united states district court for the district of...

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

________________________________________ RYAN J. STRASSER, 2121 Grove Ave. #2 Richmond, VA 23220, Plaintiff,

) ) ) ) ) ) )

VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE AND DECLARATORY RELIEF

v. SARAH JONES DICKENS, 715 Stansbury Road, Littleton, NC 27850

) ) ) ) ) )

Civ. No. __________________ Jury Trial Demanded

Defendant. __________________________________________

) )

VERIFIED COMPLAINT

Plaintiff Ryan J. Strasser, for his verified complaint against Defendant Sarah Jones

Dickens, states and alleges the following:

INTRODUCTION Plaintiff Ryan J. Strasser (“Mr. Strasser”) and Defendant Sarah Jones Dickens

(“Defendant”) lived together for more than two years, during which Mr. Strasser assumed the

responsibilities of a sole breadwinner. After roughly a year together, in anticipation of marriage,

Mr. Strasser purchased a 4.06-carat, $100,000+ diamond engagement ring, which he offered to

Defendant with his proposal of marriage. Defendant accepted the ring and the marriage proposal

upon which the offer of the ring was predicated. Roughly eleven months later, the parties’

marriage plans collapsed with a highly contentious break up that ended their engagement.

Although Mr. Strasser was the sole lessee of their communal home in Washington, D.C., he

Case 1:18-cv-02207 Document 1 Filed 09/24/18 of 23

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vacated the premises but continued to pay rent for her occupancy. Following repeated requests

and months of negotiation during which Mr. Strasser sought to retrieve his belongings, Defendant

finally agreed to return most but certainly not all of Mr. Strasser’s property remaining at the home

she continued to occupy. However, she refused to return Mr. Strasser’s conditional gift of the

engagement ring, as well as electronic equipment. While she ultimately abandoned the leasehold

estate without informing Mr. Strasser (and left conditions that Mr. Strasser, as lessee, had to pay to

clean up or repair), she apparently retained possession of his ring and his electronics. After

repeated unsuccessful entreaties to her counsel to arrange for the return of these items, Mr.

Strasser was left with no choice but to file this action for the return of his belongings and for

injury to his leasehold tenancy caused by Defendant.

PARTIES

1. Mr. Strasser is a resident of the Commonwealth of Virginia, residing therein at

2121 Grove Ave., #2, Richmond, Virginia, 23220.

2. Upon information and belief, Defendant has resettled to the state of North Carolina

and is domiciled therein at 715 Stansbury Road, Littleton, North Carolina, 27850.

JURISDICTION

3. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a)(1) as

the parties are diverse and the amount in controversy exceeds $75,000.

4. Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391(b)(1). Mr.

Strasser and Defendant resided at 6520 Barnaby Street, NW, Washington, DC, 20015, from July

21, 2016 until the parties terminated their relationship on January 8, 2018, and the facts giving rise

to the claims alleged herein occurred within this District. Defendant, having resided in the district


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throughout the engagement and beyond, has sustained sufficient contacts with the District, and it

is reasonably foreseeable that she will be held accountable for her actions in this District.

FACTUAL BACKGROUND

The Relationship’s Formation

5. Mr. Strasser and Defendant (the “Parties”) met as college classmates at Duke

University in approximately 2004. Despite taking different paths after college—Mr. Strasser

earned a law degree and a Master of Public Administration, whereas Defendant studied art history

in Cambodia and later enrolled in a Ph.D. program at Duke University—the parties enjoyed a

friendly relationship for many years and eventually began dating in early November of 2015.

6. At the time that the parties began dating, Mr. Strasser was residing in Arlington,

Virginia at a one-bedroom condominium unit he had purchased in June 2013 (the “Westview”)

and was associated with a prominent D.C. law firm. Defendant resided with her parents in

Littleton, North Carolina and was pursuing her Ph.D degree from Duke University.

The Parties’ Co-Residency at the Westview

7. On December 4, 2015, Defendant drove to visit Mr. Strasser at the Westview after

conducting research in New England for her Ph.D. dissertation. As she approached the Westview,

Defendant’s car was struck by a vehicle in a hit-and-run. Defendant’s car sustained significant

damage and was taken to a vehicle repair shop. In light of their new relationship and Defendant’s

inability to drive back to North Carolina following the weekend, Mr. Strasser permitted Defendant

to stay in his Westview condominium unit until her car could be repaired. The parties decided at

that time to commit to an exclusive romantic relationship.

8. The repair shop required several weeks to repair Defendant’s vehicle and thus she

stayed at Mr. Strasser’s apartment for approximately three weeks. At Christmas, both parties


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returned to their respective families’ homes. By December 27, 2015, however, the parties had

returned to Arlington, and Defendant effectively moved in full time to Mr. Strasser’s one-

bedroom condominium.

9. Defendant did not contribute to the mortgage or expenses. Mr. Strasser operated as

the parties’ sole breadwinner from the beginning to the end of their cohabitation. Defendant

during this time period was not employed in either a full-time or part-time capacity and thus had

no income. She previously received stipends of several thousand dollars each semester from

Duke University; however, in approximately May 2016, Duke University informed her that she

would not receive any stipends for the summer or the forthcoming summer or semesters.

10. Mr. Strasser had adopted two rescue dogs, who lived in the unit with him prior to

the Parties’ relationship and Defendant brought a dog of her own that she had prior to the

relationship to live in the Westview as well. Over the next several months, the living space

available in the unit proved difficult for the Parties and the three dogs.

11. In addition, following her move in, Defendant insisted that Mr. Strasser needed to

refurnish his apartment. Mr. Strasser paid for virtually all of this furniture, save a piece or two of

minor furniture gifted to the Parties by Defendant’s parents. Nevertheless, Defendant did not

make financial contributions toward these purchases.

12. In early spring 2016, Defendant requested that Mr. Strasser consider moving the

Parties and their pets into a larger, more spacious residence, and either sell or rent the Westview.

Mr. Strasser was initially reluctant but succumbed to considering an alternative residency at

Defendant’s repeated behest. Accordingly, Defendant conducted significant research and

identified a number of homes that the Parties viewed, usually together.


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13. Eventually, Defendant brought to Mr. Strasser’s attention a home available for rent

in the Chevy Chase neighborhood of Washington, DC, located at 6520 Barnaby Street, NW,

Washington, DC, 20015 (the “Barnaby Property”). Mr. Strasser submitted an application and was

accepted. In June 2016, Mr. Strasser executed a lease agreement in which he agreed to rent the

Barnaby Property at a rate of $4,800.00 per month for 24 months, from July 21, 2016 through July

20, 2018. The lease only listed Ryan Strasser as a “Lessee” but did list Sarah Jones Dickens as a

“Permitted Occupant.” To obtain this lease, Mr. Strasser provided a security deposit of $4,800, or

one month’s rent.

14. The Parties moved out of the Westview on July 21, 2016. During the period in

which Defendant lived with Mr. Strasser at the Westview, from December 4, 2015, through July

21, 2016, Mr. Strasser alone paid the mortgage, the housing association fees, all utilities, and all

living expenses for both Parties. Defendant made no financial contributions to the Parties’ shared

cohabitation.

The Parties’ Residence at the Barnaby Property & Search for an Engagement Ring

15. The Parties moved into the Barnaby Property. The financial burdens of the parties

remained the same: Mr. Strasser continued to pay all rent, all utilities, and for all living expenses.

This continued for the roughly year and a half that the Parties cohabitated at the Washington, D.C.

property, and persisted even after Mr. Strasser had moved out.

