Lawsuit: In Session Pepecuu v. Aveke [2025] DCR 97

Pepecuu

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Case Filing


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

Pepecuu

Plaintiff

V.

Aveke
Defendant

COMPLAINT

The Defendant failed to fully repay a mortgage loan to the Plaintiff within the agreed-upon timeline, committing Breach of Contract, and the loan has defaulted. For the convenience of the Court, a copy of the signed contract has been attached.

I. PARTIES
1. Pepecuu (Plaintiff)
2. Aveke (Defendant)

II. FACTS
  1. On the 19th of October 2025, the Plaintiff sent a Mortgage agreement to the Defendant, and the Defendant signed the agreement.
  2. The Mortgage agreement stipulated that the Defendant would be loaned a sum of $35,000, and that the total required amount to be repaid would be $35,000 within one calendar month of the contract.
  3. The loan amount of $35,000 has not been paid, and the contract is in default as of the 23rd of November 2025.

III. CLAIMS FOR RELIEF
  1. The Defendant has committed Breach of Contract under §7 of the Contracts Act, as they have failed to pay the required $35,000 on the loan within the timeframe required.
  2. In the event of a default, §3(2) of the Mortgage Agreement states that the Plaintiff shall have the right to "accelerate the entire unpaid balance of the Loan", "foreclose on the properties in accordance with Redmont mortgage law", or "pursue any other remedies available under applicable law."

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
  1. $35,000 in Compensatory Damages for the remaining loan amount.
  2. $10,000 in Punitive damages for the outrageous conduct of the creation of a contract, in which the Plaintiff completed their end of the bargain, while the Defendant failed to pay or provide any reason for not paying for the installment as agreed-upon by both parties.
  3. $10,500 in Legal fees as a pro se litigant, equal to 30% of the case value, as stipulated by §9 of the Legal Damages Act.
  4. A Court Order mandating the transfer of the Collateral (Plot C676) to the Plaintiff, due to the default of the loan.

 

Attachments

Writ of Summons

@Aveke, is required to appear before the District Court in the case of Pepecuu v. Aveke [2025] DCR 97

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.

 
Defendant has failed to appear, PD will be assigned shortly.
 
@Dogeington has been assigned as the defendant's counsel. They shall have 48 hours to present an answer to complaint.
 
@Dogeington has been assigned as the defendant's counsel. They shall have 48 hours to present an answer to complaint.
Your honor, I would like to request a 24 hour extention
 

Answer to Complaint


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
ANSWER TO COMPLAINT

Pepecuu
Plaintiff

v.

Aveke
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM that on the 19th of October 2025, the Plaintiff sent a Mortgage agreement to the Defendant, and the Defendant signed the agreement.
2. AFFIRM that the Mortgage agreement stipulated that the Defendant would be loaned a sum of $35,000, while DENYING that the total required amount to be repaid would be $35,000 within one calendar month of the contract.
3. Neither AFFIRM nor DENY that the loan amount of $35,000 has not been paid, and the contract is in default as of the 23rd of November 2025.


II. DEFENCES

1. Lack of claim​

The Plaintiff has failed to provide any evidence in support of fact 3. Court Rules and Procedures 2.1 Standing Application states that:
In order for a plaintiff to pursue a case, they must show the following to the court:
1. Suffered some injury caused by a clear second party; or is affected by an application of law.
2. The cause of injury was against the law.
3. Remedy is applicable under relevant law that can be granted by a favorable decision.
It is unacceptable for such a claim to be made against the defendant without any proof whatsoever that the contract has been violated. In civil cases the burden of proof is on the plaintiff to prove harm, not the defense to prove innocence. The Defence, in a show of charitability to the Plaintiff, will hold off on a motion for dismissal in hopes that such proof will be submitted in discovery.

2. The contract is unenforceable​

a. Uncertainty in the repayment amount
Within P-001, Loan Terms §1.3 states:
Repayment Schedule: Borrower agrees to repay the Loan in ONE (1) installment of ONE HUNDRED THOUSAND (35,000.00) Redmont Dollars, payable as follows:
● First installment due ONE (1) calendar months from the date of this Agreement.
There is a great deal of ambiguity in the repayment amount as stated by the terms of the Mortgage Agreement. It is unclear within the contract if the single repayment amount is $100,000 or $35,000, as both are stated and equally valid interpretations of this contract.

b. Contract does not have the necessary components of a contract
The Contracts Act §6.1 states:
(1) Contracts must meet the requirements outlined in this Act to be valid and enforceable.
While further stating in §4.2.c:
“(c) Consideration. Consideration, an essential element, involves the exchange of something of value between parties, with sufficiency though not necessarily adequacy. Consideration can be tangible or intangible."
Consideration is a necessary component of enforceable contracts as defined by redmont law. The Mortgage Agreement as provided in P-001 does not contain exchange of value between the lender and the creditor. The debtor receives $35,000, but the lender does not receive anything of value. They do not gain interest on this money, and no value is exchanged between parties. The only thing that the lender receives in this contract is lien on the property C676 which serves as collateral to this loan, and is not value in and of itself.

c. Contract was made in bad faith
The Contracts Act §14 states
(1) Parties to a contract shall perform their respective duties and exercise their rights under the contract in good faith and in a manner that is fair and just.
(2) There exists an implied covenant of good faith and fair dealing in every contract covered by this Act, whether or not expressly stated. This covenant shall be read into contracts to ensure that the parties act with honesty, integrity, and fairness in all aspects of their contractual relationship.
All Redmontian contracts must be written in good faith, with all parties acting with honesty, integrity and fairness in all aspects of their contractual relationship. This contract was made to be paid back in one month, with 0% interest, with terms explicitly outlining the lender’s priority on collecting the assets of this player in the instance they fail to repay the contract. As this loan has a 0% interest rate, it is exempt from the consumer protections provided in the Credit Standards Act. The lender clearly had no intention that the contract would be upheld. If they did, it would not have been a 0% interest rate loan with a one month lump sum repayment. The Plaintiff has not shown any evidence that they pursued the retrieval of the owed amount beyond the initial contract. This shows that this contract was written to be violated so the lender would be able to take the debtor to court and seize their assets.

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 1st day of December 2025

 
Case is now entering discovery lasting 5 days.
 
Case is now entering discovery lasting 5 days.
Your Honor,
Discovery starts right as I enter a 4-day vacation, where I might be uncontactable for the duration of the trip.

Accordingly, I would like to request an extension of 72 hours to ensure that I will have sufficient time for me to provide evidence or respond to the Defendant's counsel.
 
Your Honor,
Discovery starts right as I enter a 4-day vacation, where I might be uncontactable for the duration of the trip.

Accordingly, I would like to request an extension of 72 hours to ensure that I will have sufficient time for me to provide evidence or respond to the Defendant's counsel.
Granted.
 
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