week, as opposed to 4 weeks and a signing bonus.


This is a violation of §7.1 of the Contracts Act (Breach of Contract).


I. PARTIES

1. Dodrio3 (Plaintiff)
2. Dragon Law Firm (Def


II. FACTS

1. On June 15, AlexanderLove announced Dragon Law Firm was hiring a clerk (see Exhibit P-1)

2. Pay included $1,000 per week and a $5,000 bonus one month after being hired (see Exhibit P-1)

3. Dodrio3 began training on June 18 (see Exhibit P-2)

5. Dodrio3 showed proof he was only paid for the first week, to which Managing Partner AlexanderLove responded “Wild, ok I’ll make sure they pay you back with [an extra] 10% for the weeks worked” (see Exhibit P-3)

6. On July 19, Dodrio3 put in a 1 weeks’ notice, but was immediately fired after saying so (see Exhibit P-4)

7. Despite Dodrio3 working at Dragon Law for 1 month and 2 days, he was not given the $5,000 bonus (see Exhibit P-4)

8. Despite Dodrio3 working at Dragon Law for 1 month and 2 days, he was not paid more than the original $1,000 for the first week (see Exhibit P-4).


III. CLAIMS FOR RELIEF

1. Breach of Contract – Dodrio3 was guaranteed a $5,000 bonus one month after being hired, and was not given it.

2. Breach of Contract – Dodrio3 was only paid for a quarter of the weeks he worked (one of four weeks).


IV. PRAYER FOR RELIEF

The Plaintiff seeks the following from the Defendant:

1. $8,300 in Compensatory Damages for Breach of Contract (3 weeks missed pay + the extra 10% Promised, $5,000 bonus)

2. $4,000 for Consequential Damages (Emotional Damages, Loss of Enjoyment), as having the opportunity to grow their savings through this employment was ripped away from them.

3. $5,000 in Punitive Damages, as a Law Firm abusing its employees and refusing to pay them the required amount is outrageous.

4. $5,190 in Legal Fees(30% of the overall value of the case).


EVIDENCE

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By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.


DATED: This 8 day of 8 2024
 
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IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
WRIT OF SUMMONS

@Alexander P. Love is required to appear before the District Court in the case of Dodrio3 Vs. Dragon Law [2024] DCR 31. Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case. Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.​
 
IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
ANSWER TO COMPLAINT

dodrio3
Plaintiff

v.

Dragon Law Firm
Defendant

I. ANSWER TO COMPLAINT
1. The defense AFFIRMS that "On June 15, AlexanderLove announced Dragon Law Firm was hiring a clerk."
2. The defense DOES NOT DISPUTE that "Pay included $1,000 per week and a $5,000 bonus one month after being hired" noting that this was the abbreviated advertisement, and the contract reflects these conditions differently.
3. The defense AFFIRMS that "Dodrio3 began training on June 18."
4. The defense AFFIRMS that the plaintiff cannot count.
5. The defense DOES NOT DISPUTE that "Dodrio3 showed proof he was only paid for the first week, to which Managing Partner AlexanderLove responded 'Wild, ok I’ll make sure they pay you back with [an extra] 10% for the weeks worked.'"
6. The defense AFFIRMS that "On July 19, Dodrio3 put in a 1 weeks’ notice, but was immediately fired after saying so", noting that Dodrio3 was fired for his conduct, attitude, and inactivity and nothing more.
7. The defense DISPUTES that "Despite Dodrio3 working at Dragon Law for 1 month and 2 days, he was not given the $5,000 bonus." Dodrio3 did not work at Dragon Law for over a month; he was inactive and therefore not considered working for at least two weeks.
8. The defense DISPUTES that "Despite Dodrio3 working at Dragon Law for 1 month and 2 days, he was not paid more than the original $1,000 for the first week." The plaintiff only worked for two full weeks, with his last work-related message occurring on July 2nd, 2024.

II. DEFENSES
1. The plaintiff only worked for two weeks, and is entitled only to $1,000 more. This was a clerical error with our bank. I have proof that I am attaching below that we ordered our bank to pay Dodrio3 what he was owed. The bank did not accomplish this, and therefore, there was little we could do especially since Dodrio3 did not communicate with us. He never said he didn't receive the money, so we didn't check up on it.
2. The plaintiff is entitled to nothing more than $1,000 as he is not entitled to be paid for weeks he didn't work per our employee agreement, including the signing bonus. "The employer is not obligated to pay the employee for weeks where the employee was absent or inactive from work duties."


I apologize for the late filing, your honor. I have a lot on my plate as far as cases right now.


By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This 12th day of August, 2024.
 
I respectfully request that the court proceed to summary judgment in the above-referenced case. The defense has failed to file their response within the specified timeframe and did not request an extension.

Their failure to respond in a timely manner violates my constitutional right to a fair trial by delaying the resolution of this matter. Therefore, I ask the court to consider this request to ensure a fair and timely conclusion to this case.
 