16. In the months that followed, Defendant demanded that Mr. Strasser make

numerous purchases to furnish the five-bedroom house, which Mr. Strasser reluctantly did most of

the time. On several occasions when Mr. Strasser would not make such purchases, Defendant

would use Mr. Strasser’s credit cards to purchase those items and others for the home. Although

Mr. Strasser had on occasion previously permitted Defendant to use his credit cards to purchase


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certain items, Defendant construed such consent as unfettered and boundless, such that she could

make such purchases without Mr. Strasser’s express consent or over Mr. Strasser’s objections.

Mr. Strasser vocalized his displeasure with Defendant’s actions and repeatedly counseled her not

to abuse his credit cards or to use them on items the Parties had not discussed.

17. Within months of commencing their relationship, Defendant notified Mr. Strasser

that she expected Mr. Strasser to propose to her with an engagement ring within one year of the

start of their relationship. Defendant noted that she felt an urgency to wed and refused to wait

longer than one year for an engagement.

18. In the Fall of 2016, Defendant requested that the Parties begin to look for an

engagement ring together. Defendant insisted that she deserved a “large” engagement ring

because she did not believe in “wasting” money on a wedding and so the Parties should instead

spend “extra” on an engagement ring, something she would enjoy daily for the rest of her married

life.

19. The Parties had some preliminary discussion about the parameters of an

engagement ring that Mr. Strasser would eventually buy for the purpose of proposing to

Defendant. Mr. Strasser indicated that he was willing to purchase a diamond of approximately 4

carats and had contemplated a budget of approximately $40,000. Defendant stated that whatever

she would eventually want likely would cost more than that.

20. Following multiple trips to various jewelers, Defendant declared that she had to

have an engagement ring of about 3.5 to 5 carats with an inclusion rating of no “worse” than VS2

and a color rating of no “worse” than G, ratings regarding the quality of the diamond in question.

She also advised that her diamond could have no florescence. Defendant further determined that

she wanted an Old European Cut diamond, a type of diamond cut using a manufacturing process


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in the early part of the 1900s that has since fallen out of fashion due to improved diamond-cutting

technology and due to the diamond industry’s marketing of more modern cuts as having superior

“sparkle.” Diamonds that fit all of these criteria far exceeded Mr. Strasser’s contemplated

$40,000 budget.

The Betteridge Diamond Engagement Ring

21. On Sunday, December 18, 2016, Defendant brought to Mr. Strasser’s attention via

e-mail a diamond engagement ring that she recently located on-line at a reputable jewelry store in

Greenwich, Connecticut, called Betteridge. Mr. Strasser first reviewed this option on a website

containing pictures of the “diamond engagement ring” and described its features. True and

correct copies of that webpage, which remains active as of September 14, 2018, are attached

hereto as Exhibits 1(a), 1(b), and 1(c). The diamond engagement ring that piqued Defendant’s

interest contained a primary 4.06 carat, G-colored, VS2 diamond, designated as an Old European

Cut on its GIA report, with smaller, baguette diamonds along a platinum band (“Engagement

Ring”). See Ex. 1(c). At the time the webpage listed the price for this ring at approximately

$119,000. A true and correct copy of a receipt reflecting this initial list price is attached hereto as

Exhibit 2.

22. Although he repeatedly told Defendant that the price far exceeded his budget, Mr.

Strasser eventually acceded and undertook to negotiate for the ring. Upon contacting the store,

Mr. Strasser reached Win Betteridge, the son of the owner of the store and its Chief Financial

Officer. Mr. Betteridge informed Plaintiff that he was willing to discount the ring and sell it at a

reduced price of $99,800. See Ex. 2. Mr. Strasser requested that Mr. Betteridge pull the ring from

the showroom and set it aside for the Parties to inspect in person. Mr. Strasser agreed to take off


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from work on Monday, December 19, 2016, to travel with Defendant to Greenwich, Connecticut,

to inspect and consider the Engagement Ring in person.

23. At the store the Parties met with Mr. Betteridge. Ultimately, Mr. Strasser

determined that the ring was right for his presumptive future wife and that he would purchase the

ring. First, however, Defendant wished to have the Engagement Ring and diamond regraded by

the GIA because the then-operative GIA report was dated January 9, 2012, and she wanted

assurance that the diamond had not sustained any damage since that 2012 GIA report.

24. At Defendant’s behest, Mr. Strasser contacted Mr. Betteridge on or about

December 19, 2016. Mr. Betteridge agreed to have the diamond recertified in light of the

intervening time period to ensure the diamond had not suffered any damage since the prior

grading report on January 9, 2012. He advised he could likely expedite the process given his

relationship with the GIA. Mr. Strasser made no payment at the time.

25. On December 21, 2016, the GIA completed its regrading of the Engagement Ring

and issued a new report. A true and correct copy of the December 21, 2016 GIA Report is

attached hereto as Exhibit 3. Mr. Betteridge e-mailed it to Mr. Strasser as soon as he received it.

On that same day, Mr. Strasser made his first payment of $10,000.00. He then made four

payments of $20,000.00, one on January 10, 2017; one on January 12, 2017; one on January 14,

2017; and one on January 24, 2017. He made two final payment on January 26, 2017, one for

$3,800.00 on one credit card and one for $6,000.00 on a second credit card. To help make all of

the payments, Mr. Strasser took out a $30,000 personal loan through SoFi at an interest rate of

5.95% per annum. Since February 2, 2017, Mr. Strasser has made monthly installment payments

of $912.71, and he is obligated to continue making such monthly payments through January 1,

2020.


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26. On January 3, 2017, an in-house appraiser at Betteridge prepared an appraisal of

the Engagement Ring, which asserted,

We have this day appraised, for retail replacement value, the following article which is the property of:

Ryan Strasser 6520 Barnaby Street Northwest

Washington, DC 20015 Platinum and diamond ring set with one 4.06 ct near-colorless very slightly included old European-cut diamond measuring 10.14 to 10.26 by 6.16 mm (GIA grade G-VS 2, report number 2145290277) in a four-prong mounting, with shoulders set with 14 near-colorless very slightly to very very slightly included round brilliant-cut diamonds weighing .20 ct in total, marked “AEB” for Albert E. Betteridge $119,000 By: /s/ Alexia S. Palmer Alexia S. Palmer, G.G. BETTERIDGE JEWELERS, INC. (emphasis added). A true and correct copy of this appraisal is attached hereto as Exhibit 4.

27. On or about January 4, 2017, Mr. Strasser reached out to John Underwood of

Nationwide Insurance Company (“Nationwide”) to insure the Engagement Ring. Mr.

Underwood was able to write the policy, and it went into effect on or about January 6, 2017.

Nationwide charged an annual premium in the amount of $1,051 for the Engagement Ring.

Installment payments of approximately $87.58 are automatically deducted monthly from Mr.

Strasser’s bank account. Mr. Strasser continues to pay for the full insurance on the

Engagement Ring.

28. On February 8, 2017, the Parties had the Engagement Ring re-reviewed by an

independent appraiser, Martin Fuller Appraisals, LLC (“Martin Fuller”). On February 18,


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2018, Martin Fuller e-mailed Mr. Strasser a copy of his full independent appraisal report.

That report contained an appraisal value of $122,550.00. A true and correct copy of the

Martin Fuller appraisal value page is attached hereto as Exhibit 5.

The Engagement

29. On or about January 26, 2017, the Parties received a shipment from Betteridge

containing the Engagement Ring; title to the Engagement Ring; the original December 21,

2016 GIA Report; and a final Bill of Sale.

30. On February 9, 2017, Mr. Strasser asked Defendant to marry him. Mr.

Strasser assumed the traditional proposal position on one knee, extending the engagement

ring box and opening it, while asking Defendant if she would marry him. Defendant

accepted Mr. Strasser’s proposal and the Engagement Ring and agreed to marriage, and with

that Mr. Strasser placed the Engagement Ring on the fourth finger of Defendant’s left hand,

traditionally referred to as the ring finger. Mr. Strasser proposed in a public location with a

professional photographer present to document Mr. Strasser asking Defendant to marry him.

