UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

CIVIL COMPLAINT 

(Write the full name of each Plaintiff 

who is filing this complaint. If the 

names of all the plaintiffs cannot fit 

in the space above, please write 

"see attached" in the space and 

attach an additional page with ·the 

full list of names.) 

v. 

(Write the full name of each Defendant 

who is being sued. If the names of all 

the Defendants cannot fit in the space 

above, please write "see attached" in 

the space and attach an additional 

page with the full list of names.) 

I --------------

NDFL Pro Se I (Rev. 12/16) Civil Complaint 

ClerlcAdmin/OfficiaVFonns 

FILED USDC FUID GV \ 7 ,r\ A 

f\UG 17 '20 AH11:30 t-.\ ~ \ 

Case No.: I-)_ l)- c_V- \<i?{)-A,v l 

(To be filled in by the Clerk's Office) (;g;f 

Jury Trial Requested? 

o YES \a'NO 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 1 of 11
I. PARTIES TO THIS COMPLAINT 

A. Plaintiff( s) 

1. Plaintiffs Name: r1k65To\>~a..< ~ '?<U2y-css, 

Address: 1-c5 St.. \ 1a:\:\o. ~o.. . A¢: "2--4:~ 

City, State, and Zip Code: ~~t\Q,.S\/~\le.. FL. ".32-':?0 \ I 

Telephone: -;51..- ~:>39 - b'2--4~ (Home) 3S:-'.2--~~3:) - b2,..L.fb (Cell) 

2. Plaintiff's Name: ------------------

Address: ---------------------

City, State, and Zip Code: ______________ _ 

Telephone: _______ (Home) ________ (Cell) 

(Provide this information for any additional Plaintiffs in this case by 

attaching an additional page as needed.) 

B. Defendant(s) 

1. Defendant's Name: £p,c (1Q$Y)e..$ 

Name of Employer (if relevant): ____________ _ 

Address: <oi.o C.rosscoajs 'b\vd . 

City, State, and Zip Code: C.D-c-t) 1 NC. :'2--1:5l'is - (oq lo~ 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 2 of 11
2. Defendant's Name: --------------------

Name of Employer (if relevant): ____________ _ 

Address: -----------------------

City, State, and Zip Code: ______________ _ 

3. Defendant's Name: --------------------

Name of Employer (if relevant): _____________ _ 

Address: -----------------------

City, State, and Zip Code: _ _ _____________ _ 

(Pro,~ide this information for any additional Defendants in this case by 

attaching additional pages as needed.) 

II. BASIS FOR JURISDICTION 

Federal courts have limited jurisdiction. Generally, only two types of cases 

may be heard in federal court: (1) a case involving a federal question or (2) 

case involving diversity of citizenship of the parties. A "federal question" 

case arises under the United States Constitution or federal laws or treaties. 28 

U.S.C. § 1331. A "diversity" case means a citizen of one State sues a citizen 

of another State or nation. No defendant may be a citizen of the same State as 

any Plaintiff in a diversity case, and the amount in controversy must be more 

NDFL Pro S• I (Rev. I 2116) Civil Compl&i nt 

ClerkAdmin/OfliciaVFonns 3 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 3 of 11
than $75,000. 28 U.S.C. § 1332. 

What is the basis for federal court jurisdiction? (check all that apply) 

't1' Federal Question • Diversity of Citizenship 

Fill out the paragraphs in this section that apply to this case. 

A. If the Basis for Jurisdiction Is a Federal Question: 

List the specific f.edera~ statutes, federal treaties, and/or provisions of the 

United States Constitution that are at issue in this case: -------

B. If the Basis for Jurisdiction is Diversity of Citizenship: 

1. Plaintiff( s) 

a. Plaintiff is an individual and a citizen of: ----------

b. If any Plaintiff is a business or corporation, list the State where the 

business is incorporated ________ or has its principal 

place ofbusiness: - -----------------

(Note: Businesses/Corporations must be represented by counsel. 

