First Amended Complaint Clark Lafferty Jones

IN UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF
MISSOURI,
CENTRAL DIVISION
THE HONORABLE NANETTE K. LAUGHERY, PRESIDING
AHMED SALAU,
) Case No. 2:14-CV-04307NKL
P. O. BOX 6008,
PRINCETON, WV 24740.
)
)
Plaintiff, pro se
)
)
)FIRST AMENDED
COMPLAINT
vs.
)
CLARK LAFFERTY
JONES,
11 NORTH 7TH STREET,
COLUMBIA MO 65201
)
JURY TRIAL
DEMANDED
)
JONES, SCHNEIDER &
STEVENS LLC.
11 NORTH 7TH STREET,
COLUMBIA MO 65201
)
)
DefendantS.
COMPLAINT
Plaintiff Ahmed Salau, pro se, for his first amended complaint alleges as follows:
NATURE OF THE CAUSE
This is an action for breach of contract, negligent representation, intentional

infliction of emotional distress, outrage, breach of fiduciary duty, legal malpractice and
conspiracy to commit all of the above arising out of the tortious misconduct of the
Defendants Clark Lafferty Jones and his employer Jones, Schneider & Stephens LLC
committed while they represented the Plaintiff in various legal and quasi-legal
proceedings. As detailed herein, Plaintiff is entitled to actual damages, exemplary
damages, special damages, compensatory and punitive damages. The events alleged
herein took place in the Western District of Missouri such that Missouri substantive laws
apply herein. Plaintiff requests a jury decide each and every one of his claims as pled and
as triable by a jury.
JURISDICTION AND VENUE
This Court has subject matter jurisdiction over this action based on diversity
of citizenship pursuant to 28 U.S.C 1332(a). Venue is proper pursuant to 28 U.S.C
1391(b) because all of the events or actions giving rise to Salaus claims arose in
this district. Salau has incurred harm in this district as a result of the tortious
misconduct of the Defendants, and the Defendants expressly aimed their tortious
misconduct at this district.
THE PARTIES
1. Plaintiff, Ahmed Salau is a natural person and is a resident of Princeton,

West Virginia. Plaintiff majored in chemistry and psychology and had a
minor in women and gender studies. Plaintiff was also a professional research
associate, co-author, co-investigator on a number of ongoing scientific
projects that have been published in peer-reviewed journals published by
reputable organizations like the American Chemical Society among others.
Plaintiff also had another job as a student customer service assistant at the
University of Missouri Campus Dining Services. Plaintiff was also involved
and/or is a member of numerous groups on campus including but not limited
to STOP TRAFFIC, BAPTIST STUDENT UNION, ON THE ROCK,
AUTISM SPEAKS, PSI CHI, THE FOOD BANK, GREEN DOT,
Foundation for the International Medical Relief of Children
(FIMRC),among other organizations. Plaintiff is also the Founder, President
and Chief Executive Officer of PARIS Angels a mentoring program for atrisk youth.
2. Defendant, Clark Lafferty Jones is a natural person and is a resident of
Columbia, Missouri. Defendant Clark Lafferty Jones represented Plaintiff
Salau in various legal and quasi-legal proceedings.
3. Defendant Jones, Schneider & Stevens is a Missouri corporation with her

principal place of business in Columbia, Missouri. Defendant Jones,
Schneider & Stevens was the employer of Defendant Clark Lafferty Jones
during all relevant times alleged herein.
STATEMENT OF FACTS
3.
On or about September 11th 2012, an Emergency Domestic Violence

Protection Order was entered against the Plaintiff by the Circuit Court of
Boone County, Missouri upon application by Hannah Noelle Brackett.
4.
On or about October 1st 2012, the Plaintiff hired the Defendants Clark
Lafferty Jones and Jones, Schneider & Stevens LLC to represent him in
the Domestic Violence Protection Order hearing.
5.
On or about October 1st, 2012, the Plaintiff provided Defendants Clark