The photographer witnessed Defendant accept Mr. Strasser’s proposal and witnessed Mr.

Strasser slip the ring on Defendant’s ring finger as soon as Defendant agreed to the marriage

proposal. In addition, the proposal took place in a public location, and the Parties had many

strangers, who had witnessed the event from afar, congratulate them shortly thereafter. The

Parties also called both sets of parents that evening to inform them that they had become

engaged. The Parties informed friends and other family members by text message

sporadically over the next several days.

31. Shortly after the proposal, Defendant began discussing a wedding. In fact,

one of the strangers who congratulated the Parties on their engagement was a wedding


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planner whose card Defendant requested upon learning of the woman’s occupation.

Defendant reached out to that wedding planner several weeks later to inquire about pricing,

logistics, and next steps. In addition, Defendant reached out to several venues about the

possibility of hosting a small wedding for the Parties. For instance, on March 12, 2017,

Defendant contacted the Park Hyatt in Beaver Creek, Colorado, to inquire about whether it

could accommodate a wedding of 30-40 people on January 27, 2018. A true and correct

copy of Defendant’s e-mail correspondence with the Park Hyatt in Beaver Creek is attached

hereto as Exhibit 6. Mr. Strasser also contacted Ted Steers of Vail Village Rentals—at

Defendant’s behest and with Defendant physically beside him—to inquire about the

possibility of renting a ski chalet for the purposes of hosting a wedding from approximately

January 25-29, 2018. A true and correct copy of Defendant’s subsequent correspondence

with Ted Steers is attached hereto as Exhibit 7.

32. Defendant also began creating a wedding registry for the Parties shortly after

their engagement. Although it was recently removed, the registry the Defendant created

listed a “wedding registry” for “Ryan Strasser & Sarah Jones Dickens” and identified a

wedding date of January 27, 2018. True and correct copies of screenshots capturing how the

website appeared publicly as of January 30, 2018 are attached hereto as Exhibits 8, 9, and 10.

33. On August 28, 2017, Defendant posted on her Facebook Page a series of

twelve engagement photographs taken by Jeffrey Hulse that the Parties had not previously

publicly displayed. She included a caption that characterized the photos as follows: “A few

engagement photos taken from February 2017 . . . .” Several of these photographs show

Defendant wearing the Engagement Ring on her ring finger. Those photographs received

hundreds of “likes” from the Parties’ friends and family members, dozens of which offered


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“congratulations” to the Parties on their engagement. True and correct copies of examples of

Defendant’s posts are attached hereto as Exhibits 11 and 12. At some point in time,

Defendant also changed her Facebook “relationship status” to “Engaged.”

34. After determining that many of their preferred venues already were booked

for more than a year in advance, the Parties took a hiatus from wedding planning.

Additionally, Defendant began focusing again on writing her Ph.D. dissertation and

immersed herself in research and writing. Defendant decided that she preferred to wait for

wedding planning until after she finished her dissertation in spring 2018. The Parties agreed

on a prolonged engagement to facilitate her graduation and expected to turn back to wedding

planning after her expected May 2018 commencement.

The End of the Relationship

35. Eventually, the Parties’ relationship soured and grew especially tumultuous in

December 2017. After a particularly dramatic weekend, on Sunday, January 7, 2018, Defendant

placed a phone call around 8:30 PM to Mr. Strasser’s parents, Sharon and Joseph Strasser, who

reside in New Jersey. Defendant informed Mr. Strasser’s parents that Mr. Strasser would “not

stop crying” and Defendant informed Joseph Strasser that she was unhappy with the relationship

and ordered Joseph Strasser to “come get [Mr. Strasser] out of the house.” Joseph Strasser

objected that because Mr. Strasser pays all the rent, is the only lessee, pays all the utilities, and

pays all the living expenses, Defendant should be the one to leave the house. Defendant refused

to leave, and Mr. Strasser’s parents decided to drive down to Washington, DC, that evening to be

with Mr. Strasser. Mr. Strasser left the Barnaby Property and met his parents at a nearby hotel,

where they rented a room for the night. He confirmed that the engagement was over.


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36. The next morning, on January 8, 2018, Mr. Strasser and his parents went back to

the Barnaby Property so that Mr. Strasser could retrieve certain items he needed for work. At the

home Mr. Strasser confronted Defendant and demanded that she return the engagement ring.

Defendant refused. Mr. Strasser again, in the presence of his parents, demanded that Defendant

hand over the Engagement Ring. Defendant again refused and stated that she intended to keep it

until she “completed her dissertation and moved all of her property out of” the Barnaby Property.

37. Mr. Strasser and his parents left the house, and Mr. Strasser went off to work. Mr.

Strasser’s parents subsequently returned to the Barnaby Property without Mr. Strasser in order to

retrieve Mr. Strasser’s two dogs.

38. Around the time that they returned to the Barnaby Property, Mr. Strasser’s parents

discovered that Defendant’s father Samuel Dickens had arrived at the Barnaby Property. Joseph

Strasser and Samuel Dickens had lengthy discussions about how the Parties could begin to

untangle the living arrangement in the most amicable way possible. Mr. Strasser returned to the

Barnaby Property in the early afternoon after his office closed early due to inclement weather.

After returning home, Mr. Strasser engaged in similar discussions with Defendant and her father.

During one such conversation directly with Defendant, Mr. Strasser requested the Engagement

Ring so that they could both part peacefully. Defendant once again refused to return it to him.

39. Mr. Strasser indicated to Defendant and her father that he appreciated Defendant’s

desire to remain in the home until she finished her dissertation in approximately April 2018 and

stated that he was amenable to that arrangement on the condition that she produce the

Engagement Ring. Mr. Strasser explained that in light of the Parties’ engagement ending, Mr.

Strasser desired to return or to sell the Engagement Ring in order to pay off his personal loan with

SoFi that enabled him to pay for the engagement ring and so that he could cancel the monthly


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Engagement Ring insurance with Nationwide. Mr. Strasser further explained that he could not

financially afford to pay for Defendant to live in the Barnaby Property at $4,800.00 per month

plus its utilities, in addition to having to pay for a new residence and utilities for himself, with the

weight of the monthly Engagement Ring payment of $912.71 per month and the $87.58 per

month insurance.

40. Initially, Defendant’s father expressed a modicum of sympathy for Mr. Strasser’s

position. He indicated, however, that he could not return the Engagement Ring to Defendant

because Defendant then would have no “leverage” to prevent Mr. Strasser from evicting

Defendant from the Barnaby Residence, given that she was not on the lease. Mr. Strasser asked

Defendant’s father whether Defendant would consent (1) to returning the Engagement Ring on a

date certain following Defendant’s completion of her dissertation; (2) to paying some portion of

the monthly Barnaby Property rent; and (3) to putting the parties’ understanding concerning these

matters in writing in the form of a signed contract, in exchange for Mr. Strasser vacating the

Barnaby Property and allowing Defendant to remain there with Mr. Strasser continuing to pay the

rent. Defendant’s father unequivocally agreed to that arrangement.