NDFL Pm Se I (Rev. 12/16) Civil Complaint 

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Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 4 of 11
(continued from page 4) 

1. All transactions are allowed to take place that are not unlawful yet Google and Apple do 

act to stop transactions taking place that are legal. 

2. All transactions that take place don't need to pay a tax to any one private business yet 

Apple and Google do act to place a tax on any app that is reaching consumers through 

the Android or Apple phone app stores. 

3. The consumers on Google and Apple devices have no say in what apps are allowed to 

exist despite refusing to pay Google and Apple so this is a tyranny on the consumer as 

much as on the business of Epic Games. 

4. The consumers on Google and Apple devices have no alternative and would be forced 

to abandon their lawful property to switch so Google and Apple have stolen from these 

consumers. 

5. The extortion of all the property developers on these app stores has continued for so 

long the amount of money stolen has amounted to the felony penalty of larceny, grand 

and both Apple and Google have committed felony crimes making this case suitable for 

a federal court. 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 5 of 11
Attach additional page to provide this information for additional 

Plaintiffs.) 

2. Defendant(s) 

a. If the Defendant is an individual, identify their citizenship below. 

1. Defendant (name) 

is a citizen of (State) 

2. Defendant (name) 

is a citizen of (State) 

3. Defendant (name) 

is a citizen of (State) 

b. If the Defendant is a corporation or business, list the state of 

incorporation or principal place of business below. 

1. Defendant (name) _______________ _ 

State of Incorporation is ______________ _ 

or Principal Place of Business is ------------

2. Defendant (name) ------------------

State of Incorporation is ______________ _ 

or Principal Place of Business is ___________ _ 

(Attach additional page £( necessary to list all Defendants.) 

3. Have you previously been involved in litigation with one or more 

NDFL Pro Sc I (Rev. 12/1 6) Civil Coniplaint 

ClerkAdmin/Offici~I/Forms 5 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 6 of 11
of the named Defendants? 

o Yes o No 

If yes, identify prior case #: _______ Date: ____ _ 

Court: ----- - - ---------------

Defendant: --------------------

Judge: ------~---------------

Result: ----- -----------------

III. STATEMENT OF CLAIM 

Write a short and plain statement of your claim. Do not make legal 

arguments or quote from cases. State the facts which show what happened, 

as well as where and when it happened. State how each Defendant was 

involved and explain what a Defendant did or did not do; identify how each 

Defendant caused yo_'.1 hanp or violated federal law. Write each statement in 

numbered paragraphs, limited as far as practicable to a single event or 

incident. If more than one claim is asserted, number each claim, and ensure 

that a short and plain statement of facts supporting each claim is included in 

the facts alleged·. Attach no more than two (2) additional pages to state your 

claim. 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 7 of 11
(continued from page 6) 

1. All principles of each app store of Google and Apple are illegal because they tax 

developers to transact money. 

2. The Google and Apple app stores are in violation of free market principle because they 

will not allow these businesses that are not Apple's or Google's to transact lawfully 

without paying Google or Apple depending on the market. 

3. The consumer of Epic Games is not necessarily the consumer of Apple or Google yet 

Apple and Google do act to remove Epic Games when informed of this fact. 

4. The consumer of Epic Games is not allowed to choose not to pay Apple or Google yet 

still have regular access to the game they have already acquired so Apple and Google 

are both taxing the consumer as well as the business. 

5. The market on the phone is not property of Apple or Google because there are 

properties on the market that do not belong to Apple or Google despite any language 

they use that seems to steal ownership for the platform these properties are sold or 

operated on. All property exists and so who can claim to have the best way to use it is 

not necessarily the owner. The owner is the owner and property may not transfer by 

extortion or by other criminal act. 

6. The verdict here will be to release all property owners of any indemnity to Apple or 

Google that are on these app stores and continue to function them normally so the 

privatization of the store must take place. 

