Loretta Lax Miller, Pro Se
PO
BOX 69243
HARRISBURG,
PA 17106
717-782-1403
Info@LorettaMiller2016,com
__________________________________/
Loretta
Lax Miller Pro Se | COURTS OF THE
COMMONWEALTH OF
Plaintiff | PENNSYLVANIA, DAUPHIN COUNTY
|
VS. |CIVIL
COURT – TORT PREMISES LIABILITY -
| JURY TRIAL
|
Ata
Richard Zandieh |
210
Lewis Street | No:2015CV1580CV
Harrisburg
Pa 17101 |
|
Behzad Zandieh |
210 Lewis Street |
Harrisburg Pa 17101 |
|
Joyce A. Zandieh |
210 Lewis
Street |
Harrisburg
Pa 17101 |
|
Jaleh
Martha Zandieh |
210 Lewis
Street |
Harrisburg Pa 17101 |
|
|
Defendants
|
COMPLAINT
COMES NOW, Loretta Lax Miller, Plaintiff, hereby sues
Ata Richard Zandieh and Behzad Zandieh, Joyce A. Zandieh, and Jaleh
Martha Zandieh (John/Jane Does) Defendant(s) for the property of
350 Market Street. Highspire, Pa, 17034 for personal injury pain and suffering
future surgeries to the right foot and her teeth from a sink hole on his/their
property and all residing at 210 Lewis Street, Harrisburg Pa, 17101 for the
following reasons:
1. Loretta
Lax Miller, the Plaintiff, is a natural born citizen, widow on Social Security,
and is disabled of the County of Dauphin State of Pennsylvania mailing address at PO Box 69243, Harrisburg Pa 17106
2. Ata
Richard Zandieh (Zandieh), Defendant, is a single man with unknown partners who
he claims to be “investors”, with a passport and a flight risk to the Middle
East residing at 210 Lewis Street, Harrisburg Pa, 17101.
3.
John and Jane Does, who Ata Richard
Zandieh is in partnership with and invests for or borrows money for
investments. Zandieh’s mother and father are listed as partners. Behzad Zandieh is his father and Joyce A. Zandieh is his mother and
shall be known as partners residing at 210 Lewis Street,
Harrisburg Pa, 17101
4. Another Jane Doe
is Jaleh Martha Zandieh who a partner ( shall be included in the list of
partners) and is a flight risk to Portugal residing at 210
Lewis Street, Harrisburg Pa, 17101
5. Behzad
Zandieh his father and Joyce A. Zandieh his mother hide Ata Zandieh from service, creditors
and lawsuits.
6. Loretta
Lax Miller, Plaintiff, hereby sues Ata Richard Zandieh and John/Jane Does
Defendant(s) for the property of 350 Market Street. Highspire, Pa, 17034, 1334
Earl Street and 1838 Webster Streets in Philadelphia Pa for endangering the
life of Loretta Lax Miller with a sink hole which caused her to fall,
fracturing her right foot, causing a contusion to her right hand, causing trauma
to her right knee, and loss of all teeth in her mouth as well as pain and
suffering and future teeth corrections and surgeries to her foot and mouth.
7. Ata Zandieh was asked 3 times to give
Loretta Lax Miller his insurance information for the property of 350 Market
Street, Highspire Pa 17034.
8. Zandieh
uses numerous mailing addresses to hide from creditors and is currently being
investigated by the FBI for Mortgage fraud with his association and one address
linking him to Pyramid Investments Inc. along with a phone number linked to the
same address, auto insurance fraud stating his residence is in Philadelphia Pa
to the Courts not to the auto insurance companies when he lives at his parent’s
home 210 Lewis Street, Harrisburg Pa 17101 to avoid paying high insurance costs,
and Bankruptcy Fraud.
9. Zandieh
has claimed he makes over 1-2 million dollars using other people’s money (John
and Jane Doe’s Investors) in purchasing property. He has many bogus and empty
corporations and empty virtual addresses which the mail is forwarded to 210
Lewis Street, Harrisburg Pennsylvania 17101.
