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IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF COCONINO Motion To Strike Julie Lafaye, c/o Miriam Jordan, Housing Solutions of Northern Arizona, PO Box *, Flagstaff, AZ *, (*) *-*, Julie Lafaye Plaintiff, vs. CV *-* Martin Ross / Mobile Body Tech LLC, Defendant Plaintiff's Response to Defendant’s Motion INTRODUCTION The plaintiff, Julie Lafaye, submits this Motion to strike against the defendants, Martin Ross and Mobile Body Tech LLC. The plaintiff filed this litigation in “Good Faith” and has provided relevant laws supporting her claims. She prioritized Ross’s health over her own, helped with his business and continues to pray for him. Wagenseller v. Scottsdale Memorial Hospital and Pyeatte v. Pyeatte *. **Contracts and Agreements**Arizona Bd. of Regents v. York RefrigerationCo., * Ariz.*, *, * P.2d *, * (*), and there is no difference in legal effect between an expressed contract and an implied contract. Swingle v. Myerson, * Ariz. App. *, *, * P.2d *, * I(*) An implied contract inferred by law as a matter of reason and justice from the acts and conduct of the parties and circumstances surrounding their transaction. Alexander v. O’Neil, * Ariz. *, *, 267P.2d *, * (*) Any Performance bargained for is consideration, and consideration need not be of like or identical value. *. Constructive Trust/Resulting Trust**: Suppose one cohabitant acquires property but deems that both intended it to be shared. If one has contributed to its acquisition or maintenance, the other might argue for a constructive trust or resulting trust. Lafaye asks the court to recognize a Key Case Studies: *. **Arizona Supreme Court addressed how property and financial matters should be handled when an unmarried couple separates. It recognized that in the absence of a legal marriage, equitable doctrines (like unjust enrichment and potential implied contracts) could prevent one party from being unfairly enriched at the expense of the other. *. **Winer v. Winer, * P.3d * (Ariz. Ct. App. *)**: Although this case primarily addressed issues post-divorce, its considerations can analogically apply regarding equitable principles in property division situations. This case examined in detail the interests of parties in jointly used and developed assets. Key Case Studies: *. **Cook v. Cook, * Ariz. * (*)**: Arizona Supreme Court addressed how property and financial matters should be handled when an unmarried couple separates. It recognized that in the absence of a legal marriage, equitable doctrines (like unjust enrichment and potential implied contracts) could prevent one party from being unfairly enriched at the expense of the other. *. **Winer v. Winer, * P.3d * (Ariz. Ct. App. *)**: Although this case primarily addressed issues post-divorce, its considerations can analogically apply regarding the use of equitable principles in property division situations. This case examined the interests of parties in jointly used and developed assets. In summary, JURISDICTION AND VENUE This Court has jurisdiction over this matter under the relevant Arizona Revised Statutes: Cook v. Cook, * Ariz. *, * P.2d * (*) Carroll v. Lee, * Ariz. * (*) * P.2d * Marvin v. Marvin, * Cal. 3d *, * Cal. Rptr *, * P.2d * (*). While holding themselves out as husband and wife, she provided household services, and he would support her for life. “Homemaking, severable from the meretricious relationship, can support an implied agreement between two parties. FACTUAL BACKGROUND The plaintiff and Martin Ross cohabitated for *.5 years. The plaintiff’s extensive contributions to the defendant’s business, personal health care, and homemaking demonstrate an implied contract that she would be supported and share in the benefits accrued during their relationship. Wagenseller v. Scottsdale Memorial Hospital, * Ariz. *, * P.2d * (*) & Pyeatte v. Pyeatte, * Ariz *, * P.2d * (*) During this period, they acquired significant financial assets intended to be shared, establishing a shared interest (based on fairness) even if title and formal ownership are in one person’s name. The plaintiff contributed to the household, the defendant’s Mobile Body Tech LLC business, and his healthcare. Upon the dissolution of their relationship, the defendant retained the plaintiff’s personal property by obtaining a restraining order. CLAIMS FOR RELIEF Count I: Return of Personal Property or Compensation The plaintiff demands the return of her personal property or compensation equivalent to its value, as listed in Exhibit A. Count II: Constructive Trust The defendant breached the terms of the implied contract by engaging in misconduct/ cheating during their relationship. The plaintiff seeks the imposition of a constructive trust over the assets acquired during their cohabitation. She helped the defendant purchase the lot for an unbelievable price and helped him sell it at a fantastic profit. Exhibit C Valento