I respectfully request that the court proceed to summary judgment in the above-referenced case. The defense has failed to file their response within the specified timeframe and did not request an extension.

Their failure to respond in a timely manner violates my constitutional right to a fair trial by delaying the resolution of this matter. Therefore, I ask the court to consider this request to ensure a fair and timely conclusion to this case.
The response was submitted within a few hours of the deadline; a reasonable submission. There was no delay as the presiding officer hasn't even reviewed it up until this point.
 
I respectfully request that the court proceed to summary judgment in the above-referenced case. The defense has failed to file their response within the specified timeframe and did not request an extension.

Their failure to respond in a timely manner violates my constitutional right to a fair trial by delaying the resolution of this matter. Therefore, I ask the court to consider this request to ensure a fair and timely conclusion to this case.
Request denied.
 
We will now be moving into a 3-Day Discovery period.
 
The plaintiff motions to end discovery early.
 
Following the resignation of former magistrate Aladeen, I will be taking over this case.
 
Interrogatory
1. Isn’t it true you stopped working on July 2nd, 2024?
2. Why did you stop working?
3. Did you let anyone in management know about alleged non-payment before you stopped working?
4. Were you aware of the provision in the Dragon Law employment contract that states employees are not entitled to receive pay for weeks not worked?
 
Witness List
The defense tenders Avaneesh2008, Towloo, and Bardiya_King in their capacity as Dragon Law administrators as witnesses.

The defense tenders Nexalin on behalf of Vanguard Private Bank as a witness.
 
Motion to Dismiss
Your honor, I move to dismiss under rule 5.5 lack of claim. Dragon Law did everything reasonably possible to ensure the plaintiff was paid what he was owed. He is claiming compensation for weeks not worked, and is therefore frivolously suing us. Furthermore, he lacks evidence that he wasn’t paid, or that he was active during weeks beyond the first. Due to his lack of evidence and lack of standing under the employee agreement, the defense moves to have this case dismissed with prejudice.
 
Motion to Compel
Your honor, since the plaintiff is requesting legal fees, we ask that the plaintiff be compelled to provide the Court evidence of the plaintiff’s retainer agreement / fee agreement with Titan Law Firm.
 
IMG_7420.jpeg

The defense hereby counterclaims for $5,000 in legal fees.
 
Motion to Dismiss
Your honor, I move to dismiss under rule 5.5 lack of claim. Dragon Law did everything reasonably possible to ensure the plaintiff was paid what he was owed. He is claiming compensation for weeks not worked, and is therefore frivolously suing us. Furthermore, he lacks evidence that he wasn’t paid, or that he was active during weeks beyond the first. Due to his lack of evidence and lack of standing under the employee agreement, the defense moves to have this case dismissed with prejudice.
Response to motion

Your Honour, it is unreasonable to expect the plaintiff to provide evidence of transactions that never occurred. It lies with the defence to demonstrate that these transactions took place. Furthermore, the only evidence provided by the defence regarding my client’s alleged inactivity is from July 19th. The defence has not presented any substantial proof before this date.
 
Response to motion

Your Honour, it is unreasonable to expect the plaintiff to provide evidence of transactions that never occurred. It lies with the defence to demonstrate that these transactions took place. Furthermore, the only evidence provided by the defence regarding my client’s alleged inactivity is from July 19th. The defence has not presented any substantial proof before this date.
Objection
Breach of Procedure

A response to the motion wasn’t requested by the Court.
 
OBJECTION
Relevance

The "D-2" contract is a general agreement from Dragon Law that remains unsigned by both the plaintiff and the defense. As it currently stands, the contract lacks legal validity, and there is a concern that portions of it could potentially be fabricated to benefit the defence's case.
If the plaintiff believes any section to be fabricated, they may raise that separately. I bet they will not.
 
Motion to Dismiss
Your honor, I move to dismiss under rule 5.5 lack of claim. Dragon Law did everything reasonably possible to ensure the plaintiff was paid what he was owed. He is claiming compensation for weeks not worked, and is therefore frivolously suing us. Furthermore, he lacks evidence that he wasn’t paid, or that he was active during weeks beyond the first. Due to his lack of evidence and lack of standing under the employee agreement, the defense moves to have this case dismissed with prejudice.
Sustained. The filing presented by the plaintiff is inadequate, as it lacks sufficient evidence to support the claims made. Despite the opportunity during the discovery period, no new evidence was submitted by the plaintiff. The evidence provided includes a statement from the plaintiff saying, "you could have just paid me before I went AWOL," which supports the defendant's argument that the plaintiff was not working and, therefore, not entitled to payment. The plaintiff failed to provide evidence of non-payment and did not offer any proof regarding the timeline of work. This case is dismissed with prejudice due to its lack of merit and insufficient evidence to support the plaintiff's claims.
 
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