COMPLAINT FOR DAMAGES and INJUNCTIVE RELIEF

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405-2929 Tims Street

Abbotsford, British Columbia V2T 4G1

CANADA

Facsimile: (705) 417-1939

E-Mail: peter@eurekainnovates.com

PRO SE for Defendants 

PETER SGROMO 

WAGMORE & BARKLESS LLC

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

BESTWAY (USA), INC.; 

BESTWAY (HONG KONG) 

INTERNATIONAL LTD.; and 

BESTWAY INFLATABLES 

AND MATERIAL 

CORPORATION;

Plaintiffs,

vs. 

PIETRO PASQUALE-ANTONIO 

SGROMO (a/k/a PETER ANTHONY 

SGROMO ); WAGMORE & BARKLESS 

LLC, LEONARD GREGORY SCOTT

(a/k/a LEE SILVER), 

EUREKA INVENTIONS LLC,

Defendants.

Civil Case No. 4:2017cv00205_____

REQUEST FOR THIS COURT TO 

RECONSIDER DISMISSING THE 

ENTIRE ACTION ON THE 

GROUNDS THAT THE PROPER 

PARTIES IN THE DISPUTE ARE 

NOT BEFORE THE COURT, AND 

DEFENDANTS SGROMO ET AL. 

DO NOT MEET MINIMUM 

CONTACTS WITH FORUM

Date: December 11, 2017 

Judge: Haywood S Gilliam 

Case 4:17-cv-00205-HSG Document 66 Filed 12/09/17 Page 1 of 4
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COMPLAINT FOR DAMAGES and INJUNCTIVE RELIEF

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TO THE JUDGE: HAYWARD S GILLMAN

NOTICE HAS ALREADY HEREBY GIVEN that Defendants, Pietro Pasquale-Antonio 

Sgromo & Wagmore & Barkless LLC (hereinafter collectively “Sgromo et al.”) notify this court 

and Judge Hayward S Gillman as an individual, the right of Sgromo et al to sue Judge Hayward S 

Gillman, as an individual as well as the UNITED STATES GOVERNMENT in the Supreme Court 

of British Columbia, CANADA in accordance with the State Immunity Act, and the Court 

Jurisdiction and Proceedings Transfer Act, S.B.C. 2003, c.28 [“CJPTA”]. 

This right was based on the Notice, the Memorandum of Points and Authorities filed 

December 6th 2017, with the declarations in support of this Notice from Defendants Pietro PasqualeAntonio Sgromo (“ Sgromo ”) as an individual and representing Wagmore & Barkless LLC 

(“W&B”).

Given the proper parties (namely Wide Eyes Marketing Ltd., hereinafter “WEM”) who 

unequivocally owns the ENTIRE RIGHTS connected to the royatlies in this dispute are not before 

this court this action cannot proceed and any relief WEM, a Canadian Company incorporated under 

British Columbia, Canada Laws, with no contacts with the forum of California must be pursued 

against the United States Government and Judge Hayward Gillman as an individual in accordante 

with the State Immunity Act, and the CJPTA.

Dated this 11th day of December, 2017 

PIETRO PASQUALE-ANTONIO SGROMO 

Pro Se for Defendants, Sgromo et al. 

Case 4:17-cv-00205-HSG Document 66 Filed 12/09/17 Page 2 of 4
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COMPLAINT FOR DAMAGES and INJUNCTIVE RELIEF

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I. STATEMENT OF THE ISSUES PRESENTED

1 Whether this court should reconsider its previous decision to quash service and dismiss this 

action with prejudice in its entirety. 

2 Whether Defendants, Sgromo et al. are entitled to costs. 

II. THE NOTIFYING PARTIES

Plaintiff Peter Sgromo is an individual who, at all times relevant hereto, has been a citizen 

of Canada. Sgromo ’s time spent in San Francisco, CA was for temporary work under temporary 

TN (Trade North America) work visas under NAFTA (North American Free Trade Agreement) 

petitioned by three separate clients, Kensington Technology Group, Bestway (USA) Inc., and 

Eureka Inventions LLC. Under NAFTA, a Canadian Citizen can work and temporarily domicile in

the USA for a period of three years under strict professional categories, by a Petitioner. Work can 

only be completed for the specific petitioner in the professional category and any additional work 

for a separate entity must be accompanied by a separate petition with the US Customs and Border 

Patrol and Department of Homeland Security. 

 Sgromo had firm plans to move back to Canada permanently on July 9, 2015. However on 

two separate occasions, July 6, 2015 and July 11, 2015 the other Defendant and owner of Eureka, 

Leonard Gregory Scott (“Scott”) alleged Domestic Violence charges and Sgromo faced a lengthy 

trial for 18 months, when in December of 2016 he was cleared of all charges and the trial was 

suddenly dropped on the first day. Is should be noted Sgromo had already permanently moved back 

to Canada and flew to San Francisco solely to face trial and clear his name. Since he could not work 

in the US and needed to survive, he created Wagmore and Barkless in order to support himself 

throughout the trial. He simply could not operate his Canadian Company in California and this 

essentially was his only option 

MOST IMPORTANTLY, WEM is the sole owner of the marks. Scott purports to have 

lawfully obtained the patents and trademarks first for the alleged “domestic violence” and “drug 

abuse” having “their price to pay” and then for unpaid rent. However, the marks belong to WEM 

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COMPLAINT FOR DAMAGES and INJUNCTIVE RELIEF

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and at no time were every transferred to Sgromo as an individual. WEM is not liable for the false 

domestic charges or the claioms of unpaid rent. WEM was not facign criminal charges, nor is WEM 

a party to the lease agreement and certainly not a party to the dispute. It is nothing short of absurdity 

for this court or any competent court of jurisdiction for that matter, to make decisions on WEM’s 

property when WEM is not a party to the dispute. 

It is thereby established that at the time of the incidents surrounding the action that Sgromo 

was “voluntarily” in the jurisdiction of California. 

III. STATEMENT OF UNDISPUTED FACTS

The statement of the Unidispted Facts remain unchanged. 

IV. POINTS AND AUTHORITIES

The Points and Authorities remain unchanged. 

V. RELIEF SOUGHT

In order to avoid an absurdity in decision and certain duplicative and additional 

unnecessary action in the province of British Columbia, Canada, this Court should dismiss 

this action with prejudice prior to December 22, 2017. 

Costs of fifty-thousand United States dollars (US $50,000.00) are respectfully

requested given the vexatious nature of this prolonged litigation. 

DATED: December 11th, 2017 

By:

Pro Se 

PIETRO PASQUALE-ANTONIO SGROMO

(PETER SGROMO) FOR THE DEFENDANTS:

PIETRO PASQUALE-ANTONIO SGROMO;

WAGMORE & BARKLESS LLC

Case 4:17-cv-00205-HSG Document 66 Filed 12/09/17 Page 4 of 4