THE ACCIDENT
10. On November 11,
2014, after torrential rains of approximately 2-3 days hit the Harrisburg area,
Loretta Lax Miller went outside to walk her dog at 8pm. Loretta Lax Miller was
using a flashlight to see because the area is dark. Loretta Lax Miller being
right foot dominant stepped down between the drive way and the grass and felt
the ground give way. She then fell with her right foot caught in the dirt
holding onto the leash and the flash light flying in the air Loretta Lax Miller
landed on her mouth, hand and knee. One front tooth fell out with about 4-6
molars and loosened the rest of her teeth in her mouth.
11. At
that point she didn’t feel that her foot was fractured but her mouth was
swollen and bleeding. More teeth were falling out. Loretta Lax Miller called
the police who said go to the hospital and refused to take a phone report.
Loretta Lax Miller was spitting out teeth, her front uppers were hanging when
her son Marcus F. Miller saw he mouth and insisted on taking her to the
hospital.
12. Loretta Lax Miller
went to the hospital emergency room thinking it was only a dental problem and
found out she had a fractured foot and had contusions on her hand and knee. Her
foot was immediately casted and the next day she went to the first dentist who
told her that they cannot save the teeth do to all the trauma. She needed to
remove the teeth and get dentures and someday in the future when her gums heal
she may be a candidate for implants.
13. Loretta Lax Miller
went to the Orthopedic Institute of Pennsylvania walk-in clinic. Loretta Lax
Miller was their prior to this fall for a Ganglian Cyst of the left foot and x-rays
of both feet were taken for a comparison. No fracture was seen at the previous
x-ray taken 3 weeks prior but there was a fracture on the navicular bone after
the fall. The navicular bone is the anchor of the ankle and the foot. Her foot
was placed in an air cast and 1 week later in a cast by her Orthopedist. She
was given more pain killers.
14. Loretta Lax Miller
went for a 2nd opinion for her teeth since she really wanted to see
if her teeth could be saved. Again due to the trauma the teeth could not be saved
and she went for the oral surgery on Wednesday December 17th, 2014.
She was told that her gums must heal and that she may be able to get implants
sometime in the future but a bone graft is needed prior to this any procedure
after her gums and the infection this fall has caused.
15. Loretta Lax Miller
has to relearn to eat, speak and endure swollen gums for the next 6 months to a
year. And then again when the next step in the surgery would be for either
implants or a bone graft and implants.
16. Loretta Lax Miller
received a call from Zandieh on November 14, 2014 cursing her about the sink-hole
Loretta Lax Miller fell in. Her son, Marcus F. Miller, received that call since
his cell number is listed on Dauphin County Court Filings. Zandieh’s call was
not about asking the condition of the Loretta Lax Miller but to blame Loretta
Lax Miller for the sinkhole which is in clear sight from the curb and to
threaten Loretta Lax Miller. The outside of the house has begun to shift away
from the side of the driveway and a 4th sink hole was found in the
front of the home. The floor in the basement began to buckle leaving the
beginning of another sinkhole. (EXHIBIT 4 PHONE RECORD)
17. Loretta Lax Miller
went to John Hopkins on February 26, 2015 for a 2nd opinion on her
foot since she felt a bone protruding and pain in that area and she is barely
placing pressure on that foot. Her foot is pronated and she had lost her arch.
She was re-casted and told it may take 1 year or longer for the bone
(navicular) to heal and may need surgery because the Tendons and the Ligaments
have ruptured and torn due to the fall from the sink hole.
18. Loretta Lax Miller’s
right foot is now deformed from the fall. Loretta Lax Miller both feet were
narrow and now she has one narrow foot and one extra wide foot due to the
arches that have fallen from the trauma.
19. Loretta Lax Miller
has gone into a depression from a life altering experience.
20. Ata Zandieh aka
Ata R. Zandieh aka A. Richard Zandieh aka A. R. Zandieh aka Z Ata aka Ms. Ata
Zandieh declares various addresses for his residence, but his bills for all his
real estate ventures goes to his mother’s and father’s address who are his partners
at 210 Lewis Street in Harrisburg Pa 17101.
21. Ata Zandieh has no
insurance because he owes Creditors over $400,000.00 and they are placing his
properties up for Sheriff Sale. Loretta Lax Miller wants to sue Ata Zandieh who
claims he is the owner after a long battle of who owns what in another Case in
Dauphin County and since he was declared the rightful owner then Ata Zandieh is
fully responsible now for the property liability since September 16, 2013 even
though he filed Bankruptcy 10 days before he purchased the property in a tax
sale according to Judge Bruce Bratton who is now being sued in Federal Court
for the violation of Loretta Lax Millers Civil and Constitutional Rights.
