IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON (portland) ev' BR M" COMPLAINT. (Replevin- Claim & Delivery) JURISDICTION

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1 Robert S Simon Attorney at Law OSB WSB 20382/CASB PO Box Portland, Oregon ( ( Robert@RSSimonlaw.com IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON (portland JOHN CARUOID, PlaintifJ(s, vs. THE MONEY MARKET, an assumed business name ofwoo SInN (PETER LIM, and BEAVERTON PAWN, INC., an Oregon corporation. ev' BR M".- COMPLAINT (Replevin- Claim & Delivery Defendant(s. COMES NOW, the PlaintiffJohn Carughi, by and through attorney Robert S Simon of The Robert S Simon LawFirm, and does hereby allege as follows: JURISDICTION The plaintiff is a citizen ofwashington. The defendants are both citizens oforegon. The amount in controversy exceeds $75,000. This Court has Jurisdiction in Diversity pursuant to 28 U.S.C TIleRobert S Slmoa Law FIrm PO 80s 82.OO3!l Portlud OR 972G-tll35 (503H

2 STATEMENT OF FACTS 5. On or about January through March 2009 approximately forty three (43 antique firearms which are the sole property ofthe plaintiffwere taken from where they were stored in Washington and delivered to the defendants, one or more, by persons with no legal right to possession or control ofsame. 6. The firearms are ofsuch distinction and extraordinary rarity and value that was unmistakable to professionals in the field ofvaluing personal property as collateral for loans. 7. The firearms are ofsuch age and vintage thatthey do not possess serial nwnbers nor are they registered with any government agency. 8. The firearms are ofsuch distinction and extraordinary rarity thatthe descriptions set forth below are sufficient to allow identification ofthe firearms with reasonable specificity. 9. On information and belief; The firearms were taken by Chris Craig, anapproximately 30 year old, male Washington resident, and delivered to the defendants by him. 10. On information and belief; Chris Craig has fled the jurisdictionofthis court and as of this date is believed to be residing in Box Elder COWlty, Utah. 11. On or about February 17, 2008 through JWle 23, thenfrom September 11,2008 through December 05,2008, and again from February 18, 2009 thru September and October 16, 2009 through the present, the plaintiffis a civilian contractor in specialty electrical work deployed to the Iraq theater ofoperations under contract to serve the needs ofthe United States military forces stationed there. 12. On information and beliefthe following below listed firearms are in the possession and control ofone or more ofthe defendants (hereinafter "firearms": 2-

3 A Harper's Ferry;lp dated 1808; OF Z Colt; London model; small B Ames; USN fluted cylinder C. US Army signal pistol AA Colt Navy;NY address wliron D. pro Italian fl pistols;bbl mkd bs&tg Lazarino, locks mkd Geronomino BB Colt Navy Zucolo; circa 1685; of CC ColtNavy wlsm iron tg&bs E. pro fl Queen Anne pistols; silver 2, mounted; byj. Hannon; OF DD Colt Navy; 3rd model F Colt revolving rifle marked US EE. Colt 2nd model dragoon wi spur tag FF. Model 1780 British light dragoon G. British volley gun; 1st model; GG. Silver mounted pistol; mkd Pistoia H. Sharps carbine; Texas ranger marked HH. Silver mounted ft pistol by I. Dance Bros. #247 Bumford;OF J North;eagle only on 1p;RC; n Colt Navy engraved; ivory K North conversion;rc grips L Colt Army, US issue n. Colt Walker M. Sharps 4 barrel derringer with carved KK. Griswold revolver ivory grips LL. Cased pro fl Andres Kuchemeuter N North;RC dueling pistols; OF; prfl brass O North;RC Queen Anne box lock pistols; silver P Johnson Conversion wire inlaid; Q Ames; USR MM. Tranter revolver; mkd Hyde & R. US Navy signal pistol Goodrich; S. Whitney Navy NN. Kerr revolver T. 1st Model LeMat 00. Cased pr silver mtd fl dueling U. 2nd Model LeMat pistols;conv. to perc.; by Christoph V. Transition model LeMat Kuchenreuter W. Metropolitan Navy revolver PP. Dolne Apache knuckle duster; X Colt Army engraved wi QQ Staff& field officer: checkered ivory grips presentation Y Colt Army conv FIRST CLAIM FOR RELIEF (Replevin- Claim & Delivery (Countij (The Money Market The plaintiffrealleges paragraphs 1-11 above and further alleges as follows: 12. The defendant The Money Market is an assumed business name ofwoo Shin (peter Lim (hereinafter "Money Market" The defendant Money Market, at all times material, was/is a licensed Pawnbroker in the n.llolhot ss!mod t... llinn PO Box ! PordIIad OR" (

4 State oforegon with license number PB The plaintiffhas contacted agents for the defendant and demanded the return ofthe aforementioned firearms, to the extent in the possession and control ofthe defendant, and that demand has been refused. 15. On information and belief; The defendant Money Market has possession and/or control over one or more ofthe firearms. FIRST CLAIM FOR RELIEF (Replevin- Claim & Delivery (CountID OJeaverton Pawn 16. The defendant Beaverton Pawn also does business under the name of"hillsboro Pawn" located in Washington County, Oregon. 17. The defendant Beaverton Pawn, at all times material, was/is a licensed Pawnbroker in the State oforegon with license number PB The plaintiffhas contacted agents for the defendant and demanded the return ofthe aforementioned :firearms, to the extent in the possession and control ofthe defendant, and that demand has been refused. 19. On information and belief; The defendant Beaverton Pawn has possession and/or control over one or more ofthe :firearms. PRAYER FOR RELIEF The plaintiff has been damaged by the loss ofcustody and control ofthe fireanns, and prays for relief from this court in the following particulars: FIRST CLAIM FOR RELIEF- (Replevin- Claim & Delivery (Count 1- Money Market a. An Order ofreplevin commanding the defendants to surrender the frreanns to the 4- De Robert S SIm01l x-jilrm PO BoJ; Pordud Oil ~103!(W U

5 custody and control ofthe plaintiff; b. Injunctive relief from the court prohibiting the defendants from effecting the transfer, alienation, or loss ofcustody and control ofthe fireanns without an order authorizing same issued by this court; c. In the alternative, the fair market value ofthose firearms for which Replevin is not an available remedy; d. The award ofthe plaintiff's costs incurred inthe pursuit ofthis reliefafter demand was made for the return ofthe firearms; e. All other such reliefthe court determines is just and equitable. FIRST CLAIM FOR RELIEF- <Replevin- Claim & DeliveJY (Count 11- Beaverton Pawn a. An Order ofreplevin commanding the defendants to surrender the firearms to the custody and control ofthe plaintiff; b. Injunctive relieffrom the court prohibiting the defendants from effecting the transfer, alienation, or loss ofcustody and control ofthe firearms without an order authorizing same issued by this court; c. In the alternative, the fair market value ofthose ftrearms for which Replevin is not an available remedy; d. The award ofthe plaintiff's costs incurred in the pursuit ofthis reliefafter demand was made for the return ofthe firearms; e. All other such reliefthe court determines is just and equitable. Dated this February 16,2010 ~ OSB 90120/ WSB 20382/CASB for The Robert S Simon Law Firm Attorneys for PlaintiffJohn Carughi 5- TIle Robilrt S Simod Law FirIIl PO Box IZOO35 Pordod OR (

DEPARTMENT OF THE NAVY HEADQUARTERS UNITED STATES MARINE CORPS 3000 MARINE CORPS PENTAGON WASHINGTON DC

DEPARTMENT OF THE NAVY HEADQUARTERS UNITED STATES MARINE CORPS 3000 MARINE CORPS PENTAGON WASHINGTON DC 20350-3000 MARINE CORPS ORDER 5354.1E ADMIN CH From: Commandant of the Marine Corps To: Distribution