Lafferty Jones & Jones, Schneider & Stevens LLC with the copies of the
Emergency Domestic Violence Protection Order & Notice of Hearing on
the full Domestic Violence Protection hearing scheduled for October 3 rd,
2012 & payment of $500.00 for the legal services to be provided.
6.
On or about October 1st 2012, the Defendant Clark Lafferty Jones acting
individually on his behalf and as an agent &/or other duly authorized
representative of the Defendant Jones, Schneider & Stevens LLC informed
the Petitioner that he need not appear at the October 3 rd 2012 hearing
because he would request a continuance and take care of it.
7.
On or about October 3rd 2012, the Defendant Clark Lafferty Jones acting
individually on his behalf and as an agent &/or other duly authorized
representative of the Defendant Jones, Schneider & Stevens LLC failed to
show up at the Domestic Violence Protection hearing or request a
continuance.
8.
Due to the tortious misconduct of Defendant Clark Lafferty Jones and

Defendant Jones, Schneider & Stevens LLC, the Petitioner was not only
able to present evidence in his favor but not at all which directly and
proximately caused a fraudulently obtained Domestic Violence Protection
Order to go into effect.
9.
On or about October 4th 2012, the Plaintiff Salau was conducting his
lawful activities as an employee of the University of Missouri Campus
Dining Services when he was approached by Hannah Brackett and
University of Missouri law enforcement officers John Doe and Jane Doe
about allegedly being in violation of the Domestic Violence Protection
Order for being at work in the Rollins Dining Hall.
10.
The Plaintiff Salau immediately contacted his direct supervisor Jeffrey J.

Lee and made his exit before any contact was made with the Law
Enforcement Officers and Hannah Brackett.
11.
On/or about October 4th 2012, the Plaintiff Salau was informed by Jeffrey
J. Lee that he would no longer work at the Rollins Dining Hall and that he
would be transferred to a different Dining Hall.
12.
On/or about October 5th 2012, the Plaintiff was informed by Jeffrey J. Lee
that, we received word from our administration that we have to
terminate you.
13.
Accordingly, the Plaintiff was terminated from his employment with the
Campus Dining Services.
14.
On/or about October 4th 2012, the Plaintiff make inquiries from the
Defendant Clark Lafferty Jones as to why he failed to show up for the
Domestic Violence Protection hearing or request a continuance on October
3rd 2012, and the Defendant Clark Lafferty Jones stated that he did not
know that the hearing was on that day, notwithstanding the fact that the
Plaintiff Salau had properly informed him of said hearing and given him
the Emergency Order entered apriori.
15.
On/or about October 9th 2012, the Defendant Clark Lafferty Jones filed a
motion for a new trial in the Domestic Violence Protection Order matter.
16.
On/or about October 12th 2012, Honorable Leslie Schneider transferred the
case to Honorable Sara Miller the Family Court Commissioner, due to a
conflict of interest as her husband Mr. Schneider, is a Partner in the firm
of Jones, Schneider & Stevens LLC The Defendant Clark Lafferty Jones
employer.
17.
On/or about October 22nd 2012, the Domestic Violence Protection Order is
set for a hearing on November 28th 2012 on the motion for a new trial.
18.
On/or about November 28th 2012, the Defendant Clark Lafferty Jones
informed the Plaintiff Salau that, it is better to just consent to the
DVPO & deny the allegations.
19.
On/or about November 28th 2012, the Plaintiff Salau, upon the Defendant
Clark Lafferty Jones erroneous and negligent advice consented to the
Domestic Violence Protection Order.
20.
On/or about February 1 st 2013, the Plaintiff Salau recognizes the erroneous
advice he had been provided by the Defendant Clark Lafferty Jones in the
Domestic Violence Protection Order matter and files a pro se motion to set
aside the Order due to it being obtained by fraud and requested a new trial.
21.
The Motion for a new trial was litigated for several months before the
fraudulently obtained Domestic Violence Protection Order expired on/or
about November 22nd 2013.
22.
Multiple complexities resulted as a result of the Defendants Clark Lafferty

Jones and Jones, Schneider & Stevens LLCs tortious misconduct
including but not limited to the Plaintiff Salaus inability to subpoena
records beneficial to his case, the inability to cross-examine Hannah
Brackett under oath and ultimately, the inability to expose the improper
and fraudulent nature of Hannah Bracketts Domestic Violence Protection
application.
23.
During the pendency of the fraudulently obtained Domestic Violence

