Jeffrey S. Amick J.D.

7423 Minnesota,
St. Louis, Mo. 63111

Mr. John Carter., Tradewinds, LLC

2400 S. Jefferson
St. Louis, Mo. 63104
Friday, December 13, 2019
DEMAND LETTER
STATEMENT OF FACTS
John Carter (Defendant herein) is the owner of the Jefferson Underground, which is an event and
luxury residential living venue, located in an enormous warehouse, near Jefferson and Gravois
Streets, in the city of St. Louis. Jeffrey Amick (claimant herein) is the owner of a building
located at 2401 Indiana Avenue, which is directly behind John Carter’s building, and also
borders a parking lot, owned by Tradewinds, LLC, which is a corporate property, under John
Carter’s immediate custody and control.
Claimant bought this building from the homeowner when he was near graduation, as a
graduation present to himself, with the intention of renovating, while he studied for the bar exam.
Shortly after claimant initially bought the building, defendant approached claimant, asking if he
would sell the building. Claimant said he really liked the area because he had lived 3 blocks from
there, for 5 years on McNair street, but if defendant wanted to give him 15k more than what he
had just paid for it, that he would sell it to him.
Defendant refused claimant’s offer, got angry and stormed off and threatened that this wouldn’t
be the last that I heard from him., and good luck with getting anything done, that he has all kinds
of friends in the city and he’d put a stop to all this. Claimant ignored this commentary and
decided to go ahead and move forward with his renovation. Claimant first rented a dumpster to
remove all the old appliances, older household materials and housing fixtures and requested the
dumpster be placed on his property located near his property line bordering his privacy fence,
and whatever easements which may be included. The dumpster was then placed next to
claimant’s building, on a then clean strip of land,which bordered tradewind’s empty dirt lot,
which was then filled with rocks and debris.

Immediately thereafter John Carter called the dumpster company complaining about it’s
placement, and claimant disagreed and stated that we’d have to get a survey to determine the
proper lines., but to avoid the current controversy, he agreed to place it on the street side of his
building. Claimant then proceeded to completely gut the building of anything he couldn’t fix
through his own carpentry and building skills. Due to some of the electric wires and pex

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plumbing lines being damaged, claimant decided that he would replace the wiring and pex lines
also, to improve overall efficiency.
Claimant then brought in new appliances, flooring and building materials so he could advance to
the next stage of his renovation. Shortly thereafter, claimant came to start work one day and
found that his building had been boarded up by the city of st. louis (with no notice) and
condemned because of s structural deficiency and that he would need to have architectural
designs drafted and submitted to the city, along with getting a professional tradesman to file for a
work permit, before any more work could be complete or any entry into the building would be
allowed. Thereafter, he also started to receive a plethora of mail regarding trash and dumping
and other trivial matters and being unnecessarily and vindictively fined, for behaviors, that John
Carter (unbeknownst at the time) was indirectly responsible for, or the cause thereof.
Claimant felt like the City of St. Louis was overreaching and being vindictive, in their
assessment of the structural soundness, since there was very little or minimal structural damage,
if at all, but he decided to go ahead and appease the city and meet their requirements. Claimant
thereafter made an exhaustive search of architects and finally found one, that he could afford.
The architect looked at the joists in question, and stated that the city was likely wrong about the
overall structural integrity of these joists, and that they could probably last another 120 years,
without doing anything, but to appease them, we could sister up 3 boards to the joists, out of the
18 or 20 that were present., in a small portion of the house.

These architectural designs were then drafted, after all the necessary fees were paid. Claimant
then filed for the building permit himself, and after arguing with the inspector about being able
to pull the permit myself, and having to prove I was a union carpenter previously, the inspector
finally, but reluctantly accepted the submittal and granted a 6 month work permit.

Claimant then bought the materials to complete the job and sistered the 3 boards up to the joists,
as per the architectural designs, and approved city permit. While claimant was nearing
completion on working on outside matters that the city had cited him for, a city inspector then
came by, and demanded to look at the completed work, to which claimant agreed. The city
inspector concluded that since screws (which were even stronger and recommended for use)
were used, instead of what the plans called for, nails that we would have to take those down and
replace them with nails and he would also have to sister up 4 more boards, if he wanted it to pass
inspection. Claimant then complied with the exact perimeters of the designs and the new
modifications. Claimant sistered up 4 more boards and got a nail into every spot he could reach
between the joists, with a hammer and nail gun and screwed the rest off and reinforced the joists,
with hangers.
Shortly after this, claimant was injured in a car accident where he suffered a broken neck and
back and had to relearn how to walk again. All work on the building completely stopped at this
point, until claimant started to regain the ability to even walk again. Shortly after getting out of
the hospital, claimant received a phone call from the inspector and claimant relayed the fact of
his accident and the reason for not getting the outside matters addressed, but stated that i would
address the rest of that, but much of the work except the tuck pointing and replacing of 1 window
pane of a 4 pane window were already done, that the boards were already sistered up in the
basement, per the plans as much as could be had with nails and also the extra boards too, along

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with alternate reinforcement. The inspector stated that he knew that already, but now that I’d
have to brick and mortar these joists in, that i had sistered up too, and that he would only grant a
14 day extension on the permit, to complete that.

Claimant agreed with the inspector about this additional requirement and stated that he’d try to
complete that work within the best of his time frame, but that it was gonna be difficult, because
he knew what to do to complete the tuckpointing, but had to rely on other people who either
knew how to do the work, or he could explain it to, because he currently lacked the physical
capacity or financial resources to do it. With assistance, claimant later finished up the tuck
pointing that needed to be completed to the outside of the building and also had brick and
mortared up 5 of the floor joists. During this new period of work, claimant had to replace more
of the windows that were broken when he was in the hospital, remove more debris that had been
illegally dumped, and also had to now replace virtually an entire fence, that was tore down, that
witnesses, attest to seeing defendant do.
After claimant had completed some work one day, he was sitting in the backyard area, relaxing
when an electrician pulled up in a white truck and said it looked like this place is being rehabbed
and asked claimant if he needed any electric work done, and stated if so, that he could pull a
permit, and complete the work. Claimant responded that he was pretty proficient in most
building matters himself, and had drilled the holes for the new lines, but nothing was live,
because he was just gonna pull a homeowner’s permit and install new and up to date outlets and
everything prepped to instal the new wire to the old 100 amp boxes, which I didn’t need a
master or professional electrician to do, and that both of the outside meters were good too, so no
need there.
The electrician then offered to come check out my work and said he’d give me any pointers on
anything I could do, to avoid getting a failed inspection and so I agreed. Claimant then proceeded
to show him the electrical work that was 90% complete and explained how I changed some old
pex line and changed a couple water intake valves, and also showed him the work I had done to
the joists., and then explained that tomorrow, I was going to brick and mortar the remaining
joists, and was picking up 2 house numbers that had fell off the front of the building, but that by
tomorrow afternoon, I’d be calling the inspector to tell him all the outside work was complete,
along with the inside joists. Claimant and the electrician exchanged pleasantries, and then the
electrician gave me his phone number and offered to help, if I ever did have any electrical needs.
The next day claimant and his worker showed up to finish up adding brick and mortar to the
floor joists and less than 10 minutes after arriving, a city inspector pulled up as we were entering
the building and demanded to do his inspection then. Claimant agreed with his demand and
allowed him to enter and after he got done inspecting the joists stated that we were gonna have to
have new architectural designs drafted, because the brick and mortar of the joists , wasn’t in the
designs and wasn’t approved by the city, so claimant would have to file for a new work permit as
well. When claimant objected and said that he was only doing, that which, he was told to do, the
inspector said “rules are rules and I don’t make them, just here to make sure you don’t break
them.”
As the inspector was leaving, he inquired into the status of the plumbing and electrical in the
building, and therefore I showed him what i had done and explained that I was replacing all the
old toilets and sinks and some of the corroded water lines and shut off valves on the plumbing
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and that I was leaving the old 100 amp boxes and outdoor meters in, because they were both
good, but that I was preparing to replace the outlets and some fixtures and their wire, which
would eventually be, being ran into the electric box, but that each were not completely done
because I needed to pull a homeowners permit for the electric, but wanted to research whether
i’d even need a plumbing permit, because i figured that I wouldn’t likely need it. for the little bit
of plumbing work I was doing, but would pull a homeowner’s permit for that as well , if
necessary. The inspector responded that he didn’t think it’d be necessary to pull a homeowner’s
permit for the plumbing, but would for the electric and to just keep it like it was for now. because
that was fine.
The inspector then complimented me on my knowledge, the work completed and my building
skills and said everything should be alright as soon as I got the new architectural designs
submitted, and approved by the city, that then the new work permit would issue. He’d then come
inspect it from there, and that it should pass without a problem and that we could work on the
rest from there. The inspector advised claimant that he couldn’t be at the house anymore, without
a valid work permit thou, and he had to immediately leave now, so claimant and his worker
agreed and left, saying that I would speak with my architect later that day, and would have these
new and extra measures completed as well, over the next couple of days, and would file a
homeowner’s permit for the electric, from there. Claimant also asked the inspector if he could
make a quick inspection of the exterior premises, so he would quit citing me for matters that
have already been fixed, and he said he would do it later on today, because he didn’t have that
paperwork with him.
Approximately 2-3 hours later claimant returned to his home to take pictures for the architect, of
the brick and mortar job on the floor joists, but upon arrival, he noticed a black impala with a
very large african american male sitting in the driver’s seat, wearing a bulletproof vest, tactical
gear, and bearing some sort of insignia on a vest, he was also wearing. When claimant arrived at
the rear of the home to gain entry, he notices the city inspector sitting in his backyard, who
immediately says I thought I told you not to be here. Claimant responded that his architect
wanted pictures of what additional matters had been completed, so he could include it in his new
designs. The inspector stated that’s no longer applicable now, because I’m placing a stop work
order on you, while smiling, with a huge grin on his face. He said that this prohibits any work
whatsoever from being completed, until an electric permit is pulled. The inspector stated that he
didn’t care what I said about “the breaker panel and meter base still being good, or that I was just
running new wire and outlets” or that “a homeowner’s permit is viable or covers you for that.”
The inspector then said that it’s been put into the system, to where you’re gonna need a
professional electrician to redo everything you’ve already done, and replace it. That is now going
to cost you probably about 10-15k for that, and probably another 7.5-10k for plumbing. He then
said that, unless I had 20-25k more to dump into this dump, that I should just consider selling it
and then said that “this guy, (pointing to John Carter’s building,) will buy it. So if I were you I’d
do it, because I don’t think you’re ever gonna be able to get this place up to code and/ or me to
get it to pass inspection either, even if you can get the permits, you’re gonna still lose and should
cut your losses, while you still can.” The inspector then got up out of my lawn chair and
proceeded to staple a stop work order on my door, and told me that if I attempted to go into my
house, to do anything other than getting my tools/materials, out of here that may be still in there,
that the big mean looking guy sitting out front, or someone like him, would be carrying me off to
jail and that they were known to get very aggressive, mean, and many times violent, in their

