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ASHLEY MORGAN IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION [CAPTION]

COMPLAINT Parties 1. Plaintiff, Patrick Packer (Packer), is a citizen of the state of Missouri and a resident of Kansas City, Jackson County, Missouri, in the Western District of Missouri. 2. Defendant, Dennis Denton (Denton), is a citizen of the state of Kansas and a resident of Fairway, Johnson County, Kansas. Jurisdiction and Venue 3. This is an action brought under 42 U.S.C 1982. 4. This Court has jurisdiction over this action under 28 U.S.C. 1343 (4), and 28 U.S.C. 1331. 5. Venue is properly placed in this Court under 28 U.S.C. 1391 (b)(2) since a substantial part of the events or omissions giving rise to the claim took place in this District. COUNT I Facts 6. Plaintiff incorporates by reference each and every allegation contained in paragraphs 1 through 5 above. 7. On or about July 14, 2006, Packer learned of Dentons house for sale from a classified advertisement in the Kansas City Star. 8. Denton followed Packer as he was trying to visually inspect house as if Packer was going to steal from the house. 9. Denton intentionally tried to dissuade Packer from buying house by exaggerating numerous deficiencies while excluding all positive features of house, such as detailing a tiny water spot on bedroom ceiling, instead of noting the rooms great closet space and beauty.
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10. Denton refused to negotiate the sale price of house even after Packer offered to pay cash for the reasonable amount of $250,000 with no contingencies. 11.Denton became annoyed with Packer and stated that Packers offer will not even be considered due to race. 12. Denton has sold the house as of February 12, 2007 to another couple. 13. Denton violated 42 U.S.C. 1982 by allowing race to be a motivating factor in: a. discouraging Packer from viewing house, b. discouraging Packer from making an offer on house, c. refusing to sell house to Packer, and d. refusing to negotiate sale price of house 14. Dentons racially discriminatory conduct was willful, wanton and malicious entitling Packer to punitive damages in the amount of $100,000 Prayer WHEREFORE, Plaintiff Packer prays for judgment against Defendant Denton on Count I of plaintiff's complaint as follows: A. Judgment against Defendant Dennis Denton in the amount of $10,000 compensatory damages for Plaintiff Patrick Parkers emotional distress and humiliation after being discouraged and rejected from buying Defendants house solely because of Parkers race. B. Judgment against Defendant Dennis Denton in the amount of $100,000 punitive and exemplary damages for his willful, wanton and malicious racial discrimination against Plaintiff Patrick Packer. C. Judgment against Defendant Dennis Denton for the cost of gas and time spent viewing the home. D. Judgment for such other relief as is just. DEMAND FOR JURY TRIAL Plaintiff demands trial by jury on all issues. [SIGNATURE BLOCK]
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