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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 ENFORCEMENT OF MULTIPLE STATE LAW AND ORDINANCE VIOLATIONS AGAINST RESPONDENTS,

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Complainant respectfully Petitions supra Clark County to Reopen

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Complaint because Director Investigator Ricardo Restrepo failed to locate

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Respondents wrecked Craigslist Rental Car parked at or near Auto Vas LLC

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during Investigation against Crime Victims Civil Rights1.

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Clark County, NV, Code of Ordinances, Title 6, Business Licensing, including, but not limited to Chapter 6.04.010 - License Required through Chapter 6.12.729, Motor Vehicle Rentals. O'Neal v RoadRunner Rentals Inc et al, 1

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NEVADA CRIME VICTIMS RIGHTS,

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Complainant hereby invokes Nevada Crime Victims authority to

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and charges Director of Clark County Business License Complaint Section with Duty imposed through legislation to Enforce against Respondents based upon evidence supporting commission of multiple offenses as

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recommended by Clark County District Attorney 2. II.

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REINSTATEMENT OF BUSINESS LICENSE COMPLAINT FOR ENFORCEMENT OF STATE LAWS AND COUNTY ORDINANANCES, Complainant supra submitted Clark County Business License

Complaint against Respondent California RoadRunner Auto Group Inc 3. In

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response, Director supra assigned Agent Ricardo Restrepo to investigate.

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USCA 14, 5, 1; Title 42 USC Sect. 1985(3); Nevada Const. Art. 8, Sect. 5; Fed. R. Civ. Proc. Rules 56(c); Fed. R. Civ. Proc. Rules 45(a); O'Neal v Empire Fire & Marine Insurance Company Inc et al, 2:16-cv-02313-JCM, (D.Nev). 2 See attached Email from Clark County District Attorney and Letter from Nevada Department of Insurance in support. USCA 14, 5, 1; Title 18 USC § 3771; Nev. Const. § 8A(1)(a)(4); Nev. Const. Art. 8. § 5; NRS. 482.31776; NRS. 482.362; NRS 482.352(a)((e)(g)(j)(i); NRS. 482.326; NRS § 482:323; NRS. § 482.322(5)(a); NRS. § 482.300; NRS § 482.155; NRS. 482.107; Clark County Code of Ordinances, Title 6. Business License, Chap. 6.04 , (General Provisions) through 6.12.729, (Motor Vehicle Rentals)., including, but mot limited to Chap. 6.04.105, (State License) through Chap. 6.04.150, (Authority to Issue Citations). 3 See attached Facts and Exhibits Supporting RoadRunner supra Las Vegas Car Rental Business License Complaint PP. 1-7 dated 05/26/2016 in support. 2

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3. Agent Restrepo supra visited 3425 S. Decatur Blvd in Las Vegas and

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later reported he could not locate any evidence of Respondent supra 3 4 5

Craigslist Rental Car Business or any Criminal Activity transpiring at said address despite several photographs identifying a 2011 Aleo in immobile

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wrecked condition parked near Auto Vas Inc as specifically detailed in said

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Business License Complaint supra 4 . Contrarily, Respondent Insurance

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Carrier Empire Fire supra Supervisor Claims Adjustor Anthony Adams email

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evidences RoadRunner Craigslist 2011 Chevy Aleo supra was not towed

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from near Auto Vas LLC until 06/22/2016 5 . Respondent supra Craigslist

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Rental was towed to Copart Auto Auctions at 4810 N. Lamb Blvd, Las Vegas

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NV. 89115 on 06/22/2016. Id.

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See attached Spokeo Record Exhibit identifying Nevada Resident Jamie Santos as Person who placed Craigslist Rental Advertisement because Telephone Number matches Craigslist Rental Car Advertisement also attached. Moreover, Photograph of Respondent supra Unlicensed Salesperson Boaz evidences possession of said cellular device used to contact California Co-Defendants Carol Millaud or First Named David on 10/11/2016 based upon information and belief. Additionally, see attached Agent Restrepo Emails dated 05/31/2016, 06/01/2016, including, Photographs of said Craigslist 2011 Aleo Rental Car parked near Auto Vas Inc in support. 5 See attached Anthony Adams email dated 06/22/2016 at 08:10 am in support. 3

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4. Clark County Business License Director supra Agent supra Closed

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Case before Craigslist supra rental car was removed from premises of 3425 3 4 5

S. Decatur Blvd supra based upon preponderance of foregoing information presented in denial of said Crime Victims Civil Rights to Equal Protection and

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Procedural Due Process under Color of Nevada laws cited6. Complainant

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relied upon Director supra acknowledgment Respondents supra committed

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Crimes leasing rental cars without business and other required licenses at 3425 S. Decatur Blvd supra as alleged and evidenced by Nevada Dept. of Insurance Letter supra attachment. Reinstatement supra hereby alleges

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Unlicensed Salesperson Boaz or Jamie Santos supra leased several rental

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cars through Craigslist without employer RoadRunner supra having licensed

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Used Car Dealership or Business Place contrary to Clark County Business

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License Section, Nevada Department of Motor Vehicle and Insurance

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Regulations7.