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arrests and that I would then have to bond out, and that after that, I would be facing criminal
charges.
From that point forward, claimant rarely went to his house, but for the limited purpose of
retrieving tools, maintaining the exterior, or attempting to take corrective measures to keep
burglars out, but was even accosted by the police on 4 different occasions thereafter, and
threatened with arrest in those limited appearances. Furthermore, 3 days after the stop work order
was placed on me, I went to my house and noticed the same electrician’s truck, who had come
over offering me work, was actually working for John Carter doing electric work instead, and
claimant then believed he was spying for John Carter, but acting helpful. That when his spy
reported claimant’s status, to John Carter, defendant then reported that status, to the city
inspector. The inspector then correspondingly fabricates a stop work order to prohibit the work,
that the law permitted claimant to do. Under this defacto discrimination and vindictiveness,
claimant is threatened with going to jail on 4 different occasions and on the last occasion even
almost had his brand new door (he had to replace because of burglars, which was now
reinforced) kicked in and the door, frame, and reinforcement plates, were severely damaged in
this process, and the door still won’t latch properly all the way because of it, and the police were
the culprits.
On this occasion claimant was moving materials to his basement because he was waiting on a
real estate investor to do a walkthrough, and wanted the space to be as clear and open as
possible, to promote the sale of his place (that he did not initially want to sell) out of my now
fear of the city inspector, John Carter, and all of his other city officials. When I opened the door
there were three officers present and they told me to come out and put my hands behind my back
and they then placed me in handcuffs. When they asked what I was doing I said that I was
waiting to see a real estate agent that I had an appointment with in 20 minutes, whose interested
in buying my house. They then asked why I was in nothing , but my boxer shorts, I said because
it was hot and I wanted to be able to wipe seat and throw on a clean shirt and pants on and not be
all sweaty when the real estate investor, got here.
At the time I felt humiliated because many of my neighbors were on their porches and balconies
and on the sidewalk, wondering why the cops almost beat in my door and now had me in cuffs
on my own porch, for doing nothing in my own house. Therefore, I then asked if they could just
take me to jail, or take me out of the cuffs and let me go back inside so we could avoid any
further humility because I didn’t want to, nor did I have to, stand out here virtually naked. They
agreed , but wouldn’t take me out of cuffs or go back inside alone and said we’re going inside to
make sure you’re not hiding nothing and if you don’t agree with that you’re going to jail and
we’re searching to make sure anyways .
Then 2 officers walked right into my house and started to search every crevice of it, while the
other 1 proceeded to threaten to take me to jail unless I gave them a good reason not to, or some
information about drug activity. I then told them that I had no idea about any drugs that i
consumed medical marijuana because of my injuries, but he accused me of doing more, but i
vehemently denied it, and then instead, he wanted to know where I got my medical marijuana
from and threatened to take me to jail, if I didn’t tell him. I stated that if he wanted to take me to
jail he could, but i was the building’s owner and wasn’t doing anything wrong and had a
veritable appointment set up with a real estate investor, that I could call right then and there, to
confirm.

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The officer then said that’s fine, but if you don’t cooperate or if we find anything in your house,
you will be going to jail. After a thorough search of my premises, the officers uncovered no
drugs or illicit activity, and then decided they would leave and not take me to jail, for refusing to
provide any information, but said if they caught me over there anytime for anything else, other
than selling my house, they would would take me to jail. The officers then left my property,
which was approximately 2-5 minutes after my potential buyer had arrived, and he was sitting in
his car watching. Claimant believes that John Carter either knew of the scheduled showing
through a possible straw buyer, who he sent in an attempt to devalue his home, or maybe he even
possibly sensed that claimant’s cleanup signified something of importance,, that he believed he
should quash, and correspondingly, he either had these three police officers on standby or there,
within 15 minutes, when in contrast, even many 911, and other response calls, for more
significant matters are commonly ignored, or responded to hours later.
The backside of the Jefferson Underground, faces the back of claimant’s building, which the
back constitutes the access point into claimant’s building, and therefore defendant would stand in
his looking glass back windows, and has just diligently watched every move claimant has made,
since he purchased the property.
Defendant was originally told that he could buy the property, the day claimant took possession of
the property, with the minimal profit amount (previously referenced sum) attached to it, and he
got angered at this proposition. Afterwards, claimant rented a dumpster, labored himself, hired
laborers, and proceeded with the idea he envisioned of a primary gut to the building, and started
purchasing and bringing the materials over, necessary to complete the renovation. As stated
previously, claimant also possessed all the knowledge and skills necessary to complete every
facet of the work. After this work was completed and the renovation began to take a clearer
form, it is believed John Carter, seen these progressions and felt the characteristics could be
present in claimant, to complete the task at hand.
Claimant believes this is why defendant came over again (after the initial offer and dumpster
dispute) later to talk to claimant about what his ideas were, moving forward. Claimant then
talked about his current projects inside the home and workmanship involved. Defendant stated
that doing all that work was gonna cost claimant a hundred grand to hire contractors to complete
and do right and he then asked claimant if he had that kind of money to spend and claimant
replied that he did not. Claimant then advised defendant, that he had spent many years doing
carpentry and concrete work, but that he had also worked as a Master Plumber’s assistant before
too, and did a lot of HVAC work also, and knew the home basics of electric, because of all that
and that I could pretty much do anything, that needs to be done in a house. Defendant seemed
impressed, but stated that he knew all there was to know about rehabbing and that he had
rehabbed blues city deli, and many more places, and that he was a master rehabber. Claimant
joked that he wasn’t a master rehabber or anything, and even offered that this was his first home
purchase, but joked that he felt like “anything short of foundational issues or structural damage,
that I’d need to do a major renovation to the foundation or structure upon, and need an engineer
or architect to draft design plans for, that I should be good for anything short of that, based on
everything I’ve seen, inspected, and have intimate knowledge of, in my own construction related
pursuits.”
At this point John Carter, cut me off and stated I’m just gonna stop ya right there ok, I forgot
more than you know about rehabbing, I’ll just say that, and then started laughing hysterically, in

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a socially awkward (laughing) pattern, that actually made claimant not say anything, because he
needed to pause to consider the sanctity of this seemingly cackled manner like laugh that
defendant just emanated, and to also to gather my bewildered thoughts and to adjust, my likely
confused appearance on my face, as well. Defendant then stated that he had thought about my
original offer of $40k, 20k per side (on the day I took possession of the bldg) and was ready to
accept it,/ and that he could sign a check tomorrow. At which time claimant relayed that he had
already completed a portion of the work necessary for the renovation and had exerted, time,
energy, efforts and resources towards these ends., so would now need an additional 15- up to
20k, than was previously mentioned, (and would also include all the materials I had, which was
about 75% of everything needed, at the time, to complete renovation) but that since he was a lot
wealthier, and had more experience than me, that this little bit more money now, shouldn’t be a
major hurdle for him. Defendant again got angry and mad, at this offer and said that I was just a
dumb construction worker, and still young to this rehabbing business, and that if I knew about
life and rehabbing, like he did, that I should just take the money and walk away from this whole
thing and well if you don’t, you’re gonna wish u had, because I tried to be nice about all this, but
if you don’t take my offer, right here and now, this is gonna turn into hardball, and you’re gonna
strike out.
Claimant stated that he didn’t know what he was talking about, but that he definitely wouldn’t
take anything less than 55k now, but was really thinking more like 58-60k. He explained that the
minimal market value upon renovation of the duplex would be 125-up to150k per side and even
at 60, that would be 30 k per side, and that left plenty of meat on the bone for him. John Carter
then stormed off, back over to this property, while yelling I tried to tell ya, and don’t say I didn’t
tell ya. Claimant, initially dismissed these rants, and decided that while he didn’t know his
neighbor all that well, that he settled on the fact, that he seemed to have a quirky disposition and
definitely was very unbecoming, in any type of professional negotiations., thus far.
The next day when claimant and some coworkers were on lunch, an inspector came by and
announced himself to a worker still at the house , and said he was there to do a routine inspection
to check on our progress and one of the workers allowed entry for that purpose. After the
inspector was done, the worker asked him whether there were any issues that he should tell the
homeowner about, when he got back and he stated no. When I got back from lunch and my
worker had told me about what had happened, I immediately thought of the defendant, but
initially shrugged it off. We completed work that day, and when we returned the next, we noticed
that the city had boarded up the house and condemned it, and would not permit entry, until this
newly discovered and extremely coincidental, exaggerated “structural issue,” was completely
addressed. After claimant gets architectural designs drafted, and a new work permit issued,
claimant starts to work on his building and him and his workers are threatened by John Carter
with going to jail, for simply working on the building, on 3 different occasions, and the police
come to the building at 2 different times, during this brief work period, no one ever went to jail
or was cited for any wrongdoing, but rather the police had to explain to defendant, on each
occasion, that it was lawful a work order, and operation.
Claimant also appropriated a lot of other work into the building during his time, while he
reinforced the joists, per the city approved plans. Claimant tore out the floors and put new
backboard in places, he wanted to put marble in at, and also put new floors in other areas, and
started painting the interior and lower exterior of the building. John Carter, noticing the
improvements, approached claimant again and said he would now give him a check for the last