41. Both Parties, Mr. Strasser’s parents, and Defendant’s father relaxed after this deal

had been struck. Indeed, Joseph Strasser returned to New Jersey in reliance on the representation

that the Parties had reached an agreement. Several hours later, however, Defendant retreated to

the master bedroom alone to speak with Teenie Dickens, her mother. After approximately 30

minutes, Defendant reappeared and abruptly proclaimed that she had changed her mind, that in

her and her Mother’s view the Engagement Ring “belonged to her” forever, that she would “never

give it back,” that the “deal was off,” and that she was not leaving the Barnaby Property under any


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circumstances until her dissertation was complete. Defendant’s father was audibly and visibly

frustrated but announced he refused further involvement in the matter.

42. This moment ended the conversation, and the Parties retreated to their separate

rooms. Mr. Strasser memorialized the events of the day in a letter that he authored and sent to

Defendant later that evening, which inter alia requested that she vacate the premises, requested

that she provide a departure date by which she could remove all of her personal property, and

requested once more that she return the Engagement Ring. A true and correct copy of this letter is

attached hereto as Exhibit 13. Mr. Strasser’s thorough e-mail never received a response.

43. Deciding that it was not a prudent living arrangement for the Parties to remain

under the same roof, Mr. Strasser left and took up refuge the next day at a hotel with Sharon

Strasser until Defendant could gather her belongings and depart. However, Defendant refused to

depart. She remained in complete possession of the premises and all chattel on the premises,

including Mr. Strasser’s; refused to pay for rent or utilities; and repeatedly denied Mr. Strasser

access to any of his personal property, including prescription immunology medication not easily

replaceable and that was subsequently ruined as a result of its non-timely return. Mr. Strasser left

the Barnaby Property with only the few articles of clothing he could quickly carry out of the house

on January 9, 2018, and nothing more.

Further Attempts to Retrieve Mr. Strasser’s Property

44. Several weeks later, Mr. Strasser relocated permanently to Richmond, Virginia. In

the ensuing months, however, Mr. Strasser repeatedly requested through counsel that Defendant

grant Mr. Strasser access to the house to retrieve certain core personal items, such as his work

wardrobe, shoes, casual clothes, and his two personal laptop computers and iPad. Mr. Strasser

also sought access to his strong box, which included critical documents including his passport,


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birth certificate, social security card, title to the Westview condo, loan documents for the

Westview condo, and title to Mr. Strasser’s 2011 Chevrolet Camaro automobile, as well as gold

and silver coins valued at approximately $4,400.00. And Mr. Strasser also sought and was denied

access to the house to retrieve numerous personal property items for which he solely paid, before

and during the relationship, and to which he has sole title.

45. After weeks of requests to retrieve Mr. Strasser’s things submitted through

counsel to Defendant being ignored, Defendant, through counsel, granted Mr. Strasser entry onto

the premises—the house where Mr. Strasser still was the sole lessee and sole payor of rent. On

March 3, 2018, Mr. Strasser was permitted access but solely to the house’s garage. Mr. Strasser

was able to retrieve many of his personal effects, but not all. He was not able to retrieve items

such as his strongbox, any furniture, or other larger items. Mr. Strasser’s electronics also largely

were absent from the garage. Most importantly, the Engagement Ring still was not returned.

Defendant was in the house at the time of retrieval, but Mr. Strasser, accompanied by counsel

throughout the retrieval, made no attempt whatsoever to interface or converse with Defendant.

46. Mr. Strasser noted and inventoried the additional items that he wished to retrieve.

Mr. Strasser’s counsel made multiple attempts to arrange another pickup, but such attempts were

thwarted by Defendant’s counsel, who rather than trying to resolve the situation, threatened Mr.

Strasser with legal action. Defendant’s counsel later ignored multiple letters requesting a second

entry to retrieve Mr. Strasser’s remaining possessions.

47. On May 20, 2018, having previously requested that Defendant leave the premises

before that date, and after a friend had driven by the Barnaby Street house and observed that it

appeared to have been abandoned by Defendant, Mr. Strasser and a friend reentered the house.

There was no sign of Defendant, and she clearly had moved out of the house many weeks prior.


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The house smelled terrible due to the refrigerator having been turned off and rancid meat having

seeped out. A true and correct copy of a photograph of the refrigerator has been attached as

Exhibit 14. There were also angry writings on the walls of the house in pen and permanent

marker.

48. Mr. Strasser was able to retrieve most of his remaining belongings, and most of the

furniture that was his had been left in the house. However, Mr. Strasser’s electronics, including

two computers, an ipad, an ipod, a Bluetooth speaker, and various other items were missing.

There was no sign of the Engagement Ring—Defendant never returned it. A full and complete

inventory of items belonging to Mr. Strasser that have not been rightfully returned to him is

attached hereto as Exhibit 15.

49. On August 19, 2018, after Mr. Strasser had arranged to be released from his lease

and after all remaining belongings left in the house by Defendant had been removed, the owners

of the Barnaby Property informed Mr. Strasser that they would not provide Mr. Strasser with the

full balance of his security deposit but instead would keep $3,800 of the deposit to pay for

necessary repairs to the house (returning $1,000 to Mr. Strasser despite claiming more than

$5,000 in damages). Chief among the reasons for withholding the security deposit were the need

to replace the refrigerator due to Defendant’s neglect and the need to replace a window in the attic

that Defendant had left open, leading to rotting from rain damage. A true and correct copy of the

e-mail explaining the owners’ decision to withhold the security deposit is attached as Exhibit 16.

COUNT ONE: REPLEVIN FOR WRONGFULLY POSSESSED ENGAGEMENT RING

50. Mr. Strasser realleges and incorporates herein by reference the allegations of

numbered paragraphs 1-49 of this Verified Complaint.


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51. When Mr. Strasser offered the Engagement Ring to Defendant on February 9,

2017, Mr. Strasser did so as part of a proposal that Defendant marry him. Mr. Strasser therefore

conditioned the gift of the Engagement Ring on a subsequent condition—a marriage—taking

place.

52. Under D.C. law, the giving of an engagement ring as part of a proposal to marry

is a conditional gift, whereby title to the Engagement Ring reverts to the donor if a wedding fails

to occur due to a broken engagement. See Singer v. Singer, 636 A.2d 422, 422, n.3 (D.C. 1994).

D.C. courts also look to Maryland law, “the most authoritative body of law other than” D.C.’s

own precedent. In re CAP, 633 A.2d 787 (D.C. 1993). Maryland law provides that an

engagement ring is a conditional gift that must be returned to the donor if a marriage fails to

occur subsequently. In re Stoltz, 283 B.R. 842 (B.R. Md. 2002) (“[T]he right of a disappointed

fiancé to recover possession of an engagement ring given in contemplation of marriage survives

because Maryland recognizes the right of a donor to recover a conditional gift.”) (citing

Grossman v. Greenstein, 161 Md. 71 (1931) (emphasis added)); see also Ver Brycke v. Ver

Brycke, 379 Md. 669 (2004), reconsid. denied (“Although this is the general rule, in limited

instances, ‘[a] donor may limit a gift to a particular purpose, and render it so conditioned and

dependent upon an expected state of facts that, failing that state of facts, the gift should fail with

it’”).

53. When the Parties ended their relationship and thus broke their engagement, the

condition to the offer of the Engagement Ring failed because no marriage will take place.

54. Once the condition of a marriage occurring failed, full legal and equitable title to

the Engagement Ring reverted to Mr. Strasser, the donor. Accordingly, the Engagement Ring is

Mr. Strasser’s chattel.


SMRH:227865081.2 -19-

55. Because Defendant refuses to deliver the Engagement Ring to Mr. Strasser

despite multiple demands, Defendant has wrongfully taken and detained Mr. Strasser’s chattel.