Protection Order, the Plaintiff Salau experienced a loss of multiple
constitutionally guaranteed rights including but not limited to rights
secured by the 2nd Amendment and 14th Amendment.
24.
On/or about September 25th 2012, Plaintiff received an email from the
University of Missouri Office of Student Conduct requesting that the
Plaintiff, call the Office of Student Conduct and schedule a meeting
with Donell Young due to allegations of student conduct violations
stemming from the fraudulent claims made by Hannah Brackett.
25.
On/or about October 1st 2012, the Plaintiff Salau met with Defendant
Clark Lafferty Jones and hired him to represent the Plaintiff in the Student
Conduct proceedings and made a payment of $500.00 towards same.
26.
On/or about October 5th 2012, upon the Plaintiff Salau met with Donell
Young and scheduled a meeting between the Plaintiff Salau, Donell
Young, & Defendant Clark Lafferty Jones for October 9 th 2012 at 3:00pm.
27.
On/or about October 9th 2012, Plaintiff Salau, Defendant Clark Lafferty
Jones & Donell Young meet at the Office of Student Conduct.
28.
During the above meeting, Plaintiff Salau & Defendant Clark Lafferty
Jones requested any & all supporting documents underlying the alleged
student conduct violations and if the stated allegations were the only set
the Plaintiff would be defending.
29.
Donell Young responded that the allegations concerning Hannah Brackett

were the only allegations the Plaintiff Salau would be defending.
30.
The Plaintiff Salau and Defendant Clark Lafferty Jones requested a formal
hearing during which the Plaintiff Salau could challenge, rebut & offer
evidence.
31.
The formal hearing was scheduled for November 12th 2012. At least a
week before this date, the Plaintiff Salau instructs the Defendant Clark
Lafferty Jones to request a continuance to allow for time to receive all
requested supporting materials from the University and the Defendant
Clark Lafferty Jones does not request same.
32.
On/or about November 7th 2012, the Plaintiff Salau upon knowledge,
information, and belief that Defendant Jones had not requested the
continuance, requests same himself.
33.
Shortly after the Plaintiff Salau sent his request for a continuance, the
Defendant Clark Lafferty Jones requests the continuance he had failed to
request as instructed. This was a part of the series of actions &/or inactions
taken or not taken by the Defendant Clark Lafferty Jones to undermine and
ultimately defeat the Plaintiff Salaus cause.
34.
A continuance was granted on November 12th 2012 and a new hearing date
was set for November 28th 2012.
35.
On/or about November 2nd 2012, a file was sent to the Defendant Clark
Lafferty Jones as part of our requests for evidence. This file
20121102102450.pdf allegedly contained all of the Universitys case
against the Plaintiff Salau, which consisted solely of the false allegations
made by Hannah Brackett.
36.
requested after multiple requests by the Plaintiff Salau, video surveillance
footage and card swipe logs from the University.
37.
On/or about November 6th 2012, the request was denied by the University
and the Plaintiff requested that the Defendant Clark Lafferty Jones compel
them to produce the requested records by, filing anything like a
preliminary injunction
38.
incorrectly informs the Plaintiff that no relief was possible in the student
conduct proceedings from the Circuit Court of Boone County, Missouri.
39.
On/or about November 21st 2012, the Office of Student Conduct added
more allegations of student conduct violations to the Plaintiffs case.
40.
On/or about November 21st 2012, the Plaintiff requests that the Defendant
Clark Lafferty Jones request the names and addresses of any and all
witnesses and complainants so that the Plaintiff could investigate said
claims and conduct other forms of due diligence necessary.
41.
On/or about November 21st 2012, the request for names and addresses of
any and all witnesses and complainants was denied by the University and
the Plaintiff Salau requests that the Defendant Clark Lafferty Jones file
something to compel the University to release same and the Defendant
Clark Lafferty Jones negligently re-asserts that there is no relief possible
from the Circuit Courts of Boone County, Missouri.
42.
On/or about November 23rd 2012 four days before the new hearing date,
a bunch of documents were made available to the Defendants Clark
Lafferty Jones and Jones, Schneider & Stevens LLC excluding the video
footage, and card swipe logs, names & addresses of all witnesses and
complainants.
43.
As such, the Plaintiff Salau requests that the Defendant Clark Lafferty
Jones request another continuance to receive the pertinent information.
44.
The Defendant Clark Lafferty Jones failed so to do until 10AM of