v. Valento, * Ariz. *, * P.3d * (App. *) & Cook v. Cook, * Ariz. *, * P.2d * (*) Count III: Unjust Enrichment The plaintiff contributed significantly to acquiring and maintaining assets, including the property at * N. Locksley Dr (Exhibit C). Additionally, there were contributions to his business and personal care, and homemaking which have unjustly enriched the defendant. Murdock-Bryant Construction, Inc. v. Pearson * Ariz. * * P.2d * (*) The plaintiff demands *% of all financial acquisitions during their *.5 years of cohabitation as compensation for her contributions. REQUEST FOR PRO BONO PARTICIPATION The plaintiff respectfully requests to participate in the Pro Bono Program to assist in the litigation of this case. EVIDENCE Exhibit A: Itemized list of personal property. Exhibit B: Documentation of an implied contract. Exhibit C: Documentation related to the acquisition and sale of * N. Locksley Dr. Parks, Arizona. PRAYER FOR RELIEF WHEREFORE, the plaintiff respectfully requests that this Court: Order the defendant to return the plaintiff’s personal property or compensate her for its value. Impose a constructive trust over the assets acquired during the cohabitation. Award the plaintiff *% of the financial acquisitions during the *.5 years of cohabitation. Grant any other relief the Court deems just and proper. Deny the defendant's request for the plaintiff to pay his legal fees. Allow the plaintiff to participate in the Pro Bono Program. REQUESTS The plaintiff seeks a court order of all financial records including tax returns to separate personal and business assets to recover the cost of belongings and to determine the financial acquisitions during their cohabitation.IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF COCONINO Motion To Strike Julie Lafaye, c/o Miriam Jordan, Housing Solutions of Northern Arizona, PO Box *, Flagstaff, AZ *, (*) *-*, Julie Lafaye Plaintiff, vs. CV *-* Martin Ross / Mobile Body Tech LLC, Defendant Plaintiff's Response to Defendant’s Motion INTRODUCTION The plaintiff, Julie Lafaye, submits this Motion to strike against the defendants, Martin Ross and Mobile Body Tech LLC. The plaintiff filed this litigation in “Good Faith” and has provided relevant laws supporting her claims. She prioritized Ross’s health over her own, helped with his business and continues to pray for him. Wagenseller v. Scottsdale Memorial Hospital and Pyeatte v. Pyeatte *. **Contracts and Agreements**Arizona Bd. of Regents v. York RefrigerationCo., * Ariz.*, *, * P.2d *, * (*), and there is no difference in legal effect between an expressed contract and an implied contract. Swingle v. Myerson, * Ariz. App. *, *, * P.2d *, * I(*) An implied contract inferred by law as a matter of reason and justice from the acts and conduct of the parties and circumstances surrounding their transaction. Alexander v. O’Neil, * Ariz. *, *, 267P.2d *, * (*) Any Performance bargained for is consideration, and consideration need not be of like or identical value. *. Constructive Trust/Resulting Trust**: Suppose one cohabitant acquires property but deems that both intended it to be shared. If one has contributed to its acquisition or maintenance, the other might argue for a constructive trust or resulting trust. Lafaye asks the court to recognize a Key Case Studies: *. **Arizona Supreme Court addressed how property and financial matters should be handled when an unmarried couple separates. It recognized that in the absence of a legal marriage, equitable doctrines (like unjust enrichment and potential implied contracts) could prevent one party from being unfairly enriched at the expense of the other. *. **Winer v. Winer, * P.3d * (Ariz. Ct. App. *)**: Although this case primarily addressed issues post-divorce, its considerations can analogically apply regarding equitable principles in property division situations. This case examined in detail the interests of parties in jointly used and developed assets. Key Case Studies: *. **Cook v. Cook, * Ariz. * (*)**: Arizona Supreme Court addressed how property and financial matters should be handled when an unmarried couple separates. It recognized that in the absence of a legal marriage, equitable doctrines (like unjust enrichment and potential implied contracts) could prevent one party from being unfairly enriched at the expense of the other. *. **Winer v. Winer, * P.3d * (Ariz. Ct. App. *)**: Although this case primarily addressed issues post-divorce, its considerations can analogically apply regarding the use of equitable principles in property division situations. This case examined the interests of parties in jointly used and developed assets. In summary, JURISDICTION AND VENUE This Court has jurisdiction over this matter under the relevant Arizona Revised Statutes: Cook v. Cook, * Ariz. *, * P.2d * (*) Carroll v. Lee, * Ariz. * (*) * P.2d * Marvin v. Marvin, * Cal. 3d *, * Cal. Rptr *, * P.2d * (*). While holding themselves out as husband and wife, she