56. Under D.C. law, if a party has wrongfully or unjustly taken or detained the

chattels of another, the true owner is entitled to have those chattels taken and delivered to him by

court order. D.C. Code § 16-3701-02.

57. All remedies available to a party at state law are available to a party in federal

court to secure the satisfaction of a potential judgment. Fed. R. Civ. P. 64(a). D.C. law

specifically allows for the return of property via replevin. See D.C. Code § 16-3-3701-02 et seq.

58. Replevin also is specifically allowed by the Federal Rules of Civil Procedure. See

Fed. R. Civ. P. 64(b).

59. Defendant’s conduct is willful and malicious. Defendant’s wrongful action is

ongoing and continuous. Therefore, Mr. Strasser is entitled to a writ of replevin and to the

immediate delivery of the Engagement Ring to Mr. Strasser.

COUNT TWO: REPLEVIN FOR KNOWN CHATTELS

OF WHICH DEFENDANT HAS DEPRIVED PLAINTIFF



61. Mr. Strasser repeatedly has requested the return and the opportunity to retrieve his

personal property (“Known Chattels”) described in the inventory attached as Exhibit 15, but

Defendant has failed and refused to return such property.

62. Thus, Defendant wrongfully and unjustly has taken Mr. Strasser’s Known

Chattels.


SMRH:227865081.2 -20-

63. Therefore, Mr. Strasser is entitled under Rule 64 of the Federal Rules of Civil

Procedure and Rule 64-II of the Superior Court Civil Rules to a writ of replevin and to the

delivery of the Known Chattels to Plaintiff.

COUNT THREE: CONVERSION OF THE WRONGFULLY POSSESSED

RING AND KNOWN CHATTELS



65. Under D.C. law, conversion consists of “an unlawful exercise of ownership,

dominion, and control over the personal property of another in denial of his right to such

property.” Baltimore v. District of Columbia, 10 A.3d 1141, 1155 (D.C. 2011).

66. Mr. Strasser has a right to the Engagement Ring that he provided to Defendant as

a conditional gift as explained in numbered paragraphs 51–54 and as incorporated herein.

67. Mr. Strasser has a right to his Known Chattels.

68. In the alternative, Defendant has sold or otherwise disposed of the ring

committing a tortious act of conversion.

69. In the alternative, Defendant has sold or otherwise disposed of the known chattels

committing a tortious act of conversion.

70. Mr. Strasser is entitled to damages for any and all of Defendant’s acts of

conversion.

COUNT FOUR: DAMAGE TO PLAINTIFF’S LEASEHOLD




SMRH:227865081.2 -21-

72. In order to secure a leasehold on the Barnaby Property, Mr. Strasser provided a

$4,800 security deposit to the lessors.

73. Defendant caused property damage in excess of $5,000 to the Barnaby Property.

This damage included writings on the interior walls of the premises, leaving rotten and spoiled

meat in the refrigerator after she abandoned her occupancy without notifying Mr. Strasser,

allowing an attic window and frame to rot by leaving it open and susceptible to rain damage, and

necessitating the rekeying of the house and mailbox.

74. Upon information and belief, Defendant’s actions in causing the foregoing

damage to the leasehold and preventing mitigation by abandoning the leasehold without notice to

Mr. Strasser were willful and intended to cause harm to Mr. Strasser.

75. As a direct and proximate result of Defendant’s actions, Mr. Strasser lost the sum

of $3,800 of the security deposit used to secure the leasehold.

76. Mr. Strasser is entitled to reimbursement from Defendant for the sum of $3,800

for damage caused by and during her exclusive occupancy, plus interest, to account for loss of

this portion of his security deposit.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Ryan J. Strasser respectfully requests that judgment be entered

against Defendant as follows:

(a) Declaring Plaintiff to be the sole owner of the Engagement Ring;

(b) Issuing a writ of replevin directing Defendant to deliver the Engagement Ring to

Plaintiff;

(c) Issuing a writ of replevin directing Defendant to deliver the Known Chattels to

Plaintiff;


SMRH:227865081.2 -22-

(d) In the alternative, requiring the Defendant to pay damages for the Engagement

Ring or any Known Chattels that have been sold or otherwise disposed of.

(e) Awarding Ryan Strasser the sum of $3,800, plus interest, to damage to the

leasehold during Defendant’s exclusive occupancy, resulting in the loss of that portion of his

security deposit.

(f) Awarding reasonable attorneys’ fees and costs under D.C. Code § 2-1403.13 and

42 U.S.C. § 12205; and

(g) Awarding all other and further relief as this court may deem just and proper.

DEMAND FOR JURY TRIAL

Plaintiff requests trial by jury as to all issues in this case triable of right to a jury.

DATED: September 24, 2018 Respectfully submitted,

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

By: /s/ Steven P. Hollman Steven P. Hollman (DC Bar No. 375658) Steven P. Hollman James N. Bierman, Jr. 2099 Pennsylvania Ave., Suite 100 Washington, D.C. 20006 Telephone: (202) 747-1931 Facsimile: (202) 747-3817 [email protected] [email protected] Counsel for Plaintiff Ryan J. Strasser


EXHIBIT 1(a)

Case 1:18-cv-02207 Document 1-1 Filed 09/24/18 Page 1 of 2

EXHIBIT 1(b)


EXHIBIT 1(c)


EXHIBIT 2


Ryan Strasser Mr. Ryan Strasser

Washington, DC 200156520 Barnaby St Nw

Washington, DC 20015

6520 Barnaby St Nw

Sold To: Ship To:

WEB SALES - WIN 101908-892-2258Telephone: Salesperson: Source:

12/20/2016 7028403CBAccount Type: Account Number:Transaction Date:

* * * Layaway Down * * * Receipt #: 419068

Salesperson: WEB SALES - WIN

Price ExtensionQuantityDescriptionItem

14.06ct Diamond RingDR30R04337 99,800.00

Diamond engagement ring, centering a near-colorless old European brilliant-cut diamond

weighing 4.06 carats (G-color/VS2-clarity), with tapering bead-set round-cut diamond

shoulders, mounted in platinum. Fourteen diamond accents weighing 0.20 total carats

. Ring discounted from $119,000 to $99,800 per Win Betteridge.

Mr. Strasser to put down $10,000 credit card deposit to hold ring, pending new GIA

certificate for 4.06ct diamond to be provided by Betteridge.

Total

Tax

Subtotal 99,800.00

99,800.00

10,000.00Tot Paid

VISA 10,000.00 0.00

Old Amt on Dpst

New Amt on Dpst

Lay Bal

0.00

-10,000.00

89,800.00

THANK YOU FOR SHOPPING BETTERIDGE JEWELERS

_______________________________________________ M-3550070-ST88-P12/20/2016Page 1 of 1Signature:


EXHIBIT 3


T HE S E C UR I T Y F E AT UR E S IN T H I S D O C UME N T, IN C L UD IN G T HE H O L O G R A M , S E C U R I T Y S C R E E N A N D M I C R O P R I N T L I N E S , I N A D D I T I O N T O T H O S E N O T L I S T E D , E X C E E D D O C U M E N T S E C U R I T Y I N D U S T R Y G U I D E L I N E S .

