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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT

OF WEST VIRGINIA , CHARLESTON, WV 25301


IN RE: THE MATTER OF AHMED OLASUNKANMI SALAU
CASE #: 15-10001-BK
THE HONORABLE RONALD PEARSON, PRESIDING
ADVERSARIAL PROCEEDING AGAINST MERCER WRECKER INC., MIKE ROLES,
KRISTA SOMER THOMPSON, AND JUDY THOMPSON.
ADVERSARIAL PROCEEDING #
MOTION FOR SERVICE BY THE UNITED STATES MARSHALL SERVICE.

Comes now Petitioner pro se, Ahmed Salau, and moves the Honorable Court in the above-styled
matter for service by the United States Marshall Service and states in support that:
1. The Plaintiff filed a motion to proceed in forma pauperis which motion the Court granted
by Order dated 1/12/2015;
2. The Plaintiff is without the financial resources to obtain service on the Defendants in the
above-styled matter herein;
3. The granting of this motion for service to be obtained by the United States Marshall
Service is consistent with the Courts Order granting in forma pauperis status and is
within the sound discretion of this Honorable Court;
4. The granting of this motion for service by the United States Marshall Service will allow
the Plaintiff substantial and meaningful access to the Courts and will allow substantial
Justice to be done;
AND the Plaintiff prays for said Order authorizing service to be obtained by the United States
Marshall Service in the above-styled matter and any and all such and further Orders that the
Courts deems proper.
Respectfully Submitted,

Ahmed Salau
Petitioner pro se
Dated 2/17/2015

IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT


OF WEST VIRGINIA , CHARLESTON, WV 25301
IN RE: THE MATTER OF AHMED OLASUNKANMI SALAU
CASE #: 15-10001-BK
THE HONORABLE RONALD PEARSON, PRESIDING
ADVERSARIAL PROCEEDING AGAINST MERCER WRECKER INC., MIKE ROLES,
KRISTA SOMER THOMPSON, AND JUDY THOMPSON
ADVERSARIAL PROCEEDING #
JURY TRIAL DEMANDED

AHMED OLASUNKANMI SALAU, DEBTOR/PLAINTIFF


P O BOX 671,
CLAY, WV 25043.
PLAINTIFF
VERSUS,

MERCER WRECKER INCORPORATED, CREDITOR/DEFENDANT,


210 COUNTY HIGHWAY 24/1,
PRINCETON, WV 24740;
MIKE ROLES, CREDITOR/DEFENDANT
210 COUNTY HIGHWAY 24/1,
PRINCETON, WV 24740.
KRISTA SOMER THOMPSON, DEFENDANT
P O BOX 79,
PIPESTEM, WV 25979
JUDY THOMPSON, DEFENDANT
P O BOX79,
PIPESTEM, WV 25979
DEFENDANTS

COMPLAINT

Plaintiff Ahmed Salau, pro se, for his complaint alleges as follows:
NATURE OF THE CAUSE
This is an adversarial proceeding alleging unfair business practices, fraudulent
enrichment against the Defendants Mike Roles and Mercer Wrecker and alleging Defamation
Slander per se, Defamation Libel per se against the Defendants Krista Thompson and alleging
intentional infliction of emotional distress and outrage against Mike Roles, Mercer Wrecker,
Judy Thompson, and Krista Thompson. Plaintiff, Ahmed Salau, seeks relief for the Defendants
egregious tortious misconduct.

The Plaintiff seeks damages both compensatory and punitive, affirmative & equitable
relief, special & exemplary damages, an award of costs and attorneys fees & such other and
further relief the Court deems equitable and proper.
The Defendants actions started on/or about March 28th 2014 and continues till today and
occurred substantially in the Southern District of West Virginia such that West Virginia
substantive laws apply herein.
JURISDICTION AND VENUE
Jurisdiction is conferred upon this Court by 28 U.S.C 1334(b) and 1332(a), this
being an action that arises under Title 11 and that will alter the Debtors Bankruptcy Estate; and
involving diversity of citizenship.
Plaintiffs claim for declaratory and injunctive relief is authorized by 28 U.S.C 2201
and 2202 and Rule 57 of the Federal Rules of Civil Procedure.
The Plaintiff further invokes this Courts pendent jurisdiction pursuant to 28 U.S.C 1367
(a) as against all parties that are so related to claims in this action within the original jurisdiction
of this Court that they form part of the same case or controversy.

