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NEVADA,

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CLARK COUNTY BUSINESS LICENSING SECTION,

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WENDELL DWAYNE O’NEAL, 5575 SIMMONS STREET STE. 1-211, LAS VEGAS, NEVADA 89031, Complainant,

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Vs

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ROADRUNNER RENTALS INC, FIRST NAMED BOAZ (JAMIE SANTOS), 3320 ALPLAND LANE, SPARKS, NEVADA 89434; ROADRUNNER AUTO GROUP INC, CAROL MILLAUD, FIRST NAME DAVID, 21024 SHERMAN WAY, CANOGA PARK, CA 91303; MATTHEW WOLF, ASST. VICE-PRESIDENT, EMPIRE FIRE & MARINE INSURANCE CO. INC, P.O. BOX 4034, SCHAUMBURG, ILLINOIS 60168-4034,

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Respondents Jointly & Severally,

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PETITION TO REOPEN CLARK COUNTY BUSINESS LICENSE COMPLAINT FOR PROSECUTION AGAINST RESPONDENTS,

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Complainant respectfully requests Clark County Business Licensing

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Section Reopen attached Complaint because Investigator Ricardo Restrepo

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apparently failed to locate Respondents wrecked Craigslist Rental Car

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parked at or near Auto Vas LLC during Investigation and Closed Case1.

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See attached Complainant Email to Investigator Restrepo at 04:33 pm on 05/31/2016 and Restrepo Response dated on approximately 06/01/2016 in support. 1

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REINSTATED COMPLAINT FOR PROSECUTION,

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1. Respondent Empire Fire supra Supervisor Claims Adjustor Anthony 3 4 5

Adams evidences RoadRunner Craigslist 2011 Chevy Aleo in wrecked condition was not towed from near Auto Vas LLC until 06/22/2016 well after

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Investigator Restrepo surveyed area searching for Commission of Crime as

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described in attached Business Licensing Complaint Information2. Craigslist

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Rental was towed to Copart Auto Auctions at 4810 N. Lamb Blvd, Las Vegas NV. 89115 on 06/22/2016. Clark County Business License Investigation Case Close before Craigslist supra rental car was removed from premises

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of 3425 S. Decatur Blvd supra 3 . Business License Complaint alleged

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Respondent RoadRunner Rentals Employees leased rental cars through

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Craigslist without licensed Used Car Dealership, Business Place or Licensed

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Salesperson contrary to Clark County Business License Section, Nevada

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Department of Motor Vehicle and Insurance Codes4.

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See attached Anthony Adams email dated 06/22/2016 at 08:10 am in support. Title 42 USC § 1985(3). 4 Nev. Const. Sec. 8A(a)(4), Rights of Victim Of Crime. NRS. § 482.36423; NRS. § 482.3663; NRS § 482.3665; NRS. § 482.362 et seq; NRS 33.010 et seq. 2 3

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2. Respondents RoadRunner Rental Inc Employees leased several low

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cost, late model, fully insured vehicles through Craigslist without License or 3 4 5

Registered Used Car Dealership, Business Place or Licensed Salesperson contrary to Clark County supra, Department of Motor Vehicle and Insurance

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Codes constituting Class D Felonies or Gross Misdemeanors according to

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Nevada laws herein cited. Complainant possesses Audio Recording of

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Respondent Boaz indicating he sold out of rental cars on 05/17/2016. Audio Recording supra of RoadRunner supra or Auto Vas LLC Employee First Name Jennifer purporting Secretarial Services for Craigslist supra rental car

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operation. Audio Recording supra of California RoadRunner Employee

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David indicating knowledge of Craigslist supra rental car business in Las

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Vegas for review by Clark County supra or District Attorney to evidence Interstate Conspiracy to Commit Unlicensed Car leasing Crimes. Complainant is Crime Victim because he suffered financial losses incident to

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RoadRunner supra Craiglist Car Rental supra beginning on 09/06/2016

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through 11/28/20165.

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O’Neal v Empire Fire & Marine Insurance Company Inc. et al, 2:16-cv-02313-JCM, (D.Nev). 3

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3. Respondents had no licensed Used Car Dealership, Place of

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Business or Salesperson licensed with State of Nevada Insurance 3 4

Department to lease Craigslist Rental Cars in Las Vegas on 05/10/2016

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through 06/22/20166. Respondent RoadRunner Auto Group Inc. supra is a

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Used Car Dealer who maintains Principal Place of Business at 21024

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Sherman Way, Canoga Park, CA 91303.

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4. RoadRunner supra employs Boaz, Jennifer, Carol Millaud and First

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Named David at all times relevant. RoadRunner supra employed Boaz (Jamie Santos) in Nevada to rent low cost, late model, fully insured vehicles through Craigslist supra in Las Vegas according to from Millaud, First Named

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David supra and Spokeo supra Research Records7

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5. Respondents transacted Craigslist rental car leases at Auto Vas Inc.

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located within 3425 S. Decatur Blvd, Las Vegas Nevada 89102 based upon

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personal observation, video, audio and photographic evidence.

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See attached Letter from Nevada DMV Compliance Enforcement Division dated 11/14/2016 and Letter from Empire Fire & Marine Insurance Vice-President Matthew Wolf and attached True Copy of Email received from Ricardo Restrepo, Clark County Business License Complaint Section Fri, Oct. 14, 2016 in support. NRS. 482.31776; NRS.482.31515; NRS. 482.326; NRS. 482.362; NRS. 482.323; NRS. 482.322; NRS. 482.300; NRS. 482.107; NRS. 482.107; NRS 33.010 et seq. 7 See attached Craigslist Rental Car Advertisement Exhibit bearing same Telephone No. (702)-626-2307 as produced by Spokeo Exhibit in support. 4

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3425 S. Decatur Blvd is a Commercial Automotive Lot owned by

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Las Vegas Dr. Sebastian and Diane Balle who may employ MDL Property 3 4

Mgmt Group to supervise activities at said location at all times relevant.