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price he offered and would even pay 60k for the extra stuff I previously did, and had now
completed too., Mr. Amick refused this amount, and stated he wasn’t even interested in selling it
now, at this point, not only because he wasn’t sure if defendant wasn’t indirectly the cause of his
condemnation, but that he really liked the area, despite his presence, but if he did sell it, it would
be at least 20k more than the last price he was told because I had did more since then too, and
would be in the very least, 75k range, but likely 80k. John Carter, in a somewhat predicable
manner, got enraged at this proposition/offer, and stormed off and said you should’ve learned the
first time and stated, you’re gonna regret this decision too. Shortly after this claimant was in a
car accident and suffered severe injuries. All work on the home temporarily subsided then.
Approximately 3-4 months later , after claimant was released from the hospital and was able to
gain limited mobility, he started to go his building again, and had friends that he guided, do the
work on the exterior, he fixed a chimney and some other tuck pointing around the house,
replaced a fence that John Carter was personally witnessed tearing down and some more interior
work consisting of replacing additional windows which were witnessed being busted, by John
Carter as well. Many other renovations occurred during this period, and claimant was also visited
personally by Alderman Dan Gunther, and Department of Public Safety official Barbara Potts,
who came over to his house on multiple occasions, Ms. Potts came to his residence 3 times and
Mr. Guenther twice, each encouraging him to just give up on this project ,and to just accept
whatever John Carter is willing to give you., because it’s likely the best you’re gonna get. That
you were in that accident, and are probably hurting for money, and I’m sure could use it, and I’d
take it before he changes his mind, or something else happens.
Each time, Mr. Amick was polite to the city officials, but stated that he was not interested in
selling his property at this point, that all the exterior violations were almost corrected and also
the inspector’s revised work plans for the basement joists would be completed soon too and that I
would file my homeowner’s permits for the electric and be up to code after that, but that I might
consider selling, after it was fully renovated, because that would allow me to make a substantial
amount of money, based on the fair market value of the property. Through claimant’s
conversation, with Barb Potts, claimant had revealed that he planned to do a air bnb out of both
sides of the building, and eventually the basement too, and that he had worked out a contract
with Elders’ antique furniture, on Cherokee street. Barb Potts stated that she knew that location,
liked the people who ran the store, and their furniture, and that, that was a good idea.
At this point in time, claimant had been going through tragic depression over not being given the
ability or means, to reside in his own home , along with John Carter’s and the City’s conduct,
since his accident. Claimant couldn’t work at this point, so he was homeless also, so he was
basically focusing all his time , resources, energy, and efforts on renovating his house, to take his
mind off things, while working on his own place to live, trying to figure out a new way to
generate revenue, and still maintaining recovering, in his own physical capacities, from the
accident, as well. For the most part, claimant was couch surfing, because he couldn’t live in his
own home and many times when he couldn’t find somewhere to sleep, he’d find a place to park
and sleep in his car. On one of these mornings, 3 days before the stop work order was placed on
claimant’s home, he was sleeping in his car and waiting for his tuck pointer helper, to arrive
between 8;30-9, when he awoke to a tapping sound on the car window. Initially startled awoke,
claimant looked to see John Carter’s odd looking face and grin, while half waving his arm and
hand at me in a crooked fashion, and was relieved to see it was him, and not a cop or robber, but
sad at the same time, since I knew what this conversation would be about.

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After I rolled down the window, he said that he seen that I was over here still doing my rehab,
and that I had done the tuck pointing, just got done doing some roof work, replaced the privacy
fence , among other things, and that it was getting ok looking, but that I should just really
consider selling it to him again, and to just tell him what I’d need to just walk away from the
home, at this point, and he’d cut a check and I could let the big boys and professionals, take it
over from here. Claimant stated that he really wasn’t interested in selling the property still,
because he wanted his place to live in, and loved the area, but stated he was really hurting for
money, so if he wanted to give claimant 100k, (50k per side) which was only 20k more than the
last offer claimant made to him, and that was previous to the major concrete and tuck pointing
work, the new fence, along with now having 100% of the material needed to finish the
renovation. John Carter then claimed defendant was way out of the ballpark, and that the most
he’d go was my last offer of 80k and I should just take it, because nobody was going to give me
more, and if I didn’t accept it, that he’d make sure I have to sell it or would just lose it this time.
While claimant was upset and frustrated over Mr. Carter’s negotiation skills and tactics, he just
maintained composure and his disposition, and firmly stated the that the matrix, and fair market
value of the home, based on the property values in the area, demanded more than that, and
especially now that i completed the extra work, and have more materials, and that 100k was my
asking price , but he was more than welcome to refuse my offer, but I wasn’t budging on my
price. John Carter then stormed off, walking in an angry cockeyed, zigzagging fashion with his
hands balled up and shaking his fists and arms, uttering this ain’t the last of me and this won’t be
the last he hears from me, a hundred thousand dollars, is he out of his mind, he then jumped over
the little step of his iron gate and slammed it shut and entered his building. Claimant ended up
working that entire day and the next, which was when John Carter’s employee or agent, came
over and wanted to inquire into the need for electrical services, and then the inspector showed up
the next morning and issued his full stop work order.
As previously referenced, when the inspector issued his order to stop any and all work, until an
electric and plumbing permit were pulled, along with their being the implied threat of violence or
harm upon arrest, along with the criminal penalties, sanctions and also other collateral
consequences, claimant stopped all activity at his home. Claimant also didn’t have the financial
resources to complete the job, so he reached out to John Carter, and said that he would accept
85k, which was only 5k more than what he said, he’d pay before. Claimant waited and waited to
hear something back from John Carter, but instead claimant received 4 visits from the police
instead , had more things dumped on his property illegally, received 2 notice violations from the
city for cars that were parked on his property, that they threatened to have towed, if they weren’t
removed within 5 days, and on the 4th day of the first 5 day notice, claimant had all the windows
busted out of one of the vehicles that night, along with the plates being stolen and claimant was
already planning it’s removal to a friend’s house, the next day. Claimant had to end up selling
that vehicle to a junkyard for 100 and the other for 100 too, because claimant couldn’t stand the
thought of the city taking something off his property too, and him not getting paid at least
something for it. Claimant had originally paid 1500 and 2000 respectively, for each vehicle thou,
but had to sell each for pennies on the dollar, in comparison. Claimant also learned at about this
time, that city official Barb Potts had also defamed him by going to meet the owner of Elders
Antique Furniture, and other employees, and falsely relaying that claimant was the target of a
major federal criminal investigation at 2401 Indiana. That the home was under 24 hour, FBI
surveillance, and that any furniture could be the subject of an asset forfeiture proceeding, and a
criminal investigation, into their own affairs as well. Thereafter, claimant was contacted by a

