Date Filed: 23rd of June, 2025

Plaintiff Name and Phone Number:
- Strokemasters brand
represented by -
Timothy Gentry (Owner)
- Phone #: (555)-6567
Plaintiff Availability: NA hours.

Attorney Name and Phone Number:
- Annabelle Celestine
- Phone #: (555)-1328
Attorney Availability: EU & early NA hours.

Defendant Name and Phone Number:
- Leo Salvatorre
- Phone #: (555)-7151

Incident Date: 25th of May, 2025
Date of Service: 23rd of June, 2025
Name of Person Served: Leo Salvatorre
Phone of Person Served: (555)-7151
Name of Person Serving: Annabelle Celestine
Phone of Person Serving: (555)-1328

Reason for Suit:
On the 25th of May, Mr Salvatorre was found by a flipped boxtruck by Deputy Randy Wrangler of the Blaine County Sheriff's Office. During the inventory process, Deputy Wrangler uncovered several stolen items and materials. Mr Salvatorre admitted to Deputy Wrangler that he removes catalytic converters from cars left on the side of the road, processes said items for materials, and uses those materials in the process of creation of repair kits, specifically by using tools provided by Strokemasters Autoshop to their employees, which Mr Salvatorre was, at the time of the arrest.

Following the interaction, Mr Salvatorre was arrested and found guilty in the court of law of the following list of charges:

1x Impeding Traffic - “Disrupts or stops the flow of traffic”
1x Negligent Driving - “Drives without due care or attention”
5x Petty Theft - “The act of taking money or property without permission or legal right from a person or property”
1x Felony Fraud - “The wrongful or criminal deception intended to result in financial or personal gain from a business or institution”

During the process of arrest, the Blaine County Sheriff’s Office and the District Attorney’s Office requested approval of a search warrant regarding Strokemaster's property. It was approved by Honorable Theodore Lars. Said search resulted in all materials and items found on Strokemasters' property being seized.

List of seized materials and items (and their value at the time of seizure):

67x Basic Repair Kit (valued at $1,000/per)
13x Normal Repair Kit (at $1,000/per)
15x Pro Repair Kit (at $1,000/per)
7x Cleaning Kit (at $100/per)
14x Tyre Repair Kit (at $250/per)
3x Lock Replacement Kit (at $1,600/per)
8x Basic Restoration Kit (at $2,000/per)
3x Improved Restoration Kit (at $4,000/per)
1x Pro Restoration Kit (at $6,000/per)
2x Spray Kit (at $500/per)
24,708x Plastic (at $2.69/per)
11,650x Metal (at $4.2/per)
17,522x Wood (at $2.1/per)
7,203x Components (at $3.1/per)
17,577x Cloth (at $1.1/per)
3,745x Processed Metal (at $45.2/per)
5,258x Processed Plastic (at $26.99/per)
315x Processed Wood (at $25/per)
358x Glue (at $12/per)
162x Acrylic Coat (at $58/per)

Following the aforementioned search and seizure, the District Attorney’s Office has filed for an Emergency Injunction against Strokemasters, barring entry and seizing operation of all properties, as well as freezing all related bank accounts.

Said Injunction was granted for an investigative purpose by Honorable Judge Yee-Atrick:
- Injunction Start Date: 5/26/25 at 17:24 EST
- Injunction End Date 6/5/25 at 17:24 EST

Following that injunction’s end, the District Attorney’s Office has filed a CIVIL ASSET FORFEITURE case against Strokemasters, requesting seizure of the following:

33A Magellan Avenue (“Strokemasters Repair Shop”)
33B Magellan Avenue (“ Strokemasters Dealership”)
Organization ID 1010 (“Quick Strokes”)
Organization ID 1179 (“Gentry Auto Sales”)

The CIVIL ASSET FORFEITURE case was dismissed with prejudice by Honorable Judge Nigel Buckham-Smythe.

No criminal case or charges were pressed against any other employee of Strokemasters, its owner (Timothy Gentry), or the business as a whole following Mr Salvatorre’s arrest.

