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STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
WAKE COUNTY SUPERIOR COURT DIVISION
24CV015927-910
BILLY STEVE MYRICK, JR., )
Plaintiff, )
COMPLAINT
Jury Trial Demanded
Vv.
CHRISTOPHER JOHN BLONK, )
Defendant.
Plaintiff, complaining of Defendant, alleges and says:
FIRST CLAIM OF RELIEF ALIENATION OF AFFECTIONS
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1. Plaintiff is a resident of Wake County, North Carolina, and has been a
resident of North Carolina for more than six months prior to the filing of this
Complaint.
2. Defendant is a resident of Wake County, North Carolina.
3. The acts complained of herein took place in North Carolina.
A. On May 9, 1992, Plaintiff married Michelle Massey Myrick (Ms. Myrick)
thereafter, Plaintiff and Ms. Myrick lived continuously together as husband and wife
until their date of separation, April 1, 2022. Plaintiff and Ms. Myrick were divorced
on May 3, 2024. Two children were born of the marriage of Plaintiff and Ms. Myrick.
5. Plaintiff and Ms. Myrick had a good and loving marriage with genuine
love and affection existing between them.
6. As a direct result of the Defendant's actions, an almost thirty (80) year
marriage was destroyed which has devasted, distraught, humiliated, depressed and
caused the Plaintiff to suffer emotional pain and distress.
7. During the marriage of Plaintiff and Ms. Myrick, Defendant began
pursuing a romantic and sexual relationship with Ms. Myrick to the detriment of the
loving marriage that existed. By way of example:
a. The parties enjoyed romantic getaways together. In fact, Plaintiff had
taken Ms. Myrick to a hotel in Winston-Salem, North Carolina and took
her to dine at the most affluent Italian restaurant in town. During this
time, Plaintiff was unaware of Defendant's blatant seduction of Ms.
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El
ectroni
cal
lyFi
led Date:5/21/2024 10:01 AM W ake CountyCl
erkofSuperi
orCourt
Myrick had begun. Because of Defendant's influence, Ms. Myrick was
distant and not interested in enjoying the Plaintiffs companionship
because she was distracted by Defendant's influence.
b. Up until Defendant's introduction to Ms. Myrick, the parties enjoyed a
loving and robust sexual relationship.
c. The parties enjoyed their grandson and caring for them together.
d. The parties were planning for retirement and had purchased a beach
house so that when the time came, they could reside at the Crystal
Coast.
8. Defendant willfully sought to seduce, entice, and alienate the love and
affection of Ms. Myrick from Plaintiff, even though Defendant was fully aware of the
marriage between Plaintiff and Ms. Myrick.
9. Defendant is a friend of the Plaintiffs sister and his brother-in-law.
10. Ms. Myrick would visit her sister-in-law (Plaintiffs sister) and her
husband and attend parties with them on a regular basis.
11. Defendant also attended these parties and would flirt and drink to
excess with Ms. Myrick.
12. Prior to April 1, 2022, Defendant encouraged Ms. Myrick to attend
parties without the Plaintiff, would get Ms. Myrick drunk and sexually entice Ms.
Myrick. On one occasion, Defendant escorted Ms. Myrick outside the residence where
the party was held and performed various sexual acts on Ms. Myrick, including but
not limited to sexual intercourse.
13. Defendant and Ms. Myrick engaged in a romantic relationship as a
result of Defendant's actions.
14. Defendant and Ms. Myrick engaged in a sexual relationship as a result
of Defendant's actions.
15. Prior to April 1, 2022, Defendant invited Ms. Myrick to his home during
the early morning hours to engage in sexual relations.
16. Prior to April 1, 2022, Defendant and Ms. Myrick engaged in sexual
intercourse.
17. Prior to April 1, 2022, Defendant and Ms. Myrick engaged in sexual
intercourse in North Carolina.
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18. Ms. Myrick has admitted to the Plaintiff that she engaged in sexual
intercourse and engaged in a romantic relationship with the Defendant in North
Carolina prior to April 1, 2022.
19. Ms. Myrick has admitted to the Plaintiff that she engaged in sexual
intercourse with other third parties in North Carolina prior to April 1, 2022.
20. Defendant's sexual and romantic relationship with Ms. Myrick has
continued through the date on which this Complaint is executed, upon information
and belief.