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member of the Elders’ Antique Furniture team, and notified that a contingency pay arrangement
on their furniture , for use in the air bnb, was no longer possible, and only later did claimant find
out, through a third party, the real reasons why.
After claimant never had a response from John Carter, about his 85k offer, and then started
feeling harassed by the city police, and vehicle enforcement too, on top of the rest of the city
officials, and now the professional business community too., Claimant finally decided to let John
Carter know how he now felt about him. In the wake of this new animosity, that he was
seemingly spreading around, all the time, and claimant decided to finally tell him that “he was
the last person on earth that he would sell the property to, and that if he did buy it, it would be
from someone other than me, and that they would ensure they’re making the money on the rehab,
that you could’ve easily made as well, if you’d of accepted any 1, of my 4 offers, which all of
them were more than reasonable , at each offering point, in time..”
Thereafter, since claimant was in a bind of sorts, he decided he was going to sell his residence,
and listed it for 105k on zillow, which was still significantly lower than the fair market value.
Claimant got a plethora of calls from interested buyers, but found they were all looking for a 10-
15k price drop, so claimant decided that he would drop the price significantly down, which he
did and ended up settling on 88k as his bottom dollar, which was around the same bottom dollar
price, last given to John Carter previously. After an assortment of different perspective buyers
had presented themselves, a buyer who claimed to be a real estate investor, seemed extremely
adamant about the purchase, and said that my bottom dollar of the, 85k, seemed like a steal and
that he wanted to come by and look at it, and would sign a contract for sale, right then if so.
Claimant agreed to the meet for the showing, and arrived early that day, and that was the day , he
was being released from cuffs, and the cops were walking out, as the investor pulled up, and my
neighbors were still standing outside also. The investor then asked me if I was Jeff, and what was
the cops being there, all about? I explained that it was because of my neighbor consistently
calling them on me, anytime i come over here, and explained a brief history of our disputes, and
my own life, which lead up to this point. In turn the investor told me that he really liked the
property, it’s location., it’s commercial and residential zoning factor and the profit margin, that
he could stand to make on this deal. He then stated, the neighbor seemed like he’d be a big
problem for him, and his prospective renters thou, and that this was a risk that he didn’t
encounter, at first sight. He said it was not a risk that he was willing to take on, without a
significant price drop, to potentially cover the likely legal costs of having to either fight with the
city, or John Carter, or both. He said that he would agree to purchase it for 75k though, and just
deal with the pesky neighbor, and city influences, and whatever nuances they created, with that
money. Claimant thought about it and didn’t really want to accept this lower amount, but
remembered the fact that he had just been released from handcuffs, and thought that if he did sell
it now, he could just walk away, free and clear and try not to think about John Carter, or city
inspectors, alderman, public safety , or police, anymore and that he could just then, put all this
behind him, and move on to something else. After the signing of the contract for the sale of this
property, claimant took it off the market, and recorded the 75k sale price and was then was
waiting for the closing to occur in 21 days, but claimant’s investor called 3 days after signing the
contract, stating he could not be wrapped up a year or more, fighting with the city, and John
Carter, for this place to get legally up to code, which is what he feared would happen, from what
I told him, and that he was looking for a quick flip instead, and was now backing out of the

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contract. Since claimant felt as if the sale price was too low, now anyways and was having
second thoughts, he agreed and decided to not pursue any litigation over a mutually held feeling.
Thereafter, claimant tried to re-list his property on the market, but now noticed that the estimated
value of his home, had dropped nearly 100k since he had initially listed the sale price of his
home, which had now been converted into, its actual value. Not happy with this new estimated
value, claimant decided to list his home for a higher price than its estimated value, and to take his
chances on the open market, because he figured that savvy buyers would do their due diligence
in research, and would know the actual value of his property. The momentum of online views of
the property significantly declined, after the house was re-listed on the market. For
approximately 2 months the market climate did not change, and claimant had already dropped
the selling price of the home to its lowest value, that he felt comfortable in selling. Claimant then
started researching possible bank loan options, to determine whether this could be available and
came across an FHA renovation loan, that seemed possible. After researching the matter more
extensively, claimant decided against this option, and decided instead to go with a home equity
line of credit, through the New Frontier Bank, located at 1771 Zumbehl Road, St. Charles, Mo.
63303. Through the course of the application process, it was revealed that an appraisal would
need to be conducted, which after this procedure was explained, it became clear that getting an
inspection/appraisal done at 2401 Indiana, would be impossible without having John Carter, City
Officials, or the police getting involved. After claimant realized that he would be facing an uphill
battle in the appraisal/inspection, aspect of the loan process, and wouldn’t likely win in this
forum either, he decided that his best course of action, would be to find a way to get a loan in
secret.
After an exhaustive search, claimant finally found a private lender, who offered a “hard money”
loan instead, which was secured through a promissory note. At this point, claimant finally felt
like he was gonna be able to do something. At this point, claimant had been back and forth with
city inspectors, supervisors, and other officials, arguing that he didn’t need a plumbing permit for
replacing a sink, and that the work envisioned in my electrical needs for the home, was all within
the purview of a homeowner’s permit. Through numerous, and countless attempts he was never
successful in negotiating with any city officials, in this matter, or getting his initial building
permit extended, or modified either. At about this same time, claimant noticed that John Carter
must have gotten approved for the building of his parking lot thou, bordering on claimant’s
property line, because not only was he building, but he had extended past his own property line,
while even exceeding any residential easements that were necessarily allocated, and noticed that
the concrete perimeter of the parking lot, was likely less than 6 inches from his house, and
wouldn’t even allow claimant to open his basement windows, or his gate on his newly
constructed privacy fence, along with there being no easements to maintain the side of his
building, facing parking lot side, or an easement for his driveway located in the rear, on the same
side. Claimant has pictures, from 11/20/19, which depict the intentional and obvious, improper
conversion of land, since even if only a minimal 3 foot easement was allocated (which there was
likely more), for this residential facility, defendant would still be 2 1/2 ft. over.
Claimant decided that it was small potatoes at the time, and decided that he would just see a
resolution in that matter , after getting his electric on, to allow further renovation to occur, and
claimant finally felt good about his prospects moving forward, and knew that by first pulling an
electric permit, it would be the springboard to allow the fountain of renovation he was looking
for, to again prosper. Claimant figured that his best course of action would be to find an

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independent electrician, free of significant company involvement, that could complete the work,
semi-covertly because he could not take any risks, with having any of the aforementioned
entities getting involved and damaging this relationship too. Claimant finally located an
individual who said that he could do the work and pull the permit and could do an estimate after
hours, and would come by after he got off of work. After looking at the work to be completed,
the electrician and claimant settled on a price for labor, materials, and pulling the permit,
claimant then paid him and the electrician stated that with the materials that were present, he
could start some preliminary stuff immediately, and if I wanted to run to the hardware store, for
what we didn’t have on hand, that he could get together what we did have, and would wait to
finish the rest, but could pull a permit in the morning, before he finished up, the next evening,
and that we should be able to call ameren the following day, and have at least temporary service
started, to allow completion of the construction, in the building. Claimant agreed and then ran to
the Home Depot Warehouse on Kingshighway, and when he returned, he was advised that John
Carter, had came over to clamant’s property, while he went to the hardware store, and had told
my electrician, that he couldn’t be on my property and that he was going to call the cops and
possibly use force, if the electrician did not “get in his little fancy electric truck, and get the fuck
out of here.” The electrician stated that he had gained permission from the homeowner himself to
be on the property, to inspect the job site and make temporary accommodations for future work.,
but if he had legal authority to make hime leave he would, but he would not if he didn’t and then
then the electrician asked him, who he was. Defendant replied that he was John Carter, one of the
biggest rehabbers and business owners in St. Louis and that claimant’s electrician didn’t know
who he was messing with, that he knew all kinds of business owners and would get him fired
from his job, blackballed and he would lose his ability to ever pull permits again, in the city of
St. Louis, it would be permanently revoked.
Claimant’s electrician felt very threatened, with John Carter at this point, and decided that he
would just stop what he was doing and wait for the homeowner/claimant to return. The
electrician then revealed that he was just an “easy going guy” and wasn’t looking for any
problems, but feared that he would run into some, if he continued to work on this project, and he
told claimant that he would have to think about what to do from here, but would still get the
permit for him and possibly do the work to get you up to temporary service, but that he might try
and find others to do the rest of the work, because he wasn’t trying to get arrested, physically
hurt, fired from his job and definitely not black balled, in his industry, moving forward. The
electrician stated that he would think overnight, about what the best course of action for him
would be, and that he’d get back with me in the morning or early afternoon, but that he was
already considering just hiring a subcontractor to do his labor., so he didn’t have to return to the
residence, or very little if he did.
The very next day, defendant, started an email conversation, (from the email address of
johncarter987@icloud.com) , with the owner of Southwestern Electric Company, (3838
Broadway, St. Louis, Mo. 63118) Thomas E. Frisella,( tom-e@sweco1948.com ). Wherein, he
falsely accused claimant’s electrician of threatening/offering violence to him, by “hitting him in
the head with a hammer”, if he didn’t “kick rocks” and “get the fuck outta here”. Furthermore, he
falsely accused claimant, of offering harm on this same night, and at about the same time, when
claimant wasn’t even at the location, and only was briefly there when he returned and arrived,
and never even seen John Carter on this night, which is verifiable by claimant’s riding
companion at the time, a 36 year old, single white female, with no criminal record, and 2 of his

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neighbors, a 66 year single, black female, her adult son, and his mother’s 58 year old, single
black male friend.
At 12:58 PM, on 11/26/19, Mr. Frisella, replied to John Carter’s email, by stating that his
employee had been reprimanded (even though the allegations were false) and that any of his
employees, moving forward on this project, would be professional, at all times, from here on out
and correspondingly apologized for his employee’s allegedly improper conduct. At 1:26 PM, on
11/26/19, John Carter replies that “THIS PROPERTY OWNER IS A KNOWN DRUG
TRAFFICKER, AND DESTROYING THIS NEIGHBORHOOD. YOU SHOULD VET WORK
SO YOU DO NOT SUPPORT ORGANIZED CRIME.” John Carter then sent numerous other
emails, after this point, all trying to dissuade Mr. Frisella, from doing any business with Mr.
Amick, and even then threatened him with criminal prosecution, for aiding and abetting,
organized crime, if he accepted any monies, from Mr. Amick, for doing any electrical work, at
all. After Mr. Amick learned these new facts, he decided he would finally have to pursue legal
claims of relief, from defendant, because of the egregious conduct, and there appeared to be “no
end in sight”. In addition, that Mr. Carter’s conduct was reprehensible in the past, and likely
would be in the future too. Claimant is refusing to continue his status quo of being bullied by
John Carter, and all the other city officials. This set of facts, forms the basis of the legal claims
depicted below, against defendant, and the other named individuals therein.
LEGAL CLAIMS, AND DAMAGE REQUEST, FOR OUT OF COURT SETTLEMENT
FEDERAL JURISDICTIONAL STATEMENT

