https://docs.google.com/document/d/17hEsFRNeDEUmESeZDQlb2o97cCgmxfqlVGLWtVaMrdE/edit
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THE DISTRICT COURT OF GUAM
CIVIL CASE NO. 24-00008
ELAINE KILELEMAN,
Plaintiff,
VS.
ROBERT UNPINGCO, ROBINETTE UNPINGCO, and TERRENCE BROOKS,
Defendants.
**AMENDED COMPLAINT FOR HARASSMENT AND DECLARATORY JUDGMENT**
**COMES NOW,** the Plaintiff, **Elaine Kileleman**, and for her Complaint against the Defendants, **Robert Unpingco, Robinette Unpingco, and Terrence Brooks**, states as follows:
### 1. Parties
1. Plaintiff, **Elaine Kileleman**, is an individual residing at **[Your Address]**, [City], [State], [ZIP Code].
2. Defendants, **Robert Unpingco, Robinette Unpingco, and Terrence Brooks**, are individuals residing at **[Defendants' Address]**, [City], [State], [ZIP Code].
### 2. Jurisdiction and Venue
3. This Court has jurisdiction over this matter pursuant to [insert applicable state statute or rule] because the events giving rise to this claim occurred within this Court’s jurisdiction.
4. Venue is proper in this Court because the property in question is located in [County, State], and all parties reside within this jurisdiction.
### 3. Facts
5. Plaintiff is the owner of the property located at **[Your Address]**, described in the attached Exhibit A (legal description of your property).
6. Defendants own property adjacent to Plaintiff’s property, located at **[Defendants' Address]**, described in the attached Exhibit B (legal description of their property).
7. Plaintiff’s property is properly marked and has been established as Elaine Kileleman’s lawful property by survey and the title deeds.
8. Despite the clearly defined boundary lines, Defendants have repeatedly claimed, without evidence, that Plaintiff is trespassing on Defendants’ property.
9. Defendants have engaged in a pattern of harassment, including but not limited to:
a. Verbally threatening Plaintiff.
b. Making false accusations to local authorities about Plaintiff trespassing on Defendants’ property.
c. Posting false notices or markers purporting to claim Plaintiff’s property as their own.
10. Plaintiff has made multiple attempts to resolve this dispute amicably, including providing copies of the legal survey and deeds to Defendants, but Defendants have persisted in their false claims and harassment.
### 4. Causes of Action
#### Count I: Harassment
11. Plaintiff incorporates by reference all prior paragraphs as though fully set forth herein.
12. Defendants’ actions, including verbal threats and false accusations, constitute harassment under [insert applicable state statute or case law].
13. As a result of Defendants’ harassment, Plaintiff has suffered and continues to suffer emotional distress, anxiety, and inconvenience.
14. Plaintiff is entitled to damages as a result of Defendants’ unlawful actions.
#### Count II: Declaratory Judgment
15. Plaintiff incorporates by reference all prior paragraphs as though fully set forth herein.
16. An actual controversy exists between the Plaintiff and Defendants regarding the boundary line and the right of the Plaintiff to use her own property without interference.
17. Plaintiff seeks a declaratory judgment from this Court confirming that the property at **[Your Address]** is legally owned by Plaintiff and that Plaintiff has the right to use her property without interference or false claims from Defendants.
### 5. Prayer for Relief
WHEREFORE, Plaintiff respectfully requests that this Court:
A. Enter judgment in favor of Plaintiff on all counts;
B. Award Plaintiff compensatory damages for harassment in an amount to be determined at trial;
C. Issue a declaratory judgment confirming Plaintiff’s ownership and right to peaceful enjoyment of her property;
D. Grant Plaintiff any other relief that this Court deems just and proper.
**Dated:** [Date]
**Respectfully submitted,**
**[Your Signature]**
**Elaine Kileleman**
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### **Attachments:**
– **Exhibit A:** Legal Description of Plaintiff’s Property
– **Exhibit B:** Legal Description of Defendants’ Property
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Make sure to replace the placeholders with specific details related to your case.
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