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GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA GEMOLOGICAL INSTITUTE OF AMERICA

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G I A R E P O R T

P R O P O R T I O N S

C L A R I T Y C H A R A C T E R I S T I C S

G R A D I N G S C A L E S

A D D I T I O N A L G R A D I N G I N F O R M AT I O N

G R A D I N G R E S U LT S

G I A D I A M O N D G R A D I N G R E P O R T

T he resul ts documented in th is repor t re fer only to the diamond descr ibed, and were obtained using the techniques and equipment used by G I A a t the t ime of examination. This report is not a guarantee or valuation. For addit ional informat ion and impor tant l imitat ions a n d d i s c l a i m e r s , p l e a s e s e e w w w. g i a . e d u / t e r m s o r c a l l +1 8 0 0 4 2 1 7 2 5 0 o r +1 76 0 6 0 3 4 5 0 0 . © 2 0 1 4 G e m o l o g i c a l I n s t i t u t e o f A m e r i c a , I n c .

www.gia.edu

Ver i f y this repor t a t g ia .edu

FA C S I M I L EThis is a digital representation of the original GIA Report. This representation might not be accepted in lieu of the original GIA Report in certain circumstances. The original GIA Report includes certain security features which are not reproducible on this facsimile.

December 21, 2016

GIA Report Number ........................................ 2145290277

Shape and Cutting Style ................ Old European Brilliant

Measurements ........................... 10.14 - 10.26 x 6.16 mm

Carat Weight ......................................................... 4.06 carat

Color Grade .......................................................................... G

Clarity Grade .................................................................... VS2

Polish ............................................................................. Good

Symmetry ...................................................................... Good

Fluorescence ................................................................ None

Comments: Additional clouds are not shown. Pinpoints

are not shown.

2145290277

KEY TO SYMBOLS*

Crystal

Cloud

Feather

Indented Natural

Extra Facet

* Red symbols denote internal characteristics (inclusions). Green or black symbols denote external characteristics

(blemishes). Diagram is an approximate representation of the diamond, and symbols shown indicate type, position, and

approximate size of clarity characteristics. All clarity characteristics may not be shown. Details of finish are not shown.

reportcheck.gia.edu

2


EXHIBIT 4


EXHIBIT 5


EXHIBIT 6


2/23/2018 Gmail - Fwd: Congratulations from the Park Hyatt Beaver Creek - Dickens Wedding

https://mail.google.com/mail/u/0/?ui=2&ik=91c32aee13&jsver=iEEFj798MIw.en.&view=pt&msg=15acb1d742630481&q=dickens%20wedding&qs=true… 1/7

Ryan Strasser <[email protected]>

Fwd: Congratulations from the Park Hyatt Beaver Creek - Dickens Wedding

Sarah Jones Dickens <[email protected]> Tue, Mar 14, 2017 at 12:39 AMTo: Ryan Strasser <[email protected]>

---------- Forwarded message --------- From: Patten, Theresa (BEAVE) <[email protected]> Date: Mon, Mar 13, 2017 at 4:53 PM Subject: Congratulations from the Park Hyatt Beaver Creek - Dickens Wedding To: Francis, Kate (BEAVE) <[email protected]>, Sarah Jones Dickens <[email protected]>

Hi Sarah

Congratula�ons on your engagement! I’m happy to assist you with holding hotel rooms for your guests and weddingparty at the Park Hya� Beaver Creek Resort and Spa.

We are happy to work with you on a space available basis or a contracted basis for the dates of Feb 1-4, 2018. Whata beau�ful �me of year to be married and exci�ng for your guests.

cid:[email protected]

Space Available:

We can provide you with a special code your guests use to make their reserva�ons either online orthrough our reserva�on department. Rates and Space are subject to availability and subject tochange. We would not be holding any inventory for the block nor will we have the ability to checkwho has/hasn’t made a reserva�on. Rates can vary and are not guaranteed.

Based on rates as of today it looks like the rate would start around: $899-999/night

In addi�on to the rates above there is a $50/room/day Resort Fee and $50/day Valet charge.

The current tax which is not included above is 10.71% and subject to change.

Contract:

We would ask you to sign a contract. We will pull the agreed upon number of rooms out of inventoryand hold it �ll the reserva�on deadline for your guests. Your room rate is guaranteed based on spaceavailable in your block. If you need to increase the block we are happy to do this based on availability




and with a simple addendum to the contract. We will need to contract on a 10 rooms/nightminimum. The contract signer will be held financially obligated to see that the block of rooms arereserved regardless of if they are occupied. We are happy to contract rooms for the weddingweekend with a minimum three night stay , rates star�ng at: $589/night

In addi�on to the rates above there is a $50/room/day Resort Fee and $50/day Valet charge. With acontract we can reduce the Resort Fee to $40/day/room and the Valet to $40/day. The current taxwhich is not included in the above rates is 10.71% and subject to change.

By contrac�ng BOTH Food and Beverage and Sleeping rooms we can adjust the above to include

· The Honeymoon couple will also receive a complimentary Park Fireside Suite the night ofthe wedding

· We can reduce the Resort Fee as well as the Valet Fee to $30 each (a savings of $20 offResort Fee and $20 off Valet)

Please let me know which direc�on you would like me to proceed to assist you with the special rates for your guests. Rooms are not being held at this �me, space and rate are not confirmed or held �ll a contract is signed.

Kind regards,

Theresa Patten

Sr. Sales Manager

______________________________________________________________________________________

Park Hyatt Beaver Creek Resort and Spa

50 West Thomas Place

Beaver Creek, CO 81620 USA

D. + 1 970 445 1008

F. + 1 970 827 6796

[email protected]

parkhyattbeavercreek.com

View my profile on LinkedInView my profile

______________________________________________________________________________________

#MyLuxList: Smore’s by the open flame under the star filled sky | Slope-side Hot Tub Bottle Service | Balcony withMountain Views




WHAT’S ON YOUR LUXURY LIST?


FOLLOW US ON:

Description: Description: cid:[email protected]

Description: Description: cid:[email protected] Description: Description: cid:[email protected] Description: Description: cid:[email protected]

2015 Donald N. Pritzker Award | Best Hotel Team Of The Year

2015 Travel + Leisure 500 World’s Best Award | #90

2015 US News & World Report Best Hotel In Colorado | #14

2015 Meetings Today Best of the West Award

2015 Colorado Meetings + Events Best Hotel or Resort with Meeting Space | Top 3 Finalist

2016 Wedding Wire Couples’ Choice Award Winner | Top 5% of Wedding Professionals Nationwide

2016 Wine Spectator Award of Excellence | 8100 Mountainside Bar and Grill

2016 Condé Nast Traveler Reader’s Choice Award Top Resorts in Colorado | Top 6 Finalist

From: Francis, Kate (BEAVE) Sent: Monday, March 13, 2017 2:23 PM To: Sarah Jones Dickens Cc: Patten, Theresa (BEAVE) Subject: RE: Wedding January 27,2018

Hi Sarah-

The BC Culinary weekend is slated to be on the weekend of 1/20. We have a large group in the following weekend,and they are occupying all of our space, including the private dining room a�ached to our restaurant. The maindining room is not available, as we do not rent that out and keep it open to the public.

2/3/2018 is wide open and everything is available.




Thank You

Kate Francis

Event Sales Manager

970-827-6526

From: Sarah Jones Dickens [mailto:[email protected]] Sent: Monday, March 13, 2017 2:13 PM To: Francis, Kate (BEAVE) Cc: Patten, Theresa (BEAVE) Subject: Re: Wedding January 27,2018

Hi Kate,

Thanks for this information. Will the main dining room also be occupied? Is there a larger event going on that weekend? Iwant to make sure that date is not coinciding with the food & wine festival...

Theresa, would you mind providing information about reserving a block of rooms, and how that process goes about?

I'll talk to Ryan about changing the dates, as everything is preliminary at the moment.

Sarah

On Mon, Mar 13, 2017 at 12:51 PM, Francis, Kate (BEAVE) <[email protected]> wrote:

Good Morning Sarah-

Congratula�ons on your engagement! We are honored that you are considering the Park Hya� Beaver Creek to be apart of your special day.