provided household services, and he would support her for life. “Homemaking, severable from the meretricious relationship, can support an implied agreement between two parties. FACTUAL BACKGROUND The plaintiff and Martin Ross cohabitated for *.5 years. The plaintiff’s extensive contributions to the defendant’s business, personal health care, and homemaking demonstrate an implied contract that she would be supported and share in the benefits accrued during their relationship. Wagenseller v. Scottsdale Memorial Hospital, * Ariz. *, * P.2d * (*) & Pyeatte v. Pyeatte, * Ariz *, * P.2d * (*) During this period, they acquired significant financial assets intended to be shared, establishing a shared interest (based on fairness) even if title and formal ownership are in one person’s name. The plaintiff contributed to the household, the defendant’s Mobile Body Tech LLC business, and his healthcare. Upon the dissolution of their relationship, the defendant retained the plaintiff’s personal property by obtaining a restraining order. CLAIMS FOR RELIEF Count I: Return of Personal Property or Compensation The plaintiff demands the return of her personal property or compensation equivalent to its value, as listed in Exhibit A. Count II: Constructive Trust The defendant breached the terms of the implied contract by engaging in misconduct/ cheating during their relationship. The plaintiff seeks the imposition of a constructive trust over the assets acquired during their cohabitation. She helped the defendant purchase the lot for an unbelievable price and helped him sell it at a fantastic profit. Exhibit C Valento v. Valento, * Ariz. *, * P.3d * (App. *) & Cook v. Cook, * Ariz. *, * P.2d * (*) Count III: Unjust Enrichment The plaintiff contributed significantly to acquiring and maintaining assets, including the property at * N. Locksley Dr (Exhibit C). Additionally, there were contributions to his business and personal care, and homemaking which have unjustly enriched the defendant. Murdock-Bryant Construction, Inc. v. Pearson * Ariz. * * P.2d * (*) The plaintiff demands *% of all financial acquisitions during their *.5 years of cohabitation as compensation for her contributions. REQUEST FOR PRO BONO PARTICIPATION The plaintiff respectfully requests to participate in the Pro Bono Program to assist in the litigation of this case. EVIDENCE Exhibit A: Itemized list of personal property. Exhibit B: Documentation of an implied contract. Exhibit C: Documentation related to the acquisition and sale of * N. Locksley Dr. Parks, Arizona. PRAYER FOR RELIEF WHEREFORE, the plaintiff respectfully requests that this Court: Order the defendant to return the plaintiff’s personal property or compensate her for its value. Impose a constructive trust over the assets acquired during the cohabitation. Award the plaintiff *% of the financial acquisitions during the *.5 years of cohabitation. Grant any other relief the Court deems just and proper. Deny the defendant's request for the plaintiff to pay his legal fees. Allow the plaintiff to participate in the Pro Bono Program. REQUESTS The plaintiff seeks a court order of all financial records including tax returns to separate personal and business assets to recover the cost of belongings and to determine the financial acquisitions during their cohabitation. IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF COCONINO Motion To Strike Julie Lafaye, c/o Miriam Jordan, Housing Solutions of Northern Arizona, PO Box *, Flagstaff, AZ *, (*) *-*, Julie Lafaye Plaintiff, vs. CV *-* Martin Ross / Mobile Body Tech LLC, Defendant Plaintiff's Response to Defendant’s Motion INTRODUCTION The plaintiff, Julie Lafaye, submits this Motion to strike against the defendants, Martin Ross and Mobile Body Tech LLC. The plaintiff filed this litigation in “Good Faith” and has provided relevant laws supporting her claims. She prioritized Ross’s health over her own, helped with his business and continues to pray for him. Wagenseller v. Scottsdale Memorial Hospital and Pyeatte v. Pyeatte *. **Contracts and Agreements**Arizona Bd. of Regents v. York RefrigerationCo., * Ariz.*, *, * P.2d *, * (*), and there is no difference in legal effect between an expressed contract and an implied contract. Swingle v. Myerson, * Ariz. App. *, *, * P.2d *, * I(*) An implied contract inferred by law as a matter of reason and justice from the acts and conduct of the parties and circumstances surrounding their transaction. Alexander v. O’Neil, * Ariz. *, *, 267P.2d *, * (*) Any Performance bargained for is consideration, and consideration need not be of like or identical value. *. Constructive Trust/Resulting Trust**: Suppose one cohabitant acquires property but deems that both intended it to be shared. If one has contributed to its acquisition or maintenance, the other might argue for a constructive trust or resulting trust. Lafaye asks the court to recognize a Key Case Studies: *. **Arizona Supreme Court