DIVERSITY JURISDICTION
Pursuant to U.S. Constitution Article III, section 2, the U.S. Federal District Courts have subject
matter jurisdiction, to hear cases between “citizens of different states”., There is diversity present
between the litigants, (Mr. Amick is from St. Louis, Mo. and John Carter’s domicile is in another
state.) therefore, complete Strawbridge diversity, is present in this cause, see Strawbridge V
Curtiss, 7 U.S. 267 (1806)., and under 28 U.S.C. section 1332 (a), the amount in controversy is
over $75,000.00, and aggregation of damages, in the underlying claims, is proper. Pursuant to 28
U.S.C. section 1391(b)(2), venue in this matter would be proper in the United States District
Court for the Eastern District of Missouri, on the ground that “a substantial part of the events or
omissions giving rising to the claim occurred there.” Furthermore, pursuant to the Rules of
Decisions Act, 28 U.S.C section 1652, and the Rules Enabling Act, 28 U.S.C. section 2072, the
Federal Courts have the authority and power, to determine the rights and liabilities of diversity
litigant’s claims, based on their state statutory, or common law rights. see also Eerie Railroad v.
Tompkins, 304 U.S. 64 (1938)
ARISING UNDER, FEDERAL SUBJECT MATTER JURISDICTION
Claimant has conspiracy claims against defendant(s), asserting that under a concert of action
theory, they violated sections 42 U.S.C. section 3604 (b),(d),(e), (f)(1)(A), (f)(2)(A), and
(f)(3)(B), along with violations to his Civil Rights, by those acting under color of state law, and
are directly liable or liable under a cat’s paw or a concert of action, theory of liability, and are
claims actionable under 42 U.S.C. section 1983.

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LEGAL CLAIMS GIVING RISE TO REQUESTS FOR MONETARY RELIEF, AND A
CORRESPONDING RELEASE OF LIABILITY ON CLAIMS, UPON RECEIPT
I) A. DEFAMATION Libel, John Carter’s Defamatory emails to Tom Frisella.
John Carter’s emails to Tom Frisella on 11/26/19 and also those in support of his false,
discriminatory, and derogatory social categorization thereafter, constituted a clear case of
defamation.
All of the elements, as defined under Missouri law, to support the action, are present, and met in
this cause. The elements of a defamation claim, are: 1) publication, 2) of a defamatory statement,
3) that identifies the plaintiff, 4) that is false, 5) that is published with the requisite degree of
fault, and 6) damages the plaintiff's reputation.” Overcast v. Billings Mut. Ins. Co., 11 S.W.3d
62, 70 (Mo. banc 2000). 1) Emailing the owner of the electric company constituted a publication,
2) the statement was defamatory since it categorized claimant as one of the worst members of
societies social context, and threatened the owner with criminal liability, for even doing any
current, or future business with him.
3) The email clearly referenced Mr. Amick, since it identified the homeowner as the known Drug
Trafficker and member of Organized crime. Therefrom, even if the owner of the company did
not know, who the owner of 2401 Indiana was, with one phone call or a few computer strokes,
he could determine the owner of the property, in which his company was pulling the permit for,
4) The publication was false, since claimant has never been convicted of being a drug trafficker
or a member of organized crime. 5) Defendant intentionally committed his acts to 6) damage
claimants reputation in the social and business communities and also he caused breach in the
contract dictates, that he previously had in place, with his electrician. Furthermore, since the
defamation was authored with a malicious intent to harm, underlying the act, this makes punitive
damages available in this matter, and would be in excess to any compensatory damages, which
are available for the same conduct. Punitive damages are geared to punish the defendant for their
outrageous conduct, to teach them a lesson and to also deter others from committing other
similar, gross acts in the future.
Furthermore, from the face of the complaint, it does not appear any valid defense exists for the
Defendant’s conduct, and therefore the facts in the pleading alone, would survive a F.R.C.P.
12(b)(6) motion, especially after discovery proceedings were conducted.
“In a libel action a motion to dismiss for failure to state a cause of action is solely a test of the
adequacy of the plaintiff’s petition. Nazeri v. Missouri Valley College, 860 S.W.2d 303, 306
(Mo. banc 1993). It assumes all of plaintiff’s averments are true, and liberally grants to plaintiff
all reasonable inferences therefrom. Id. The first standard requires that the alleged defamatory
words “must be stripped of any pleaded innuendo … and construed in their most innocent
sense.” Id. The second standard requires that the words “must be considered in context, giving
them their plain and ordinarily understood meaning.” Id. That is, the words “are to be taken in
the sense which is most obvious and natural and according to the ideas they are calculated to
convey to those to whom they are addressed.” Id. The court in Nazeri reversed the dismissal
entered by the trial court there, holding that an objective reading of the alleged defamatory
statement “simply does not allow these words an innocent sense.”Id. at p. 331-32.

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The same analogy applies here. First there is no innocent sense, that can be gathered from any of
these defamatory words, and secondly under their obvious and natural meaning, John Carter was
calling Mr. Amick a Drug Trafficker, and member of Organized Crime, and the idea defendant
was attempting to convey, to Mr. Frisella, was that he couldn’t do business with Mr. Amick, if he
wanted to remain free from criminal implications, and a lower estimation in the social and
business community, and it was also geared to convey claimant as one of the lowest forms of
life, in the community to add extra harm and humiliation.
In addition, it would appear from the pleadings that claimant could also likely survive a summary
judgment motion in this matter, and in either context, an in court settlement or at trial, the
compensatory damages requested currently, are likely to be at least three times more, if litigation
is sought, because of the renovation value of the home, after the electric could be turned on, and
the work completed. In addition, due to the seriousness, and extremely alarming misconduct,
involved in this case, claimant is likely to seek 4 times the amount of compensatory damages, in
punitive damages.
Count I) B. Slander, Cat’s Paw or Concert of Action, Theory of Defendant Carter’s Liability, for
Barb Potts’, slanderous and defamatory comments, to the owner of Elders’ Antique Furniture.
Claimant came into the knowledge that city official Barb Potts had defamed him, by going to
meet the owner of Elders’ Antique Furniture, and other employees, and falsely relayed that
claimant was the target of a major federal criminal investigation, at 2401 Indiana. That the home
was under 24 hour, FBI surveillance, and that any furniture given to him on a contingency
contract basis, (as was previously agreed upon, and Ms. Potts had knowledge of) could be the
subject of an asset forfeiture proceeding, and a criminal investigation into their own affairs as
well. Thereafter, claimant was contacted by a member of the Elders’ Antique Furniture team, and
notified that a contingency pay arrangement on their furniture , for use in the air bnb, was no
longer possible, and only later did claimant find out, through a third party, the real reasons why.
This conduct meets the elements of an actionable claim for defamation, announced under the
same legal authority, as that announced in the count above. Since it was likely initiated at the
behest of defendant Carter, and while not executed directly by him, he had still caused a
significant amount of damages to his reputation and lowered his standing in the community
because of it. Claimant asserts defendant’s liability under a conspiracy, cat’s paw, or acting in
concert theory of liability.
Claimants Current Agreement for Out of Court Settlement on Counts I) A. and I) B.
Count I) A. Libel, John Carter’s defamatory emails to Tom Frisella., can be settled out of court
for $50,000.00.
Count I) B. Slander, by Barb Potts to Elder’s owner, at the behest of John Carter, sought under a
joint and severable theory of liability/recovery at 50% fault of $50,000.00 is $25,000. This will
satisfy John Carter’s legal liability portion, on Count I), B of their joint liability, on this claim.
Therefore, in total, claimant is seeking $75,000.00, to resolve counts IA) and 1B) in an out of
court settlement.
Similar Claim, Under Count I for Recovery, if Litigation is Deemed Necessary