November 28th 2012 -the day of the student conduct hearing.
45.
On/or about November 26th 2012, the Plaintiff Salau is informed by the
Defendant Clark Lafferty Jones that he needs another retainer in the
amount of $1500.00 to continue representing Plaintiff Salau at the hearing
on November 28th 2012.
46.
On/or about November 28th 2012, the Plaintiff informs the Defendant
Clark Lafferty Jones that he does not have those funds. The Defendant
Clark Lafferty Jones and the Defendant Jones, Schneider & Stevens LLC
then discharge the Plaintiff Salau as a client and delivered a discharge
letter to the Plaintiff Salau.
47.
Plaintiff Salau then requested that the Defendant Clark Lafferty Jones
communicate with the Office of Student Conduct, the need for another
continuance to allow the Plaintiff Salau time to retain new Counsel.
48.
Plaintiff Salau also informs the Defendant Clark Lafferty Jones that due to
the criminal back drop of the allegations, the right to Counsel at even a
student conduct proceeding has been interpreted liberally by some Federal
Courts.
49.
Upon this information, the Defendant Clark Lafferty Jones consults with
John Doe(s) 1 & 2 Partners in the Defendant Jones, Schneider & Stevens
LLC.
50.
Upon confirmation of the right to counsel as being applicable in the

student conduct proceedings, and after consultation with the Partner(s), the
Defendant Clark Lafferty Jones informs the Plaintiff that he would request
a continuance to allow for the Plaintiff Salau to hire substitute Counsel.
51.
The Plaintiff Salau then advises the Defendant Clark Lafferty Jones that
should he be unable to get a continuance, he was discharged and released
from further representation of the Plaintiff Salau because Defendant Jones
should have requested the continuance weeks earlier.
52.
Around 1pm on November 28th 2012 the day of the Student Conduct
hearing, and after multiple failed attempts to reach the Defendant Clark
Lafferty Jones by office phone, cellular phone, & email, to confirm he had
requested the continuance as agreed, the Plaintiff Salau reiterates by text
message to Defendant Clark Lafferty Jones that he is discharged and
released from further representation of the Plaintiff Salau.
53.
The Plaintiff Salau subsequently heads to the Student Conduct hearing to

inform the panel of the latest developments only to find the Defendant
Jones sitting in the room misrepresenting himself as the Plaintiff Salaus
attorney!!!
54.
The Plaintiff then requests a recess outside of the Panels hearing &
informs the Defendant Clark Lafferty Jones that should he continue to
improperly misrepresent himself as Plaintiff Salaus attorney, Plaintiff
Salau would pursue any and all legal actions against him.
55.
Upon conclusion of this conversation, the Defendant Clark Lafferty Jones

abruptly goes into the Panel Hearing Room despite Plaintiff Salau
requesting that he leave, and informs the Panel that Plaintiff Salau had just
discharged him an hour before the hearing as opposed to the truth that he
had abandoned Plaintiff Salau at his hour of need due to Plaintiff Salaus
inability to pay him which led to Plaintiff Salau discharging him.
56.
Due to the Defendant Clark Lafferty Jones statements to the Panel, they
ruled that the firing of Defendant Jones had been untimely and a deliberate
move specifically designed to delay the Panel meeting. The Panel further
decided to have the hearing regardless of the absence of any of the

Plaintiffs witnesses, the absence of critical evidence to properly inform
Plaintiff Salau and assist in his defense, and an attorney to protect the
Plaintiffs Constitutionally guaranteed interests.
57.
Accordingly, the Plaintiff could not present his side of the story or
disprove the other side of the story and the Plaintiff Salau was expelled
from the University, fired from his University jobs, publically branded as a
rapist, publically humiliated, lost out on all the research work he had
worked hard on, and most importantly, his Constitutionally guaranteed
rights to procedural and substantive due process & other 5th Amendment
rights were violated due in part to Defendant Clark Lafferty Jones &
Defendant Jones, Schneider & Stevens LLCs egregious and tortious
misconduct.
CLAIMS FOR RELIEF