All of our event space is being held by a large group we have in on 1/27/2018. Would you be open to a differentdate? The weekend a�er is open (2/3/2018). We also may be able to make 1/20 work as well, although the hotel isfairly busy then as well.

I have copied Theresa Pa�en on this email who can assist with guest rooms. I just handle event space.




Thank You

Kate Francis

Event Sales Manager

______________________________________________________________________________________

Park Hyatt Beaver Creek Resort and Spa

50 West Thomas Place

Beaver Creek, CO 81620 USA

D. + 1-970-827-6526

F. + 1-970-827-6796

[email protected]

parkhyattbeavercreek.com

Menus

Brochures

______________________________________________________________________________________

#MyLuxList: Allegria Spa | Fine Wine| Cozy Fireplaces

WHAT’S ON YOUR LUXURY LIST?


FOLLOW US ON:

Description: Description: cid:[email protected]

Description: Description: cid:[email protected] Description: Description: cid:[email protected] Description: Description: cid:[email protected]

2015 Donald N. Pritzker Award | Best Hotel Team Of The Year

2015 Travel + Leisure 500 World’s Best Award | #90

2015 US News & World Report Best Hotel In Colorado | #14

2015 Meetings Today Best of the West Award

2015 Colorado Meetings + Events Best Hotel or Resort with Meeting Space | Top 3 Finalist




2016 Wedding Wire Couples’ Choice Award Winner | Top 5% of Wedding Professionals Nationwide

2016 Wine Spectator Award of Excellence | 8100 Mountainside Bar and Grill

2016 Condé Nast Traveler Reader’s Choice Award Top Resorts in Colorado | Top 6 Finalist

From: Sarah Jones Dickens [mailto:[email protected]] Sent: Sunday, March 12, 2017 12:50 PM To: BEAVE-Shared MB-SALES Subject: Wedding January 27,2018

Hi

I wanted to contact you guys to inquire about a wedding reception (and possibly wedding ceremony). My fiancé and I justgot engaged out in beaver creek last month - its one of our favorite places to visit and quite sentimental - and are in theinitial stages of planning a small wedding (20-40 people). We are shooting for 27 January 2018.

In addition, do you guys do hotel blocks for small parties ? And if so, what would be the rates and process for securingthose rooms?

Thanks again!

Sarah

--

Sarah Jones Dickens Art History PhD Candidate Duke University

The information contained in this communication is confidential and intended only for the use of the recipient namedabove, and may be legally privileged and exempt from disclosure under applicable law. If the reader of this message isnot the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communicationis strictly prohibited. If you have received this communication in error, please resend it to the sender and delete theoriginal message and copy of it from your computer system. Opinions, conclusions and other information in thismessage that do not relate to our official business should be understood as neither given nor endorsed by thecompany.

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The information contained in this communication is confidential and intended only for the use of the recipient namedabove, and may be legally privileged and exempt from disclosure under applicable law. If the reader of this message isnot the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication isstrictly prohibited. If you have received this communication in error, please resend it to the sender and delete the originalmessage and copy of it from your computer system. Opinions, conclusions and other information in this message that donot relate to our official business should be understood as neither given nor endorsed by the company.--


image010.png 1K


EXHIBIT 7


2/23/2018 Gmail - Beaver creek wedding/January 2018

https://mail.google.com/mail/u/0/?ui=2&ik=91c32aee13&jsver=iEEFj798MIw.en.&view=pt&msg=15ac9516f600143b&q=dickens%20wedding%20steers… 1/2


Beaver creek wedding/January 2018

Sarah Jones Dickens <[email protected]> Mon, Mar 13, 2017 at 4:16 PMTo: Ted Steers <[email protected]>Cc: Ryan Strasser <[email protected]>, Michele Garner <[email protected]>

Hi Ted,

Thanks for getting back to us! Bachelor's Gulch is totally fine - we stayed at the Ritz a few weeks ago, and it was a verynice area. Some very large houses indeed. As for dates, I am thinking January 25 - 29 may make the most sense.

Is there a minimum number of days required?

Thanks so much, Sarah

On Mon, Mar 13, 2017 at 3:54 PM, Ted Steers <[email protected]> wrote: Hi Ryan,Yes, we are a great resource to help you. My partner Michele is pretty strong in Beaver Creek as well so i am going toloop her in.What is your opinion on Bachelor Gulch? They have some pretty nice houses up there.I will stay in touch.What dates do you think? Jan 25-29? Jan 24-28?TED

Ted Steers, Owner

Vail Village Rentals | Luxury Vacation Rentals

Vail Office: 970.476.PLAY (7529) US Cell: 970.331.4995US Fax: 888.681.8948

- Interested in Austria Haus Club or One Willow Bridge Road ownership? -

On Sat, Mar 11, 2017 at 2:19 PM, Ryan Strasser <[email protected]> wrote:

Hi Ted, Great chatting with you today! Just wanted to send you our emails to get the ball rolling. As a recap, Sarah and Igot engaged out in BC this February so we are in the very early stages of wedding planning. We are hoping tohave a small albeit elegant wedding out there with 10 close friends max (and their significant others) plusimmediate family only. Shooting for the weekend of January 27. It happens to be the only weekend with nofootball playoff games. Anyway, let us know what you are thinking and feel free to pass on any favorite vendors too if you have them. Thanks,Ryan -- ____Ryan J. Strasser, Esq.University of Pennsylvania, M.P.A. '11Cornell Law School, J.D. '10Duke University, B.A. '07


2/23/2018 Gmail - Beaver creek wedding/January 2018

https://mail.google.com/mail/u/0/?ui=2&ik=91c32aee13&jsver=iEEFj798MIw.en.&view=pt&msg=15ac9516f600143b&q=dickens%20wedding%20steers… 2/2

[email protected]

--



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EXHIBIT 13



Engagement Ring & Departure

Ryan Strasser <[email protected]> Tue, Jan 9, 2018 at 12:17 AMTo: Sarah Jones Dickens <[email protected]>Cc: Sharon Strasser <[email protected]>, Joe Strasser <[email protected]>

