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MOTION FOR EMERGENCY INJUNCTION
Your Honor,
The Plaintiff respectfully requests an immediate order preventing Two Guys Realty, its officers, employees, and agents from listing, selling, transferring, auctioning, encumbering, or otherwise disposing of RH019 while this case is pending.
TGR has expressly stated that RH019 “will be listed ASAP” and that it intends to apply sale proceeds toward the disputed loan balance. This statement is attached as Exhibit P-014.
The parties dispute whether a valid default occurred, whether the contractual notice and cure requirements were satisfied, and the correct amount owed. TGR has also newly claimed a $10,000 late fee and a total balance of $104,562.47, despite previously providing a different accounting.
TGR further stated that it will not accept an authorized payment tendered from counsel’s account because counsel is not a named party to the agreement. This refusal is attached as Exhibit P-015.
Selling RH019 before judgment could permanently alter the subject of this case and make restoration of the property impossible. The requested order would only preserve the status quo while the Court determines the parties’ rights.
The Plaintiff therefore requests that TGR be temporarily prohibited from listing, selling, transferring, auctioning, encumbering, or otherwise disposing of RH019 until further order of the Court.
Respectfully submitted,
Lbozo13
Barrister — Contract Law
Counsel for 1vtmdeveloper
SUPPLEMENT TO PLAINTIFF’S MOTION FOR EMERGENCY INJUNCTION
Your Honor,
Plaintiff supplements the pending Motion for Emergency Injunction with a request for preservation of relevant evidence.
After litigation was expressly contemplated and preservation of records had been requested, Two Guys Realty closed the RH019 dispute ticket without prior notice, removing Plaintiff and counsel’s access to the communications contained within it. A screenshot of the closure is attached as Exhibit P-016.
Plaintiff does not presently claim that closing the ticket proves that evidence was deleted. However, the ticket contains communications, attachments, accounting statements, notices, and other records directly relevant to this dispute.
Plaintiff therefore respectfully requests that the Court order Two Guys Realty and anyone acting on its behalf to preserve, without deletion, alteration, or concealment:
Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
1vtmdeveloper, represented by Lbozo13, Barrister — Contract Law
Plaintiff
v.
Two Guys Realty (TGR)
Defendant
The Plaintiff submits the following Complaint for Declaratory, Accounting, and Injunctive Relief.
Proof that the Plaintiff officially retained counsel is included as Exhibit P-013.
Attached is the Plaintiff’s Complaint and supporting exhibits.
Noting the Plaintiff has failed to update their case to a proper format, the Court dismisses the case without prejudice.