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Title 42 USC § 1985(3); Nevada Const. Art. 8, Sect. 5; Fed. R. Civ. Proc. Rules 56(c); Fed. R. Civ. Proc. Rules 45(a); Fed. R. Civ. Proc. Rules 15(c)(d); O'Neal v Empire Fire & Marine Insurance Company Inc et al, Id. 7 See attached Nevada DMV Compliance Enforcement Official Kim Kulman Letter dated 11/14/2016 and Nevada Dept. of Insurance Letter dated 12/02/2016 in support. 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. 4

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5. Respondents RoadRunner Rental Inc Employee Boaz supra

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advertised several low cost, late model, fully insured vehicles through 3 4 5

Craigslist. Complainant presents Audio Recording of discussion where said unlicensed Salesperson Boaz supra indicated he sold out of Craigslist Rental

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Cars by 05/17/2016 constituting commission of several Class D Felonies or

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Gross Misdemeanors according to Nevada laws herein cited.

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6. Complainant possesses Audio Recording supra of telephone

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discussion with RoadRunner supra or Auto Vas LLC Employee First Name Jennifer who states she works as “Secretary at place visited where Boaz supra leased several Craigslist Rental Cars (Auto Vas LLC). Complainant

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possesses Audio Recording supra of California RoadRunner Employee David acknowledging Las Vegas Craigslist supra rental car business for

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review by Clark County Business License Director supra to evidence Interstate Conspiracy to Commit Unlicensed Car leasing Crimes8.

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Complainant will present all Audio Recording for Clark County Business License Director supra Review whenever opportunity permits. 5

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7. Respondent RoadRunner Auto Group Inc. supra is a California

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registered Used Car Dealer who maintains Principal Place of Business at 3 4

21024 Sherman Way, Canoga Park, CA 91303.

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8. RoadRunner supra employs Boaz, Jennifer, Carol Millaud and First Named David at all times relevant. Respondents transacted Craigslist rental car leases at Auto Vas Inc. located within 3425 S. Decatur Blvd, Las Vegas

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Nevada 89102 based upon personal observation, video, audio and photographic evidence. Auto Vas Inc is a foreign vehicle diagnostic,

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engineering and repair 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

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

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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 employed MDL Property 3 4

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

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upon information and belief 9 . Empire Fire & Marine Insurance Company

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Vice-President Matthew Wolf Misrepresented Tort liability insurance

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coverage for RoadRunner supra Craigslist Rental Car supra operation at

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said commercial address despite no license to lease automobiles in Nevada supra10.

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10. Complainant supra charges Conspiracy to Commit Insurance

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Fraud against Respondent supra and Empire Fire supra because Rental

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Policy voids Concealment, Trickey, Deceit, Misrepresentation and Fraud 11.

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See attached Photograph of Clark County Assessor Data for Parcel No. 163-13-504-011 and email transactions between MDL Group Property Mgmt. Employee Ginger Cager and Complainant in support. No one from MDL supra Replied confirming RoadRunner supra had no lease agreement authorization to conduct any business at 3425 S. Decatur Blvd on 05/10/2016 as discussed with Cager supra. Moreover, Las Vegas News indicated said property Owners or Occupants are involved in Insurance Fraud. 10 See attached Letter Empire Fire supra published to Nevada DMV supra Representative Kim Kulhman dated 10/04/2016 in support. 11 See attached RoadRunner supra Insurance Policy at Top of PP. 10 of 14, Subsection 3. Concealment, Misrepresentation or Fraud and Nevada DOI Letter indicating Respondent was not Licensed in support. Clark County Code of Ordinances Title 6. Business License, Section 6.12.729, (Motor Vehicle Rental); Section 6.04.150 – (Authority to Issue Citation); 6.04105 – (State License Required) 7

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11. Empire Fire supra Agent Anthony Adams offered to settle Crime

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Victim Jessieanna Brown MVA Injury Claim for approximately $800.00 despite RoadRunner supra had no legitimate business leasing cars at said commercial property on 05/10/2016 based upon Nevada Dept. of Insurance

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supra and Agent Restrepo supra investigation of premises on or about 05/31/2016.

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12. Nevada State Trooper Georgiev reviewed RoadRunner supra

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Rental Car Lease Agreement and determined MVA supra involved California Used Car Dealer with no place of business in Las Vegas 12 .Complainant supra relied upon Misrepresentations supra Empire Fire supra insured

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RoadRunner supra to detriment of monetary losses. Id. Complainant supra is Crime Victim supra because of said reliance and Actual monetary losses

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in excess of over $10,000.00 based upon Contractual Agreements with Lessee and MVA Passengers.

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See State Trooper Georgiev MVA Report dated 05/10/2016 in support. 8

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13. Complainant supra suffers increased Tort liability insurance

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coverage costs from State Farm incident to Empire Fire supra Tort liability 3 4 5

coverage Misrepresentations under herein related circumstances presented. Respondents. Clark County District Attorney recommended Clark County

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Business Licensing Section Director supra investigate and prosecute where

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evident Crimes supra were committed against Nevada laws including herein

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identified Ordinances supra last week13.

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REQUESTED RELIEFS SOUGHT,

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WHEREFORE, Complainant requests Case Reopening supra for

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Clark County supra Complaint to Las Vegas Metropolitan Police against

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herein identified Persons who knowingly violated Interstate supra Commerce

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Laws to Commit Insurance Fraud together with Order for no further business

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in State based upon herein Reinstatement supra.

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RESPECTFULLY SUBMITTED,

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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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See attached email from Clark County District Attorney in support. 9

12/11/2016 2:35:48 PM