Sarah, I am writing to memorialize today's sequence of events. This morning you informed my parents and I that you wouldreturn to me the engagement ring I had given you upon the removal of your property from the residence at 6520 BarnabyStreet, NW, Washington, DC 20015, since there will not be a wedding or a marriage. I was and am completely amenableto your keeping possession of and removing all of your personal property, including furniture, as soon as possible. As you know, the purchase price of the ring was $100,000 and as of February 2017 had an appraised value ofapproximately $125,000. As you can imagine, I am eager to return this ring because I continue to make monthly financepayments on it in the amount of $912.71 (including interest) and also am paying for the insurance on it in monthlyinstallments of $135.23. Since there will be no marriage, I wish to cease paying insurance on the ring immediately, as wellas to return the ring to dispense with the outstanding balance and the accruing interest. This morning you sent an e-mail to me requesting the privilege of remaining in the residency as a permitted occupant foranother 60-90 days. Your request is unreasonable and unacceptable for at least three reasons. First, as you know, I payfor all rent, all utilities, and all monthly expenses for the two of us, including food. At the time I signed the lease yourequested not to be included as a lessee and thus are not included as such on the lease, which you readily acknowledge.Since we are no longer together, I intend to sublease the premises or, at the very least, obtain roommates immediately todefray the rental cost of $4,800 per month. Accordingly, your request to remain in the house for an additional 60-90 days,rent-free, deprives me of the opportunity to recuperate rental costs in these ways. Second, as you note in your e-mail earlier today, you have a dissertation to finish. You have repeatedly indicated that theresidence is not conducive to your writing the remainder of your dissertation. You have reiterated to me and my family oninnumerable occasions, verbally, in e-mails, and by text message, that you do not have time for distractions. I agree. Thatwill not change now that our relationship has ended. In addition, residing in the household after a break-up with me andmy parents would create an enormous distraction. It is therefore necessary for you to complete your dissertationelsewhere. The good news is that you acknowledged having other places to go because, as you indicated last weekendwhen you communicated that you intended to move out of the premises immediately with your dog, books, andresearch, there is a beach home in North Carolina, owned by the friend of your mother's, available to you that, in yourwords, would be free from distractions. In addition, your father said you were welcome to move in to his and your mother'shouse, although you objected to their lack of internet. Third, your 60-90-day play prejudices me greatly. You decreed that you will withhold the engagement ring until you havefinished moving all of your property out of the house. Accordingly, your request to remain in the residence for another 60-90 days with your furniture and property necessarily means you will not return the engagement ring for several months.Consequently, you would be forcing me to continue paying the monthly outstanding balance, interest, and insuranceinstallments, which I would not otherwise be obligated to do if you left sooner. For these reasons, I cannot agree to yourrequest to remain in the residence for another 60-90 days. Nonetheless, in the spirit of navigating an uncomfortable situation as amicably as possibly, my parents and I spoke atlength with you and your father today from approximately 2 pm until 9:30 pm. During that period, many different solutionswere proposed, which both of us, your father Samuel Dickens and my parents, Joseph Strasser and Sharon Strasserwere witness to. You and your father continually reiterated that your only goal was the completion of your dissertation andto that end requested 51 days, with an absolute drop dead date of March 15, for your continued residence at the 6520Barnaby address. I indicated my financial inability to pay as well as my own professional responsibilities and inability todepart. After extended negotiation, your father in front of my parents and I (1) unequivocally offered to pay for a portion of the rentout of his own personal savings to keep you in the house; and (2) agreed to return the engagement ring on April 15 inexchange for the complete removal of all of your property from the household and your remaining in it through March 15.He stated he had discussed with you and your mother that if allowed to remain present for the 51 days and able toretrieve all property, you would return the ring on April 15, 2018 and that you and your mother had agreed. He stated thatyou simply wanted it as "collateral" to ensure I didn't attempt to evict you from the premises, an acknowledgement that


you indeed have no legal right to be present here. At that time, although less than ideal, from my standpoint I consentedso that you could finish your dissertation. Although unnecessary, he instructed me to write up an agreement in themorning to memorialize the agreement, and stated "we'll sign it." This occurred at approximately 5:45 PM, prompting myfather to depart about an hour later because all parties seemed content with the arrangement and in agreement regardinga resolution. However, at approximately 9:30 PM, you appeared from upstairs and suddenly declared that you and your motherdecided that you would not be returning the engagement ring under the circumstances discussed and proposed nocircumstances under which it would be returned. Moreover, after asking my parents and me repeatedly to come down andtake my dogs, my father attempted to take my dogs when leaving. You refused to hand over Tyus, holding him in yourarms. In closing, I write this e-mail with a heavy heart, but this course of action is best for all parties involved. I wish deeply forthis to be as amicable a separation as possible under the circumstances and am open to reasonably discussing theimmediate division of personal property. The good news is that, as far as I recall, no item of property was purchased withjoint assets and thus clear title for each piece of property in the home should clearly reside with one of us. I look forward to receiving your estimated departure date, as well as to hearing how quickly you will return theengagement ring, per your promise this morning. For both of our sakes, I look forward to completing this uncomfortableprocess as amicably as possible, to putting this process behind us, and to focusing on the next chapter of our lives. Ryan -- ____Ryan J. Strasser, [email protected]


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EXHIBIT 15


Inventory List of Personal Property Missing from Barnaby Residence

- 2013 Apple MacBook Air Laptop (still have receipt if needed) (original value of $1,900+)

- 2015 Apple MacBook Pro Laptop (still have receipt if needed) (original value of $1,550)

- 2015 Apple iPad (still have receipt if needed) (original value of $527)

- Apple iPod (original value of $100-200)

- Auvio Bluetooth Speaker (original value of $50)

- Apple Wireless Mouse (still have receipt if needed) (original value of $69)

- Engraved Waterman Pen (estimate value of $250)

- 2-4 Waterford Crystal Wineglasses (estimate value of approximately $150 each)

- All-Clad Turkey Pan and Rack (estimated value of $280)

- All-Clad Oversized Soup Pot (estimated value of $200)

- 1 Chavret tie (only 4 of 5 returned) (estimated value of $200)

- Autographed Christian Laettner photograph of “The Shot” (estimated value of $200)

- Autographed Duke National Championship Basketball (irreplaceable but value estimated

at $250)

- Matouk towel set (white) (estimated value of $300-350)

- Missing pewter Mug engraved with the words “UPenn 2011” (estimated value $75)

- Grandmother’s handwritten, framed recipe

- Official printed GIA Report for Engagement Ring

- Certificate of Title addressed to Ryan Strasser for Engagement Ring


EXHIBIT 16



Barnaby Street Rental Security Deposit

Koch (US), Michael M <[email protected]> Thu, Aug 9, 2018 at 8:36 AMTo: Ryan Strasser <[email protected]>Cc: Sarah Koch <[email protected]>

Hello Ryan,

Our apologies for the delay in replying. We've been on home leave and just made it back to India a few days ago.

We spent more than $16,000 on the house this summer in repairs. While most was upkeep for normal wear and tear thata tenant is not responsible for, a significant portion of this was expenses specifically due to damage from the home beingabandoned from early March to June, which is - as you know - a violation of the lease. We only learned of this when aneighbor informed us they thought nobody was at the house – we asked the realtor to check on it and that’s when all ofus became aware (yourself included) that it had been abandoned. We understand that you've attempted to do everythingwithin your control to make this situation right and we feel for your situation personally. We also rushed and spentconsiderable personal time to prepare the property early so that we could get it on the market quickly in the hope that wecould also save you money on rent payments by leasing to a new tenant before your lease expired. Because of this, wewere able to release you from the lease 2 weeks early and save you $2400 in additional rent.

In terms of the $4800 security deposit, our realtor instructed us that you are responsible for the repairs listed below. Wepaid to have the contents of the refrigerator removed and the unit professionally cleaned, however it had been sitting withspoiled meat and other foods for 2 months and was ruined because the smell couldn't be removed from the unit. Inaddition, a new window (less than 5 years old) in the attic room was left open and had rotted from rain damage. We wereunable to even close it. Rain had rotted the frame so we had to have that replaced. You are already aware of thenecessity to rekey the house and mailbox.

· New Refrigerator $2647

· Refrigerator and contents cleaned $200

· New screen door $500

· New window install/repair of exterior $2,000

· Locksmith $800

· Unpaid Water bill $331

Though these expenses exceed the deposit of $4800, we’re returning $1000 of your security deposit to you as a thankyou for being a good tenant. We recognize this is an unfortunate situation in which we are both perhaps victims ofsomeone else's irresponsible behavior. That said, we really do appreciate all that you've tried to do make it right fromRichmond and have no hard feelings. We wish you the best for the future.

Take care,

Sarah & Michael Koch 7289881627 1-206-397-9129 (when in USA)


AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date:Signature of Clerk or Deputy Clerk

District of Columbia

Ryan J. Strasser

Sarah Jones Dickens

Sarah Jones Dickens715 Stansbury RoadLittleton, NC 27850

Steven P. HollmanSheppard, Mullin, Richter & Hampton, LLP2099 Pennsylvania Ave, NW, Ste. 100Washington, DC 20006


AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00


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