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As an alternate or supplemental claim, if litigation is sought only, claimant is prepared to argue
that defendant’s conduct, under this claim, also constituted an actionable claim in tort, for:
FALSE LIGHT INVASION OF PRIVACY
The elements of the tort of false light invasion of privacy as follows: One who gives publicity to
a matter concerning another that places the other before the public in a false light is subject to
liability to the other for invasion of his privacy, if (a) the false light in which the other was
placed would be highly offensive to a reasonable person, and (b) the actor had knowledge of or
acted in reckless disregard as to the falsity of the publicized matter and the false light in which
the other would be placed. Section 652(E) of the Restatement (Second) of Torts.
Under these circumstances, John Carter acted with knowledge that the false light would be
highly offensive to any reasonable person, especially to claimant under these circumstances and
because it was completely false, and even went against everything claimant had personally told
him about hisself, and overall, it was nothing, but completely degrading.
“[W]e hold that a person who places another before the public in a false light may be liable in
Missouri for the resulting damages. In recognizing this cause of action, we note that as a result of
the accessibility of the internet, the barriers to generating publicity are quickly and inexpensively
surmounted. Moreover, the ethical standards regarding the acceptability of certain discourse have
been diminished. Thus, as the ability to do harm grows, we believe so must the law’s ability to
protect the innocent.” Meyerkord v. Zipatoni Co., 276 S.W.3d 319, 323 (Mo.App. 2008).
II) Tortious Interference with a Business Relationship
A. John Carter’s Intentional Interference with Claimant’s Electrical Contract:
“The elements of tortious interference with a business relationship are: (1) The plaintiff was
involved in a valid business relationship; (2) the defendant was aware of the relationship; (3) the
defendant intentionally interfered with the relationship, inducing its termination; (4) the
defendant acted without justification; and (5) the plaintiff suffered damages as a direct result of
defendant’s conduct.” Clinch v. Heartland Health, 187 S.W.3d 10, 14 (Mo.App. W.D.2006) 1)
After claimant’s electrician completed his estimate on 2401 Indiana, and they agreed on a price
to complete the work and gain the materials, and claimant paid him the monies requested, they
had a valid business relationship. 2) Defendant was aware of this relationship because he self
admitted, that he unlawfully entered claimant’s property, to tell the electrician to leave a property
that he had no authority or legitimate reason, to be on himself, and afterwards he then offered his
defamatory comments, directly to Tom Frisella, which further substantiated his knowledge of the
relationship. 3) Defendant’s first direct contact with claimant’s electrician on the evening of
11/25/19, induced him to stop working on claimant’s home on the work he had already planned
on doing, and to also not to come back to the residence, out of fear of reprisal. The second
contact, where defendant authored and sent the derogatory and defamatory emails, was an
interference as well. It was geared towards having the electrician terminated by his boss, or to at
least make him choose between claimant’s 1 time job or possibly sacrificing his day to day
employment, which he ended up doing. 4) There was no justification for John Carter to even be
on claimant’s property initially or to email Southwestern Electric Company’s owner,
subsequently. 5) The plaintiff’s damages are extensive, because the electrician refusing to come

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back over and complete the work, because of John Carter., negated claimant’s renovation, which
he stood to make anywhere between 125-175k in profit, therefrom, when completed..
“If the defendant has a legitimate interest, economic or otherwise, in the expectancy the plaintiff
seeks to protect, then the plaintiff must show that the defendant employed improper means in
seeking to further only his own interests.” Stehno v. Sprint Spectrum, L.P., 186 S.W.3d 247, 252
(Mo. banc 2006).
Plaintiff can easily deduce here, that there is no legitimate interest, that defendant could surmise,
that can overcome or defeat, the interests plaintiff was seeking to advocate, and protect.
Furthermore, “Using improper means to interfere will destroy any justification a defendant might
otherwise assert no matter what sort of relationship was involved.” Clinch, supra. 187 S.W.3d at
17. Perpetrating an extreme and outrageous defamation, sounding in fraud, qualifies as an
improper means to interfere, to which there is no contemplated justification, that could even
rebut this presumption. “Unreasonable use of a privilege for an improper purpose, such as
perpetrating a deliberate lie, will forfeit the privilege.” Hensen v. Truman Med. Ctr., Inc., 62
S.W.3d 549, 557 (Mo.App. W.D.2001) (internal quotation omitted). Under Counts I A) and B),
claimant has clearly depicted that the defendant routinely employs force, the threat thereof, the
city’s official authority, defamation, misrepresentation, and even fraud, to fulfill his improper
means and there is no justification for this wanton conduct, and any contemplated justification
for it, can be summarily dismissed, since misrepresentations and defamation certainly constitute
improper means that serve to destroy any justification the defendant could have had. Clinch, 187
S.W.3d at 17. See also Topper v. Midwest Division, Inc., WD No. 70323 (Mo. App. 2010).
Claimant has clearly made a prima facie case of an intentional interference with his contractual
relationship.
Claimant seeks $50,000.00 to resolve count II) A.
II) B. Cat’s Paw or Concert of Action, theory of joint liability, for Barb Potts’ Intentional
Interference with claimant’s business relationship with Elders’ Antique Furniture.
Under the same legal authority announced above, for John Carter, under para. II) A., defendant
Carter should also be held jointly, but have severable liability, under a cat’s paw or concert of
action, theory of liability, for the acts of Barb Potts, in the intentional interference with the
Elders’ contingency contract. Claimant came into the knowledge that city department of public
safety official, Barb Potts, had defamed him, by going to meet the owner of Elders’ Antique
Furniture, and other employees, and falsely relayed that claimant was the target of a major
federal criminal investigation, at 2401 Indiana. That the home was under 24 hour, FBI
surveillance, and that any furniture given to him on a contingency contract basis, (as was
previously agreed upon and Ms. Potts had knowledge of) could be the subject of an asset
forfeiture proceeding, and a criminal investigation into their own affairs as well. Thereafter,
claimant was contacted by a member of the Elders’ Antique Furniture team, and notified that a
contingency pay arrangement on their furniture, for use in the air bnb, was no longer possible,
and only later did claimant find out, through a third party, the real reasons why. Since it was
likely initiated at the behest of defendant, and not executed directly by him, claimant asserts
defendant’s liability under a conspiracy, cat’s paw, or acting in concert theory of liability, which
allows recovery in the matter. Ms. Potts’ conduct meets all the elements of an Intentional
Interference, and it resulted in damages, since the defamation caused a breach to the Elder’s

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contractual relationship with claimant. Which was likely done at the behest of John Carter, so he
should face joint liability, for his unlawful efforts and participation in this tortious act.
Request for Damages and Claimants Current Agreement for Out of Court Settlement, on Count
IIA) John Carter’s Direct and Intentional Interference with claimant’s contractual and business
relationship with his electrician. $50,000.00 IIB) Indirect intentional Interference of claimant’s
business relationship, by Barb Potts to Elder’s owner, at the behest of John Carter, sought under
a joint and severable theory of liability/recovery at 50% fault of $50,000.00., is $25,000.00.
Therefore, $25,000.00 will satisfy John Carter’s legal liability portion, on Count II), B of
defendant’s joint liability on this claim.
Therefore, claimant is seeking a total of $75,000.00, for Count II. This is $50,000.00 for count
II) A. and $25,000.00 for count II) B. John Carter’s severable liability of $25,000.00, attached to
Carter and Pott’s, joint liability, of $50,000.00; Therefore, a total of $75,000.00, will fully
release John Carter’s liability on counts IIA) and IIB), in this out of court settlement.
Legal Basis Underlying a Reckless Infliction of Emotional Distress Claim, That is Laying in
Wait, in this Matter
To recover for intentional infliction of emotional distress, a Missouri plaintiff must establish that
(1) defendant’s conduct was extreme and outrageous; (2) defendant acted intentionally or
recklessly; and, (3) defendant’s conduct caused extreme emotional distress resulting in bodily
harm; additionally, plaintiff must establish that defendant’s sole intent in acting was to cause
emotional distress. Central Missouri Elec. Co-op v. Balke, 119 S.W. 3d 627,636 (Mo. Ct. App.
2003). Balke is a summary judgment case in which the defendants bolstered their motion for
summary judgment with affidavits. Like defamation, the defendant is subject to punitive
damages. “A submissible case is made if the evidence and the inferences drawn therefrom are
sufficient to permit a reasonable juror to conclude that the plaintiff established with convincing
clarity-that is, that it was highly probable-that the defendant’s conduct was outrageous because
of evil motive or reckless indifference.” Smith v. Brown & Williamson Tobacco Corp., 275
S.W.3d 748, 811 (Mo.App. W.D.2008) (internal quotation omitted). “It is not so much the
commission of the intentional tort as the conduct or motives, i.e., the defendant’s state of mind
which prompted its commission, that form the basis for a punitive damage award.” Hoyt v. GE
Capital Mortgage Servs. Inc., 193 S.W.3d 315, 323 (Mo.App. E.D.2006). “Factual inferences
which convincingly and clearly support the notion that the defendant acted with evil motive or
reckless indifference to the rights of others are sufficient to meet the standard for submission of
punitive damages.” Johnson v. Allstate Ins. Co., 262 S.W.3d 655, 666 (Mo.App. W.D.2008)
(internal quotation omitted).
III) Nuisance, Trespass to Land Claim, and Request for Ejectment Action and Monetary
Relief
1, A. Nuisance
“The tort of nuisance arises when a defendant’s use of his or her property is so ‘unreasonable,
unusual, or unnatural’ that it substantially impairs the rights of another to enjoy his or her
property. Moore v. Weeks, 85 S.W.3d 709, 716 (Mo.App. W.D.2002).” Rychnovsky v. Cole, 119
S.W.3d 204 (Mo. App., 2003). Defendant’s conduct throughout claimant’s ownership, has been a