The Plaintiff demands a trial by jury on each and every one of his claims as pled. Venue
is proper for the United District Court for the Southern District of West Virginia pursuant to 28
U.S.C 1391 (a), (b) and (c).
THE PARTIES
1. Plaintiff, Ahmed Salau is a natural person and is a resident of Bloomington,
Indiana. Plaintiff majored in chemistry and psychology and had a minor in legal
studies. Plaintiff was a research associate, co-author, co-investigator on a number of
ongoing and completed scientific projects that have been published in peer-reviewed
journals like the American Chemical Society Journal, Journal of Thermodynamics
among others. Plaintiff also had jobs as a tutor and teaching assistant at Concord
University in Athens, WV and also as a. Plaintiff was also a maintenance associate at
Sams Club in Bluefield, Virginia. Plaintiff was also involved and/or is a member of
numerous groups on campus including but not limited to International Students Club,
and Bluefield Union Mission. Plaintiff is also the Founder, President and Chief
Executive Officer of PARIS Angels a mentoring program for at-risk youth. The
Plaintiff is also the recipient of numerous scholarships for academic achievement
including the McNair National Research scholarship, Judy C Johnston Chemistry
Prize, Mary R Futch Humanities Prize, etc. The Plaintiff is an African-American
permanent resident of the United States, and was at all times relevant herein a
resident of the City of Bluefield, WV, County of Mercer, State of West Virginia.
2.

Defendant Mercer Wrecker is a business entity created and authorized under the
laws of the State of West Virginia. It is authorized by law to carry out wrecker
services in Mercer County, WV and surrounding counties and assumes the risks
incidental to the maintenance of its wrecker, and the employment and supervision
of her officers. The business is sued officially.

3.

Defendant Mike Roles is a natural person and the Owner of Mercer Wrecker with
his primary business activities conducted in Princeton, West Virginia and assumes

supervisory authorities over the actions of himself and employees. He is sued


individually and in his official capacity.
4.

Defendant Krista Thompson is a natural person, a resident of Pipestem, WV, and


was married to the Plaintiff during the periods pertinent herein. She is sued
individually.

5.

Defendant Judy Thompson is a natural person, a resident of Pipestem, WV, and is


the biological grandmother of Defendant Krista Thompson and legal mother of
Defendant Krista Thompson. She is sued individually.
STATEMENT OF FACTS

BACKGROUND INFORMATION
6. On/or about &/or between October 26th 2013 & November 5th 2013, the Plaintiff
separated from his wife Krista Thompson, and took Krista Thompson to her
Mother Judy Thompsons house on Boulder Trail in Pipestem, WV.
7. On/or about &/or between October 26th 2013 & March 31st 2014, the Defendant
Krista Thompson repeatedly stalks the Plaintiff at his work at Walmart in
Princeton, WV and at his home on Vermillion Street in Athens, WV.
8.
The Plaintiff becomes fearful for his life and relocates from Princeton,
WV to Bluefield, WV and transfers from his place of employment at WalMart in
Princeton, WV to Sams Club in Bluefield, VA.
9. During this period of physical separation, the Defendant Krista Thompson
repeatedly asks the Plaintiff to spend a day with her and the Plaintiff informs the
Defendant that Marital counselling would be a more preferred route to
reconciliation.

10. On/or about March 27th 2014, the Plaintiff finds out that the Defendant Krista
Thompson was engaged in multiple extra-marital affairs and calls off the proposed
counselling and reconciliation and suggests the signing of a legal separation or
divorce agreement.

11. On/or about March 28th 2014, the Defendant Krista Thompson, and Defendant
Judy Thompson travel to the Plaintiffs school and place of employment Concord
University, and make a false allegation of abuse and rape that apparently had taken
place on some unknown date in November 2013.
12. On/or about &/or between March 31 st 2014 and April 17th 2014, the Defendant
Krista Thompson and Defendant Judy Thompson unlawfully took possession of
the Plaintiffs Red Nissan Frontier Truck and disgorged it of its contents.
13. The contents that were unlawfully disgorged from the truck include but are not
limited to the following:
a.
HP Laptop Computer
b.
Various Textbooks
c.
Various Clothings
d.
Various Electronic devices
e.
Other personal possessions.
14. The Defendants Krista Thompson, Judy Thompson, Mike Roles, and Mercer
Wrecker conspired to illegally take possession of the Red Nissan Frontier Truck
from the campus of Concord University and transfer the same to the home of
Defendants Krista Thompson and Judy Thompson and subsequently transfer same
to the facilities of Mercer Wrecker in Princeton, WV. These actions took place
between April 15th 2014 and April 20th 2014.