7. The public trust of Apple and Google must be broken up to release the future property 

owners of any further indemnity to Apple or Google. All the points of the phone 

manufacturing must be separated from the market acts. 

8. The revenue that was paid to Apple and Google for the app stores was extortion 

because there was no consumer that was purchasing from Apple or Google yet Apple 

and Google did act to insert themselves into the transaction to receive a fee for being 

present. The transactiOIJ should have been with the business owner only but by rating 

the fee by how many customers Apple and Google were seeing the customer is 

assumed to also be a customer of Apple or Google and this is false. The customer 

arrived to purchase from the business Epic Games for the game and similarly in the 

game itself for merchandise and Apple and Google explicitly forbid this by removing Epic 

Games for avoiding this demand. 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 8 of 11
IV. RELIEF REQUESTED . 

State briefly and precisely what damages or other relief the plaintiff asks the 

court to order. Do not make legal arguments. Include any basis for claiming 

that the wrongs alleged are continuing at the present time. Include the 

amounts of any actual damages claimed for the acts alleged and the basis for 

these amounts. Include any punitive or exemplary damages claimed, the 

amounts, and the reasons you claim you are entitled to actual or punitive 

money damages. __ ....,_(,..... c;.,._e,_-Q,'---'-' O~fu...u.o.._Cawb.11e..1 0A_,c.._""""~""-ef-- ~ ).__,,_'----------

V. CERTIFICATION 

As required by Federal Rule of Civil Procedure 11, I certify by signing below 

that to the best of my knowledge, information, and belief, this complaint: (1) 

is not being presented for an improper purpose, such as to harass, cause 

unnecessary delay, or needlessly increase the cost of litigation; (2) is 

supported by existing law or by a non-frivolous argument for extending, 

NDFL Pro Se I (Rev. 12/16) Civil Complaint 

ClerkAdmin/Official/Forms 7 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 9 of 11
(continued from page 7) 

1. Break up Google and Apple to avoid further indemnity from any property owner that is 

not owned by either having to pay them simply to use their property or allow their 

property to be used. 

2. Create a future-trust that is the sum of all moneys paid into Apple or Google each to fight 

against all the monopolies that will exist anytime the sole ownership of a device is used 

against property owners. The money that was paid into Apple or Google as part of this 

monopoly-verdict cannot all be returned to each original party because this theft has 

taken place for so long so none of it can be returned fairly without a substitute for all 

returns. This trust-fund will defend future similar victims of monopoly and is a real way to 

prevent this fraud from happening again. The parties who are still in existence may 

appeal to have their money returned and to this trust-fund with adequate records. 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 10 of 11
modifying, or reversmg existing law; (3) the factual contentions have 

evidentiary support or, will "likely have evidentiary support after a reasonable 

opportunity for further investigation or discovery; and ( 4) the complaint 

otherwise complies with the requirements of Rule 11. 

I agree to timely notify the Clerk's Office if there is any change to my 

mailing address. I understand that my failure to keep a current address on file 

with the Clerk's Office may result in the dismissal of my case. 

Date: 1⁄2 -I lo 1,07oPlaintiff s Signature~ 

Printed Name of Plaintiff: . Clo c, SmJ?hctc Jo<'\ 'H'-cgq2,$\ 

Address: '2..oS S$. I b:tlo Ave., . &¢ . '.2..4 /:\. 

E-Mail Address: s.\e..cacrdnVeC\?o e 3~ \. com 

Telephone Number: $2,. --32A- {;{2..Cffa 

(Additional signature pages must be attached if there is more than one 

Plaintiff.) 

NDFL Pro Se I (Rev. 12/16) Civil Complain< 

ClerkAdmin/OfficiaUFonn::i 8 

Case 1:20-cv-00180-AW-GRJ Document 1 Filed 08/17/20 Page 11 of 11