Friday, July 24, 2015
SUPERIOR COURT OF GULMOROGOD
Susan Derpantsoff Attorney-at-Law
Lhorenzho, Hamul Jinn, et. al. (to include other as yet unnamed John Does that may request joinder via Class Action suit)
MIURA BULL, Neo-Bushido
Case No: unassigned
NOTICE OF MOTION AND MOTION FOR PRELIMINARY INJUNCTION - ALLIANCE MENTORSHIP PROGRAM
Plaintiff Lhorenzho and named (Hamul Jinn) and unnamed co plaintiffs move for the issuance of a preliminary injunction pending the outcome of trial in this action, enjoining defendant MIURA BULL and his employees, agents, and persons acting with him or on his behalf, from creating this Mentorship Program.
This motion is based upon the memorandum in support and declaration set forth below, and the complaint in this action.
List of materials and exhibits:
There is an old adage that states simply..."STRIKE WHILE THE IRON IS HOT".
This ancient catchphrase has been the motivation for many a charlatan to move actively and resolutely on his unbridled impulses to swindle, con, cheat, scam, hoodwink, connive, fleece, bilk, hustle and rip-off his unsuspecting targets.
The recent publication of what has been described as a "WHITE PAPER" (exhibit 2A-24E) ostensibly compiled, collated, synthesized and summarized by NEW EDEN statistical data crunchers and collectors was the apparent catalyst that inspired defendant MIURA BULL to establish his latest instrument of deceit and chicanery, THE ALLIANCE MENTORSHIP PROGRAM. (exhibit 2A-24D)
The only adjective to describe this program is OUTRAGEOUS.
As an aside and relating to the WHITE PAPER, where is the legendary math error correcting BEAN COUNTER Kaeda Maxwell when you need him to proof read an important paper being used by a twisted leader for nefarious ends?
Now more than ever your alliance needs you!
Step forward and expose the mathematical shortcomings of Da Bull's source of inspiration.
POINTS AND AUTHORITIES:
As a bit of background I provide the following short paragraphs.
Our legal firm has a long history of acrimonious interactions with MIURA BULL.
I would direct the court to have the clerk pull all documents filed by us in the last 5 years as they will clearly demonstrate the contentious nature of our contact.
I have never met MIURA BULL personally but have had, as the record will show, innumerable contacts of one form or another stemming from his continual malfeasance in conducting his affairs.
Generally, I would not waste a moment worrying about the activities of a known criminal, but when his actions bring him into conflict with my employer, a powerful man in his own right, I am forced to act with impunity.
As the current and long standing legal representative of LHORENZHO, we have had to confront "DA BULL", as he is affectionately called by his minions, almost daily either by way of communication device warnings, restraining orders or actual legal filings as we attempted to quell his penchant for odiously outrageous schemes generally meant to missappropriate funds from various individuals and corporate entities.
I will not try the courts patience by detailing the scurrilous marketing schemes he has orchestrated over the years in his efforts to scam honest hard working pilots out of their hard earned ISK by selling brazenly bogus items such as "a box of hope".
The actions speak for themselves.
Res Ipsa Loquitor!
With a track record like that is it any wonder that he has now been emboldened to sell "FUN".
FUN is the last thing his underlings would use as a descriptor to characterize their existence under his heinous reign.
Its no secret that corporations under his tutelage have over the years suffered from an inordinate number of maladies and unfortunate incidents to include but certainly not limited to bio-massings, hooliganistic brawls after hours injuring innocent hard working strippers (they desperately need to unionize), widespread alcohol and drug abuse, human, animal and clone trafficking, creating and exploiting bio-mechanical devices (SGU's and PMU's), countless child labor law violations, and the unmitigated production and selling of subpar equipment and modules, many to his own pilots.
The list is endless.
I might add that he exerts tremendous pressure on his own membership to purchase ALL of their supplies from his "suppliers" which according to our investigative efforts appear to be agents operating in shadow corporations fully owned and operated by MIURA BULL.
Lest the court view this filing as a mere litany of anecdotal complaints compiled by me personally as Lhorenzho's legal counsel, let it be known that at trial we intend to parade an array of witnesses before the court that will establish clearly the need for some form of governmental, administrative and/or judicial management of this out of control and diabolical "force of nature" that is MIURA BULL.
He must be stopped before he embellishes further his devilish legacy.
As the bard said...."The evil that men do lives after them: the good is oft interred with their bones."
While we intend at this juncture to deal only with stopping the implementation of the ALLIANCE MENTORSHIP PROGRAM, our hope is that ultimately our success here will act as a template of sorts to guide others as they attempt to curb and corral further transgressions and peccadillos that may be fermenting in Mr. BULL's twisted mind.
