Defendant's Storzbach's attorney Richard Conlin Lawsuit

State of Michigan
In the Livingston County Circuit Court
204 S. Highlander Way, Howell, Michigan 48843
517-546-9816


George Edward Lyons,
11994 Weiman
Pinckney, Michigan 48169
734-954-4040

Plaintiff,
vs.

Ronald Allen Storzbach and
Virginia E. Storzbach, H/W
912 Sand Wedge Court
Bowling Green, Ky. 42103-2508
Last known address
Phone unavailable
Defendants,

Michael R. Coad
3053 Adams
Rochester Hills, Michigan
Last known address
Phone unavailable
Defendant

Case No.:




Complaint



NOW COMES THE PLAINTIFF GEORGE EDWARD LYONS, and complaint against Defendants Ronald Storzbach and Virginia Storzbach H/W, and Defendant Michael R. Coad stating as follows:

COMMON ALLEGATIONS AND COMPLAINT
ALL PLAINTIFF’S RESPONSES FOR THIS COMPLAINT ARE DONE IN BLUE.

1. That Plaintiff George Edward Lyons is a resident of Township of Putnam Township, Livingston County, Michigan. Defendant Ronald Storzbach and Virginia Storzbach was a resident of Hamburg Township, Livingston County, Michigan. Who is now residing in 912 Sand Wedge Court, Bowling Green, Kentucky.

2. That Plaintiff George Edward Lyons is a resident of Township of Putnam Township, Livingston County, Michigan. Defendant Michael R. Coad was a subcontractor Carpenter for Defendant Storzbach on lot 16 Partridge Pointe, Michigan, Hamburg Township, Livingston County, Michigan. Who in last notification resides 3053 Adams, Rochester Hills, Michigan.
3. Storzbach’s Complaint drafted by Storzbach’s Attorney Richard Conlin. Plaintiff is responding to every false allegations starting with the Following:

4. Storzbach’s and there attorney Richard Conlin received consent judgment by criminal actions. Storzbach made terrorized threats to the health and lives against Plaintiff and his Family. If Plaintiff George Lyons did not sign the consent judgment.

Plaintiff George Lyons Complaint case because Storzbach’s committed terrorized the Plaintiff, and extortion, embezzlement, tortuous Interference. Civil conspiracy against Plaintiff. And forcing Plaintiff to wrongfully signing consent judgment.

The Plaintiff Motion to re-open case because of Defendant’s criminal actions was filed 1 day after consent judgment was signed.

Per letter from Defendant’s attorney Richard Conlin dated October 27th 1995 committed extortion. Forcing Plaintiff to either sell Defendant lot 16, Partridge Point, Brighton, Michigan or he would file a wrongful levy against all 8 lots that Plaintiff owned in Partridge Point, Brighton, and Mi. See attached Short version page 7 and 11. Plaintiff was force to sell lot 16 Partridge Point, Brighton.

To do this Plaintiff sold this property for $ 4,900.00 less then what plaintiff paid for the Lot 16, Partridge Point, Brighton, Mich. If Plaintiff did not sell the property for what Storzbach’s and their attorney Richard Conlin did committed extortion. Plaintiff would lose 4 other clients that were interest in Plaintiff property.

a. Defendant attorney Richard Conlin committed perjury in Judge Stanley Laterille court: Plaintiff George Lyons was represented by attorney Thomas Brady: Defendant’s attorney Conlin stated “that attorney Richard Conlin personally put document (NOTICE TO APPEAR IN COURT). into mail box”

b. This statement was false and misleading on attorney Richard Conlin part to acquire a Default Judgment against Plaintiff George Lyons. Proof of Services shows that Richard Conlin did not deposit notice to appear as stated in court.

c. Attorney Richard Conlin law firm was to send copy of notice to Plaintiff George Lyons and his attorney Thomas Brady to appear before Judge Stanley Laterille.

d. Attorney Richard Conlin stated before Judge Stanley Laterille, that he had no idea that George Lyons was represented by an attorney Thomas Brady, this false statement was to acquire a default judgments for his Clients Ronald and Virginia Storzbach from Plaintiff George Lyons for $ 51,000.00 and fraudulent attorney fees for $ 3,000.00.

e. Per audio tape conversation between Plaintiff George Lyons and Storzbach Attorney Richard Conlin and Plaintiff attorney Thomas Brady. “That Storzbach Attorney Richard Conlin agreed to send all documents to Thomas Brady office in Farmington Hills in Defendant Storzbach’s Lawsuit.


f. Per Audio tape conversation Attorney repeated the address back to Thomas Brady. This was recorded in George Lyons Chrysler New Yorker, on his hands free set. Approx. 30 days prior to Storzbach attorney Richard Conlin filed suit, and Storzbach’s attorney Richard Conlin false notice to appear in court.

THIS IS DONE PER STORZBACH’S FRAUDULENT LAWSUIT-COMPLAINT FILED BY DEFENDANT’S ATTORNEY RICHARD CONLIN DATED: MAY 5TH 1994. Evidence enclosed as Short version of Defendant’s Storzbach’s and Long Version of Defendant’s Storzbach’s Short version will be used as Exhibits.

PLAINTIFF RESPONSE AND COMPLAINT SHALL BE VIEWED AS BLUE
ALL STATEMENTS DONE BY DEFENDANT’S ARE DONE IN BLACK

5. That on or about September 4th 1993, Plaintiffs and Defendants entered into a Building Contract for the construction of a residential home for Plaintiffs for the total price, including land, of $ 205,000.00, to be erected on real property described as Unit 16, Partridge Point, Hamburg Township, and Livingston County, Michigan. Further, that said Contract was subsequently amended on October 28th, 1993. A copy of said Contract, as amended in attached hereto and made a part hereof. (See attached Exhibit “A”)

PLAINTIFF RESPONSE: Further, that said Contract was subsequently amended on October 28th, 1993. A copy of said Contract, as amended in attached hereto and made a part hereof. (See attached Exhibit “A”).

CONTRACT WAS AMENDED UNDER FORCE BY STORZBACH ATTORNEY RICHARD CONLIN. SEE STORZBACH SHORT VERSION. STORZBACHS COMMITTED EXTORTION, AND EMBEZZLEMENT. A LETTER FROM STORZBACHS ATTORNEY TO PLAINTIFF LYONS ATTORNEY THOMAS BRADY DATED: OCTOBER 27TH 1993.

STATING THE FOLLOWING: PAGE ONE: As stated by Storzbach’s attorney Richard Conlin in a letter to Plaintiff attorney Thomas Brady in paragraph b. An equitable lien will be filed with the Livingston County Register of Deeds on all the lots being purchased.

PER BUILDING CONTRACT SIGNED AN APPROVED BY STORZBACH STATES. SEE PARAGRAPH. GEORGE LYONS HAD 8 LOTS IN PARTRIDGE POINT, BRIGHTON, MI. THE ATTORNEY RICHARD CONLIN STATE UNDER OATH

PAGE TWO OF LETTER FROM ATTORNEY RICHARD CONLIN TO PLAINTIFF ATTORNEY THOMAS BRADY: Hopefully these steps will not be necessary, but I can assure you they will be taken unless my client obtains immediate security in the form of A WARRANTY DEED FOR THE $41,000.00 OF THEIR MONEY PRESENTLY POSSESSED BY LYONS BUILDERS. THIS IS CALLED EXTORTION. ATTACHED SHORT VERSION PAGE 4 AND 5 OF 32 PAGES.

DEFINING EXTORTION - The use, or the express or implicit threat of the use, of violence or other criminal means to cause harm to person, reputation, or property as a means to obtain property from someone else with his consent. USC 18

DEFINING EMBEZZLEMENT [MCL 750.174]
· Since 01/01/1999, Michigan defines 4 levels of Embezzlement:
o under $200: Misdemeanor -- up to 93 days and/or $500, or 3 times amount embezzled, whichever is greater
o at least $200 but less than $1,000 (or repeat offender of above): Misdemeanor -- up to 1 year and/or $2,000, or 3 times amount embezzled, whichever is greater
o at least $1,000 but less than $20,000 (or repeat offender of above): Felony -- up to 5 years and/or $10,000, or 3 times amount embezzled, whichever is greater
o $20,000 or more (or repeat offender of above): Felony -- up to 10 years and/or $15,000, or 3 times amount embezzled, whichever is greater · The essence of this crime is a violation of trust --- the agent (e.g., employee) was entrusted with the principal's (e.g., employer) property, acquired the principal's property through that relationship of trust, and dishonestly disposed of/took/hid/converted the property to his own use

On October 30th 1993: Plaintiff George Lyons was forced to sell lot 16 Partridge Point, Brighton, Michigan to Ronald and Virginia Storzbach by Storzbach’s attorney Richard Conlin. On October 30th 1993: Plaintiff transfer warranty deed to Ronald and Virginia Storzbach for $ 41,000.00 which on the same day same closing with Storzbach’s attorney present. Plaintiff George Lyons of Lyons Builders, Inc. Paid $ 45,900.00. A $ 4,900.00 difference/lose to Plaintiff George Lyons. Why would Plaintiff do this is to protect other clients interested in Plaintiff’s lots in Partridge Pointe, Brighton, Michigan.