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consistent and relentless, period of multifaceted nuisances, as depicted in claimant’s statement of
facts, referenced above.
Furthermore, pursuant to R.S.Mo. section 537.296.1.6. Nothing in this section shall: (1) Prohibit
a person from recovering damages for annoyance, discomfort, sickness, or emotional distress;
provided that such damages are awarded on the basis of other causes of action independent of a
claim of nuisance.
1, B. Intentional Interference With Property and Trespass to Land
“Where real estate is involved, ‘trespass is the unauthorized entry upon the land of another,
regardless of the amount of force used, even if no damage is done or the injury is slight.’
Rosenfeld v. Thoele, 28 S.W.3d 446, 449 (Mo.App. E.D.2000).] The unauthorized entry may be
made by a person or an object as a result of a person’s actions. Id. The tort of trespass arises from
the direct physical interference with the person or property of another. Rychnovsky v. Cole, 119
S.W.3d 204, 211 (Mo. App., 2003)(citing Looney v. Hindman, 649 S.W.2d 207, 212 (Mo. banc
1983)). Defendant has committed multiple instances of trespass to claimant’s land, over the
course of his ownership, and will continue on in such pursuits, unless he is impeded in some
fashion. Just recently, defendant self disclosed the fact that he entered claimant’s property, on
11/25/19 without justification or authority, for an improper purpose, and executed extreme and
outrageous conduct, thereupon. Furthermore, claimant has pictures of a parking lot under the
defendant’s ownership, custody, and control, that its boundaries, are excessively over
defendant’s ;and his authorized perimeters, which would’ve been easily understood, even by a
young, working class professional, first time property owner. From a multiple business owner,
and seasoned property owner’s perspective, who has, bought, sold, rehabbed and been privy to
multiple real estate transactions, his conduct was clearly intentional, and done out of spite
towards claimant, and an intent to take this property from him, without the proper and just
compensation. John Carter can not possibly assume that anyone could reasonably believe, from
his professional position, and previous real estate ventures that he did not know he was
committing trespass, or an attempted theft of land. In this context, John Carter is similar to a
merchant in contract law, since he possesses a higher degree of knowledge and skills, which
support scienter, in regards to the act of trespassing.
1, C. Ejectment
R.S.Mo. 524.010 gives persons or entities the right to bring an action in ejectment, stating the
following: “[a]n action for the recovery of the possession of premises may be maintained in all
cases where the plaintiff is legally entitled to the possession thereof.” R.S.Mo. 524.010 (2016).
An ejectment action is defined as “[a] legal action by which a person wrongfully ejected from
property seeks to recover possession, damages, and costs.” Black’s Law Dictionary 594 (9th Ed.
2009).“To make a claim for ejectment, the plaintiff must show the defendant was in possession
of premises to which plaintiff had a right of possession. Smith v. Seamster, 36 S.W.3d 18, 20-21
(Mo.App. W.D.2000). Plaintiff must further plead that he was damaged as a result of the
defendants’ unlawful possession of the premises. Section 524.060.” Rychnovsky v. Cole, 119
S.W.3d 204 (Mo. App., 2003). Claimant has suffered damages from defendant’s trespass,
because from the 11/20/19 pictures, it can be seen claimant can’t even open the gate, to his own
newly constructed privacy fence, or the windows in the basement of his house, or gain entry into
his own back private driveway. Furthermore, this trespass has a certain degree of permanence

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attached to it, the parking lot was constructed out of concrete and paved over with asphalt, so it
does not appear to be going anywhere anytime soon and makes an ejectment to possess, and
recover damages proper.
Pursuant to R.S.Mo. 524.060 (2016) claimant meets the statutory definition of a proper ejectment
because: 1)Plaintiff/claimant was entitled to the possession of
the land, since he is the registered homeowner of, 2) 2401-03 Indiana, and he is 3) still entitled to
possession of this land at the time of commencement of this action. R.S.Mo. 524.080 (2016)
Defendant, on or before 11/20/19, entered into claimant’s premises, and has unlawfully withheld
from the claimant his lawful possession thereof, ever since this point, and continues to be.
For the aforementioned reasons, claimant has been damaged, because he has unlawfully been
kept out of possession of his land.
1, D. Relevant Statute underlying the multiple instances of Trespass
Laying in Wait Claim of: Malicious trespass--to personalty--double damages--issuance of
attachment, when.
Pursuant to R.S.Mo. section 537.330., If any person shall maliciously or wantonly damage or
destroy any personal property, goods, chattels, furniture or livestock, the person so offending
shall pay to the party injured double the value of the things so damaged or destroyed; and upon
an affidavit that said damage or destruction was wantonly or maliciously done, it shall be a good
ground for an attachment to issue, as in other cases by attachment.
Claimant’s Current Request for Damages on count III) A.-D.
Claimant seeks $50,000.00 collectively, to resolve claims listed in counts III) A-D, in an out of
court settlement, and through this demand letter.
2, Option to Exercise Special Settlement Conditions of a Rider Contract to the Settlement
Contract, for A. the Sale of Land Adjacent to His Home, and b) the same Easement Rights
of that Adjacent land, attached to 2401-03 Indiana, for $49,000.00.
2, A. Defendant can purchase all property rights he is currently trespassing upon, from claimant,
under the liberal assumption, that he is only 3 feet over his own property boundary lines, at 10k
per every foot, that claimant is liberally construing, Mr. Carter is currently over. Therefore, 30k
total, is what it’ll cost, if defendant wishes to extend this special option, towards purchasing
claimant’s property, that he is currently trespassing upon.
2, B. Defendant can also purchase an agreement to purchase the easement rights, of 2401-03
Indiana, so that no: 1) easement for his driveway, 2) building/providing, of a common
throughway between his house and the parking lot, 3) access point be appropriated, to open his
privacy fence gate, to the parking lot side of his backyard, 4) access point be appropriated, to
open his basement windows, parking lot side, will be available. Therefore, 19k total, which is
4.5k, per each of the 4 options, is what it’ll cost, if defendant wishes to collectively, extend these
special options, to the overall settlement proposition, and 4.5k per option, is still a very liberal
cost.

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IV) CIVIL CONSPIRACY and ACTING IN CONCERT, THEORY OF LIABILITY,
CAUSING VIOLATIONS OF A. RIGHTS SECURED UNDER 42 U.S.C. section 1983; and
B. 42 U.S.C. SECTION 3604.
In Missouri, a civil conspiracy is “an agreement or understanding between persons to do an
unlawful act, or to use unlawful means to do a lawful act.” Gibson v. Brewer, 952 S.W. 2d 239,
245 (Mo. App. 1997). Claimant asserts that a civil conspiracy existed, to deprive him of rights and
benefits secured by 42 U.S.C. section 1983 and 42 U.S.C. section 3604. This occurred between John
Carter, and officials/agents, of/for the City of St. Louis. To support a civil conspiracy theory a plaintiff
must provide factual support of a meeting of the minds and the act in furtherance of the conspiracy.
Croskey v. Cty of St. Louis, No. 4:14CV00867 ERW, 2014 WL 3956617 at *5 (E.D.Mo. Aug.
13, 2014).
The elements of a civil conspiracy claim are (1) two or more persons, (2) an unlawful objective,
a (3) meeting of the minds, (4) one act in furtherance of the conspiracy and (5) damages. Oak
Bluff Partners, Inc. v. Meyer, 3 S.W.3d 777, 781 (Mo. 1999). Claimant’s statement of facts,
provide support to the theory, that there was in fact a “meeting of the minds,” on multiple
instances, with multiple city officials, over claimant, and his property. “A plaintiff must establish
that two or more persons with an unlawful objective, after a meeting of the minds, committed at
least one act in furtherance of the conspiracy, damaging the plaintiff.” Gibson, Id., supra.
Multiple acts of unlawful objectives have been cited by claimant, which can be inferred from the
facts, but assuming arguendo, that they can not be gleaned., Claimant first of all asserts that the
underlying conspiracy, was the proximate cause for the multiple hurdles he had to overcome, and
roadblocks that were constructed by City Inspection Officials. Furthermore, that these acts were
not Constitutional, and did not even adhere to the city’s own policies, or if they did, the policies
themselves, were unconstitutional or made unavailable. The facts in this cause, support a civil
conspiracy because the majority of defendants’ conduct, in this regard, was “an unlawful act, or
to use unlawful means to do a lawful act.” Gibson, Id. While civil conspiracy has its own
separate elements, it is not a distinct cause of action either. Breeden v. Hueser, 273 S.W.3d 1,
13 (Mo. Ct. App. 2008). Rather it is geared to function, as a means to hold the conspirators
jointly and severally liable for underlying, improper conduct. 8000 Maryland, LLC v. Hutleigh
Fin. Services, Inc., 292 S.W.3d 439, 451 (Mo. Ct. App. 2001).
Therefore, the core of the action is not the conspiracy itself, but the wrong done by acts in
furtherance of the conspiracy resulting in damage to plaintiff. Id. First of all, John Carter and the
plethora of city officials and employees, violated his civil rights under 42 U.S.C. 1983., and
secondly, they also violated multiple rights, secured under Title VIII of the Fair Housing Rights
Act of 1968, in the purchase of his home, both before and after his accident occurred. See also 42
U.S.C. 3604(b),(d),(e), (f)(1)(A), (f)(2)(A), (f)(3)(B). John Carter and other city official’s acts
are not constitutional, and were extremely unlawful. “Unlawful” for purposes of a civil
conspiracy is not limited to conduct that is criminally liable; for example, it may include
individuals associating for the purpose of causing or inducing a breach of contract or business
expectancy. Lyn-Flex West, Inc. v. Dieckhaus, 24 S.W.3d 693, 700-01 (Mo. Ct. App. 1999).
John Carter’s basis of liability can be found by looking at a “concert of action theory in liability.
“The concert of action theory imposes liability upon ‘all those who, in pursuance of a common
plan or design to commit a tortious act, actively take part in it, or further it by cooperation or
request, or who lend aid or encouragement to the wrongdoer, or ratify and adopt his acts done for
their benefit...” Blaes v. Johnson & Johnson , 71 F.Supp.3d 944, 947 (E.D.Mo.2014)