15. In multiple conversations from the Southern Regional Jail in Beaver, WV with
representatives of the Athens Police Department and Mercer Wrecker, the Plaintiff
was informed that the Red Nissan Truck was requested to be towed by the Athens
Police Department and that it was towed by Mercer Wrecker from the campus of
Concord University where it was legally decaled and parked to Princeton WV.
These conversations took place between May and June 2014.
16. On/or about &/or between September 2014 and January 2015, the Defendants
Mike Roles, Mercer Wrecker, Krista Thompson, and Judy Thompson have
continued to maintain that the Red Nissan Truck was removed from the campus of
Concord University by the Defendants Judy Thompson and Krista Thompson and
that it was only after it was at the Thompson residence that the Defendants Mike
Roles and Mercer Wrecker were called all the way from a different County to
remove the Red Nissan Truck from the Thompson residence.
17. On/or about &/or between September 2014 and October 2014, the Plaintiff
contacted the Summers County Sheriffs Office, as to why an out of County
wrecker would have been called to effectuate a tow in Summers County and was

informed by the Sergeant on duty that this was not normal and that his office was
never contacted to effectuate a tow and if they had been called, they would have
utilized a tow company in Summers County, WV.
18. On/or about &/or between October 2014 and December 2014, an evidentiary
hearing was held in the Mercer County Courthouse before the Honorable Omar
AboulHosn, during which all the Defendants continued to maintain under oath that
the Red Nissan Frontier Truck was towed from Pipestem and not the campus of
Concord University.

19. On/or about &/or between December 2014 and January 2015, the Plaintiff
repeatedly contacts the Defendants Mike Roles and Mercer Wrecker by himself
and through Counsel Hiram Lewis IV Esq. to provide the Plaintiff with a receipt
so that the funds could be raised to release the truck.
20. On/or about December 24th 2014, the Defendants Mike Roles and Mercer
Wrecker, informed Mr. Lewis that a total of $3000 was owed on the truck.
21. On/or about December 28th 2014, the Plaintiff contacts the Defendants Mike Roles
and Mercer Wrecker for a receipt to that effect, and the Defendants informed the
Plaintiff in the presence of Counsel that the amount owed had changed to more
than $8000 and that a receipt to that effect would not be provided.
22. The Plaintiff is still unable to get a receipt showing the total bill owed on the Red
Nissan Frontier Truck.
23. Due to the actions of the Defendants Krista Thompson, Judy Thompson, Mike
Roles, and Mercer Wrecker, the Defendant has lost use of his Red Nissan Truck.
24. The Defendant was unable to use the truck to assist in the ministry he worked on
with Mr. Lewis at the American Chapel at Elkhurst in Elkhurst, WV.
25. The Defendant has been unable to use his truck to navigate the snow covered
roads in West Virginia and Indiana.
26. The Plaintiff states upon true belief that a lien has been placed on the truck by the
Defendants Mike Roles and Mercer Wrecker.
27.

The Plaintiff needs his truck.

28.
The Plaintiff never raped the Defendant Krista Thompson. The Defendants
Krista Thompson and Judy Thompson had no right to take possession of the
Plaintiffs truck.
29.
The Defendants Mike Roles and Mercer Wrecker had no right to conspire
with the Defendants Krista Thompson and Judy Thompson to deprive him of the
lawful use of his truck.

FIRST CLAIM FOR RELIEF


INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
30.
The Plaintiff repeats and re-alleges the statements in paragraph 1 to 29 as
if fully set forth herein. The tortious misconduct of Mike Roles and Mercer
Wrecker and Krista Thompson and Judy Thompson in illegally dispossessing the
Plaintiff of the lawful use of his truck was a deliberate action taken with reckless
disregard and/or malice and was taken knowing that the Plaintiff would suffer
severe emotional distress.
31. The deliberate actions of Krista Thompson and Judy Thompson in conspiring
to falsely accuse the Plaintiff of rape has caused the Plaintiff severe emotional
distress. The Defendants Krista Thompson and Judy Thompson knew or
should have known that the false accusation of rape would proximately result
in the nine (9) months of incarceration suffered by the Plaintiff.
32. The deliberate actions of the Defendants Krista Thompson and Judy
Thompson in conspiring to disgorge the Plaintiff of the contents of his truck
and the actual truck proximately caused the Plaintiff to lose said contents and
said truck.
33. The deliberate actions of the Defendant Mike Roles and Mercer Wrecker in
refusing to provide an up to date tow bill and in conspiring with the above
named Defendants and their unsued co-conspirators proximately caused the
severe emotional distress the Plaintiff feels now at all times.
34. The Plaintiff will soon have to seek professional help for his emotional distress
proximately caused by the Defendants.

SECOND CLAIM FOR RELIEFT


UNFAIR AND DECEPTIVE BUSINESS PRACTICES
35. The Plaintiff repeats and re-alleges the statements in paragraph 1 to 34 as if
fully set forth herein. The tortious misconduct of Mike Roles and Mercer
Wrecker in illegally dispossessing the Plaintiff of the lawful use of his truck
was a deliberate action taken with reckless disregard and/or malice and was
taken knowing that their actions were unlawful and contrary to law.