Per the above Storzbach stated to State of Michigan Consumer & Industry Service that Defendant’s Storzbach’s paid Plaintiff George Lyons of Lyons Builders, Inc. A retainer of $ 41,000.00 and Defendant paid $ 41,000.00 for Lot 16 Partridge Pointe, Brighton, Michigan. This was a fraudulent statement on the Storzbach’s part.

PLAINTIFF RESPONSE: THIS FRAUDULENT STATEMENT IN THE DEFENDANT’S STORZBACH’S FALSE STATEMENTS TO CONSUMER & INDUSTRY SERVICES AND THEN TO THE LIVINGSTON COUNTY COURT SYSTEM COMPLETELY SHOWED THAT DEFENDANTS STORZBACH’S PAID PLAINTIFF $ 82,000.00 PLUS $ 29,400.00. THIS STATEMENT BY DEFENDANT’S STORZBACH SHOWS EMBEZZLEMENT AND EXTORTION...

Storzbach’s used this false statement to acquire a fraudulent report from Consumer & Industry Service. This fraudulent report was used in the Defendant’s Storzbach’s fraudulent lawsuit against Plaintiff George Lyons and his company Lyons Builders, Inc.

On October 30th 1993: Defendant’s Storzbach’s used Plaintiff retainer of $ 41,000.00 to purchase Lot 16 Partridge Point, Brighton, Michigan.

Per accounting and as of October 30th 1993. Plaintiff was in the whole $24,411.51 by using the $ 41,000.00 to start construction. Then Plaintiff had to use his own money in the returning retainer to Storzbach’s see accounting:

BUILDING CONTRACT WAS CONTINGENT UPON STORZBACH’S ACQUIRING FINANCING SEE AUDIO TAPES AND DOCUMENTS WHICH STORZBACH’S DID NOT RECEIVE THERE CONSTRUCTION LOAN UNTIL NOVEMBER 3RD 1993.

THIS IS WHEN THE TRUE BUILDING CONTRACT STARTED. THE STATEMENT ON STORZBACH’S PART WAS DELAYED BECAUSE DEFENDANT’S STORZBACH’S WERE NOT PAYING THEIR OBLIGATIONS ON THE CONTRACT.

Storzbach’s went to Chelsea Lumber in Chelsea, Mi. to acquire a construction loan. Storzbach’s hold-up was Storzbach’s applied for a loan through General Motors Mortgage company after weeks of hold-ups Storzbach’s found out that General Motors Mortgage Company did not do Construction Loans 9/24/93. PAGE 4 OF STORZBACH’S LONG VERSION.

Defendant’s Storzbach’s in going to Chelsea lumber, Chelsea, Michigan for a construction loan. Chelsea Lumber requirements are the following:

This was Defendant’s Storzbach’s construction loan and requirements per building contract, the requirements are to have money to pay for Defendant’s obligations. This was neither Plaintiffs obligation nor Lyons Builders, Inc obligation.

Defendant’s Storzbach’s per the building contract with Lyons Builders, Inc.

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT. POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT. PAGE 14 OF BUILDING CONTRACT OR PAGE 20 OF 51 STORZBACH LONG VERSIONS.

FOOTNOTE: THERE WAS EXTORTION OF LOT 16 PARTRIDGE POINT BY THE DEFENDANT’S STORZBACH AND THERE ATTORNEY RICHARD CONLIN, THERE WAS NO FULL PAYMENT TO BE MADE TO CONTRACTOR FOR ALL SUMS DUE HIM UNDER THIS CONTRACT TO THE CONTRACTOR (PLAINTIFF). THERE WAS THEIF BY DEFENDANT’S STORZBACH’S AGAINST PLAINTIFF.

AND THERE WAS NO CLOSING UNDER THE BUILDING CONTRACT. THERE WAS EMBEZZLEMENT ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF. THERE WAS THEIF ON DEFENDANT’S STORZBACH’S PART IN NOT PAYING FOR UPGRADE’S THAT WERE CRIMINALLY CHARGED AGAINST PLAINTIFF. SEE AUDIO’S

THE FOLLOWING IS AN OBLIGATION BY DEFENDANT’S STORZBACH’S TO ACQUIRE A CONSTRUCTION LOAN THROUGH CHELSEA LUMBER FINANCIAL DEPARTMENT. BUT THIS WAS NOT PLAINTIFF’S OBLIGATION THROUGH CHELSEA LUMBER. THERE WAS A SIGNED AND APPROVED BUILDING CONTRACT BY DEFENDANT’S STORZBACH’S PRIOR TO CHELSEA LUMBER CONSTRUCTION LOAN. THAT DEFENDANT’S STORZBACH’S DID NOT FOLLOW.

Home Construction Financing Detail Sheet

1. You bring a set of blueprints to Chelsea Lumber Company.

2. Chelsea Lumber Company completes a material estimate for you.

3. Bring your completed credit application to Chelsea Lumber Company.

4. You collect bids for labor and/or materials from subcontractors as shown on the reverse side of this sheet. (See Storzbach’s Long version page 50).

5. Chelsea Lumber representative meets with you to transfer your bids to Chelsea Lumber’s worksheet and mutually agree on a dollar needed to complete the project.

6. Chelsea Lumber Company orders certified appraisal.

7. You deliver a copy of existing title policy to Chelsea Lumber Company. If a Title policy is not available, a copy of a deed or land contract will suffice.

8. Chelsea Lumber Company updates the title policy, insuring Chelsea Lumber Company. This process could take two (2) weeks. This fee will be charged to your account.

9. You deliver a copy of a builder’s risk of homeowner’s insurance policy to Chelsea lumber Company. No binders, client must pay a one-year premium in advance. Mortgages clauses must read as follows:

1st Mortgages
Mail Code 3394
Commercial & Real Estate Loan Documentation Dept.
Comerica Bank
P.O. Box 33019
Detroit, Mi 48232-5019

2nd Mortgages
Chelsea Lumber Company & additional insured
1 Old Barn Circle
Chelsea, Mi 48118

10. You take out a workman’s compensation insurance policy and provide a certificate of such policy or application to Chelsea Lumber Company.

11. After the foundation is completed. Chelsea Lumber Company representative meets
With client to sign necessary documents and close on construction mortgage.

12. After the foundation is completed. Chelsea Lumber Company orders a mortgage survey.
This fee will be charged to your account.

13. If there is an existing Land-contract or mortgage pay-off, lending laws require Chelsea Lumber Company to wait at least three (3) Business days from the time of signing the mortgage until we can open the account and payoff the property.


Reverse side of Storzbach’s Home Construction Financing Check List:
BIDDING CHECK LIST (APPROVED BY STORZBACH’S)

1
FOUNDATION EXCAVATION
7,000.00
2
DRIVEWAY
1,000.00
3
BLOCK FOUNDATION*
2,500.00
4
POURED FOOTING &FOUNDATION
17,000.00
5
CHELSEA LUMBER MATERIAL PACKAGE
50,141.09
6
ROUGH FRAMING LABOR
16,200.00
7
FINISH TRIM MATERIAL*
included

8
FINISH TRIM LABOR

9
WINDOWS*
5,600.00
10
EXTERIOR DOORS*
included
-
11
ROOFING-LABOR & MATERIAL*
included
2,000.00
12
CONCRETE FLATWORK
included
-
13
PLUMBING-LABOR AND MATERIALS
3,430.00
14
BATH FIXTURES
included

15
HEATING-LABOR & MATERIALS
5,800.00
16
ELECTRICAL-LABOR & MATERIALS
4,900.00
17
LIGHT FIXTURES* INCLUDED IN ELECTRICAL
included
-
18
INSULATION -LABOR & MATERIALS*
include/labor
1,000.00
19
DRYWALL-LABOR & MATERIALS*
include/labor
3,000.00
20
BRICK-HOUSE AND LABOR
and labor
2,500.00
21
BRICK-FIREPLACE
included
22
KITCHEN CABINETS*
4,500.00
23
COUNTERTOPS*
included

24
BATH VANITY & TOPS*
included

25
SEPTIC FIELD (OR TAP FEE)
3,000.00
26
WELL (OR TAP FEE)
2,500.00
27
PAINT & STAIN-LABOR & MATERIALS*
2,000.00
28
FLOORING-CARPET, VINYLE, TILE
4,800.00
29
APPLIANCES*
900.00
30
GUTTERS*
not included

31
UTILITIES HOOKUP
not included
-
32
RISK INSURANCE
500.00
33
PERMIT & FEES
1,000.00
34
WORKMAN'S COMPENSATION INSURANCE
owner
-
Total money for construction STORZBACH HOME
141,271.09
SEE AUDIO
LOT 16 PARTRIDGE POINTE, BRIGHTON, MICHIGAN
41,000.00
182,271.09
BUILDING CONTRACT PRICE
(205,000.00)
BALANCE OWED LYONS BUILDERS, INC.
(22,728.91) THIS DOES NOT INCLUDED THE CHANGE'S MADE BY DEFENDANT'S STORZBACH'S

COUNT I –BREACH OF CONTRACT

6. That pursuant to the terms of the contract as previously set forth herein, Defendants were obligated as follows:
a. To construct a home for Plaintiff in accordance with the construction plans for a total price, including land, in the amount of $ 205,000.00.