FIRST CLAIM FOR RELIEF
(Breach of Fiduciary Duty)
58.
Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 57 as if fully set forth at length herein.
59.
The Defendants Clark Lafferty Jones and Jones, Schneider & Stevens LLC
had a legal obligation to defend Plaintiff Salau to the best of their abilities
and without regard to whether or not Plaintiff Salau owed an existing
balance or not.
.
60.
In spite of the legal obligation to properly defend Plaintiff Salau in the

Domestic Violence Protection Order matter and the Student Conduct
proceedings, the Defendants Clark Lafferty Jones & Jones, Schneider &
Stevens breached their fiduciary obligations to Plaintiff Salau in one or
more of the following ways:

a)
Defendants failed to fully investigate Plaintiff Salaus merits in the
Domestic Violence Protection Order proceedings and failed to fully

investigate Salaus student conduct matter;
b)
Defendants failed to recognize the severity of Bracketts
fraudulent allegations;
c)
Defendants ignored the potential for an action seeking
extraordinary relief to compel the University to produce the requested

evidence;
d)
Defendants ignored the adverse effect that a fraudulently obtained
Domestic Violence protection Order would have on the Student Conduct

Proceedings;
e)
Defendants failed to act in the best interest of the Plaintiff Salau
when Defendant Clark Lafferty Jones failed ot make timely requests for
evidence and continuances;
f)
Defendants failed to act in the best interest of Plaintiff Salau when
the Defendant Clark Lafferty Jones upon advise of Senior Partners at

Defendant Jones, Schneider & Stevens LLC decided to misrepresent
himself as Plaintiffs Counsel at the Student Conduct hearing
notwithstanding their prior agreement that Defendant Clark Lafferty Jones
would request a continuance to allow for the hiring of substitute Counsel;
g)
Defendants breached their duty of care to Plaintiff Salau by
intentionally &/or recklessly failing to use reasonable means to advise the

University and the Office of Student Conduct that Plaintiff Salau has
certain unalienable rights that needed to be protected and/or preserved by
the granting of a continuance to hire substitute counsel;
h)
As a direct and proximate result of the Defendants Clark Lafferty
Jones and Jones, Schneider & Stevens LLCs breach of their fiduciary
duty to Plaintiff Salau, the Plaintiff Salau has suffered substantial injuries
and damages as herein set forth:
1)
Plaintiff has lost income from his campus
employment;
2)
Plaintiff has lost the good name he had due to the stigma
attached to anyone expelled from an institution of higher learning

especially for alleged sexual misconduct.
3)
Plaintiff has incurred significant expenses in prosecuting
the student conduct proceedings and the Domestic Violence Protection

Order as a result of the Defendants reckless handling of both matters not
only in the Circuit Court of Boone County, MO but also in the Missouri
Court of Appeals.
4)
Plaintiff Salau has suffered an extreme amount of
emotional distress & will likely incur additional damages in the future both
emotionally and financially.
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against
Defendant awarding compensatory damages in the amount of $1,100,000.00 plus
punitive damages in an amount that will fairly and reasonably punish Defendant
for their conduct, and further ordering Defendant to pay consequential and
incidental damages, pre-judgment and post-judgment interest costs of suit and
attorneys fees, and further equitable relief as this honorable Court deems just.
SECOND CLAIM FOR RELIEF

(Legal Malpractice)
61.

62.
balance or not.
.
63.

Stevens committed legal malpractice in one or more of the following
ways:
a)
b)
c)
evidence;
d)
Proceedings;
e)
f)
g)
h)
1)
employment;
2)
3)
Court of Appeals.
4)
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment

against Defendant awarding compensatory damages in the amount of
$1,100,000.00 plus punitive damages in an amount that will fairly and
reasonably punish Defendant for their conduct, and further ordering
Defendant to pay consequential and incidental damages, pre-judgment and postjudgment interest costs of suit and attorneys fees, and further equitable relief as
this honorable Court deems just.
THIRD CLAIM FOR RELIEF

(Outrage)
64.

65.
repeats and re-alleges the allegations set forth in paragraphs

66.
balance or not.
67.

Stevens committed outrage against Plaintiff Salau in one or more of the
following ways:
a)
b)
c)
evidence;
d)
Proceedings;
e)
f)
g)
h)
1)
employment;
2)
3)
Court of Appeals.
4)

FOURTH CLAIM FOR RELIEF

(Negligent Representation)
68.

