I am planning to file a lawsuit in Oregon pro se for fraud, breach of contract, conversion, etc.
I have a draft of the complaint and I need it to be reviewed and strengthened. The complaint is based upon one drafted by my attorney to file in Tennessee, but I have decided to file in Oregon and go pro se.
AI generated suggested improvements, but I do not know if they are legit. Also, I am open to all analysis and potential improvement.
Clarify the relationship between the defendants. Explain how Prime Trading Partners, PrimeDomain, and Keith Buck are interrelated and acted in concert to defraud the plaintiff. Provide more factual details about their shared office, personnel, operations, etc.
Expand on the fraud allegations. Provide additional specific examples of false statements and misrepresentations made by the defendants, including dates, times, methods of communication, and the exact promises made. Explain how the pattern of lies prevented the plaintiff from discovering the fraud earlier.
Address potential statute of limitations issues. Argue that the fraud could not have been discovered earlier despite due diligence, and/or that the defendants' ongoing misrepresentations tolled the limitations period under the continuing tort doctrine until March 2024.
Strengthen the alter ego liability allegations against Buck individually. Provide specific facts showing how he disregarded the corporate form, commingled assets, failed to observe corporate formalities, undercapitalized the LLCs, etc. Explain how the LLCs were mere instrumentalities for his personal dealings.
Quantify damages for breach of contract. Specify the market price of silver and the quantity of coins promised, to allow calculation of actual damages based on the 1% below market term.
Assert joint and several liability against all defendants on all claims, based on their concerted action and shared culpability.
Consider adding a civil conspiracy claim, alleging the defendants acted in concert and agreed to perpetrate an unlawful scheme against the plaintiff.
Proofread carefully and ensure all key factual allegations are included in each relevant count.
Confirm subject matter and personal jurisdiction are properly alleged based on Oregon law.
Ensure the prayer for relief includes all desired remedies, including injunctive relief if appropriate.