As a result of Mr Salvatorre’s criminal actions, the brand of Strokemasters has suffered the following:

- Temporary Seizure of Property by the State
- Injunction on the operations of the Business
- Loss of government-issued wages for all employees
- Loss of profits generated by the Business being open
- Damage to reputation due to the lengthy inactivity of the Business
- Emotional damage to the Owner and Managerial staff running the Business
- Legal fees associated with legal issues arising from the mentioned arrest

List of Damages:
$810,000 in Lost Revenue - (Average of $30,000 in daily revenue - 05.25.2025-06.20.2025)
$1,458,000 in Lost Wages - ($750/hour, 6h daily shifts, 12 employees - 05.25.2025-06.20.2025)
$200,000 in Stolen Revenue - (Estimated unpaid cut of revenue - 03.15.2025-05.25.2025)
$500,000 in Reputation Damages - (Estimated impact of raid and following inactivity)
$665,609 in Lost Items - (All legal seized items based on their market value)
$242,000 in Legal Fees - ($8000/day lawyer fee + $2,000 filing fee - 05.25.2025-06.23.2025)
…for a total of $3,875,609.00

In-depth explanation for each item on the list:

Lost Revenue:
As shown by the evidence, the employees of Strokemasters would bring profits averaging $30,000 a day. The shop was unable to be operated due to seizure of over $600,000 worth of materials on the 25th of May, and starting from absolute scratch, it took the Employees until June 20th to get to the point where they'd be able to open the shop again. While the materials were still not returned at that point, we're not seeking lost revenue beyond that point, since, while difficult, Strokemasters managed to rebuild and open once again.
Multiplying the daily average revenue by the number of days the shop was unable to operate, we get a sum of $810,000.

Lost wages:
As shown by the evidence, at the time of the initial incident, Strokemasters was employing 12 people, excluding Mr Salvatorre. The mechanic shops allows employees to “clock-in” in order to receive government issued salary, measured at the time of arrest at $750/hour.
With 12 active employees ranging in schedules from early birds to late night mechanics, and healthy 6-hour shifts for each spanning the closed shop period, the total of lost wages comes up to $1,458,000.

Reputation damages:
In the fields of service and repair, consistency is key when it comes to drawing the attention of customers and their business. For a business to solidify itself in the minds of potential customers as reliable, it has to be such. Inability to operate a business for almost a month causes near-irreparable damage to the public perception, where a shop being closed just for a few hours a day is enough of a reason for customers to change their mind and look for a different place to take their business to.
Prolonged seizures and police involvement brings negative attention to the business, making people believe that the owners are doing something wrong, which couldn't be further from the truth in this case, where the only person who committed questionable decisions was Mr Salvatorre.
The plaintiff's counsel believes that $500,000 is an amount perfectly encompassing damage to the brand, as it is physically smaller than other damages listed in this suit, yet it exists to cover a broader timeframe of undeniable negative attention Mr Salvatorre brought to his place of work from the moment of his arrest.

Lost items:
The exact market value of most items seized as the results of Mr Salvatorre’s arrest, with exceptions made for random, less valuable and less relevant items. The sum of $665,609 is a raw market value of materials and tools necessary for a mechanic shop to function, that have been taken from the property by the State.
[Currently, STROKEMASTERS is attempting to retrieve the seized property from the State through civil litigation, and if such is successful, the plaintiff will move to amend the above-mentioned portion of the damages.]