69. The Defendants Clark Lafferty Jones and Jones, Schneider & Stevens LLC
balance or not.
70. In spite of the legal obligation to properly defend Plaintiff Salau in the
Stevens negligently represented Plaintiff Salau in one or more of the
following ways:
a) Defendants failed to fully investigate Plaintiff Salaus merits in the
b) Defendants failed to recognize the severity of Bracketts fraudulent
allegations;
c) Defendants ignored the potential for an action seeking extraordinary relief
to compel the University to produce the requested evidence;
d) Defendants ignored the adverse effect that a fraudulently obtained
Proceedings;
e) Defendants failed to act in the best interest of the Plaintiff Salau when
Defendant Clark Lafferty Jones failed ot make timely requests for evidence
and continuances;
f) Defendants failed to act in the best interest of Plaintiff Salau when the
Defendant Clark Lafferty Jones upon advise of Senior Partners at Defendant
Jones, Schneider & Stevens LLC decided to misrepresent himself as

Plaintiffs Counsel at the Student Conduct hearing notwithstanding their prior
agreement that Defendant Clark Lafferty Jones would request a continuance
to allow for the hiring of substitute Counsel;
g) Defendants breached their duty of care to Plaintiff Salau by intentionally
&/or recklessly failing to use reasonable means to advise the University and
the Office of Student Conduct that Plaintiff Salau has certain unalienable
rights that needed to be protected and/or preserved by the granting of a
continuance to hire substitute counsel;
h) As a direct and proximate result of the Defendants Clark Lafferty Jones
and Jones, Schneider & Stevens LLCs breach of their fiduciary duty to
Plaintiff Salau, the Plaintiff Salau has suffered substantial injuries and
damages as herein set forth:
1)
Plaintiff has lost income from his campus employment;
2) Plaintiff has lost the good name he had due to the stigma attached
to anyone expelled from an institution of higher learning especially for
alleged sexual misconduct.
3) Plaintiff has incurred significant expenses in prosecuting the
student conduct proceedings and the Domestic Violence Protection Order as a
result of the Defendants reckless handling of both matters not only in the
Circuit Court of Boone County, MO but also in the Missouri Court of
Appeals.
4) Plaintiff Salau has suffered an extreme amount of emotional
distress & will likely incur additional damages in the future both emotionally
and financially.

for their conduct, and further ordering
Defendant to pay consequential and incidental damages, pre-judgment and postjudgment interest costs of suit and attorneys fees, and further equitable relief as
this honorable Court deems just.
FIFTH CLAIM FOR RELIEF

(Breach of Contract)
71.
Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 7

as if fully set forth at length herein.
72.
The Defendants Clark Lafferty Jones and Jones, Schneider & Stevens
LLC had a legal obligation to defend Plaintiff Salau to the best of their
abilities and without regard to whether or not Plaintiff Salau owed an
existing balance or not.
73.

Stevens breached their contract with Plaintiff Salau in one or more of the
following ways:
a)

b)
c)

evidence;
d)

Proceedings;
e)
f)

g)

h)
1)
employment;
2)

3)

Court of Appeals.
4)
SIXTH CLAIM FOR RELIEF

(Intentional infliction of Emotional Distress)
74. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to
73 as if fully set forth at length herein.
.
75. The Defendants Clark Lafferty Jones and Jones, Schneider & Stevens LLC
balance or not.
.
76.

Stevens intentionally inflicted emotional distress on Plaintiff Salau in one
or more of the following ways:
a)
b)
c)
evidence;
d)
Proceedings;
e)
f)
g)

h)
1)
employment;
2)
3)
Court of Appeals.
4)
SEVENTH CLAIM FOR RELIEF

(Conspiracy to commit all the above torts)
77.
Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to

76 as if fully set forth at length herein.
78.
balance or not.
79.