PLAINTIFF RESPONSE: Defendant’s Storzbach’s committed breach of contract, also per audio tapes show an overwhelming of up-grades that Defendant’s Storzbach’s acquired without Plaintiff George Lyons permission. That Defendant’s Storzbach’s embezzled from Plaintiff George Lyons.

b. To complete the home on or before December 1, 1993, which said date was subsequently amended to extend it to ninety days following closing of Plaintiff’s construction loan. Said construction loan closed on or about November 5, 1993. Further to pay a penalty to Plaintiff in the amount of $ 25.00 per day if not completed within said time frame (Contract. Article 1).

PLAINTIFF RESPONSE: Defendant’s Storzbach’s did not follow contract: Page 3 and 4 of Short version. Stated by Storzbach’s attorney Richard Conlin in a letter to Plaintiff attorney Thomas Brady.

PAGE TWO: Hopefully these steps will not be necessary, but I can assure you they will be taken unless my client obtains immediate security in the form of A WARRANTY DEED FOR THE $41,000.00 OF THEIR MONEY PRESENTLY POSSESSED BY LYONS BUILDERS. THIS IS CALLED EXTORTION ON STORZBACH’S AND HIS ATTORNEY RICHARD CONLIN PART.

PAGE 1: Storzbach’s Building contract was Signed and approved September 4th 1993. On October 27, 1993 53 DAYS AFTER SIGNING BUILDING CONTRACT. Storzbach’s attorney criminally forces George Lyons of Lyons Builders, inc. to CHANGE BUILDING CONTACT AND FORCING IN SELLING Lot 16 Partridge Point, Pinckney, Michigan. NOT PER CONTRACT.

DEFENDANT'S ATTORNEY STATED As stated in b. An equitable lien will be filed with the Livingston County Register of Deeds on all the lots being purchased.

c. To be paid pursuant to Article 4 of the contract, only upon completion of certain work, as follows: a) 20% at time of signing the contract to be held and used as a retainer;

PLAINTIFF RESPONSE: WHERE STORZBACH’S IN RECEIVING BACK THE $ 41,000.00 RETAINER FOR LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

STORZBACH’S ATTORNEY RICHARD CONLIN IS STILL INSISTING THAT PLAINTIFF RECEIVED THE RETAINER AND STORZBACH PAID $ 41,000.00 FOR LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN. SHOWING THAT FALSE STATEMENT THAT STORZBACH’S PAID $82,000.00.

THIS PARAGRAPH IS FALSE AND MISLEADING TO THE LIVINGSTON COUNTY COURT SYSTEM ON STORZBACH’S AND STORZBACH’S ATTORNEY RICHARD CONLIN PART.

THE ONLY MONEY RECEIVED FROM STORZBACH IS $ 41,000.00 RETAINER THAT WAS USED TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

PLAINTIFF RESPONSE: THE ONLY MONEY RECEIVED FROM STORZBACH IS $ 41,000.00 RETAINER THAT WAS USED TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

AND $ 29,500.00 FOR WORK THAT HAS ALREADY BE DONE AND APPROVED BY STORZBACH’S AND CHELSEA LUMBER LOAN FOR CONSTRUCTION.

PER CHELSEA LUMBER CONSTRUCTION LOAN FOR STROZBACH’S PLAINTIFF GAVE CHELSEA LUMBER LOAN DEPARTMENT ALL SWORN STATEMENTS AND WAIVERS OF LIENS, AND PARTIAL AND FULL UN-CONTIONAL AND CONTIIONAL WAVIERS OF WHICH ALL SWORN STATEMENTS AND MATERIAL HANDLERS AND SUBCONTRACTOR WERE CONTACTED AND ASK IF THEY WERE PAID BY LYONS BUILDERS, INC.

COPIES OF THESE DOCUMENTS WERE ALSO GIVEN TO DEFENDANTS STORZBACH’S. SEE AUDIO TAPES OF STORZBACH’S RECEIVING THESE DOCUMENTS.

DEFENDANTS STORZBACHS BREACH BUILDING CONTRACT BY TAKING BACK RETAINER $ 41,000.00 TO PURCHASE LOT 16 PARTRIDGE POINTE, BRIGHTON, MICHIGAN.
.
b) First draw only upon completion of “excavation of basement, rough frame of house and windows, roofing material, septic or sewer hookup, well, etc.”;

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENTS WERE GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW.

c) rough heating, rough mechanics, rough plumbing, etc.”; d) third draw upon the completion of “drywall, finish lighting, carpentry, cabinets, plumbing, countertops, tile work, paint, stain, garage doors and openers, etc,”; e) fourth, Certificate of Occupancy , finish permits and waivers of any and all work.

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW.
d. To “give all necessary notices to, and obtain the necessary permits and sanctions of the proper governmental authorities concerning the work and the safety and protection of personal property, in respect to said work, and general comply with the building codes and other regulation of said authorities”. (See Article 2, Contract)

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW.

e. To prior to the receipt of any construction draw, deliver to the owner a sworn statement listing the names and amounts due all subcontractors, mechanics, workman, and suppliers and to furnish waivers of lien from persons furnishing labor or material in connection with the erection of the home. (See Article 8, Contract)

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW. REPRESENTATIVE FROM CHELSEA LUMBER ARE MORE THAN WILLING TO TESTIFY BEFORE THIS COURT.


PLAINTIFF RESPONSE: THE ONLY MONEY RECEIVED FROM STORZBACH IS $ 41,000.00 RETAINER THAT WAS USED TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

AND $ 29,500.00 FOR WORK THAT HAS ALREADY BE DONE AND APPROVED BY STORZBACH’S AND CHELSEA LUMBER LOAN FOR CONSTRUCTION.

PER CHELSEA LUMBER CONSTRUCTION LOAN PLAINTIFF GAVE CHELSEA LUMBER LOAN DEPARTMENT ALL SWORN STATEMENTS AND WAIVERS OF LIENS, OF WHICH ALL SWORN STATEMENTS AND MATERIAL HANDLERS AND SUBCONTRACTOR WERE CONTACTED AND ASK IF THEY WERE PAID BY LYONS BUILDERS, INC.

COPIES OF THESE DOCUMENTS WERE ALSO GIVEN TO DEFENDANTS STORZBACH’S. SEE AUDIO TAPES OF STORZBACH’S RECEIVING THESE DOCUMENTS.

f. To pay transfer tax when title to the property passes pursuant to Article 10 of the contract.
g. To provide an Owner’s policy of title insurance without standard exceptions in the amount of the contract price at contractor’s expense pursuant to Article 10 of the contract.
7. That nevertheless and in spite of said contractual duties, Defendants breached the same in the following respects:

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW AND TRUTHFULNESS.

a. In failing to construct the home for Plaintiffs in the amount of $ 205,000.00, including land, as contracted; and /or to make satisfactory progress in the construction of said home so that said home could foreseeably have been built for said sum and in a timely fashion. As a result of Defendant’s anticipatory breach in failing to make adequate progress in said construction.

b. Plaintiffs were forced to remove the Defendants in December 1993 and complete the home on their own at an excess expense of approximately $ 50,000.00.

PLAINTIFF RESPONSE: was wrongfully removed from property not in December 1993. Per permit history Plaintiff performed over $ 175,890.00 worth of work on Storzbach project.

See accounting that Storzbach’s did not reimburse Plaintiff. Upgrades over $ 75,000.00+ done by Storzbach’s that were not in building contract. Audio tapes conversation with Storzbach’s on upgrades that Storzbach’s was repetitively asked to sign.

See accounting. Audio tape conversations with Storzbach’s and Jerry Jarvis developer of Partridge Pointe, Brighton, Michigan asking subcontractor’s to make a fraudulent complaint to the State of Michigan Consumer & Industry services to wrongfully remove Plaintiff builders license to Stop Plaintiff George Lyons in having any money for an attorney.

c. In failing to obtain necessary permits or notify utility companies of upcoming needs for services resulting in excessive expense for Plaintiffs. Further, in violating certain ordinances in the maintenance of the premises in burning construction debris on site.