36. The tortious misconduct of Mike Roles and Mercer Wrecker in giving different
amounts for the tow bill owed to them and in failing to provide an up to date
tow bill to the Plaintiff and his representatives amount to unlawful business
practices under the West Virginia Code 33-11-4.
37. The tortious misconduct of Mike Roles and Mercer Wrecker in providing
differing positions as to the circumstances surrounding the towing of the truck
amounted to unfair and deceptive business practices.
TO WIT:
a.
Claiming in recorded phone conversations between May and June
2014 that the truck was towed from Concord University; and
b.
Claiming in sworn testimony that the truck was towed from
Pipestem, WV.
38.
The tortious misconduct of Mike Roles and Mercer Wrecker in failing to
give an accurate up to-date bill to the Plaintiff and his representatives amounted to
unfair and deceptive business practices.

THIRD CLAIM FOR RELIEF


DEFAMATION SLANDER PER SE
39.
The plaintiff repeats and re-alleges the statements in paragraphs 1 to 38 as
if fully set forth herein. The Tortious misconduct of the Defendant Krista Thompson in falsely
accusing the Plaintiff of raping her was a conscious and deliberate decision that
has caused the Plaintiff known and unknown injury including but not limited to
the loss of his scholarships, loss of income, loss of familial association, loss of an
education and more importantly the public branding of the Plaintiff as a rapist.
40.
The Defendant Krista Thompsons false and defamatory statements that
the Plaintiff raped her was not protected and was widely distributed to third

parties including but not limited to his college peers, college advisors, college
professors, research collaborators, non-profit associates, friends, family
and the whole world as same statements were widely published on print and
news media.
41.
The Plaintiffs name is forever tarnished as a result of the Defendants
tortious misconduct. The Defendant Krista Thompsons actions amounted to
slander per se as these statements were published with the requisite
degree of fault.
FOURTH CLAIM FOR RELIEF
DEFAMATION LIBEL PER SE
42.
The Plaintiff repeats and re-alleges the statements in Paragraphs 1 to 41 as
if fully set forth herein. The Tortious misconduct of the Defendant Krista Thompson in falsely
accusing the Plaintiff of raping her was a conscious and deliberate decision that
has caused the Plaintiff known and unknown injury including but not limited to
the loss of his scholarships, loss of income, loss of familial association, loss of an
education and more importantly the public branding of the Plaintiff as a rapist.
43.
The Defendant Krista Thompsons false and defamatory statements that
the Plaintiff raped her was not protected and was widely distributed to third
parties including but not limited to his college peers, college advisors, college
professors, research collaborators, non-profit associates, friends, family
and the whole world as same statements were widely published on print and
news media.
44.
The Plaintiffs name is forever tarnished as a result of the
Defendants tortious misconduct. The Defendant Krista Thompsons actions
amount to libel per se as they were written statements published with the
requisite degree of fault.

FIFTH CLAIM FOR RELIEF


OUTRAGE
45.
The Plaintiff repeats and re-alleges the statements in paragraph 1 to 44 as
if fully set forth herein. The tortious misconduct of the Defendants Krista Thompson, Judy
Thompson, Mike Roles, and Mercer Wrecker in conspiring to and in
disgorging the Plaintiff of his lawful possession amounted to outrage.

46.
The Defendants knew that their actions would proximately cause the
outrage to the Plaintiff by their actions.

WHEREFORE, the Plaintiff prays that the Court enter Injunctive and Declaratory Judgement
against the Defendants Mike Roles, Mercer Wrecker, Judy Thompson, and Krista Thompson as
to their actions in disgorging the Plaintiff of his truck and declare said action illegal and Order
the return of said truck to the Plaintiff.
The Plaintiff further prays that the Court set aside the lien that has been placed on the truck as a
result of the over $8000 in storage fees on the truck as it interferes with his ability to claim the
truck as an exemption in his bankruptcy proceedings.
The Plaintiff further prays that the Court enter Judgement against the Defendant Krista
Thompson individually in an amount to be determined at trial in excess of $75,000 for actual
damages, punitive damages, special damages, exemplary damages for her misconduct.
The Plaintiff further prays that the Court enter Judgement against the Defendant Judy Thompson
individually in an amount to be determined at trial in excess of $75,000 for actual damages,
punitive damages, special damages, exemplary damages for her misconduct.
The Plaintiff further prays that the Court enter Judgement against the Defendants Mike Roles and
Mercer Wrecker jointly and severally in an amount in excess of $75,000 for actual damages,
punitive damages, special damages, exemplary damages for their role in this fraudulent scheme.
The Plaintiff further prays that the Court enter an ORDER declaring that the Plaintiff is entitled
to attorneys fees in this matter.
AND The Plaintiff further prays that a Jury decide any and all claims as triable for a jury and any
and all such and further ORDERS that the Court deems just and proper.

Ahmed Salau
Petitioner pro se
Dated 2/17/2015