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7. California RoadRunner Auto Group Inc Unlicensed Salesperson Boaz (Jamie Santos) met with Complainant Clients to lease rental cars through

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Craigslist supra on 05/10/2016 contrary to Nevada Motor Vehicle and Insurance Codes.

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8. Auto Vas Inc is a foreign vehicle diagnostic, engineering and repair

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shop that does not explain 2 day repair work performed on 2011 Aleo leased to Complainant Clients on 05/10/2016. Id.

Auto Vas Inc. repaired

RoadRunner supra Foreign make Volkswagon and White BMW rental

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vehicles between 05/09/2016 and 05/10/2016 based upon information and belief.

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Client MVA Victims reported RoadRunner supra 2011 Aleo supra

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lost control and careened into a wall on I-95 at approximate 55 miles per hour. Empire Fire & Marine Insurance Company Inc undermined Nevada Preservation of Evidence Warning for inspection of RoadRunner supra

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Craigslist rental vehicle by causing removal purporting to pay MVA Claims.

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10. Complainant concluded 2011 Aleo supra was rigged for MVA supra

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False Insurance Claim because RoadRunner supra had Unlicensed 3 4 5

business and Salesperson supra who purportedly leased vehicle to Lessee Calvin Richey who had no personal liability insurance coverage for rental car

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damages. Id.

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11. Nevada State Trooper Georgiev reviewed RoadRunner supra lease

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agreement and ascertained RoadRunner supra is a California Used Car

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Dealer with no place of business in Las Vegas supra at all times relevant 8.

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12. Clark County and Nevada DMV Compliance Enforcement Division

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both determined RoadRunner supra had no licensed Used Car Dealership,

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Salesperson or Place of Business in Las Vegas on 05/10/20169. Id. Empire

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Fire supra Assistant Vice-President presented letter to Nevada DMV falsifying liability insurance coverage for RoadRunner supra 2011 Aleo supra

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registered in California despite Craigslist supra Commercial usage in Las Vegas with no place of business supra10.

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See State Trooper Georgiev MVA Report dated 05/10/2016 in support. See attached Email from Clark County Business License Complaint Section and Letter from Nevada DMV Enforcement Compliance in support. 10 See attached Empire Fire supra Vice-President Letter presented to Nevada DMV dated 10/04/2016 in support. 6 9

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13. Boaz or Santos communicated RoadRunner supra sold out of

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Craigslist Rental Cars without indication additional vehicles were no longer 3 4 5

marketed anywhere in Nevada. RoadRunner supra leased multiple Craiglist Rental Cars without license contrary to Nevada Motor Vehicle and Insurance

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Codes according to recorded discussion of Boaz supra on 05/17/2016.

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14. Nevada supra prohibits lease of Craiglist Rental Cars supra without

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Used Car Dealer or Salesperson licenses as above related. Nevada supra

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defines above related unlicensed activity by RoadRunner supra as Category D. Felony or Gross Misdemeanor11.

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15. Empire Fire supra Supervisor Claims Adjustor Anthony Adams

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and Vice-President Matthew Wolf both Misrepresented Tort Liability Insurance Coverage for Roadrunner supra 2011 Aleo Vehicle between 06/09/2016 and 10/04/2016 contrary to lawful Nevada DMV Compliance

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Enforcement Division Regulations12. Id.

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NRS. § 482.3665. See attached Email from Empire Fire & Marine Insurance Company Inc. Claims Adjustor Adams and Letter Responses in support. 7 12

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16. Complainant relied upon Adams and Wolf Misrepresentations

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Empire Fire supra insured RoadRunner supra Las Vegas Craigslist 2011 3 4

Aleo to detriment of monetary losses. Id.

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17. Complainant suffers Actual monetary damages in excess of over

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$10,000.00 based upon Contractual Agreements with Lessee supra and

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MVA Accident Clients. Additionally, Complainant suffers increased Tort liability insurance coverage costs from State Farm incident to acts

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complained

against

Respondents.

Clark

District

Attorney

recommended referral of herein matter to Clark County by email received last week13.

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County

See attached email from Clark County District Attorney in support. 8

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REQUESTED RELIEFS SOUGHT, 2 3 4

WHEREFORE, Clark County Business Licensing Section Reopen initially submitted Complaint because Investigator Restrepo supra somehow

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could not locate Respondents wrecked Craigslist Rental Car Parked near

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Auto Vas LLC as described by California license plate and VIN in writing as

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well as supported by photographic evidence. Complainant continues injuries 9 10 11

suffered if Respondents continue Marketing Rental Cars without Licensing required by County and Nevada DMV supra laws to Misrepresent material

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facts before Nevada DMV Officials despite ample opportunity to have settled

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Dispute.

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Additionally, Complainant respectfully requests Formal Complaint to Las Vegas Metropolitan Police for Investigation pursuant to Clark County District Attorney Prosecution as Relief hereinafter sought

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RESPECTFULLY SUBMITTED, WENDELL DWAYNE O’NEAL, COMPLAINANT IN PROPRIA PERSONA, 5575 SIMMONS STREET SUITE 1-211, LAS VEGAS NEVADA 89031, TX 256-361-5393, [email protected].

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12/10/2016 1:38:32 PM

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