Guild Wars 2

KRYTAN DISTRICT COURT
IN THE 4th DISTRICT OF DIVINITY’S REACH DIVISION

Mr. MARK RIPPLE,
Plaintiff,

Vs.

Legate Minister Lord CAUDECUS BEETLESTONE,
THE KRYTAN MINISTRY
Defendants,

Mr. Vitellio Romana /
Attorney for Plaintiff
Shlifax-Romana Law and Accountancy Corporation, LLP
100 Plaza of the Toad, Ste. 300 Divinity’s Reach, Kryta
State Bar No: 47358
Carrier Pigeon Number: Coop 909, Stall 555-8923
www.thetoad.hit.to

Legate Minister Lord CAUDECUS BEETLESTONE/
Defendant
Krytan Ministry
100 Upper City Plaza Divinity’s Reach, Kryta

COMPLAINT AND JURY DEMAND

There is no other civil action between these parties arising out of the same transaction or occurrence as alleged in this Complaint pending in this Court, nor has any such action been previously filed and dismissed or transferred after having been assigned to a Judge.

NOW COMES Plaintiff Mr. MARK RIPPLE, by and through his attorney, Mr. Vitellio Romana / Shlifax-Romana LAC, LLP and for his Complaint against THE KRYTAN MINISTRY – DIVINITY’S REACH hereby states as follows:

JURISDICTION AND VENUE

1. Plaintiff brings this action under the Krytans with Disability Act, 93 K.C. §18501, et seq. (“KDA”), Section 324 of the Rehabilitation Act of 1315, as amended, at 93 K.C. §346 and the Krytans With Disabilities Civil Rights Act, D.R.C.I. §21.660, et seq. (“KDA”).

2. This Court has jurisdiction pursuant to the following statutes:

a. 12 K.C. §5778, which gives district courts original jurisdiction over civil actions arising under the Monarchic Constitution, laws, or treaties of Kryta;
b. 12 K.C. §5780 which gives district courts jurisdiction over actions to secure civil rights extended by the Ministry and The Queen;

3. Venue is appropriate in this judicial district under 12 K.C. §5790(b) because the events that gave rise to this Complaint occurred in this district.

PARTIES

4. Plaintiff is a citizen of Kryta and resides in the County of Nebo Terrace, Gendarren County, which is in this judicial district.

5. Defendant Legate Minister LORD CAUDECUS BEETLESTONE is the Legate Minister of the Krytan Ministry. Defendant is sued in his/her official capacity as Legate Minister of the Krytan Ministry. As such, he/she has a duty to insure that all major roads, streets, avenues, alleys, thoroughfares, and boulevards in Divinity’s Reach and throughout Kryta are maintained, administered, and constructed in accordance with Krytan Law.

GENERAL ALLEGATIONS

6. The Krytan Universally Accessible Transportation Statute, Title IV of the Krytans with Disabilities Act, is codified at 93 K.C. §10011 et seq. It requires that all major roads, streets, avenues, alleys, thoroughfares, and boulevards in Kryta, up to and including city and local thoroughfares, be constructed in a manner such that all citizens of Kryta, including those with physical disabilities, are able to access, utilize, and enjoy the unobstructed use of the aforementioned roads.

7. Plaintiff is a 43-year-old man with the following need for accommodation:

a. Wheelchair-accessible ramps, roads, walkways, streets, avenues, thoroughfares, and boulevards
b. Wheelchair-accessible doors, fixtures, furniture, walls, floors, windows, ceilings, foundations, buildings, and edifices.

8. As a result of the following condition(s):

a. Permanently disabled left leg, amputated at lower thigh
b. Permanently disabled right leg, amputated at lower thigh
c. Permanent necessity to use a wheelchair for every-day ambulatory operation
d. Partial loss of vision in right eye due to complications from injury sustained in combat (right orbital fracture caused by centaur’s hoof)

9. On or about 80th Day – Season of Colossus, 1342, Plaintiff attempted to access banking services at 155 Dwayna High Road, Divinity’s Reach, Kryta, but was unable to due to a previously deactivated waypoint matrix. Plaintiff had not, until this day, visited Divinity’s Reach, thereby being unable to activate the network of waypoints commonly used for transportation throughout the city.

a. (Plaintiff was recruited, trained, and injured in service to the Seraph in the surrounding areas of Nebo Terrace, where plaintiff has to-date resided for the whole of their life.)

10. On or about 80th Day – Season of Colossus, 1342, Plaintiff attempted to partake in festivities and activities (“Merrymaking”) associated with Wintersday in The Crown Pavilion. After having been escorted (“carried”) to the apex of the Dwayna High Road to access Plaintiff’s bank, Plaintiff attempted to use the Melandru High Road to descend to the region wherein aforementioned festivities were taking place.

11. Upon embarking on the Melandru High Road, Plaintiff’s wheelchair began to violently and rapidly descend the High Road, on a direct course of collision with statue of Melandru at the end of the High Road, in the Plaza of Melandru.

Plaintiff uncontrollably and inadvertently struck two (2) priests of Melandru, parties to Case No. 698-DR-1425 and 698-DR-1426, whereupon plaintiff’s velocity was reduced to controllable levels, and plaintiff’s descent was finally stopped completely due to his collision with the Statue of Melandru, which was undamaged in the incident.

12. Because of a lack of alternative modes of transportation, Plaintiff was unable to reach the Crown Pavilion without sustaining and inadvertently causing significant injury to himself and to others caught in Plaintiff’s downward trajectory.

COUNT I
VIOLATION OF 93 K.C. §346

13. Plaintiff incorporates and restates each of the above paragraphs as if fully set forth herein.

*_14. Defendant deprived plaintiff of his royal constitutional right and/or statutory rights by failing to construct and or commission the construction of safe, accessible roads in the City of Divinity’s Reach; which includes the following thoroughfares:

a. Melandru High and Low Road(s)
b. Dwayna High and Low Road(s)
c. Balthazar High and Low Road(s)
d. Grenth High and Low Road(s)
e. Lyssa High and Low Road(s)
f. Kormir High and Low Road(s)_*

15. As a direct and proximate result of Defendant’s violation of 93 K.C. 346, Plaintiff has sustained the following injuries and damages:

a. Massive internal bruising to plaintiff’s head, chest, torso, arms, and upper thighs
b. Multiple skeletal fractures:
i. Left and right arm Radii and left arm Ulnae
ii. Left and right leg Femurs
iii. Thirteen (13) broken ribs
iv. Fractures to skull over the occipital, temporal, and frontal lobes

c. Punitive and Compensatory liability associated with collision with aforementioned priests of Melandru (Case No.s 698-DR-1425 and 698-DR-1426).
d. Punitive and Compensatory liability associated with property damage caused by collision with and abrasion to walls, floors, sidewalks, and road (Melandru High Road)
e. Punitive and Compensatory liability associated with property damage caused by collision with statue of Melandru and surrounding decorations
f. Punitive and Compensatory damages associated with smearing of various internal bodily fluids over aforementioned walls, floors, sidewalks, road, priests, statue, and surrounding decorations.

COUNT II
DISCRIMINATION BASED ON DISABILITY

16. Plaintiff incorporates and restate each of the above paragraphs as if fully set forth herein.

17. Plaintiff is a “qualified individual with a disability” as defined in 93 K.C. §346(2).

18. Plaintiff has been denied access to and excluded from “safe and accessible” roads, as defined in 93 K.C. §10011.

*_19. As a result of Defendant’s failure to provide “safe and accessible” roads, Defendant violated the KDA by discriminating against Plaintiff in a number of ways, including without limitation, the following:

a. By reason of Plaintiff’s disabilities, age, and need for accessible accommodations
b. The underfunding of maintenance and construction of safe and accessible roads, et seq.
c. Failure to furnish and/or cause the furnishing of “safe and accessible” roads to the citizens of Kryta, including those with physical disabilities._*

Wherefore, Plaintiff requests that this Court enter judgment against Defendant providing the following relief:

(a) Compensatory damages in whatever amount in excess of FIFTY MILLION COPPER PIECES (5000 gold, 0 silver, 0 copper), exclusive of costs and interest, that Plaintiff is found to be entitled;

(b) Punitive/exemplary damages against Defendant in whatever amount, exclusive of costs and interest, that Plaintiff is found to be entitled;

© An order placing Plaintiff in the position that he would have been in had there been no violation of his rights;

(d) An order enjoining/restraining Defendant from further acts of discrimination or retaliation;

(e) An award of interest, costs, and reasonable attorney’s fees;

(f) Any and all other remedies provided pursuant to 93 K.C. §346 “KDA”

(g) Take other appropriate nondiscriminatory measures to overcome the above described discrimination, and

(h) Such other and further relief as the Court deems appropriate.

Shlifax-Romana Law and Accountancy Corporation, LLP

By:

x Vitellio Romana
Attorney for Plaintiff
100 Plaza of the Toad, Ste. 300 Divinity’s Reach, Kryta
State Bar No: 47358
Carrier Pigeon Number: Coop 909, Stall 555-8923
www.thetoad.hit.to

An amusing (if dry) read.

The Court also notes that the plaintiff’s injuries could be remedied simply by “dying and respawning”.

Plaintiff should have gone to the local shout guardian clinic for condi removal.

Your honor and ministry officials, Legate Minister Lord Caudecus Beetlestone, while an importat ministry official himself—as you are all very much aware—is not in charge of, or responsible for, the maintenance and accessibility of every ramp, stair, street, road, or decoy-forest-trail-leading-to-ambush-by-bandits in the country.

While Minister Caudecus expresses his heartfelt sympathy for plaintiff’s injuries, the charges against the Minister are plainly misplaced. Indeed, Minister Caudecus does not even, as the plaintiff suggests, dwell in Divinity’s Reach proper, but rather in the outlaying township of Beetletun.

Plaintiff is either the victim of overly-ambitious, profiteering council, or is personally intent on targeting Minister Caudecus on the basis of his high profile, justly-obtained wealth, and famous big heart.

As the Minister’s legal representative in this matter, I ask that charges be dismissed for lack of culpability or relevance on the part of the defendant. I would also like to announce that the Minister, his generous heart moved by the plaintiff’s story, has decided to personally finance the installation of accessibility improvements throughout several major destinations within Divinity’s Reach, and to donate 110 gold pieces to the defendant to assist in his medical treatment. Minister Caudecus wishes the plaintiff and the court a very merry Wintersday.

This is the will of the Legate Minister Lord Caudecus Beetlestone, expressed through his humble legal representative to this court.

Mr. Ripple,

I must remind you that, according to the Krytan Rule of Law, all evidence for cases involving a minister will be handled by the Ministry Guard, who ultimately report to Minister Caudecus. In effect, you are attempting to use the judicial system against the person who controls the judicial system.

If you wish recompense for your damages, I would recommend you find a way to pin the blame on the monarchy or one of Caudecus’ political opponents, and sue them instead.

Facilities for the transport of the disabled – vis-à-vis Waypoint technology and conveniently-placed Festival Teleporters – are already extant and fully operational. The City of Divinity’s Reach is not responsible for the ignorance of the plaintiff.

Case summarily dismissed.