Affidavit of Complaint
Defendant: MEGA MOVING INC.
20444 North East 15th Court
North Miami Beach, Florida 33179
County of Dade, State of Florida
Plaintiff: EAGAN
County of Clark, State of Nevada
The Plaintiff (hereby as “customer”) hired the Mega Moving Inc. (hereby as “Defendant” or movers) to relocate from Pensacola, Florida to Las Vegas, Nevada.
The cause of action, charges, and complaints are as follows:
Maliciously, intentionally, deliberately, viciously damaged and destroyed the Plaintiff’s personal properties while in the Defendant’s possession for 3 weeks
Using the commercial license to steal customer’s properties; abusing the commercial license by abusing the consumer
On January 19, 2009, the Plaintiff was waiting for Defendant by the curve street. A moment Defendant’s rental truck pulled into the Plaintiff’s front yard lawn, the movers getting off a rental truck, the Defendants were demanding, threaten the customer for $200 tip upfront, before the service rendered. This was BEFORE greeting to the customer; BEFORE they identify, introduce, themselves as movers (Defendant).
The Defendant would not start to work, instead continue to harassing, intimating, demanding the Plaintiff for $200 tip by brute force, threaten the customer by saying mandatory $200 tip for movers and tip must be up front; before the service rendered.
The Plaintiff repeatedly told the Defendant to start to work, but the Defendant refused to start to work without a $200 tip upfront and continued to threaten, demand.
The Plaintiff refused to give $200 tip because the Defendant refused to start the work and Defendant wants the $200 tip before the service start, upfront. The Plaintiff informed the Defendants that after the service is completely done, we, both parties, can discuss the tip.
Using commercial license to steal customer’s property: One of the movers was sniffing through personal properties, attempted to steal an item. The Defendant said, “Wow, this is very nice - -so beautiful. I want it. Where did you get it? I need- - need one of those.” After the Defendant’s comment, the item was never to be seen, ever again.
After the Plaintiff refused to give $200 tip upfront, the Defendant then altered the binding contract from $900 to $1195.00 then threatens the customer to initials after the Defendant altered the binding contract.
As a result of an altercation over $200 tips upfront, the Plaintiff’s personal properties were destroyed by the Defendant more than 80 % of the entire properties, household goods, and personal items. The customer has to haul it out to the dumpster because it is impossible to repair the damaged properties; repair is out of question.
After 3 weeks gone by, the Defendant finally delivered the properties to the customer, but customer has to haul it out to the dumpster.
The Mega Moving Incorporation is the sole Defendant; and no other parties are involved in this case because the items were destroyed in Florida at the pick-up location. The Plaintiff has a contract with the Defendant, Mega Moving INC.
As a result of this case, the Plaintiff has been in and out of the medical facility, hospital, treating for stress and high-blood pressure.
Due to the medical conditions, the Plaintiff was unable to precede this matter in timely fashion and would like to make a motion to the Court to excuse this delay proceeding.
I, the Plaintiff, declare under penalty of perjury under the law of the State of Nevada that the foregoing is true and correct.
Executed on July 26, 2009
US DOT #: 1799704
Docket #: MC654617
US DOT #: 1799704
Docket #: MC654617