PLAINTIFF RESPONSE: DATES IN OBTAINS ALL NECESSARY PERMITS:
CHECK NO 1378 2-Sep-93

LIVINGSTON COUNTY HEALTH DEPARTMENT FOR WELL AND SEPTIC PERMITS
CASH 2-Sep-93

HAMBURG LAND USE PERMIT
CHECK NUMBER 1382 3-Sep-93

LIVINGSTON COUNTY BUILDING DEPARTMENT PERMIT 23-Sep-93


PLAINTIFF RESPONSE: CHECK NUMBER: DATE OF CHECK FOR CONSUMER POWER. ALL NECESSARY WERE ACQUIRED PER FOLLOWING DATES ON STORZBACH’S PROJECT.

NOTIFICATION OF UTILITY COMPANIES WERE ACQUIRED 27-JUN-1993 STORZBACH’S WERE NOTIFIED TO CALL UTILITY COMPANY AND GIVE THEM THERE SOCIAL SECURITY NUMBER: PER CONTRACT SPECIFICATIONS ADDED TO CONTRACT. STORZBACH’S WERE OBLIGATED FOR ALL GAS AND ELECTRIC BILLS.


Check number: 1270 27-Jun-93
CONSUMER POWER-STORZBACH’S WAS TOLD TO CONTACT-NEEDED SOCIAL SECURITY NUMBER>

APPLICATION FOR LOT 16 PARTRIDGE ($20.23)


PER STORZBACH’S SPECIFICATION ADDED TO CONTRACT:

PARAGRAPH 1.3 WORK NOT INCLUDED:

C. GAS AND ELECTRIC BILLS…………………………………………………………..NOT INCLUDED


SEE AUDIO TAPE OF CONVERSATION WITH STORZBACH’S THAT PLAINTIFF ORDER INSTALLATION OF GAS AND ELECTIC 27-JUNE-1993 FROM CONSUMER POWER: DEFENDANT’S STORZBACH’S NEEDED TO VERIFY HIS SOCIAL SECURTITY NUMBER TO ORDER THE CONSUMER POWER: (CONSUMER POWER INCLUDES: GAS AND ELECTRICITY.


SUBCONTRACTOR BURNED BUILDING MATERIAL, WITHOUT THE PERMISSION OF PLAINTIFF. WHEN PLAINTIFF FOUND OUT ABOUT THE BURNING OF MATERIALS. PLAINTIFF ACQUIRED BURN PERMIT.

IN ALL SUBCONTRACTOR AGREEMENTS, SUBS ARE TO LEAVE PROJECT IN BROOM CLEAN CONDITION.

d. In applying for and receiving construction draws without supplying the necessary sworn statements and waivers and prior to completion of the work called for in the contract. In spite of the contract language, the first draw (after payment of the $41,000.00 retainer) was applied for and received in the amount of $ 29,400.00 prior to the completion of most of the work under the terms of the contract for the first draw payment. Rough framing, as called for was.


PLAINTIFF RESPONSE: Defendant’s Storzbach breach building contract by not paying retainer of $ 41,000.00. . Per permit history Plaintiff performed over $ 175,890.00 worth of work on Storzbach project. See accounting that Storzbach’s did not reimburse Plaintiff. Upgrades that were not in building contract. Audio tapes conversation with Storzbach’s on upgrades that Storzbach’s was repeteively asked to sign change agreements.

See accounting. Audio tape conversations with Storzbach’s and Jerry Jarvis developer of Partridge Pointe, Brighton, Michigan asking subcontractor’s to make a fraudulent complaint to the State of Michigan Consumer & Industry services to wrongfully remove Plaintiff builder’s license to Stop Plaintiff George Lyons in having any money for an attorney.

Only completed in mid-December and then only after the carpenters had left the project after being given a bad check by Defendants. In spite of the fact that some of the first draw items were not completed, an application for a second draw was made in early December, again without adequate or proper supporting sworn statement or waivers lien.

PLAINTIFF RESPONSE: PLAINTIFF DID NOT GIVE CARPENTERS BAD CHECK PAGES 38 TO 41 OF SHORT VERSION WILL PROVE THIS: ALL SWORN STATEMENTS AND WAIVERS OF LIENS WERE GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR APPROVAL OF MONEY PAID BY PLAINTIFF AND HIS COMPANY. THIS WAS DEFENDANT’S RULES AND REGULATION OF CHELSEA LUMBER FINANCING COMPANY. Neither PLAINTIFF NOR HIS COMPANY.


CARPENTER MICHALE R. COAD COMMITTED FRAUD, EMBEZLLEMENT, AND OTHER CRIMINALS ACTS. SEE AUDIO TAPES.


AUDIO TAPE CONVERSATION WITH MR. COAD: MR. COAD ENTERS WITHOUT PERMISSION. AT THE OFFICE OF LYONS BUILDERS, INC. PINCKNEY, MI.

AUDIO TAPED CONVERSATION WITH MR. COAD AND PLAINTIFF. BEFORE ENTERING WITHOUT PERMISSION. PLAINTIFF STATED TO MR. COAD. PLAINTIFF STATED I MADE OUT YOUR CHECK AND SIGNED IT AND PUTTING IT INTO MY CHECK REGISTER, I CAN NOT RELEASE THIS CHECK UNTIL I GET A DEPOSIT FROM STORZBACH AND PUT IT INTO MY ACCOUNT AND HAVE THREE DAYS TO CLEAR. WHEN IT CLEARS I WILL CONTACT YOU TO PICK-UP THE CHECK.

MR. COAD WENT BACK TO MY OFFICE AND ENTER WITHOUT PLAINTIFF PERMISSION AND REMOVED THE $5,000.00 CHECK FROM THE PLAINTIFF REGISTER. THIS IS CALL IN LAYMANS TERMS STEALING BY DEFENDANT COAD.

AUDIO TAPE: OF PLAINTIFF CONFRONTING MR. COAD IN WRONGFULLY REMOVING THE CHECK. THIS WAS CRIMINAL ACT AGAINST PLAINTIFF ON MR. COAD PART.

AUDIO CONVERSATION WITH CARPENTER MIKE COAD STATING TO PLAINTIFF GEORGE LYONS THAT HE DID ENTER PLAINTIFF OFFICE WITHOUT PLAINTIFF PERMISSION AND WRONGFULLY REMOVE $5000.00 CHECK FROM PLAINTIFF OFFICE WITHOUT PLAINTIFF PERMISSION. AND WRONGFULLY TRIED TO CASH $5000.00 CHECK. PLAINTIFF STATED THAT HE PUT A STOP PAYMENT ON THE CHECK TO MR. COAD

WORKERS OF ROUGH CARPENTER MICHALE R. COAD WILL TESTIFY THAT THE ROUGH CARPENTRY FOR STORZBACH’S PROJECT WAS ONLY $ 9,800.00 AND THAT MICHAEL R. COAD DID IN FACT EMBEZZLE MONEY FROM PLAINTIFF AND HIS COMPANY.

AUDIO TAPES BETWEEN MR. COAD AND PLAINTIFF WILL ALSO VERIFY MICHAEL R. COAD ALSO DID IN FACT COMMITTED THEIF OF THE CHECK, ENTERING WITHOUT PERMISSION AND EMBEZZLEMENT FROM PLAINTIFF AND HIS COMPANY. BY MR. COAD STATING THAT HIS CONTRACT WITH LYONS BUILDERS, INC. WAS $16,000.00. THIS FALLS UNDER GRAND THEIF. FROM PLAINTIFF AND HIS COMPANY THAT’S MORE THAN $ 2,000.00.


PLAINTIFF RESPONSE: DEFENDANT SUBCONTRACTOR MICHAEL COAD AND HIS PARTNER COMMITTED EMBEZZLEMENT OF $8,000+ FROM PLAINTIFF THROUGH AUDIO TAPE CONSVERSATION WITH DEFENDANT MICHAEL COAD STATING THAT COMPLETE ROUGH CARPENTARY COST WAS $9,800.00 ONLY.

DEFENDANT STORZBACH'S COMMITTED EMBEZZELMENT AND FRAUD BY MAKING FRAUDULENT STATEMENTS TO DEFENDANT’S STORZBACH’S AND CAUSING A LOST OF FUNDS OVER $8,000.00+ AND THIS SNOW BALLED INTO LOSSES TO THE PLAINTIFF GEORGE EDWARD LYONS AND HIS COMPANY OVER $20,000.00+. THIS IS A CIVIL CASE. CRIMINAL CHARGES WILL BE FILED AFTER CIVIL CASE.