Stolen revenue:
While employed at STROKEMASTERS, Mr Salvatorre failed to deposit any cut of earnings throughout his entire time working there under Timothy Gentry’s ownership of the business. Mr Salvatorre was someone who was hired by the previous owner, Miss Morten, who has long since sold the property and rights of Strokemasters to Mr Gentry. Due to the lack of deposits, Mr Gentry could only assume two options:

Mr Salvatorre was not working at the shop.
OR
Mr Salvatorre was pocketing all earnings, failing to follow clear employment rules as laid out by the owner, which every employee had to agree to to remain employed.
The exact amount of cash he's made by using STROKEMASTERS tools is known only to Mr Salvatorre himself, but Plaintiff's counsel offers a reasonable $200,000 of stolen revenue over the term of his employment at STROKEMASTERS, before his arrest.
Said amount pales in comparison to what a full-time mechanic would make for the shop during time of employment (03.15.2025 - 05.25.2025), yet we're not going to pretend Mr Salvatorre’s main source of income was repairs, hence the heavily reduced amount.

Legal fees:
Quoting Honorable Judge Buckham-Smythe:
“This has gone on long enough. A business has been left unable to operate for a month now due to these various searches, injunctions, and other court proceedings.”
The period between the arrest of Mr Salvatorre and the current day was more than a month of patience and waiting... It was a constant legal battle on multiple fronts, requiring substantial and constant effort from STROKEMASTERS’ legal counsel, fighting for justice to prevail in a situation entirely born out of Mr Salvatorre’s selfishness and criminal actions.
Evidence will show STROKEMASTERS’ agreeing to the very reasonable fee for the amount of work this situation required, and at $8,000/day for 30 days straight throughout multiple legal avenues, we're looking at exactly $240,000 in legal counsel fees + $2,000 suit filing fee.

Plaintiff’s counsel believes that Mr Salvatorre bears full responsibility for all of those fees, as they were a direct necessity to save STROKEMASTERS from the situation he put the business into, through his illicit actions.

Emotional damages:
Due to lack of availability from San Andreas Medical Services staff qualified and open to conducting a psych evaluation or even simple therapy sessions, the plaintiff's counsel does not have any concrete evidence proving existence or the severity of any and all emotional trauma that people running the business have endured throughout a month-long process, during which they feared losing a place, they've put blood, sweat and tears into building up, daily.
All because one man could not stop himself from stealing, just to make a quick buck on the side…

The plaintiff would accept any decision made by the court regarding the validity and value of emotional distress they've suffered, but does not specifically ask for such, due to the limitations mentioned above.

LIST OF ALL EVIDENCE:
1A - Proof of Service (Screenshot of TEXT)
1B - Proof of Service (Copy of the service letter)
1C - Proof of Service (Filing Fee to DOJ account)
2A - State v. Salvatorre (Arrest report #5926)
2B - State v. Salvatorre (Court case - guilty verdict)
3A - STROKEMASTERS SEARCH AND SEIZURE (Approved)
3B - STROKEMASTERS SEARCH AND SEIZURE (Raid receipt #5924 #5925)
4A - INJUNCTION OF STROKEMASTERS (Approved)
5A - CIVIL ASSETS FORFEITURE CASE (Dismissed)
6A - STROKEMASTERS Earnings Statement [03.01-03.31] / [04.01-05.25]
7A - STROKEMASTERS Attorney Retainer Deal.
8A - STROKEMASTERS Employee List (Time of Salvatorre's arrest)
9A - STROKEMASTERS Rules of Employment and Conduct
10A - Full timeline of Events (from Purchase of Strokemasters by Mr Gentry, to Present day)

Context of service:
Annabelle Celestine obtained contact information for Leo Salvatorre from Chris Rustwood, who had it due to Mr Salvatorre being one of his employees. Annabelle reached out to Mr Salvatorre through text, to which he replied by phone call, confirming his identity. During the initial phone call, Mr Salvatorre agreed to meet with Miss Celestine at Legion Square. After arriving and being informed that Miss Celestine has something for him, Mr Salvatorre stated, "I know what this is about, I refuse", got back in the vehicle alongside his companion, and they drove off. At that moment, a copy of the service letter was sent to the same phone number, after which Mr Salvatorre began spam-calling the lawyer's phone line and hanging up as soon as Miss Celestine picked up.
The meeting was also witnessed in person by Luna Lawwright (554-3700), a paralegal.

respectfully submitted,
Annabelle Celestine, representing STROKEMASTERS