addressed how property and financial matters should be handled when an unmarried couple separates. It recognized that in the absence of a legal marriage, equitable doctrines (like unjust enrichment and potential implied contracts) could prevent one party from being unfairly enriched at the expense of the other. *. **Winer v. Winer, * P.3d * (Ariz. Ct. App. *)**: Although this case primarily addressed issues post-divorce, its considerations can analogically apply regarding equitable principles in property division situations. This case examined in detail the interests of parties in jointly used and developed assets. Key Case Studies: *. **Cook v. Cook, * Ariz. * (*)**: Arizona Supreme Court addressed how property and financial matters should be handled when an unmarried couple separates. It recognized that in the absence of a legal marriage, equitable doctrines (like unjust enrichment and potential implied contracts) could prevent one party from being unfairly enriched at the expense of the other. *. **Winer v. Winer, * P.3d * (Ariz. Ct. App. *)**: Although this case primarily addressed issues post-divorce, its considerations can analogically apply regarding the use of equitable principles in property division situations. This case examined the interests of parties in jointly used and developed assets. In summary, JURISDICTION AND VENUE This Court has jurisdiction over this matter under the relevant Arizona Revised Statutes: Cook v. Cook, * Ariz. *, * P.2d * (*) Carroll v. Lee, * Ariz. * (*) * P.2d * Marvin v. Marvin, * Cal. 3d *, * Cal. Rptr *, * P.2d * (*). While holding themselves out as husband and wife, she provided household services, and he would support her for life. “Homemaking, severable from the meretricious relationship, can support an implied agreement between two parties. FACTUAL BACKGROUND The plaintiff and Martin Ross cohabitated for *.5 years. The plaintiff’s extensive contributions to the defendant’s business, personal health care, and homemaking demonstrate an implied contract that she would be supported and share in the benefits accrued during their relationship. Wagenseller v. Scottsdale Memorial Hospital, * Ariz. *, * P.2d * (*) & Pyeatte v. Pyeatte, * Ariz *, * P.2d * (*) During this period, they acquired significant financial assets intended to be shared, establishing a shared interest (based on fairness) even if title and formal ownership are in one person’s name. The plaintiff contributed to the household, the defendant’s Mobile Body Tech LLC business, and his healthcare. Upon the dissolution of their relationship, the defendant retained the plaintiff’s personal property by obtaining a restraining order. CLAIMS FOR RELIEF Count I: Return of Personal Property or Compensation The plaintiff demands the return of her personal property or compensation equivalent to its value, as listed in Exhibit A. Count II: Constructive Trust The defendant breached the terms of the implied contract by engaging in misconduct/ cheating during their relationship. The plaintiff seeks the imposition of a constructive trust over the assets acquired during their cohabitation. She helped the defendant purchase the lot for an unbelievable price and helped him sell it at a fantastic profit. Exhibit C Valento v. Valento, * Ariz. *, * P.3d * (App. *) & Cook v. Cook, * Ariz. *, * P.2d * (*) Count III: Unjust Enrichment The plaintiff contributed significantly to acquiring and maintaining assets, including the property at * N. Locksley Dr (Exhibit C). Additionally, there were contributions to his business and personal care, and homemaking which have unjustly enriched the defendant. Murdock-Bryant Construction, Inc. v. Pearson * Ariz. * * P.2d * (*) The plaintiff demands *% of all financial acquisitions during their *.5 years of cohabitation as compensation for her contributions. REQUEST FOR PRO BONO PARTICIPATION The plaintiff respectfully requests to participate in the Pro Bono Program to assist in the litigation of this case. EVIDENCE Exhibit A: Itemized list of personal property. Exhibit B: Documentation of an implied contract. Exhibit C: Documentation related to the acquisition and sale of * N. Locksley Dr. Parks, Arizona. PRAYER FOR RELIEF WHEREFORE, the plaintiff respectfully requests that this Court: Order the defendant to return the plaintiff’s personal property or compensate her for its value. Impose a constructive trust over the assets acquired during the cohabitation. Award the plaintiff *% of the financial acquisitions during the *.5 years of cohabitation. Grant any other relief the Court deems just and proper. Deny the defendant's request for the plaintiff to pay his legal fees. Allow the plaintiff to participate in the Pro Bono Program. REQUESTS The plaintiff seeks a court order of all financial records including tax returns to separate personal and business assets to recover the cost of belongings and to determine the financial acquisitions during their cohabitation.