DEFINING EMBEZZLEMENT [MCL 750.174]
· Since 01/01/1999, Michigan defines 4 levels of Embezzlement:
o under $200: Misdemeanor -- up to 93 days and/or $500, or 3 times amount embezzled, whichever is greater
o at least $200 but less than $1,000 (or repeat offender of above): Misdemeanor -- up to 1 year and/or $2,000, or 3 times amount embezzled, whichever is greater
o at least $1,000 but less than $20,000 (or repeat offender of above): Felony -- up to 5 years and/or $10,000, or 3 times amount embezzled, whichever is greater
o $20,000 or more (or repeat offender of above): Felony -- up to 10 years and/or $15,000, or 3 times amount embezzled, whichever is greater
· The essence of this crime is a violation of trust --- the agent (e.g., employee) was entrusted with the principal's (e.g., employer) property, acquired the principal's property through that relationship of trust, and dishonestly disposed of/took/hid/converted the property to his own use.

SEE TRANSCRIPT OF AUDIO TAPE OF DEFENDANT RONALD STORZBACH’S BEING NOTIFIED 10 DAYS BEFORE MAKING ANY MORE PAYMENTS TO DEFENDANT MICHAEL R. COAD. NOT TO PAY MICHAEL R. COAD OF DIMENSION IN WOOD ANY MORE MONEY. THAT DIMENSION IN WOOD WAS PAID IN FULL.

AND THE BALANCE OF THE CONTRACT TO BE PAID TO LYONS BUILDERS, INC. SHORT VERSION. THIS TRANSCRIPT ALSO PROVES THAT DEFENDANT’S STORZBACH’S TOOK OVER ALL PAYMENTS TO SUBCONTRACTOR’S AND DID MAKE ALL SUBCONTRACTOR’S PAYMENTS AND MATERIAL HANDLERS.

THAT PLAINTIFF DID NOT HAVE ANY CONTROL OVER AND PAYMENTS OF DEFENDANT’S STORZBACH’S. AND HIS PAYMENTS ON UPGRADES THAT WAS NOT IN THE CONTRACT. THAT WAS OVER $ 75,000.00- ON STORZBACH’S PROJECT. AND DEFENDANT’S STORZBACH’S STATING TO HIS ATTORNEY THAT THE UPGRADES WERE IN THE CONTRACT.

DEFENDANT’S FILE FRAUDULENT LAWSUIT TO ACQUIRE A FRAUDULENT LEVY AGAINST PLAINTIFF PROPERTY 5654 SHOSHONI PASS, PINCKNEY, MI. AND DEFENDANT’S STORZBACH STATED TO SUBCONTRACTOR’S ON THE STORZBACH’S PROJECT THAT HE PAID PLAINTIFF GEORGE LYONS THERE MONEY. AND THAT THEY TO SHOULD FILE MECHANICAL LIENS AGAINST PLAINTIFF PROPERTY 5654 SHOSHONI PASS, PINCKNEY, MICHIGAN. DEFENDANT’S WRONGFULLY AND CRIMINALLY AND CLOUDED TITLE OF 5654 SHOSHONI PASS, PINCKNEY, MICHIGAN.
d. In failing to complete the contract in a timely fashion under the terms of the contract.

PLAINTIFF RESPONSE: DEFENDANT’S STORZBACH FAIL TO FOLLOW CONTRACT. AND IN DOING SO DEFENDANT’S STORZBACH BREACH BUILDING CONTRACT WITH PLAINTIFF AND HIS COMPANY.

DEFENDANT STORZBACH'S DID FORCE PLAINTIFF TO USE PLAINTIFF RETAINER TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, and MI. AND NEVER REPLACED RETAINER WITH THE PLAINTIFF AND HIS COMPANY. OR GET A CHANGE AGREEMENT WITH THE PLAINTIFF OR HIS COMPANY. PLAINTIFF NEVER DID RECEIVE REMIBURST MET OF RETAINER OF $ 41,000.00 FROM THE DEFENDANT’S STORZBACH’S.

DEFENDANT’S STORZBACH’S TOOK OVER ALL SUBCONTRACTOR’S PAYMENTS AFTER THE FIRST AND ONLY DRAW OF $ 29,500.00. SEE AUDIO TAPE.

e. In failing to provide transfer taxes to the owner at time of passage of title.

PLAINTIFF RESPONSE: TRANSFER OF TAXES WAS TRANSFER. AT THE SAME TIME OF CLOSINGS OF PLAINTIFF PAID $ 45,900.00 AND DEFENDANT PAID $ 41,000.00 AND $ 4,900.00 LOSES TO THE PLAINTIFF. DEFENDANT’S STORZBACH ATTORNEY ORGISTRATED THE CLOSING AT METROPOLIATION TITLE COMPANY. SEE AUDIO TAPE OF CLOSING PROVES EXTORTION ON DEFENANT’S STORZBACH’S AND THEIR ATTORNEY PART.

f. In failing to provide title insurance to the owner at time of passage of title.

PLAINTIFF RESPONSE: DEFENDANT’S STORZBACH ATTORNEY ORGISTRATED THE CLOSING AT METROPOLIATION TITLE COMPANY. SEE AUDIO TAPE OF CLOSING PROVES EXTORTION. AND AGAIN DEFENDANT MADE ACQUIRE A $ 4,900.00 FROM THE PLAINTIFF. TRUE COST OF THE PROPERTY LOT 16 PARTRIDGE POINT, BRIGHTON, MI. WAS $ 59,000.00 TO THE PLAINTIFF. SEE TITLE POLICY TO DEFENDANT STORZBACH FROM PLAINTIFF.

g. In failing to make advance provisions for utilities.

PLAINTIFF RESPONSE: NOTIFICATION OF UTILITY COMPANIES WERE ACQUIRED 27-JUN-1993 STORZBACH’S WERE NOTIFIED TO CALL UTILITY COMPANY AND GIVE THEM THERE SOCIAL SECURITY NUMBER: PER CONTRACT SPECIFICATIONS ADDED TO CONTRACT. STORZBACH’S WERE OBLIGATED FOR ALL GAS AND ELECTRIC BILLS.


CHECK NUMBER 1270 27-Jun-93
CONSUMER POWER-STORZBACH’S WAS TOLD TO CONTACT-NEEDED SOCIAL SECURITY NUMBER>

APPLICATION FOR LOT 16 PARTRIDGE
($20.23)


PER STORZBACH’S SPECIFICATIONS ADDED TO CONTRACT:

PARAGRAPH 1.3 WORK NOT INCLUDED:

C. GAS AND ELECTRIC BILLS……………………………………………………………NOT INCLUDED


SEE AUDIO TAPE OF CONVERSATION WITH STORZBACH’S THAT PLAINTIFF ORDER INSTALLATION OF GAS AND ELECTIC 27-JUNE-1993 FROM CONSUMER POWER: DEFENDANT’S STORZBACH’S NEEDED TO VERIFY HIS SOCIAL SECURTITY NUMBER TO ORDER THE CONSUMER POWER: (CONSUMER POWER INCLUDES: GAS AND ELECTRICITY).

J. In failing to order certain materials in a timely fashion.

PLAINTIFF RESPONSE: DEFENDANTS STORZBACH’S BUILDING CONTRACT NEVER STARTED, DEFENDANT’S STORZBACH’S NEVER STARTED THEY DID NOT FOLLOW THE APPROVED BUILDING CONTRACT, DEFENDANT’S STORZBACH’S FORCE PLAINTIFF TO GIVE-UP $ 41,000.00 RETAINER TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MI.

PER THE CONSTRUCTION OF DEFENDANT’S PROJECT, PLAINTIFF PER THE LIVINGSTON COUNTY BUILDING DEPARTMENT PERMIT HISTORY: PLAINTIFF GEORGE EDWARD LYONS AND HIS COMPANY LYONS BUILDERS, INC. PERFORMED OVER $ 175,890.00 SEE LIVINGSTON COUNTY BUILDING DEPARTMENT INSPECTION CODES ENCLOSED DEFENDANTS STORZBACH’S SHORT VERSION: PAGE 31 OF 32 PAGES.

TO PUT THIS IN PERSPECTIVE: Defendant’s Storzbach’s $ 41,000.00 for lot 16 Partridge Pointe, Brighton, Michigan. $ 29,400.00 for first and only draw. A total of $70,400.00.

Plaintiff George Lyons company performed per Livingston County Building Inspection permit history. Lyons Builders, Inc. performed $ 175,890.00 this did not include subcontractor’s work after Lyons Builders, Inc. was criminally removed from Defendant’s Storzbach’s project. So Defendant’s Storzbach’s criminally embezzle free work and Lyons Builders Inc. money.


Direct result of said breaches; Plaintiffs have incurred the following damages:
a. Excess cost in completion of the house in the approximate amount of $ 50,000.00;

PLAINTIFF RESPONSE: THERE WERE NO EXCESS COST IN COMPLETION OF THE HOUSE AGAINST PLAINTIFF’S THIS IS JUST ANOTHER FABERCATION OF DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN TO ACQUIRE ILLEGAL UPGRADES AGAINST THE PLAINTIFF THAT DEFENDANT DID NOT WANT TO PAY FOR.

b. Contractual penalties for delay of completion in the approximate amount of $ 1,500.00;

PLAINTIFF RESPONSE: THERE WERE NO CONTRACTUAL PENALTIES OF $ 1,500.00 AGAINST PLAINTIFF’S THIS IS JUST ANOTHER FABERCATION OF DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN: TO ACQUIRE ILLEGAL FUNDS FROM THE PLAINTIFF AND COMMITT DEFERMATION OF CHARACTER AGAINST PLAINTIFF GEORGE LYONS BY DEFENDANT’S STORZBACH’S.

c. Title insurance in the amount of $ 885.00 and $ 45.10 for transfer tax.