22. Zandieh has not
placed a dime in the property which also includes paying for sewer taxes which
Loretta Lax Miller has paid over $2,000.00 for, paying for water line
protection from the street to the house, mowing the grass at $45.00 a mow once
a week for 8 months ($2,888.00 for 2 years) maintaining an ant problem for 3
years at $1000.00, replacement of the motor in the dishwater $200.00
replacement of anchors for the top rack every 6 months $240.00, repair of stove
motherboard $300.00, and the repair of heater including thermoset inside of
heater and auto heater element to light the gas plots. The central AC is broken
and needs to be replaced as well as the fact the heater is on its last legs and
the hot water heater Loretta Lax Miller is not putting in another dime into the
property since it is not Loretta Lax Millers property. The weeds and dead
plants have not been attended. Ata Zandieh is a slum Lord.
23. Since the fall the
sink hole has deepened and the driveway is now separating from the steps and
house. There is a gap of 2 inches between the house and the driveway.
24. Since the accident,
Loretta Lax Miller found out that Judge Bratton was a partner and possibly still
a silent partner of Martsolf. Judge Bratton is friends with Zandieh through a
relative of a friend (Raymond C. Thorn age 73), family member, or a possible
roommate of Zandieh known as Raymond C. Thorn (age 36) whose address is the
same as Zandieh at 210 Lewis Street. Raymond Thorn (age 36) just so happened to
have lived at Zandieh’s home which is also his father’s house who is a partner
with Zandieh as well as his sister who lives in Europe now. Zandieh has 5 known
different addresses he gives to the courts. But the main address he and his
attorney Evan Pappas has denied is 210 Lewis Street Harrisburg Pennsylvania
17101 where he was served on several lawsuits. He sometimes denies he is Ata
Richard Zandieh to prevent service or refuses to pick up registered with
receipt requested or restricted mail only to his name with receipt requested.
25. Zandieh has used
the excuse to get out of lawsuits that he was not properly served when he does
not properly give the correct address,
26. The address
Zandieh uses in Philadelphia is 6828 Torresdale Ave, Philadelphia Pa which is an
empty “office” with a sign outside that states it’s a storage unit called Value
Storage and when you call the number linked to the filings of Ata Zandieh it
says Real Estate office and Value Storage. You cannot use the name Real Estate
without a broker’s license. This property is zoned Commercial not industrial
and cannot exist as a storage unit without proper fire codes and zoning. There
is no hours to Value Storage therefore he cannot be served there.
27. Since his parents Behzad Zandieh (father) and Joyce A
Zandieh (mother)
and his sister Jaleh Martha Zandieh are listed as partners, Loretta Lax
Miller is suing them along with Ata Zandieh.
28. The sink hole got
deeper since the snows which it is now approximately 2 feet deep and the
driveway is slowly sinking and pulling away from the house.
Count
one
29. Loretta Lax Miller
fractured her foot and broke and loosened her teeth to the point of falling out
when she smashed her mouth into the ground due the fall from the sink hole that
was beginning at the time Zandieh claims he purchased the property illegally
through money he did not declare during the filing of Chapter 13 in US
Bankruptcy Court. Zandieh refuses and refused to send any information
pertaining to his insurance on the property of 350 Market Street Highspire Pa
17034. Zandieh is fully responsible for
all damages to Loretta Lax Miller’s person. In fact Zandieh has refused to pick
up any and all certified mail with receipt requested showing he received that
notice. However, Loretta Lax Miller has sent to Zandieh the same letter by
regular US Mail.
30. This mail was not returned
therefore Zandieh is well aware of the sink hole and that he is being sued.
31. Loretta Lax Miller
had lost her teeth during this fall. The number teeth that were loose and had
to be extracted were #4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 21, 22, 23, 24, 27, and
28 all under local anesthesia. A total of 16 teeth.
32. Loretta Lax Miller’s
bleeding of the mouth was stopped with temporary dentures. However the pain
from the injury and the trauma she is enduring is so intense and mentally
painful that Loretta Miller will be seeking psychological therapy from her life
altering experience and her loss of teeth causing her to go into a depression.