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Claimant, currently seeks, on counts IV) A. and B., $300,000.00, collectively, from, the ST.
LOUIS CITY: 1) Housing Inspection Officials, 2) Department of Public Safety, and 3) Police
department., along with out of state resident, 4) John Carter.
Under a joint and severally liable theory, on Counts, IV) A. Violations of Civil and
Constitutional Rights, by those acting under color of state law, claimant seeks $150,000.00.,
and on count IV) B. Violations to the Fair Housing Act, claimant seeks $150,000.00
John Carter’s liablity under this formula would be 37,5k for each count, which is ¼ the amount
requested for an out of court settlement on this count and would total 75k, to settle both these
causes of action, and his liability under counts V) A. and B.
V) CURRENTLY NON-SOUGHT DAMAGES AND RELEASED CLAIMS, THROUGH
AN OUT OF COURT SETTLEMENT, BUT WILL BE SOUGHT IF LITIGATION IS
PURSUED
A. PUNITIVE AND EXEMPLARY DAMAGES, which could be up to 4 times, the amount of
the diminished compensatory damages, that are currently being sought.
B. INTENTIONAL INTERFERENCE with A FUTURE ECONOMIC BENEFIT, with:
SOUTHWESTERN ELECTRIC COMPANY, ELDERS’ ANTIQUES STORE, AIR B’NB AND
NEW FRONTIER BANK.
C. ATTORNEYS’ FEES
D.FRAUD/MISREPRESNTATION
E. MALICIOUS TRESPASS
F. FULL AMOUNT OF ALL COMPENSATORY DAMAGES
G. INTENTIONAL/RECKLESS INFLICTION OF EMOTIONAL DISTRESS
H. RETALIATION
I) FALSE LIGHT AND INVASION OF PRIVACY
VI) CONCLUSION
A. Basic Summary, in Further Support of Encourage an Out of Court Settlement
Pursuant to Federal Rules of Civil Procedure (F.R.CP.) 8 (a)(2), the initial complaint simply
requires a short and plain statement of the claim, showing that the pleader is entitled to relief.
This demand letter alone, would likely suffice passing muster, under the Federal notice pleading
standard, with some numbered paragraphs in his statement of facts, minor word
additions/subtractions, and word modifications, and also is highly likely to survive a motion to
dismiss, pursuant to F.R.C.P. 12 (b)(6). To even get to that stage of the pleadings, you are likely
going to have to hire an attorney, which will likely cost a good sum of money, and due to the
sufficiency of the underlying claims, plaintiff would also then likely seek an attorney, due to the
availability of Attorney’s fees being present, in these separate causes of action. Many times, the
presence of a strong case and availability of attorney fees, is almost surely a recipe for the entry
of plaintiff’s counsel soon too.

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Once we’re both through that legal gauntlet, you’ll likely be thinking twice about your options,
because of the constantly surmounting legal costs, along with the Federal Court system favoring
settlement and arbitration, as opposed to over extending judicial time and resources, but due to
the extensiveness of plaintiff’s claims and the severity they would surely entertain the multitude
of claims, along with finding sufficiency underlying them., if negotiations proved unavailing.
Furthermore, it should be noted that the settlement negotiations in Federal Court, with lawyers
present for each side, will no longer be in same monetary settlement region, that we currently
find ourselves at.
From a figurative perspective, you might feel the person stuck in legal quicksand, since you’ll
keep fighting, but you’re literally only going to be sinking deeper and likely will be spending
even more money and likely losing more business too, the longer a settlement takes. Claimant is
a very patient individual and is prepared to this wait out, as long as it takes to obtain a jury trial, f
necessary. Plantiff, would welcome the opportunity to seek more damages and possibly shed
some truthful light, upon these atrocities, but is trying this peacefu and quiet, good faith attempt,
at a successful resolution in this manner, instead.
Moreover, claimant has kept his requests for compensatory relief very, very low, and even
estimating only 3 times the amount of the compensatory damage amount, currently requested,
claimant would be looking at filing $900,000 in his compensatory damage request. Claimants
punitive and exemplary damage request, at that point, would likely be 4 times this amount as
well, and therefore could be roughly estimated, at a $3.6 million, punitive damage request, for a
4.5 million, rough total, on just counts I-IV.
This of course is not including any compensatory, or punitive damages’, calculation, or requests,
yet to occur, for counts V) A-I, either. Even at only half the amount requested for the first 4
counts, (and there are 9 unclaimed damage, counts of relief) that would be an additional $2.25
million, for a rough total of a $6.75 million damage request, for the remaining counts in this
litigation., which have likely been grossly underestimated in their accounts, and recovery ability,
as well.
The decision to litigate these matters is solely up to Mr. Carter thou. Claimant has tried to
maintain his typical and usual calm demeanor at all times with John Carter, even in the face of
all the outrageous and discriminatory conduct depicted herein, and will continue to. Claimant
doesn’t want to trade expletive words with defendant or exchange dirty looks, from across the
yard, at each other. Defendant already knew what he was doing to claimant, but now Mr. Carter
knows that claimant eventually found out what he was doing, as well, too. Claimant wasn’t
looking for any problems, and was only trying to mind his own business, while completing the
work necessary to occupy his home, John Carter could never leave plantiff alone to do that thou.
Plaintiff has always maintained his composure and demeanor in the wake of these numerous
atrocities and will continue to do the same, so if John Carter refuses claimant’s demands, then it
only means that we’ll greet each other and pick this conversation back up, in Court. Claimant is
making an extremely good faith effort to settle these claims, and has done it, in both a reasonable
manner, with reasonable requests of relief included. Claimant has made a novel attempt to settle
this out of Court too, but claimant welcomes the proposition of litigation, over these matters too.
Mr. Amick is married to law and loves every second of her, in his presence., he also is a
purveyor of justice and a truthsayer., who would be alive and present, in this truth seeking
system, so claimant will welcome this process, with open arms as well.

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An additional incentive to not litigate, and that would seem beneficial to either party, would be to
avoid any unnecessary media attention in this matter, that it could garner. Claimant feels as if
that the damages, he’s already sustained in this matter, and it could also possibly affect
defendant’s own business ventures, and sustainability, moving forward.
B. Offer on Full Cash Settlement of All Legal Claims, Contained or Construed Herein
1. THEREFORE, the best course of action, at this point, would be for defendant, John
Carter, to make a $324,000.00 check payable to Jeffrey S. Amick, Whereupon, claimant,
Jeffrey S. Amick, will sign a standard Federal settlement agreement and release of
liability, for any and all claims in counts I-V, or otherwise arising under claimant’s set of
facts. This offer of settlement and release of liability will expire in 10 days from now, on
12-23-19 at 12 pm and will likely result in litigation being filed on that day.

VII) OPTIONAL, RIDER CONTRACT FOR PROPERTY PURCHASE OF 2401-03

INDIANA, ACCOMPANYING THE SETTLEMENT DEMAND, WITH A
CORRESPONDING OFFER TO DISMISS COUNTS III) E. & F.
Plaintiff is aware that John Carter is still interested in purchasing his property, and claimant is
going to make a good faith effort, to set all the differences aside, after settlement upon his legal
clams, so he can just walk away from this whole matter, and now will agree to sell Mr. Carter,
the property at 2401-03 Indiana, for an additional 150k, which is likely still only 50% of its
likely $300k fair market value, upon full renovation, and an even better deal since the house is at
75%-80% of it’s fully renovated value, currently.
Moreover, correspondingly, claimant will also agree to Drop Counts III) E. (alleviation of 30k
for defendant’s purchase of claimant’s property, he’s currently trespassing upon, with the
overextension of his parking lot) & F.,(alleviation of 19k for having to purchase easements
rights)., which would bring the overall cost of 2401-03 Indiana down to 101k. In the event that
defendant wants to extend a rider contract, to this settlement agreement, to allow the purchase of
2401-03 Indiana, St. Louis Mo. 63104; then he should make a check payable to Jeffrey S. Amick
for the amount of $425,000.00 and schedule its delivery to him, which will settle, and release, all
of the legal claims currently pending against John Carter, and also will allow him purchase of the
property, since Mr. Amck will sign a settlement agreement and release, along with his deed
directly over to him, upon receipt of a valid check, for that amount, by approximately 5 days
from now, 12-18-19 at 12pm. The offer for a rider contract, accompanying the out of court
settlement offer, and allowing the immediate property purchase, will expire in 5 days hereafter,
along with the settlement offer and release offer, expiring 5 days from then, on 12-23-19 at
12pm.
Please feel free to contact claimant by phone, directly at 312.383.1981 or by email at
exppara1@hotmail.com to schedule payment, and I will correspondingly make arrangements to
have any necessary legal paperwork ready to complete any of the transaction depicted herein.
P.S. Normally i wouldn’t feel it necessary to mention this, but under the current and past
circumstances, I feel compelled to mention that all the offers contained in this agreement, are

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revocable at the first any sign of retaliation from you, any St. Louis City officials, agents,
employees or police. That signal will revoke any and all offers that have been proposed in this
demand letter, and will result in this litigation being filed immediately, against any and all
relevant parties, named herein.

Cc. Johncarter987@icloud.com on Friday, December 13, 2019, from exppara1@hotmail.com at

4:20 p.m.

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