I recall a line from the great Doors singer that stated..."HIS MIND IS SQUIRMING LIKE A TOAD!" Dare I say Mr. Bull resembles that remark?
Like a precociously naughty child he must be put on a permanent "TIME OUT".
Although this has been noted above as an exhibit, it is linked here again for the courts convenience.
I plan on referring to this document only briefly as I conclude this filing but the court is advised that we will be dissecting this memorandum in great detail at trial as well as the PVP "white paper" which Miura Bull has suggested gives him some form of authority to push forward with his plans.
I must stress that the ALLIANCE MENTORSHIP PROGRAM while touted by its developer as being "voluntary" is nothing but and that Miura Bull as is his custom will find a means to coerce the membership into enrolling either by direct pressure or through pressure exerted by his mechanical overseers, SEMI AUTONOMOUS GUARD UNIT (SGU) and the PROTOTYPE MOTIVATIONAL UNIT (PMU).
Separate filings asking the court to issue an order that these units be sent to a Junk Crushing Yard for recycling is pending and will be filed shortly. These two contraptions would best serve the public interest functioning as lamp stands.
We again ask that the court render an expedited order on this issue as well.
More specifically, the court is now also asked to supersede Miura Bull's corporate authority at this point in time and summarily authorize Lhorenzho to accept the application for admission filed by Hamul Jinn. We pray the court will issue an immediate order on this pivotal issue.
Miura Bull has made it clear to my client LHORENZHO that Hamul Jinn is to be considered for admission ONLY if he accepts the condition that he enter the prohibitively costly "MENTORSHIP PROGRAM".
It is rare for Lhorenzho to "VOUCH" for an applicant, but he was singularily impressed by Mr. Jinn's presentation, demeanor, and combat record, in particular the CRAKE GATERAU Kill mail that is the crown jewel on Mr. Jinn's resume.
The court must NOT allow Miura Bull to deligitimize, devalue and render worthless a Lhorenzho "VOUCH".
FUN as a product to be sold:
The law describes an AMBIGUOUS term as one....."open to more than one interpretation; having a double meaning, Unclear or inexact, of doubtful or uncertain nature..."
There are other more technical definitions but the above should suffice for the layman and the "pirate types" that may stumble on this filing.
We certainly do not want to confuse their already combat addled brains further.
There can be no dispute that to sell FUN is an activity best left to carnival barkers and bordello operators.
To make the sale of "FUN" the centerpiece of a NEW EDEN wide marketing campaign whose intent is to rake in billions and trillions of ISK while hawking a nebulous and amorphously murky concept is at best questionable and at most acutely criminal, especially considering that the first likely victims will be those most incapable of absorbing the financial burden this program will impose upon them, namely his own alliance brothers.
What is FUN? One man's fun is another man's torture.
Can FUN be put in a BOX OF HOPE?
Our legal firm has employed a small army of junior partners to pore over the WHITE PAPER and the ALLIANCE MENTORSHIP PROGRAM in excruciating detail.
They have found preliminarily a plethora of collective bargaining violations (coercing members into performing non union classified jobs categorized as FUN AGENTS), abject misrepresentations (e.g. claiming Miura Bull is a featured fun expert on channels and shows), and a host of other potentially criminal and civil crimes that will be exposed at trial.
While Miura Bull claims the sole right to expand and grow the Neo Bushido Alliance he is nevertheless required to confer with his own created "Council of leadears" when his actions may result in a sudden and exponential growth in membership. Any first year business student at Caldari U knows that uncontrolled growth in an enterprise is never a good thing.
The unofficial leadership cadre, this quasi mysterious Council of Leaders must still be given the opportunity to address this issue.
Fittingly, Lhorenzho is the leader of that council.
Miura Bull has stubbornly refused to convene this body of wise men and this omission must also be addressed.
The entire corporate ethos at SKRMR and Neo Bushido revolves around small gang warfare operating from within the confines of a small elite and very proud core of pilots.
To entertain this fanciful ALLIANCE MENTORSHIP PROGRAM is madness and its clear manifestations will undoubtedly be to destroy the Neo Bushido way of life.
This selling of "FUN" is clearly meant to induce an ill advised recruiting rush and indeed his own materials boast that the mentorship program will facilitate the rapid recruiting of entire alliances into the fold.
This will be the death knell of NEO-BUSHIDO and Skrmr.
What a chaotic atmosphere he has fomented.
On one hand singlehandedly standing at the doorway impeding the admission of one Hamul Jinn and on the other hand actively selling and recruiting to a potential pool of thousands.
The contradictions are astounding.
The damage that will be done to the existing alliance structure and lifestyle may turn out to be incalculable.
Susan Derpantsoff Esquire.
Gulmorogod CBD station. suite 105A