Date Filed: 03/22/2025, Resubmitted 04/07/2025
Plaintiff Name(s) and Phone Number(s):

Kayse Morgan - 5552403
Kelby Urban - 5552033
Alabaster Black - 553956
Victory Shields - 5551511

Plaintiff Availability: NAEST, Late night
Attorney Name(s) and Phone Number(s): N/A (Self-Representation)

Defendant Name: Guy Mann, formerly of BCSTow and currently a Deputy with the
Blaine County Sheriffs Office; and The Blaine County Sheriff's Office (BCSO)

Incident Date: 03/13/2025

Reason for Suit: On March 13, 2025, Defendant Guy Mann, acting as a BCSTow
operator and now serving as a Deputy with the Blaine County Sheriff's Office, unlawfully entered “The Rejects Scrapyard” located at the comer of South Arsenal and Alta Street (privately owned by Plaintiff Kayse Morgan). Despite the property being clearly marked with “No Trespassing” and “Private Property” signage (consistent with the zoning established by the DOJ when the property was purchased), Guy Mann proceeded to issue parking tickets and tow vehicles without proper authority.

Specifically, Guy Mann:

Issued tickets, towed, and impound five vehicles belonging to the Plaintiffs

Ticket #19429 for Kayse Morgan's Issi Classic
Ticket #19420 for Kelby Urban's Vamos
Ticket #19422 for Kelby Urban's Weevil
Ticket #19426 for Alabaster Black's Beater Dukes.
Ticket #19419 for Victory Shields’ Bodhi (erroneously identified and ticketed as a BF Club)

Additionally, without following proper BCSTow procedures or issuing a ticket, impounded a sixth vehicle - Kayse Morgan's Vigero Crusty - which was taken to Lot
Tow Impound. This vehicle was held in Lot Q impound from March 13 until its return on March 27, 2025.

Guy Mann had full access to MDT records confirming the private ownership of the
property yet negligently failed to verify this before taking action. His conduct constitutes illegal trespass, unauthorized towing, and the theft of motor vehicles from private property without the permission of either the vehicle owners or the property owner.

Relief Sought

Reimbursement of all court and filing fees incurred in this action.
Reimbursement of all impound fees incurred for the wrongful towing and
impoundment of the vehicles.
Monetary damages in the amount of $50,000 from Defendant Guy Mann for his
unlawful actions.
Additional monetary damages in the amount of $50,000 from the Blaine County
Sheriff's Office for its failure to prevent or remedy these unauthorized practices, despite knowing about this particular case since the 15th of March.
A declaration that Defendant Guy Mann is criminally liable for trespass on private
property and the theft of 6 motor vehicles.
Any other relief the Court deems just and proper.

Filed By: Kayse Morgan (Self-Represented, on behalf of all Plaintiffs)

Filing submitted in format listed below - saved here just in case the transcription does not match.

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Date Filed: 03/30/2025
Plaintiff: Kayse Morgan (Self-Represented) – 5552403
Plaintiff Availability: Late Night NA

Defendant Name: Rudy Chalk, Owner of Lot Q Tow Impound
Incident Date: 03-13-2025

Reason for Suit: On March 13, 2025, as a direct result of Guy Mann’s actions at “The Rejects Scrapyard,” Plaintiff Kayse Morgan’s Vigero Crusty was illegally towed from her private property and impounded by Lot Q Tow Impound. The vehicle was held in impound from March 13 until March 27, 2025, after which it was returned to the owner.

Defendant Rudy Chalk, as owner of Lot Q, is being sued for trespass and illegal towing of a vehicle from private property, and for the theft of a motor vehicle without the permission of either the vehicle owner or the property owner. Furthermore, an impound fee of $1000 was charged by the Defendant - a fee that was paid by a third party on behalf of the Plaintiff without her knowledge.

Seeking:
$1000 impound fee
$20,000 damages + court fees