Stevens conspired to breach their fiduciary duty, conspired to commit legal
malpractice, conspired to commit outrage, conspired to commit negligent
representation, conspired to breach their contract, conspired to
intentionally inflict emotional distress on & against the Plaintiff Salau in
one or more of the following ways:
a)
b)
c)
evidence;
d)
Proceedings;
e)
f)
g)

h)
1)
employment;
2)
3)
Court of Appeals.
4)

Defendants Clark Lafferty Jones & Jones, Schneider & Stevens LLC jointly and
severally awarding compensatory damages in the amount of
$1,100,000.00 plus punitive damages in an amount that will fairly and
reasonably punish Defendant for their conduct, pre-judgment and post-judgment
interest and further ordering Defendant to pay consequential and incidental
damages, costs of suit and attorneys fees, special damages, exemplary damages
and any and all such & further equitable relief and/or Orders as this honorable
Court deems just.
Respectfully submitted,
___________________________
Ahmed Salau
Plaintiff Pro Se
P O Box 6008
Princeton, WV 24740
Phone) 5403151147 Fax) 5403016034 ahmed@ahmedsalau.com
Dated : Princeton, West Virginia March 2nd, 2015.

First Amended Complaint Clark Lafferty Jones

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

First Amended Complaint Clark Lafferty Jones

Uploaded by

Copyright:

Available Formats

IN UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF

) Case No. 2:14-CV-04307NKL

NATURE OF THE CAUSE

This is an action for breach of contract, negligent representation, intentional

1. Plaintiff, Ahmed Salau is a natural person and is a resident of Princeton,

3. Defendant Jones, Schneider & Stevens is a Missouri corporation with her

On or about September 11th 2012, an Emergency Domestic Violence

On or about October 1st, 2012, the Plaintiff provided Defendants Clark

Due to the tortious misconduct of Defendant Clark Lafferty Jones and

The Plaintiff Salau immediately contacted his direct supervisor Jeffrey J.

Multiple complexities resulted as a result of the Defendants Clark Lafferty

During the pendency of the fraudulently obtained Domestic Violence

Donell Young responded that the allegations concerning Hannah Brackett

The Defendant Clark Lafferty Jones failed so to do until 10AM of

Upon confirmation of the right to counsel as being applicable in the

The Plaintiff Salau subsequently heads to the Student Conduct hearing to

Upon conclusion of this conversation, the Defendant Clark Lafferty Jones

decided to have the hearing regardless of the absence of any of the

CLAIMS FOR RELIEF

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

In spite of the legal obligation to properly defend Plaintiff Salau in the

more of the following ways:

Defendants failed to fully investigate Plaintiff Salaus merits in the

Domestic Violence Protection Order proceedings and failed to fully

Defendants failed to recognize the severity of Bracketts

Defendants ignored the potential for an action seeking

extraordinary relief to compel the University to produce the requested

Defendants ignored the adverse effect that a fraudulently obtained

Domestic Violence protection Order would have on the Student Conduct

Defendants failed to act in the best interest of the Plaintiff Salau

Defendants failed to act in the best interest of Plaintiff Salau when

the Defendant Clark Lafferty Jones upon advise of Senior Partners at

Defendants breached their duty of care to Plaintiff Salau by

intentionally &/or recklessly failing to use reasonable means to advise the

As a direct and proximate result of the Defendants Clark Lafferty

Plaintiff has lost income from his campus

attached to anyone expelled from an institution of higher learning

Plaintiff has incurred significant expenses in prosecuting

the student conduct proceedings and the Domestic Violence Protection

Plaintiff Salau has suffered an extreme amount of

SECOND CLAIM FOR RELIEF

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

In spite of the legal obligation to properly defend Plaintiff Salau in the

WHEREFORE, Plaintiff prays this honorable Court to enter a judgment

THIRD CLAIM FOR RELIEF

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

repeats and re-alleges the allegations set forth in paragraphs

In spite of the legal obligation to properly defend Plaintiff Salau in the

incidental damages, pre-judgment and post-judgment interest costs of suit and

FOURTH CLAIM FOR RELIEF

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

Jones, Schneider & Stevens LLC decided to misrepresent himself as

WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against

FIFTH CLAIM FOR RELIEF

Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 7

In spite of the legal obligation to properly defend Plaintiff Salau in the

Defendants failed to fully investigate Plaintiff Salaus merits in the

Domestic Violence Protection Order proceedings and failed to fully

Defendants failed to recognize the severity of Bracketts

Defendants ignored the potential for an action seeking

extraordinary relief to compel the University to produce the requested

Defendants ignored the adverse effect that a fraudulently obtained

Domestic Violence protection Order would have on the Student Conduct

Defendants failed to act in the best interest of the Plaintiff Salau