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-04307-

NKL

P. O. BOX 6008, )

PRINCETON, WV 24740. )

)

Plaintiff, pro se )

)

vs. )FIRST AMENDED

COMPLAINT

)

CLARK LAFFERTY

JONES,

) JURY TRIAL

DEMANDED

11 NORTH 7TH STREET,

COLUMBIA MO 65201

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 Salau’s 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 at-

risk 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 3rd,

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 3rd 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 1st 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 LLC’s tortious misconduct

including but not limited to the Plaintiff Salau’s 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 Brackett’s 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 9th 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 Salau’s 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 University’s case

against the Plaintiff Salau, which consisted solely of the false allegations

made by Hannah Brackett.


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…”


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 Plaintiff’s 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 Salau’s

attorney!!!

54. The Plaintiff then requests a recess outside of the Panel’s hearing &

informs the Defendant Clark Lafferty Jones that should he continue to

improperly misrepresent himself as Plaintiff Salau’s 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 Salau’s

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

Plaintiff’s witnesses, the absence of critical evidence to properly inform

Plaintiff Salau and assist in his defense, and an attorney to protect the

Plaintiff’s 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 LLC’s 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 Salau’s merits in the

Domestic Violence Protection Order proceedings and failed to fully

investigate Salau’s student conduct matter;

b) Defendants failed to recognize the severity of Brackett’s

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 Plaintiff’s 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 LLC’s 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

attorney’s fees, and further equitable relief as this honorable Court deems just.

SECOND CLAIM FOR RELIEF

(Legal Malpractice)






balance or not.

.




Stevens committed legal malpractice in one or more of the following

ways:








evidence;



Proceedings;




















employment;








Court of Appeals.




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 attorney’s fees, and further equitable relief as

this honorable Court deems just.

THIRD CLAIM FOR RELIEF

(Outrage)



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





balance or not.




Stevens committed outrage against Plaintiff Salau in one or more of the

following ways:








evidence;



Proceedings;




















employment;








Court of Appeals.










FOURTH CLAIM FOR RELIEF

(Negligent Representation)






balance or not.




Stevens negligently represented Plaintiff Salau in one or more of the

following ways:




b) Defendants failed to recognize the severity of Brackett’s fraudulent

allegations;

c) Defendants ignored the potential for an action seeking extraordinary relief

to compel the University to produce the requested evidence;



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

Plaintiff’s 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 LLC’s 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 post-

judgment interest costs of suit and attorney’s 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.




Stevens breached their contract with Plaintiff Salau in one or more of the

following ways:








evidence;



Proceedings;




















employment;








Court of Appeals.










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.

.




balance or not.

.




Stevens intentionally inflicted emotional distress on Plaintiff Salau in one

or more of the following ways:








evidence;



Proceedings;




















employment;








Court of Appeals.










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.




balance or not.




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:








evidence;



Proceedings;




















employment;








Court of Appeals.











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 attorney’s 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 [email protected]

Dated : Princeton, West Virginia March 2nd, 2015.

mailto:[email protected]

first amended complaint clark lafferty jones

Documents

plaintiff salau

defendant jones

employer jones

western district of

missouri corporation

legal malpractice

presiding ahmed salau

quasilegal proceedings