Cory , is a Citizen of the United States and a resident of the State of Florida. Cory
under the Internet Handle/Pseudonym Cory1111 entered into a contract in or about November
2010 to participate in on-line activities with EasyStreetSports.com.
10. Cory, after being directed by representatives of EasyStreetSports.com, used numerous
intermediaries to forwarded several cash payments, of approximately $250.00 (Two-Hundred
Fifty and Zero U.S. Dollars) each to EasyStreetSports.com.
11. After verification by EasyStreetSports.com of the payments, they confirmed the contractual
obligations between Cory and EasyStreetSports.com.
12. In or about the 1st quarter of 2011, Cory successfully completed the requirements of the
contract. At that time, fees and payment of those fees became due and payable to him.
13. Cory then made several demands for payment from EasyStreetSports.com.
14. EasyStreetSports.com denied the request by Cory.
15. EasySteetSports.com began to claim that Cory used prohibited methods to complete his end
of the contract.
16. Over an extended period of time amounting to several months Cory made numerous
requests and demands to EasyStreetSports.com to pay him the money he earned.
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17. EasyStreetSports.com continued to deny Cory requests.
18. After denying multiple requests by Cory, EasyStreetSports.com and its representatives and
controllers, decided, without input or contribution from Cory to involve an unauthorized
third party to determine if EasyStreetSports.com should pay Cory.
19. The third party was TheRXForum.
20. According to the terms of service posted on the EasyStreetSports.com website; in the event that
the site's operators and site users are unable to resolve a dispute, the dispute will be sent to
IBAS (the Independent Betting Adjudication Service) located in the United Kingdom.
21. In an email received from an IBAS representative, EasyStreetSports.com has never been
registered with this Alternative Dispute Resolution body.
22. In violation of their own terms of service and in a further attempt to deny Cory his money
through subterfuge, EasyStreetSports.com, TheRXForum, and the other Defendant's entered
into an overt conspiracy to deny Cory his money and to damage his personal and Internet
reputations.
23. Through publications on TheRXForum.com, representatives of TheRXForum, claimed that
after an investigation on behalf of EasyStreetSports.com and without contribution from Cory, that Cory had breached the terms of service of EasyStreetSports.com by using
automated tools which are prohibited by the terms of service of EasyStreetSports.com.
24. In repeated exchanges, Cory has denied these allegations and maintains that he was not
knowledgeable of such tools prior to the accusations by EasyStreetSports.com and
TheRXForum.
25. Wilheim, through publication on TheRXForum.com, made numerous false statements about the
actions of Cory. He further stated that his investigation (that of Wilheim) concluded that Cory had violated the terms of service of EasyStreetSports.com. He recommended that
EasyStreetSports.com not pay Cory the money they owed him.
26. EasyStreetSports.com through its representatives demanded that Cory prove that he did not
violate the terms of service.
27. EasyStreetSports.com demanded that Cory travel to Costa Rica, take a polygraph test and to
replicate his actions before they would consider paying him.
28. Cory declined as EasyStreetSports.com did not guarantee they would pay him the money if
he complied.
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29. During the time when TheRXForum and EasyStreetSports.com made the demands on Cory
public, they constantly claimed that his declination to travel from Florida to Costa Rica and to
submit to a polygraph examination was proof that he had violated the terms of service.
30. Through TheRXForum Internet Bulletin Board and other similar Internet Boards,
EasyStreetSports.com and the other Defendants spread lies and carried on a program of
character assassination against Cory in an attempt to justify their refusal to pay him the
money he was owed.
31. Cory, investigated the validity of the Defendants claims, by discussing the events with
unrelated parties and persons familiar with the underlying conditions of the contract entered
into between Cory and EasyStreetSports.com.
32. Those parties determined that EasyStreetSports.com had willingly circumvented their obligation
to Cory and their subsequent actions were an overt attempt to breach its contract with him.
In fact EasyStreetSports.com did breach its contract with Cory and to this date has refused
him any money owed.