33. The dentures are
preventing the use of her voice words and tongue to express itself due to the
fact that it’s a foreign item in her mouth and the better dentures or implants
which are unaffordable at $80,000.00 for a full mouth. These implants cannot be
placed into her gums until her gums heal which will take approximately 12
months or more to heal and Loretta Lax Miller will need a bone graft for these
implants.
34. Loretta Lax Miller
is suffering from lack of food and substance that has nourishment. The pain of
chewing with plastic in her mouth with open wounds is unbearable.
35. The cost of
temporary dentures and extractions are so far $6,000.00 and the pain from the
facial bruises including the depression from the loss of the teeth are beyond
costs.
36. The plastic
dentures reshaped her face to the point that her jaw line is not a natural jaw line
and her facial features are different or altered.
37. The Defendant Ata
Richard Zandieh and his partners have no insurance and or refuses to give the
insurance information to Loretta Lax Miller so she could collect for pain and
suffering and damages. By not giving the insurance information, the Zandieh’s
are fully responsible for her injuries and all assets are to be frozen immediately
and their passports removed so they are not a flight risk since they travels to
the Middle East.
38. Loretta Lax Miller
fractured her foot due the fall from the sink hole that was beginning at the
time Zandieh claims he purchased the property through money he did not declare
during the filing of Chapter 13 in US Bankruptcy Court.
39. Loretta Lax Miller
has a contusion on her right hand and her right knee. Her hand will have to
been seen by a hand specialist since her hand is still damaged from the fall.
40. Loretta Lax Miller
is traumatized from the fall and will be seeking psychological therapy do to
this fall which altered her appearance and her mental state.
41. The ground is
still sinking and the driveway is being pulled away from the house steps. There
is another sink hole forming in the front lawn area affecting the driveway and
the house due to negligence of Zandieh thinking that Loretta Lax Miller is
going to pay for major repairs since he has been in court with Loretta Lax
Miller with the question on the premature sale of the property by the Dauphin
County Tax Department.
42. Loretta Lax Miller
is suing Ata Zandieh and his partners for the following amounts for a fractured
foot $175,000.00.
43. For disfigurement of her foot Loretta Lax
Miller is suing Ata Zandieh and his partners for $1,000,000.00.
44. Loretta Lax Miller
is suing Ata Zandieh and his partners for pain and suffering $1,000,000.00 for
her foot.
Count Two
45. Loretta Lax Miller
fractured her foot and broke and loosened her teeth to the point of falling out
when she smashed her mouth into the ground due the fall from the sink hole that
was beginning at the time Zandieh claims he purchased the property illegally
through money he did not declare during the filing of Chapter 13 in US
Bankruptcy Court. Zandieh refuses and refused to send any information
pertaining to his insurance on the property of 350 Market Street Highspire Pa. Zandieh is fully responsible for all damages
to Loretta Lax Miller’s person. In fact Zandieh has refused to pick up any and
all certified mail with receipt requested showing he received that notice.
However, Loretta Lax Miller has sent to Zandieh the same letter by regular US
Mail. This mail was not returned therefore Zandieh is well aware of the sink
hole and that he is being sued.
46. Loretta Lax Miller
had lost her teeth during this fall. The number teeth that were loose and had
to be extracted were #4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 21, 22, 23, 24, 27, and
28 all under local anesthesia. A total of 16 teeth.
47. Loretta Lax
Millers facial features were altered from the sinkhole fall.
48. Loretta Lax Miller’s
bleeding of the mouth was stopped with temporary dentures. However the pain
from the injury and the trauma she is enduring is so intense and mentally
painful that Loretta Miller will be seeking psychological therapy from her life
altering experience and her loss of teeth causing her to go into a depression The
Defendant Ata Richard Zandieh has no insurance and or refuses to give the
insurance information to Loretta Lax Miller so she could collect for pain and
suffering and damages.
49. The dentures are
preventing the use of her voice words and tongue to express itself due to it’s
a foreign item in her mouth and the better dentures or implants which are
unaffordable at $80,000.00 for a full mouth. These implants cannot be placed
into her gums until her gums heal which will take approximately 12 months or
more to heal. Bone grafts are needed to build up the natural bone to place
implants in her mouth for a natural like chew.
50. Loretta Lax Miller
cannot eat and is still on a liquid/soft food meals from the pain of the bone
spurs.
