Cyantreuse VI

██████ █████████
P.O. BOX ████
WILMINGTON, NC 284██

STATE OF NORTH CAROLINA
COUNTY OF NEW HANOVER

██████ █████████,
Plaintiff

vs.

SOUTH COAST PAPER, INC. SUBSIDIARY OF
SCP FOUNDATION
Defendant


COMPLAINT


NOW COMES the Plaintiff, ██████ █████████ (“Plaintiff”) pro se, complaining of the Defendant and says:

INTRODUCTION

The Plaintiff and their employer, Information Breach Publications, LLC, regularly conducted business with South Coast Paper, Inc., a paper supplier in southeastern North Carolina. The Plaintiff and their employer express public non-support of the SCP Foundation, owner of South Coast Paper, Inc. The SCP Foundation did not at any point until it was forcibly revealed by the Plaintiff allow public knowledge of their ownership of South Coast Paper, Inc.

When it was revealed by the Plaintiff that the SCP Foundation is the true owner and operator of South Coast Paper, Inc., a smear campaign against the Plaintiff's public image was launched by the SCP Foundation. This campaign, taking place both internally among Foundation personnel and externally in news and local media, was slanderous and libelous in nature and needlessly targeted the Plaintiff.

The SCP Foundation conducts illicit business practices operating under a fabricated front company, and maliciously continued illegitimate business operations with Information Breach Publications, LLC despite being fully aware that Information Breach Publications, LLC is directly against the Foundation's motives, goals, and continued operation.

IDENTIFICATION OF PARTIES

Plaintiff is a citizen and resident of New Hanover County, North Carolina. Plaintiff is an employee of Information Breach Publications, LLC, a publications company specializing in exposing illegal and unethical practices conducted by the Defendant in multiple settings and locations.

Upon information and belief, the Defendant is an extralegal organization having no affiliation or obligation to any legal entities other than itself, and is regularly exempted from both United States federal regulations and international/United Nations regulations.

JURISDICTION AND VENUE

At the material times alleged herein, the Defendant was, upon information and belief, acting as a corporate entity based out of southeastern North Carolina, with a sales office located in New Hanover County, North Carolina.

Plaintiff was, at the material times alleged herein, a resident of New Hanover County, North Carolina.

This court does, in fact, have jurisdiction over all parties and matters in controversy herein and New Hanover County is the proper venue for this action.

FACTUAL ALLEGATIONS

1. The Plaintiff and their employer, Information Breach Publications, LLC regularly conducted business with South Coast Paper, Inc., believing it to be an independent paper supply company.
2. The Defendant illegally operated and owned South Coast Paper, Inc. despite full awareness of their questionable public status and the fact that Information Breach Publications, LLC serves the sole purpose of informing the public about fraudulent, unethical, illegal, and otherwise questionable activities conducted by the Defendant in their many facilities worldwide.
3. When the Defendant's malpractice was revealed by the Plaintiff, the Defendant responded by slandering the Plaintiff, and targeted them not as a representative of their employer but as an individual, thereby causing irreversible personal damages to the Plaintiff's reputation and well-being.
4. Despite the unlawful and uncivil conduct of the Defendant, as well the questionable legal status of South Coast Paper, Inc. as a legitimate independent company, South Coast Paper, Inc. is still in operation.

FIRST CLAIM FOR RELIEF
(Unfair and Deceptive Trade Practices)

5. The Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1 through 4.
6. The Plaintiff did willingly do business with South Coast Paper, Inc., fully believing it to be a functioning business with no ulterior motives or hidden corporate ownership.
7. The Defendant does regularly mislead the public about the destination of South Coast Paper, Inc.'s profits, not disclosing despite the SCP Foundation's now-public operation status that profits are benefiting that organization. The Defendant is fully aware of the legal status of this method of business practice and the fraudulence therein.
8. As a direct and proximate cause of the conduct of the Defendant, the Plaintiff has been damaged and is entitled to have and recover from the Defendant a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00).

SECOND CLAIM FOR RELIEF
(Libel)

9. The Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1 through 8.
10. When the Plaintiff exposed the actions of the Defendant and the true destination of South Coast Paper, Inc.'s income, the Plaintiff's status as a well-known reporter in the area was used against them in the form of a publicity-targeting smear campaign published by the Foundation, evidenced by information and belief as well as publications sourced from SCP Foundation-critical information examiners including but not limited to Information Breach Publications, LLC and informants.
11. During the Plaintiff's process of revealing the illegal processes through which South Coast Paper, Inc. transfers profits in full to the SCP Foundation, the Plaintiff was regularly harassed and questioned in public when recognized by Foundation personnel. Information and belief sourced from Foundation personnel indicates the Plaintiff is the subject of an internal "example case" used by high-ranking Foundation officials to illustrate an anti-Foundation public figure who will falsify evidence and incite distrust.
12. Following the Plaintiff's efforts to expose the actions of the Defendant, the Plaintiff's reputation and personal security were noticeably and irreparably damaged by Foundation efforts in a directly intentional and slanderous manner.
13. As a direct and proximate cause of the conduct of the Defendant, the Plaintiff has been damaged and is entitled to have and recover from the Defendant a sum in excess of TWO HUNDRED THOUSAND DOLLARS ($200,000.00).

THIRD CLAIM FOR RELIEF
(Punitive Damages)

14. The Plaintiff incorporates herein by reference the allegations contained in paragraphs 1 through 13 as is fully set forth herein.
15. The conduct of the Defendant was fraudulent, ethically unacceptable, and malicious, and has damaged both the Plaintiff and the public in manners characteristic of the Defendant's current and past behavior as an organization.
16. As a direct and proximate result of the conduct of the Defendant, the Plaintiff is entitled to an award of punitive damages against the Defendant in an amount to be determined by a jury at the trial of this matter. It is the Plaintiff’s desire for the Jury to consider an award of FOUR HUNDRED THOUSAND DOLLARS ($400,000.00) to mitigate the impact of the Defendant's actions.

Plaintiff pleads with the court and jury to

WHEREFORE, the Defendant prays the Court as follows:

That the Plaintiff have and recover judgment against the Defendant for compensatory damages in excess of SIX HUNDRED AND FIFTY THOUSAND and 00/100 Dollars ($650,000.00);

That the costs of this action be taxed by the Court against the Defendant;

For trial by jury on all issues so triable; and

For such other and further relief as to the Court seems just and proper.

Respectfully submitted this the 20th day of May, 2018.

██████ █████████
Pro Se Plaintiff

By: __

██████ █████████
Pro Se Plaintiff

Mailing Address:
██████ █████████
P.O. BOX ████
WILMINGTON, NC 284██

Street Address:
██████ █████████
██ █████ Court
P.O. BOX ████
WILMINGTON, NC 284██