33. Cory, after attempting to resolve this matter in a non-litigious manner was forced to retain
counsel to bring this action, to collect money owed to him and to defend his reputation and
good name from further damage.
FIRST CLAIM FOR RELIEF- BREACH OF CONTRACT
AND SUPPORTING FACTUAL ALLEGATIONS
34. Plaintiff reaffirms and incorporates by reference the foregoing facts, statements and assertions.
35. Plaintiff entered into a contract with Defendant EasyStreetSports.com on or about the _______,
day of 2011, by establishing an account and transferring funds to persons identified by the
website operators as authorized intermediaries,
36. Plaintiff successfully fulfilled his contract on or about the ____ day of ______ 2011,
37. Plaintiff made a demand to the Defendant EasyStreetSports.com for payment in the amount of
Forty-Six Thousand and Zero United States Dollars ($46,000.00), which represented the
amount owed to him and remaining in possession of EasyStreetSports.com,
38. Defendant EasyStreetSports.com denied his claim for the earned funds,
39. Plaintiff made additional demands and each was denied by Defendant EasyStreetSports.com,
40. Defendant EasyStreetSports.com unilaterally modified the agreement between, and demanded
compliance with the new terms,
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41. Plaintiff did not agree to the new terms and demanded payment again.
42. Defendant EasyStreetSports.com rebuffed the demands by Plaintiff and in return demanded
compliance with the new terms.
43. Plaintiff remains unpaid for completion of the contract with Defendant,
44. Plaintiff has been harmed by the Defendant's breach,
45. Plaintiff demands payment of the outstanding funds in the amount of Forty-Six Thousand and
Zero United States Dollars ($46,000.00).
SECOND CLAIM FOR RELIEF- FRAUD
AND SUPPORTING FACTUAL ALLEGATIONS
46. Plaintiff reaffirms and incorporates by reference the foregoing facts, statements and assertions.
47. Defendant EasyStreetSports.com made a material misrepresentation through publication on its
website that conflicts will be resolved through arbitration by IBAS,
48. Defendant EasyStreetSports.com knew at the time the statement was made that it was false,
49. Defendant EasyStreetSports.com knew at the time the Plaintiff entered into the contract that the
Plaintiff would rely upon the statement,
50. Plaintiff Cory did depended upon the statement and Defendants assurances that any disputes
would be adjudicated and resolved through IBAS,
51. Plaintiff Cory was harmed by the misrepresentation made by the Defendant in the amount of
Forty-Six Thousand and Zero United States Dollars ($46,000.00).
52. Plaintiff requests payment of the Forty-Six Thousand and Zero United States Dollars
($46,000.00), and punitive damages in the amount of One Hundred Thirty Eight Thousand and
Zero United States Dollars ($138,000.00), and the transfer of the Defendants domain names
and websites to the Plaintiff. for perpetration of the fraud.
THIRD CLAIM FOR RELIEFTORTIOUS
INTERFERENCE WITH CONTRACT
AND SUPPORTING FACTUAL ALLEGATIONS
53. Plaintiff reaffirms and incorporates by reference the foregoing facts,statements and assertions.
54. Defendants TheRx.com, TheRxforum.com, Jansen, Powers and Wilheim collectively the “RX
Defendants” did willfully inject themselves into the contractual relationship between Defendant
EasyStreetSports.com and Plaintiff Cory.
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55. The RX Defendants knew of the existing relationship between Plaintiff Cory and Defendant
EasyStreetSports.com,
56. The RX Defendants willfully interfered with the relationship between Plaintiff Cory and
Defendant EasyStreetSports.com,
57. The RX Defendants did induce, or alternatively supported through subterfuge, the decision by
Defendant EasyStreetSports.com to deny Plaintiff Cory the property lawfully due to him.
58. The RX Defendants lack any implied or explicit privilege to induce the breach between
EasyStreetSports.com and Plaintiff,
59. The actions of the RX Defendants resulted in financial damage and harm to the reputation of
Plaintiff Cory,
60. Therefore, Plaintiff asks for compensatory damages in the amount of Forty-Six Thousand and
Zero United States Dollars ($46,000.00), punitive damages in the amount of One Hundred
Thousand and Zero United States Dollars ($100,000.00) and the transfer of the Defendants
domain names and websites to the Plaintiff.