PLAINTIFF RESPONSE: CHECKS PAID BY PLAINTIFF FOR DEFENDANT’S STORZBACH’S

CHECH NUMBER 27 24-Feb-94
METROPOLITAN TITLE COMPANY $ 120.00

COUNTER 24-Feb-94
HAMBURG TOWNSHIP TAXES FOR PARTRIDGE POINT $ 163.02

CHECK NUMBER: 20 28-Feb-94
FIRST OF AMERICA TAXES FOR PARTRIDGE POINT $ 154.60

THE ABOVE TITLE INSURANCE AND TRANSFER TAXES WAS PAID FOR BY PLAINTIFF FOR STORZBACH’S PROJECT. PAID AT THE CLOSING OF LYONS BUILDERS, INC. AND JARVIS DEVELOPMENTS THAT PLAINTIFF PAID $ 45,900.00 AND THE CLOSING ½ HOUR AFTER THE ABOVE CLOSING DEFENDANT STROZBACH’S CRIMINALLY PAID ONLY $ 41,000.00.


BECAUSE OF THE EXTORTION ACTS OF DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN. PLAINTIFF LOSES WERE A $ 4,900.00 DIFFERENCE AT THE TIME OF CLOSINGS.


BOTH CLOSING WERE ORGETSTRATED BY DEFENDANT’S STORZBACH’S ATTORNEY RICHARD CONLIN. IF THERE WERE ANY MISTAKES IN THE CLOSING THIS WOULD FALL ON DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN.

Wherefore, the Plaintiffs demand Judgment in the amount of $ 55,000.00 plus interest, cost and attorneys fees.

PLAINTIFF RESPONSE: Wherefore, the Plaintiff George Lyons demand Judgment in the amount of $ 2,000,000.00 plus interest, cost and future attorney fees.

COUNT II-SLANDER OF TITLE
Plaintiffs reiterate and rellege the allegation contained in Paragraphs 1 through 8 of this Complaint.

PLAINTIFF RESPONSE: Plaintiff George Lyons reiterate and rellege the allegation contained in Paragraphs 1 through 8 of the Complaint.

9. That pursuant to the terms of the aforementioned contract, Plaintiffs became the owners of subject property on or about October 28, 1993, at the approximate time of the closing of the construction loan.

10. That at the time Plaintiffs terminated Defendant as a contractor on the project, Defendants, in retaliations, presented to Plaintiff a Claim of Lien, claiming a construction lien in the amount of $ 52,000.00. Said lien was not recorded at the time of presentation.

PLAINTIFF RESPONSE: Defendant’s had no right to terminate Plaintiff. Defendant’s Storzbach’s terminated Plaintiff to embezzle money from Plaintiff.

11. That, subsequent thereto, as Plaintiffs reached completion of their home on their own, and were in the process of applying for their mortgage financing. Defendants caused to be filed and recorded the previously presented alleged construction lien. The amount of said lien, however, was first changed from $ 52,000.00 to $ 35,000.00 and then recorded in liber 1809, page 001, Livingston County Records. (See attached Exhibit ‘’B’’)

PLAINTIFF RESPONSE: Defendant’s Storzbach reached completion of their home by using Plaintiff subcontractors. Along with stating to them that the Defendant’s Storzbach’s stated to the Subcontractor’s lies by stating that they paid George Lyons their money. See long version and Short version enclosed. Defendant’s committed criminal act in these actions.

12. That, at the time said lien was recorded, Defendants had no legitimate interest in the property in question and did not have the right to file said lien.

PLAINTIFF RESPONSE: PER THE ABOVE DESCRIPTION OF THE ITEMS THAT PLAINTIFF WENT THROUGH BECAUSE OF THE CRIMINAL ACTIONS OF THE DEFENDANT’S STORZBACH’S. PLAINTIFF DID HAVE INTEREST IN THE PROPERTY AND PER BUILDING CONTRACT:

Defendant’s Storzbach’s per the building contract with Lyons Builders, Inc.

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT. POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT.

PAGE 14 OF BUILDING CONTRACT OR PAGE 20 OF 51 STORZBACH LONG VERSIONS.

FOOTNOTE: THERE WAS EXTORTION OF LOT 16 PARTRIDGE POINT BY THE DEFENDANT’S STORZBACH AND THERE ATTORNEY RICHARD CONLIN, THERE WAS NO FULL PAYMENT TO BE MADE TO CONTRACTOR FOR ALL SUMS DUE HIM UNDER THIS CONTRACT TO THE CONTRACTOR (PLAINTIFF). THERE WAS THEIF BY DEFENDANT’S STORZBACH’S AGAINST PLAINTIFF.

AND THERE WAS NO CLOSING UNDER THE BUILDING CONTRACT. THERE WAS EMBEZZLEMENT ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF. THERE WAS THEIF ON DEFENDANT’S STORZBACH’S PART IN NOT PAYING FOR UPGRADE’S THAT WERE CRIMINALLY CHARGED AGAINST PLAINTIFF. SEE AUDIO’S

THE FOLLOWING IS AN OBLIGATION BY DEFENDANT’S STORZBACH’S TO ACQUIRE A CONSTRUCTION LOAN THROUGH CHELSEA LUMBER FINANCIAL DEPARTMENT. BUT THIS WAS NOT PLAINTIFF’S OBLIGATION THROUGH CHELSEA LUMBER. THERE WAS A SIGNED AND APPROVED BUILDING CONTRACT BY DEFENDANT’S STORZBACH’S PRIOR TO CHELSEA LUMBER CONSTRUCTION LOAN. THAT DEFENDANT’S STORZBACH’S DID NOT FOLLOW. WHICH DEFENDANT’S STORZBACH’S USED HIS ATTORNEY AS A BULLY.


14. That, further, the filing of the lien was done with malice in an obvious to prevent Plaintiffs from Obtaining financing to pay off their construction loan.

PLAINTIFF RESPONSE: THE ABOVE STATEMENT IS CALL DEFERMATION OF CHARACTER ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF.

THE LIEN WAS PLACE AGAINST STORZBACH’S PROPERTY BECAUSE STORZBACH DID NOT DO THE FOLLOWING.


A. DID NOT FOLLOW THE BUILDING CONTRACT WHICH WAS APPROVED BY DEFENDANT’S STORZBACH’S.

B. DID NOT PAY SUBCONTRACTOR’S AND STATED TO THEM THAT THEY SHOULD FILE FRAUDULENT MECHANICAL LIENS AGAINST 5640 SHOSHONI PASS, PINCKNEY, MI.

C. SEE ACCOUNTING ( PER ACCOUNTING LYONS BUILDERS, INC. WERE NOT RESPONSIBLE TO PAY FOR DEFENDANT’S DESIGN WORK THAT DEFENDANT’S STORZBACH STOLE DESIGN FROM (BASIC DESIGN COMPANY.)

D. DID NOT PAY PLAINTIFF RETAINER OF $ 41,000.00 PER CONTRACT.

E. DEFENDANT’S STORZBACH’S DID COMMIT CRIMINAL ACTS AGAINST PLAINTIFF.


14. That, as result of the filing of said false construction lien, Defendants have slandered the title of Plaintiff’s property.

PLAINTIFF RESPONSE: PLAINTIFF DID HAVE FULL RIGHT TO FILE LIEN AGAINST DEFENDANT’S STORZBACH’S PROPERTY.

PER THE ABOVE DESCRIPTION OF THE ABOVE ITEMS THAT PLAINTIFF WENT THROUGH AND BECAUSE OF THE CRIMINAL ACTIONS OF THE DEFENDANT’S STORZBACH’S. PLAINTIFF DID HAVE INTEREST IN THE PROPERTY AND PER BUILDING CONTRACT:

As Defendant’s Storzbach’s and per the building contract with Lyons Builders, Inc.

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT. POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT.

PAGE 14: REVIEW OF BUILDING CONTRACT OR PAGE 20 OF 51 STORZBACH LONG VERSIONS.

ACQUIRING A LOAN IS TOTALLY DIFFERENT FROM CLOSING ON STORZBACH’S PROJECT.

DEFENDANT’S STORZBACH’S HAD TWO DIFFERENT CHOOSES:

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL (A) HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT.

(B). POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT.

PLAINTIFF NEVER RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THE CONTRACT.

AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT. BECAUSE DEFENDANT’S STORZBACH FORCE THE USE OF THE RETAINER TO BE USED AS PURCHASING FUNDS FOR LOT 16 PARTRIDGE POINT, BRIGHTON, MI. THE BUILDING CONTRACT WAS BREACH BY THE DEFENDANT’S STORZBACH’S.

FOOTNOTE: THERE WAS EXTORTION OF LOT 16 PARTRIDGE POINT BY THE DEFENDANT’S STORZBACH AND THERE ATTORNEY RICHARD CONLIN, THERE WAS NO FULL PAYMENT TO BE MADE TO CONTRACTOR FOR ALL SUMS DUE HIM UNDER THIS CONTRACT TO THE CONTRACTOR (PLAINTIFF). THERE WAS THEIF BY DEFENDANT’S STORZBACH’S AGAINST PLAINTIFF.

AND THERE WAS NO CLOSING UNDER THE BUILDING CONTRACT. THERE WAS EMBEZZLEMENT ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF.

THERE WAS THEIF’S ON DEFENDANT’S STORZBACH’S PART IN NOT PAYING FOR UPGRADE’S THAT WERE CRIMINALLY CHARGED AGAINST PLAINTIFF. SEE AUDIO’S THIS CIVIL CASE SHALL FOLLOW WITH A CRIMINAL FILING AGAINST DEFENDANT’S BY THE PLAINTIFF.

THE FOLLOWING IS AN OBLIGATION BY DEFENDANT’S STORZBACH’S TO ACQUIRE A CONSTRUCTION LOAN THROUGH CHELSEA LUMBER FINANCIAL DEPARTMENT. BUT THIS WAS NOT PLAINTIFF’S OBLIGATION THROUGH CHELSEA LUMBER. THERE WAS A SIGNED AND APPROVED BUILDING CONTRACT BY DEFENDANT’S STORZBACH’S PRIOR TO CHELSEA LUMBER CONSTRUCTION LOAN. THAT DEFENDANT’S STORZBACH’S DID NOT FOLLOW. WHICH DEFENDANT’S STORZBACH’S USED HIS ATTORNEY AS A BULLY.

15. That, in recording said false construction lien Defendants have violated provisions of MCLA 565.108; MSA 26.1278 entitled Plaintiffs to damages, including reasonable attorney fees.

PLAINTIFF RESPONSE: PER THE ABOVE DESCRIPTION OF THE DEFENDANT’S STORZBACH’S AND THE ATTORNEY. PLAINTIFF HAD FULL RIGHTS IN FILING A CONSTRUCTION LIEN AGAINST DEFENDANT’S STORZBACH’S

16. That, further, the recording of said alleged construction lien was done by Defendants with such gross indifference to and / or reckless disregard for the Plaintiffs, as to constitute a willful and wanton act entitling Plaintiffs to exemplary damages.

PLAINTIFF RESPONSE: PER THE ABOVE DESCRIPTION OF THE DEFENDANT’S STORZBACH’S AND THE ATTORNEY. PLAINTIFF HAD FULL RIGHTS IN FILING A CONSTRUCTION LIEN AGAINST DEFENDANT’S STORZBACH’S. AND WITH THE ABOVE DISREGARD OF INVESTIGATION OF DEFENDANT’S FILES. PLAINTIFF IS WRONGLY AQUISED BY DEFENDANT’S STORZBACH FOR DEFERMATION OF CHARACTER AGAINTS PLAINTIFF. AND PLAINTIFF CONSIDERS THE ABOVE STATEMENTS IN TOTAL PERJURIOUS.

17. That, as a result of the slandered title as aforesaid Plaintiffs have incurred damages consisting of the following:

PLAINTIFF RESPONSE: That as a result of slandered title as aforesaid Plaintiff George Lyons has incurred damages consisting of the Following:

a. Impairment of vendibility;

PLAINTIFF RESPONSE: PER THESE DOCUMENTS THIS IS FABERCATED AND FALSE STATEMENT ON THE DEFENDANT’S STORZBACH’S PART.

b. Litigation expenses;

PLAINTIFF RESPONSE: PER THESE DOCUMENTS THIS IS FABERCATED AND FALSE STATEMENT ON THE DEFENDANT’S STORZBACH’S PART. PER STORZBACH’S ATTORNEY RICHARD CONLIN AND PERJUIOUS STATEMENT IN COURT TO ACQUIRE A FRAUDULENT DEFAULT JUDGMENT FOR HIS CLIENTS RONALD AND VIRGINIA STORZBACH’S THE DEFENDANT’S. FILE A COMPLAINT WITH THE STATE OF MICHIGAN ATTORNEY GRIEVANCE COMMITTEE TO REMOVE STORZBACH’S ATTORNEY RICHARD COLIN LICENSE TO PRACTICE LAW.

c. Loss or impairment of credit;

PLAINTIFF RESPONSE: BECAUSE OF THE CRIMINAL ACTIONS OF THE DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN. PLAINTIFF GEORGE LYONS LOSES THE FOLLOWING.

a. Over $ 387,000.00 that the Defendant’s Storzbach’s interference with other clients to acquire illegal funds.

b. Lose of 7 lots in Partridge Pointe, Brighton, Michigan.

c. Lose of 4 clients in Partridge Pointe, Brighton, Michigan because of Defendant’s false statements to these clients. And lose of 3 clients off Whitewood Road, Pinckney, Michigan and Defendant’s Storzbach’s fabricated statements to them.

d. Lose of income from for 5640 Shoshoni Pass, Brighton, Michigan.

e. Lose of Plaintiff home at 1194 Camelot, Pinckney, Michigan cause by Defendant’s Storzbach interference.

f. Complete loss of credit because of Defendant’s Interference.

g. Lose of income on 4 homes off Whitewood Road, Pinckney, Michigan because of Defendant’s Storzbach’s interference.

h. Lose of Builders License and Real Estate License because of false complaints to the State of Michigan Consumer & Industry service.

i. Lose of income from 1994 to present because of the criminal actions of Defendant’s Stozbach’s.

j. Defendant’s Storzbach’s cause Plaintiff to be homeless for 4 years. Evidence against Defendant’s was discovered and located in 2007. For which bring forth this case.

k. Mental stress, Defendant’s caused lost of a 20 year marriage of the Plaintiff and 10 years of lost income, lost income from 8 clients because the defendant’s interference. Plaintiff mental stress caused by Defendant’s Storzbach’s.

l. Abuse of process by the Defendant’s n. the use of legal process by illegal, malicious, or perverted means. Defendant’s include serving (officially giving) a fraudulent complaint to the State of Michigan Consumer & Industry service by Defendant’s Storzbach when it has actually been filed, just to intimidate an enemy, the Defendant’s Storzbach in filing a false declaration to other clients against Plaintiff (defendant’s Storzbach did file a paper or communicated a untruthfully stating a lies that someone has officially given a notice to another person.

Then Defendant’s Storzbach did file a lawsuit which has no basis at law, but is intended to get acquire illegal funds, or force payment through fear of legal entanglement or gain an unfair or illegal advantage against Plaintiff.

Defendant’s thought they were clever by abusing the process this way. A few unscrupulous lawyers do so intentionally and can be subject to discipline and punishment. Defendant’s attorney lawyer did abuse the process; an honest attorney will promptly correct the error and apologize. This was never done by Defendant’s or their attorney Richard Conlin and did in fact commit abuse of process against this Plaintiff.

d. Exemplary damages

PLAINTIFF RESPONSE: exemplary damages n. often called punitive damages, these are damages that Plaintiff George Lyons requests and/or awarded in this lawsuit when the defendant's Storzbach’s were willful and committed acts that were malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.

The above acts of the Defendant’s Storzbach warranting award for Plaintiff for Defendant’s committed exemplary damages against Plaintiff:

Also Plaintiff will show beyond a reasonable doubt that Defendant’s Storzbach’s Defendant’s Michael R. Coad of Dimension in wood and Defendant’s Storzbach’s were malicious, violent, oppressive, fraudulent, wanton, a and grossly reckless, in this civil lawsuit and future criminal actions that they did committed the above against Plaintiff George Edward Lyons.


e. Reasonable attorney fees.

PLAINTIFF RESPONSE: PER THESE DOCUMENTS THIS IS FABERCATED AND FALSE STATEMENT ON THE DEFENDANT’S STORZBACH’S PART. PER STORZBACH’S ATTORNEY RICHARD CONLIN AND PERJUIOUS STATEMENT IN COURT TO ACQUIRE A FRAUDULENT DEFAULT JUDGMENT FOR HIS CLIENTS RONALD AND VIRGINIA STORZBACH’S THE DEFENDANT’S. FILE AN COMPLAINT WITH THE STATE OF MICHIGAN ATTORNEY GRIEVANCE COMMITTEE TO REMOVE STORZBACH’S ATTORNEY RICHARD COLIN LICENSE TO PRACTICE LAW.

