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3 4| 5 6 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON 7 FOR KING COUNTY 3 SHYAN SELAH; 5 Plaintiff, No. ° 10] ve SUMMONS 11] TIFFANI LINDSTEDT and JOHN DOE (20 days] Lindstedt, husband and wife, and the marital 12|| community composed thereof; MICHAEL WILLIAMS and JANE DOE WILLIAMS, 13|| husband and wife, and the marital community composed thereof; and CHARLES TURBAK 14| and JANE DOE TURBAK, husband and wife, 1g] [tnd the marital community composed thereof, Defendants. 1]|| TO THE DEFENDANTS: A lawsuit has been started against you in the above-entitled court, by Shyan Selah, Plaintiff. Plaintiff's claim is stated in the written Complaint, a copy of which is "81 served upon you withthe Summons. 19]) In order to defend against the lawsuit, you must respond to the Complaint by stating your 29|| defense in writing and serving a copy upon the undersigned attorney for the plaintiff within 20 au 298 after te service ofthis Summons, excluding the day of service, ora default judgment may be entered against you without notice. A default judgment is one in which the plaintiff is entitled 2211 to what he asks for because you have not responded. If you serve a Notice of Appearance on the 731] undersigned attorney, you are entitled to notice before default judgment may be entered. ql] You may demand that the Pls fie the lawsuit with the cour. If you dos, the demand must be in writing and must be served upon the person signing the summons. Within 14 days after you 25| Shyan Selah Federal Way, WA 98023, ‘Summons (20 Days) - | Phone 206: 10| u 1 13 4 15 16 17 18 19| 20 21 22| 23| 24] serve the demand, the Plaintiff must file the lawsuit with the court, or the service on you of the Summons and Complaint will be void. If you wish to seek the advice of an attorney in the matter, you should do so promptly so that your written response, if any, may be served on time. ‘Thiser Summons is issued pursuant to rule 4 of the Superior Court Civil Rules of the State of Washington. Dated the 27 day of March, 2011 Federal Way, WA 98023 ‘Summons (20 Days) - 2 Phone 206- aaa 10) iH 12| 13 4 15 16 a7] 18 19 20| 21 22 23| 25| IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY SHYAN SELAH, No. ° Plaintiffs, COMPLAINT FOR INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONSHIPS, INTENTIONAL INTERFERENCE WITH BUSINESS OPPORTUNITY, . DEFAMATION, AND CONSPIRACY vs. {TIFFANI LINDSTEDT and JOHN DOE. Lindstedt, husband and wife, and the marital [community composed there Defendants. COMES NOW the Plaintiff and alleges as follows: 1. PLAINTIFF 1.1 Plaintiff Shyan Selah resides in Federal Way, King County, Washington. I, DEFENDANTS 2.1 Defendants Lindstedt are, to plaintiff's information and belief, residents of King County in Federal Way, Washington and at all times material hereto dwelled in the City of Federal Way. 2.2. Defendants Williams are, to plaintiff's information and belief, residents of Montgomery County in Dayton Ohio and at all times material hereto dwelled in the City of Dayton. 2.3 Defendants Turbak are, to plaintiff's information and belief, residents of New York City, New York, and at all times material hereto dwelled in the City of New York. 2.24 Defendants to plaintiff's information and belief, at all times material hereto acted on her their own behalf, on behalf of each other, and on behalf of their marital communities. 2.35. None of the defendants are active members of the armed forces of the United States, ‘Shyan Selah Federal Way, WA 98023 ‘Complaint - 1 Phone 205, > 10| rt 12| 3 14] 15 16| 17 18} 19| 20| 21 2 23 24| 25 IM. JURISDICTION 3.1. Jurisdiction and venue are proper because the actions alleged herein all occurred in King County, Washington. 3.2. Defendants who reside outside Washington state used the internet and telephone to conspire, to communicate their intentions, and to make unlawful publications within Washington as described below. All the acts alleged herein as grounds for this action have had the impact in this state which Washington tort law reprehends, and therefore said defendants shall be deemed to have submitted themselves to the jurisdiction of the courts of this state within the meaning of RCW 4.28.180 and 4.28.185. IV. GENERAL ALLEGATIONS 4.1. In March of 2011 Mr. Selah received sensitive information concerning defendants’ willful unjustified intent to conspire to bring harm to Mr. Selah's business partnerships, internal and external family, as well as employees of his Washington State Business Brave New World (BNW) and its subsidiaries. 4.2. Defendants intentionally contacted Mr. Selah’s business partnerships to disparage, defame, and cause malicious harm for the purposes of stalking and harassing Mr. Selah, his business Brave New World and its subsidiaries. 4.3 Defendants attempted to intentionally sabotage Mr. Selah’s business partnerships, executive relationships, after Mr. Selah responded immediately with a formal cease and desist letter on March 8” 2011 to Ms. Lindstedt, Mr. Williams, and Mr. Turbak. 44 In March of 2011, Defendants claimed to former and current business partners of Mr. Selah, as well as former and current employees, along with former and current friends and family, that Mr. Selah’s character is that of a fraudulent sociopath, and that they would stop at nothing to see to it that Mr. Selah was incarcerated, 4.5. Mr. Williams and Mr. Turbak, with Ms. Lindstedt’s knowledge and assistance,ed contacted the FBI in Washington State, and in Dayton Ohio to seek fraud damages against Mr. Selah and his businesses, disregarding that there has been never been any business relationship between Plaintiffs and Defendants Williams and Lindstedt. Shyan Selah Federal Way, WA 98023, Complaint -2 Phone 206 a> 10| ML 12 13] ry 15| 16| 1 18 19] 20| 2] 22] 23| 2a 25 4.6 Since that time defendants have from time to time publicly declared, on the internet through email, personal phone calls, etc., that Mr. Selah and BNW owe large sums of money through a decade of business fraud, that Mr. Selah is a crook, and that Mr. Selah’s debt is due to his continual misrepresentation of his business and talents. These attacks are untrue, are still continuing, and have injured Mr. Selah’s reputation and business relationships. 4.7 In March of 2011 Ms. Lindstedt committed corporate espionage. She contacted a former business associate of Brave New World, Ms. Jayme Asao, and told her that she had in her possession corporate financial documents that were in fact the property of Mr. Selah and his company Brave New World. FIRST CAUSE OF ACTION: INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONSHIPS 5.1 Defendants’ said misconduct as described above has damaged plaintiff's relationships in current contracts that would have undoubtedly been carried out without this interference. 5.2. Plaintiff is damaged thereby in an amount to be proved at trial, but estimated by plaintiff at $62,500.00. ‘YI. SECOND CAUSE OF ACTION: INTENTIONAL INTERFERENCE WITH BUSINESS OPPORTUNITY 6.1 Defendants' said misconduct as described above has damaged plaintiff's chances to secure future contracts that would have undoubtedly been entered into without this interference. 6.2. Plaintiff is damaged thereby in an amount to be proved at trial, but estimated by plaintiff at $500,000.00. Yl. THIRD CAUSE OF ACTION: DEFAMATION 7.1 Defendants’ said misconduct as described above unjustly damaged plaintiff's personal and business reputation. 7.2. Plaintiffs are damaged thereby in an amount to be proved at trial, but estimated by plaintiff at $2,000,000.00. ‘VIII. FOURTH CAUSE OF ACTION: CONSPIRACY 8.1 Defendants acted together in furtherance of a plan to damage plaintiff's reputation and business, Shyan Selah Federal Way, WA 98023 ‘Complaint -3 Phone 206

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