FOURTH CLAIM FOR RELIEF- DEFAMATION
AND SUPPORTING FACTUAL ALLEGATIONS
61. Plaintiff reaffirms and incorporates by reference the foregoing facts, statements and assertions.
62. By and through their overt relationship, EasyStreetSports.com and TheRXForum did make false
statements and comments regarding Cory through the use of Internet Bulletin Boards,
63. The Statements made by the Defendants were not privileged,
64. The Statements made by the Defendants were known to be false at the time of publication,
65. The Defendants continued to rely on their published unprivileged statements to support their
position in denying Cory his property.
66. The Defendants supported the continued defamation of the Plaintiff through their publication
and republication of statements designed to damage the reputation of the Plaintiff,
67. The Defendants, one and all, caused monetary damage and damage to the Plaintiff's reputation
by publishing false and misleading statements, denying him his rightful property and causing
untold harm to his personal and Internet reputation.
68. Therefore the Plaintiff demands compensation for damages in the amount of One Million
United States Dollars ($1,000,000.00), and the transfer of the Defendants domain names and
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websites to the Plaintiff.
FIFTH CLAIM FOR RELIEF- CONVERSION
AND SUPPORTING FACTUAL ALLEGATIONS
69. Plaintiff reaffirms and incorporates by reference the foregoing facts, statements and assertions,
70. Plaintiff Cory has a legal ownership interest in Forty-Six Thousand and Zero United States
Dollars ($46,000.00) owed to it from EasyStreetSports.com,
71. The Defendant, EasyStreetSports.com exercised and continues to exercise dominion and control
over the money owed Plaintiff by willfully withholding the funds from Plaintiff,
72. The Defendants, acting in concert with each other, converted the money to their personal use
and benefit by using the money owed to Plaintiff Cory for their own purpose(s),
73. Defendants actions have denied Plaintiff Cory the benefit of his contract and the use and
enjoyment of his money,
74. The Defendants actions have caused direct and measurable harm to the Plaintiff,
75. Therefore, the Plaintiff demands payment and joint and several liability of the Defendants, in
the amount of Forty-Six Thousand and Zero United States Dollars ($46,000.00) and the transfer
of the Defendants domain names and websites to the Plaintiff. .
REQUEST FOR RELIEF
Based on the aforementioned facts and claims, Plaintiff does hereby request that this
Honorable Court award to him the following relief:
1. Joint and Several Liability of the Defendants,
2. Compensatory damages in the amount of $46,000.00 (Forty-Six Thousand and Zero
United States Dollars) and statutory Interest,
3. Compensatory damages in the amount of $46,000.00 (Forty-Six Thousand and Zero
United States Dollars) and punitive damages in the amount of $138,000.00 (One
Hundred Thirty Eight Thousand and Zero United States Dollars) for the perpetration of
the fraud and the transfer of the Defendants domain names and websites to the Plaintiff.
4. Compensatory damages in the amount of $46,000.00 (Forty-Six Thousand and Zero
United States Dollars), punitive damages in the amount of $100,000.00 (One Hundred
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Thousand and Zero United States Dollars) and the transfer of the Defendants domain
names and websites to the Plaintiff.,
5. Compensatory Damages in the Amount of One Million United States Dollars
($1,000,000.00) for the Defamatory actions of the Defendants and the transfer of the
Defendants domain names and websites to the Plaintiff..
6. Damages in the Amount of Forty-Six Thousand and Zero United States Dollars
($46,000.00) plus statutory interest for the conversion of personal property owned and
owed to Plaintiff, and the transfer of the Defendants domain names and websites to the
Plaintiff,
7. Punitive Damages as determined by the Court,
8. Revocation and Transfer of the domain names of the Defendants,
9. Court Costs and Attorneys fees.
Dated this _18th_ day of _July __ 2011
By:
op:
