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Greensboro Complaint Against Greensboro Inn

Greensboro Complaint Against Greensboro Inn

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Published by Matt McKinney

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Published by: Matt McKinney on Dec 09, 2011
Copyright:Attribution Non-commercial

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10/06/2013

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/
STATE
OF
NORTH
CAROLINA
COUNTY
OF
GUILFORDSTATE
OFNORTH
CAROLINA
On
Relation
of
CITY
OF
GREENSBORO
Plaintiff,
vs.
KHAN
AND
KHAN,
INC.
aNorthCarolinaCorporation
Defendant.
INTHEGENERALCOURTOFJUSTICE
SUPERIOR
COURTDIVISION
ncvs/JX£>S3
VERIFIED
COMPLAINT
(JURY
TRIAL
REQUESTED)
ANDREQUESTFOR
TEMPORARY
RESTRAININGORDER
NOW
COMES
the
Plaintiff,
pursuant
to
Chapter
19
of
the
North
Carolina
General
Statutes,
more
particularly,NorthCarolina
General
Statutes
§§
19-2.1
and
19-2.2,and
complaining
of
the
Defendant,allegesandsays:
1.
The
Plaintiff
is
the
State
of
NorthCarolina
on
relation
of
theCity
of
Greensboro,
a
body
politic
and
corporate,organizedandexistingunderthe
laws
of
the
State
of
North
Carolinaand
is
specifically
empowered
pursuant
to
provisions
of
NorthCarolinaGeneral
Statute§
19-2.1
tobringthis
action.
2.
The
subject
real
property
of
thisaction
islocated
within
Guilford
County,
North
Carolina.
 
3.
Defendant
Khanand
Khan,
Inc.,
is
a
corporation
organized
and
existing
underthe
laws
of
the
State
of
NorthCarolina
with
its
principaloffice
and
place
of
businesslocatedinGuilford
County,NorthCarolina.
4.Khan
andKhan,
Inc.,
owns
the
propertyhousingthe
business
known
as
theGreensboro
Inn,
located
at
135
Summit
Avenue,
Greensboro,
GuilfordCounty,North
Carolina
(hereinafter
the
Property).TheProperty
is
further
describedin
theDeed
dulyrecorded
in
Deed
Book
3508,
Page1592,
in
the
Office
of
theGuilfordCounty
Register
of
Deeds,
a
copy
of
which
is
attached
hereto
and
incorporatedherein
by
reference
as
Exhibit
A.
5.
The
Property
describedhereinabove,
nowandfor
some
considerableperiod
of
time
prior
to
the
filing
of
this
Complaint,
has
beenestablished,continued,
maintained,
owned,and
used
by
Khan
andKhan,Inc.,
as
a
place
for
the
purpose
of
prostitution
andthe
illegal
possession
and
sale
of
controlled
substances
as
defined
inthe
North
CarolinaControlledSubstance
Act.
6.
The
Propertydescribedhereinabove
now,
and
forsome
considerable
period
of
time
prior
to
thefiling
of
this
Complaint,
has
been
established,continued,maintained,owned,
andused
by
Khan
andKhan,
Inc.,
as
a
place
whereinand
whereon
are
carried
on,
conducted,or
permitted,
repeated
acts
which
create
and
constitute
a
breach
of
thepeace,
includingbutnotlimited
to
armed
robberies,
assaults
on
females,
assaultsinflictingseriousinjury,aggravated
assault,and
communicatingthreats.
7.
During
Defendant's
ownership
of
the
Property,law
enforcementauthorities
havemade
at
leastfourteen
drug
chargesagainst
individuals
upon
the
Property
and
have
seizedheroin,
cocaine,
and
marijuana
from
such
individuals.
 
8.
Prior
to
filing
thisaction,Defendant
Khan
andKhan,
Inc.,received
written
notice
from
the
Plaintiff
that
a
nuisanceexisted
orwas
maintainedonthe
Property.
A
copy
of
thewritten
notice
is
attachedhereto
and
incorporated
herein
by
reference
as
Exhibit
B.
9.
In
addition
to
and
in
support
of
allegationscontained
in
this
Complaint,
Greensboro
PoliceOfficers
K.D.
Bennett,
J.D.
Brown,
C.H.
Peeden,
GreensboroPolice
Sergeants
A.H.
Hollis
and
J.E.Armstrong,andGreensboroPoliceCaptainD.W.
Scott
havesigned
affidavits
containinginformation
and
describing
factual
circumstances
and
occurrences
which
supportthe
Plaintiffs
cause
of
action.The
affidavits
are
attachedheretoand
incorporated
herein
by
reference
as
follows:the
Affidavit
of
Officer
K.D.
Bennett
is
Exhibit
C\
the
Affidavit
of
Officer
J.D.Brown
is
Exhibit
D;
the
Affidavit
of
Officer
C.H.
Peeden
is
Exhibit
E\
the
Affidavit
of
Sergeant
A.H.
Hollis
is
Exhibit
F;
the
Affidavit
of
SergeantJ.E.
Armstrong
is
Exhibit
G;
andthe
AffidavitofCaptainD.W.Scottis
Exhibit
H.
10.The
Plaintiffis
informed,believes
and
therefore
alleges
that
during
Defendant's
ownership
of
the
Property,various
persons
have
admittedto
or
have
been
found
guilty
of
engaginginnuisance
related
criminal
activity
uponthe
Property,
including
the
following:
(a)TonyLee
Barfield
Possession
of
cocainewith
intent
to
sell
and
deliver
Possession
of
stolenproperty
Assault
on
a
female
Possession
of
Marijuana
Possession
of
cocaine
with
intent
to
sell
anddeliver
Communicatingthreats
Possession
of
drugparaphernalia
(b)
GregoryManning
(c)
Robert
Carico
(d)
NatashaRicker
(e)
D'AngeloJackson
(f)
D'AngeloJackson
(g)
JeremiahMorehead

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