Steve's posting

Hey,

I tried to keep this as brief as possible, so I address only those facts that would support each element of the two claims. The caption got messed up, but we can prettify that, can't we?

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ______________________________________ Carol A. Rannels, Lynn L. Rannels, Plaintiffs,                                          Civil Case No.: _________ v. Judge Raven-Hansen S.E. Nichols, Inc., Defendant. ______________________________________)

1.	On August 4, 1977, defendant filed a criminal complain charging plaintiff with a violation of the Pennsylvania bad check statute, 18 Pa. C.S.A. s. 4105.

2.	Defendant filed the complaint despite knowledge by the manager of defendant’s store, Robert Boyde, that plaintiff’s check was not a bad check but rather a check on which payment had been stopped by plaintiff because of a dispute over defective store merchandise plaintiff had purchased with the check.

3.	When plaintiff confronted Mr. Boyd about the complaint, he remarked that the complaint had been filed because plaintiff “attempted fraud in [the] store.”

4.	Mr. Boyd made this remark in the presence of several customers, a person being interviewed for the job and plaintiff’s son.

5.	When plaintiff contacted Manfred Brecker, president of defendant corporation, and explained to him that the Pennsylvania store has instituted baseless and malicious proceedings against her, Mr. Brecker replied that he supported the malicious prosecution, despite the fact that he knew plaintiff had not attempted to defraud defendant’s store and thus had broken no law.

6.	The plaintiff was eventually acquitted of the criminal charge against her.

7.	Defendant’s instituting criminal proceedings against plaintiff and making false statements about her caused plaintiff and her husband severe emotional distress, humiliation, pain, and embarrassment, and harmed their marital relationship.

8.	The fact that defendant filed the criminal complaint against plaintiff with the knowledge that plaintiff had not defrauded the store constitutes extreme and outrageous conduct. Wherefore plaintiff demands judgment against defendant in the amount of $2, 800,000 and costs.

Dated this 6th day of November, 2006.

Respectfully submitted, ________/s/___________

Maureen McGough Jacob Meyer Anthony Prestia Stephen Satterfield

(Address)