Clemons v. Google, Inc.

Filing 1

COMPLAINT against Google, Inc., filed by Richard Clemons.(dvanm, )

FILED

United States District Court
Eastern district of Alexandria Virginia

28 P 12= l|8

CLERK US DISTRICT COURT

filenMWW^

Richard demons

Plaintiff

V

Google Inc.
Defendant

Civil complaint pursuant
To title 2 of SCA
(Parties)
Plaintiff Is a law student and is homeless. He can be reached at

[e-mail]. His previous address for venue purposes was 211 n.
union suite ICQ. Alexandria, Va. 22314

Defendant Is Google Inc. located at 1875 Explorer St. Reston, Va. 20190.
(Jurisdiction)
This court has jurisdiction pursuant to 28 USC 1331.

(The complaint)

1)On or about June of 2016 plaintiff entered a service agreement with defendant
Google Inc.-identified by statute as a service provider- for an email account which
under the agreement with plaintiff was to be named lawvermeJ^amail.com.
2) That such account was activated and maintained in good standing by plaintiff.
That such maintenance included plaintiffdepositing valuable intellectual
properties on various dates but specifically named:
a) The Poet. Ashort book to be described in deposition.
b) The Reverend. Afull novel to be described in deposition.

c) Aman and a woman. Ashort story published electronically by Web.com with
full rights reverting to plaintiff only

d) God loves skinny too. Ashort story published electronically by Web.com with
full rights reverting to plaintiff only.

e)Rome loved Jesus. Ashort story published electronically by Web.com with full
rights reverting to plaintiff only.

f) Afamily life. Ashort story published electronically by Web.com with full rights
reverting to plaintiff only.

3) That in June of 2017, plaintiff made repeated contact attempts with defendant
alerting them that such email account had been compromised and that because
of the commercial related instruments at stake, plaintiffwould need a procedure

adequate to resolve what was identity theft and fraud perpetrated upon the
account. On unspecified dates but retained by google servers, defendant

responded by automated reply that because plaintiff no longerpossessed the cell
phone he used when opening the account, that google was unable to verify that
the account belonged to plaintiff,

4) Plaintiff in written correspondence to Google's email support team informed
defendant that their automated response was insufficient because itfailed to
offer a resolution process in face of growing identity theft, maintained copy

right material with commercial value that belonged to plaintiff and that by law,
a state identification and other papers approved by the commonwealth of
Virginia, was sufficient to establish plaintiffs identity.

5) Surprisingly; two more attempts in communicating with defendant to provide a
forum for resolution in the month of August (2017) were simply ignored. Plaintiff
is still without his work and has suffered deadlines of contract dispute with his

publisher Thom Byxbe-an independent internet publisher.
(claim for relief)

Plaintiff seeks relief pursuant to 18 use 2707(a), (b)(1).

(relief sought)

Plaintiff prays preliminary injunction ordering defendant to surrender the account
in question and all electronically stored writings deposited by plaintiff andany
deposited by unauthorized parties.

Plaintiff who has established a reputation nationally for writing spiritual; and
political commentary, seeks 100;000. In damages from defendant.

Respectfully Submitted,
Richard Clemt

Fbiloyal707:

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRIGINIA
DIVISION

^

'laintiff(s).

V.

Civil Action Number: I i

Qod&k •TTor..

Defendant(s).

LOCAL RULE 83.1(M) CERTIFICATION
I declare under penalty of perjury that:

No attorney has prepared, or assisted in the preparation of_
(Title of Document)

Name ofPr ?Se I%rty (Prjnt/f Type)
Signature of Pro Se Party
Executed on:

7

Date)
OR

The following attorney(s) prepared or assisted me in preparation of
(Title of Document)
(Name of Attorney)

(Address of Attorney)

(Telephone Number of Attorney)

Prepared, or assisted in the preparationof, this document
(Name of Pro Se Party (Print or Type)

Signature of Pro Se Party

Executed on:

(Date)

0^ 63