PLAINTIFF RESPONSE: The Defendant’s caused Tortuous interference, in the common law of tort, occurs when Defendant’s Storzbach’s and Defendant Coad intentionally damages the plaintiff's contractual or with other business relationships (past clients). This tort is broadly divided into two categories, one specific to contractual relationships (irrespective of whether they involve business), and the other specific to business relationships or activities (irrespective of whether they involve a contract).

Defendant’s Tortuous interference with Plaintiff contract rights occur where the Defendant’s tortfeas did convinces a party to breach the contract against the plaintiff, or where the Defendant’s tortfeasor disrupts the ability of one party to perform his obligations under the contract, thereby preventing the plaintiff from receiving the performances promised.
The Defendant’s Tortious interference with Plaintiff business relationships occurs where the Defendant’s tortfeasor acts to prevent the plaintiff from successfully establishing or maintaining business relationships.

This tort was first described in the case of Keeble v. Hickeringill, (1707) 103 Eng. Rep. 1127,

PLAINTIFF RESPONSE: The Defendant caused CIVIL CONSPIRACY - 'The elements of an action for civil conspiracy are the formation and operation of the conspiracy and damage resulting to plaintiff from an act or acts done in furtherance of the common design. . . . In which Defendant’s Storzbach’s and Defendant Coad action caused the major significance of the conspiracy lies in the fact that it renders each Defendant’s in the wrongful act responsible as a Defendant’s joint tortfeasor for all damages ensuing from the defendant’s wrong, irrespective of whether or not Defendant’s caused a direct actor or actors and regardless of the degree of his activity.'' (Doctors' Co. v. Superior Court (1989) 49 Cal.3d 44, citing Mox Incorporated v. Woods (1927) 202 Cal. 675, 677-78.)' (Id. at 511.)

DEFINING CIVIL CONSPIRACY OR CRIMINAL CONSPIRACY: Conspiracy (civil) a civil conspiracy or collusion is an agreement between two or more parties to deprive a third party of legal rights or deceive a third party to obtain an illegal objective.[1] A conspiracy may also refer to a group of people who make an agreement to form a partnership in which each member becomes the agent or partner of every other member and engage in planning or agreeing to commit some act.

It's not necessary that the conspirators be involved in all stages of planning or be aware of all details. Any voluntary agreement and some overt act by one conspirator in furtherance of the plan are the main elements necessary to prove a conspiracy. A conspiracy may exist whether legal means are used to accomplish illegal results, or illegal means used to accomplish something legal.[2] "Even when no crime is involved, a civil action for conspiracy may be brought by the persons who were damaged."[3]In the law of tort, the legal elements necessary to establish a civil conspiracy are substantially the same as for establishing a criminal conspiracy, i.e. there is an agreement between two or more natural persons to break the law at some time in the future or to achieve a lawful aim by unlawful means.

The criminal law often requires one of the conspirators to take an overt step to accomplish the illegal act to demonstrate the reality of their intention to break the law, whereas in a civil conspiracy, an overt act towards accomplishing the wrongful goal may not be required. Etymologically, the term comes from Latin con- "with, together", and spirare "to breathe".

PLAINTIFF RESPONSE: George Lyons with audio tapes of other clients and Defendant’s Storzbach’s and Defendant Michael Coad Plaintiff will prove beyond a shadow of Doubt that both Defendant’s Storzbach’s and others committed civil conspiracy.

PLAINTIFF RESPONSE: The Defendant’s committed embezzlement against the Plaintiff George Lyons. Defendant’s embezzlement was the fraudulent appropriation by a Defendant’s to his own use of property or money entrusted to that Defendant’s care but owned or was to be owned by Plaintiff.

Wherefore, the Plaintiffs demand Judgment in such sum in excess of $ 10,000.00 as found to owe plus interest, costs and attorney fees.

PLAINTIFF RESPONSE: Wherefore the Plaintiff George Lyons demand Judgment in such sum in excess of $ 2,000,000.00+ as found to owe because of the criminal actions of the Defendant’s.

COUNT III –VIOLATION OF MICHIGAN BUILDERS TRUST FUND ACT

PLAINTIFF RESPONSE: Plaintiff never committed any violation against the Michigan Builders Trust fund act.

The Defendant’s did commit fraudulent fabricated complaints to the Michigan Builders Trust act. To acquire illegal funds.

Plaintiffs reiterate and reallege the allegations contained Paragraphs 1 through 19 of this Complaint.

PLAINTIFF RESPONSE: Plaintiff reiterates and realleges the Allegation contained Paragraphs 1 through 20 of this Complaint.

18. That under the terms of MCLA 570.151 et seq. / MSA 26.3 et seq., a contractor who is paid funds by an owner for the construction of a residence shall be considered a Trustee of as funds for the benefit of the person making the payment, Plaintiff herein.

PLAINTIFF RESPONSE: THE ABOVE STATEMENT IS FALSE AND MISLEADING. THAT THE DEFENDANT’S STORZBACH’S TOOK OVER ALL PAYMENTS TO SUBCONTRACTORS AND MATERIAL HANDLERS, SEE AUDIO TAPES. AND PLAINTIFF FEELS THAT THIS STATEMENT ON DEFENDANT’S PART IS FABERCATED.

DEFENDANT’S SHOULD BE CRIMINAL CHARGED WITH FILING FALSE COMPLAINTS WITH THE MICHIGAN BUILDERS TRUST ACT, TO ACQUIRE ILLEGAL FUNDS FROM THE STATE OF MICHIGAN BUILDERS TRUST FUND ACT. TO ACQUIRE ILLEGAL FUNDS.

19. That further, pursuant to the terms of said act, the appropriation by a contractor of any monies paid to him before the payment by him of all monies due or to be come due laborers, subcontractors, material men or others entitled to payment shall be evidence of intent to defraud.

PLAINTIFF RESPONSE: DEFENDANT’S STORZBACH’S TOOK OVER ALL PAYMENTS TO SUBCONTRACTORS AND MATERIAL HANDLERS, SEE AUDIO TAPES. AND PLAINTIFF FEELS THAT THIS STATEMENT ON DEFENDANT’S PART IS FABERCATED.

DEFENDANT’S STORZBACH'S SHOULD BE CRIMINAL CHARGED WITH FILING A FALSE COMPLAINTS WITH THE MICHIGAN BUILDERS TRUST ACT, AND TO THE STATE OF MICHIGAN CONSUMER & INDUSTRY SERVICES TO ACQUIRE ILLEGAL FUNDS FROM THE STATE OF MICHIGAN BUILDERS TRUST FUND ACT.

DEFENDANT’S STORZBACH’S SHOULD BE CRIMINALLY CHARGE FOR NOT PAYING SUBCONTRACTOR’S AND MATERIAL HANDLERS BY FALSELY STATING TO THEM THAT THEY PAID GEORGE LYONS THEIR MONEY. FORCING SUBCONTRACTOR AND MATERIAL HANDLERS TO FILE FALSE MECHANICAL LEINS AGAINST 5640 SHOSHONI PASS, PINCKNEY, MICHIGAN.

20. That Plaintiff did, in fact, pay to the Defendants sums under the terms of their contract which were subsequently appropriated to Defendants own use not in connection with the construction of said residence. That, in spite of demands by Plaintiffs have been damaged as result of said wrongful conversion of funds.


PLAINTIFF RESPONSE: THIS STATEMENT IS FALSE AND MISLEADING ON THE
DEFENDANT’S PART. THE PLAINTIFF USED ALL FUNDS GIVEN TO PLAINTIFF IN THE CONSTRUCTION OF DEFENDANT’S STORZBACH’S PROJECT. PLUS EXTRA (SEE ENCLOSED DEFENDANT’S STORAZBACH’S ACCOUNTING).

Showing that Lyons Builders, Inc performed over 82.50 % of the Defendant’s project.

See Livingston County Building Department permits history for work that has been done by Plaintiff George Edward Lyons and his company Lyons Builders, Inc.

WHEREFORE, the Plaintiffs demand Judgment in such sum in excess of $ 10,000.00 as found to be owing plus interest, cost and attorney fees. We declare that the statements above are true to the best of our information, knowledge and belief.

PLAINTIFF RESPONSE: The illegal and criminal acts of these Defendant’s still are as prevalent as today 2008 and continue as they were first wrongfully file by Defendant’s in 1994. They still continue to harm the Plaintiff today and in the future.

PLAINTIFF RESPONSE: WHEREFORE the Plaintiff George Lyons demands Judgment in
such sum in excess of $2,000,000.00 + as found to owing plus interest since 1994, plus cost of future attorney fees. Plaintiff declares the statements above are true to the best of his information, knowledge and belief.

Respectfully submitted







____________________________________
George Edward Lyons-Plaintiff
11994 Weiman
Pinckney, Michigan 48169
734-954-4040
Monday, January 07, 2008

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