51. Loretta Lax Miller
is suffering from lack of food and substance that has nourishment. The pain of
chewing with plastic in her mouth is excruciating and she is having a hard time
chewing so she could swallow her food.
52. The cost of
temporary denture and extractions are so far $6,000.00 and the pain from the
facial bruises including the depression from the loss of the teeth are beyond
costs.
53. Loretta Lax Miller
is suing Ata Zandieh and his partners for pain and suffering for loss of her
teeth $1,000,000.00
54. Loretta Lax Miller
is suing Ata Zandieh and his partners for loss of teeth $75,000.00.
REMEDY
55. Ata Zandieh should
have insurance since 350 Market Street Highspire Pa 17034 is an investment
property and not his homestead.
56. Ata Zandieh and
his partners are to surrender the property of 350 Market Street, Highspire Pa
17034 as a down payment for injury of the teeth and the foot.
57. Ata Zandieh and
his partners shall have their salaries garnished and their properties sold at Sheriff
Sale.
58. Freeze all of Ata
Zandieh and his partner’s assets including bank accounts, investments, cars and
all tangible properties.
59. Ata Zandieh and
his partners shall cease and desist in trying to possess the property of 350
Market Street Highspire Pa 17034 as a form of retaliation of the fail and
injury.
60. Ata Zandieh and
his partners are to pay one million USD ($1,000,000.00) for pain and suffering along
with mental anguish for loss of approximately sixteen plus (16 +) teeth The
cost of temporary denture and extractions are so far $6,000.00, and for loss of
teeth $75,000.00.
61. For just the teeth
Ata Zandieh and his partners owe Loretta Lax Miller a total of one Million
Eighty One thousand USD ($1,081,000.00).
62. Ata Zandieh and
his partners are to pay for the fractured right foot of the navicular torn
ligaments and tendons $175,000.00, the pain and suffering 1,000,000 and the
disfigurement of the one foot another $1,000,000.00.
63. For just the right
foot Ata Zandieh and his partners owe Loretta Lax Miller a total of two Million
One Hundred seventy five thousand USD ($2,175,000.00)
64. Total for both Three
Million Two Hundred Fifty Eight Thousand USD ($3,258,000.00). Ata Zandieh states
on his webpage he makes 2-4 million per year that Ata Zandieh can well afford the
amount asked.
65. Loretta Lax Miller
is asking for a Jury Trial and not a trail by a Judge because she does not feel
she is going to get a fair trial do to her mistrust of her experience with
Judge Bruce F. Bratton whom she has filed 3 Judicial Reviews Complaints against
and is suing him in Federal court for violation of her due process and civil
rights.
THEREFORE, Loretta Lax Miller is filing a lawsuit
against Ata Zandieh and his partners in a personal injury tort because Ata
Zandieh refused and failed to provide Loretta Lax Miller with insurance
information for a fall from a sink hole on his and his partners said properties
and grant Loretta Lax Miller the amount of three million, two hundred
fifty-eight thousand dollars ($3,258,000.00) for her injuries as well as pain
and suffer, mental anguish, and disfigurement due to the negligence of Ata
Zandieh and his partners.
By Loretta
Lax Miller March 2, 2015
CERTIFICATE OF VERIFICATION
I, Loretta Lax-Miller, hereby state that
the facts above set forth are true and correct (or are true and correct to the
best of my knowledge, information and belief) and that I expect to be able to
prove the same at a hearing held in this matter. I understand that the
statements herein are made subject to the penalties of 18 Pa.C.S.
§ 4904 (relating to unsworn falsification to authorities).
Date: March 2, 2015 By:
Loretta Lax Miller (Pro-se)
Certificate of Service
I, Loretta Lax-Miller
herby certify that I have this day March
2, 2015, handed this to the
Dauphin County Sheriff department for Service of the forgoing document upon all parties of
record and of interest in this proceeding in accordance with the requirements
of § 33.32 (relating to service by a
participant).
Date: March 2, 2015, to
Ata Richard
Zandieh , Behzad
Zandieh, Joyce A. Zandieh and Jaleh
Martha Zandieh all residing at 210 Lewis Street, Harrisburg Pa 17101
By
Loretta Lax Miller
 |
| Behzad Zandieh |
 |
| Ata Zandieh |
 |
| Jaleh Martha Zandieh |
 |
| Joyce and Behzad Zandieh |
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