21. Upon information and belief, while Plaintiff and Ms. Myrick were still
living together and husband and wife in their marital residence, Defendant
repeatedly contacted Ms. Myrick for the purpose of perpetuating a romantic and
sexual relationship with Ms. Myrick.
22. Defendant alienated the love and affection of Ms. Myrick from Plaintiff
and deprived Plaintiff of companionship, financial consortium, financial contribution,
assistance, love, and society of his wife.
23. Defendant was the proximate cause of the deterioration and ultimate
destruction of Plaintiffs marriage.
24. Upon information and belief, Defendant enticed and encouraged Ms.
Myrick to leave and seek divorce from Plaintiff.
25. Defendant's actions intentionally cultivated and developed an emotional
relationship with Ms. Myrick, all while knowing that Ms. Myrick was married to
Plaintiff and residing with Plaintiff in the marital residence.
26. Defendant's actions enticed Ms. Myrick to constructively and actually
abandon Plaintiff for the purpose of continuing his romantic relationship with Ms.
Myrick.
27. Defendant's actions were willful, wanton, and malicious. Defendant
deliberately set out to destroy Plaintiffs relationship with his wife and/or he acted
with reckless disregard for Plaintiffs marriage.
28. While pursuing Ms. Myrick romantically and sexually, Defendant knew
that Ms. Myrick was married to Plaintiff.
29. Defendant's actions have wantonly, wrongfully, and maliciously
deprived Plaintiff of his wife's love and attention and have injured and destroyed the
marital relationship that previously existed between Plaintiff and his wife.
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30. Despite the best efforts of Plaintiff, Plaintiff was unable to reconcile the
marriage during the entire period that Defendant openly and willfully pursued his
wife. Defendant's actions have caused permanent and irreconcilable damage to the
marriage of Plaintiff and Ms. Myrick.
31. Defendant, both openly and clandestinely, wrongfully and maliciously
attempted to injure and did injure Plaintiff and the marital relationship existing
between Plaintiff and Ms. Myrick and attempted to alienate and did alienate the
affections of Plaintiffs wife from Plaintiff.
32. Plaintiff has suffered economic and emotional damage due to
Defendant's wrongful interference in Plaintiffs marital relationship.
33. Asa result of Defendant's acts, the genuine love and affection which
previously existed between Plaintiff and Ms. Myrick was alienated and destroyed. In
addition, Plaintiff has been wrongfully deprived of the company, affections,
consortium, society, love, assistance, and services of his spouse, has suffered loss of
support, injury to his feelings and reputation, and has had his marital relationship
destroyed. Moreover, Plaintiff has suffered great mental and emotional anguish and
humiliation.
34. Defendant's actions have resulted in Plaintiff suffering substantial
economic damages. Defendant's actions caused and continue to cause Plaintiff to
suffer great mental anguish, humiliation, injury to his emotional health and loss of
assistance and financial support of his spouse.
35. Plaintiffs actual and compensatory damages are in excess of $25,000 as
a result of Defendant's alienation of affections of Plaintiffs wife. Plaintiffis entitled
to receive an award of actual and compensatory damages in an amount to be
determined at trial, but in no event less than $25,000.
SECOND CLAIM FOR RELIEF PUNITIVE DAMAGES FOR ALIENATION
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OF AFFECTIONS
36. The allegations contained in Paragraphs 1 through 35 above are
incorporated herein by reference as if fully set forth.
37. Defendant's actions are willful, aggravated, intentional, wanton,
malicious, and in reckless disregard of the rights of Plaintiff and with knowledge that
Plaintiff would be greatly distressed and humiliated thereby. Plaintiff is entitled to
receive an award of punitive damages in an amount to be determined at trial, but in
no event less than $25,000, on account of the aforesaid alienation of affections by
Defendant.
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THIRD CLAIM OF RELIEF CRIMINAL CONVERSATION
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38. The allegations contained in Paragraphs 1 through 37 above are
incorporated herein by reference as if fully set forth.
39. During the course of Plaintiffs marriage to Ms. Myrick and prior to April
1, 2022, Defendant engaged in sexual intercourse with Ms. Myrick in North Carolina.
40. The exclusive rights and privileges of the Plaintiffs marriage were
invaded by Defendant and Plaintiff suffered shame and embarrassment caused by
the loss of the affection of his spouse and the disgrace of the acts described herein.
41. The marital bed was dishonored, domestic comfort, was destroyed, and
the right to conjugal fellowship of the Plaintiff's spouse and her company, cooperation,
and aid were substantially and actually destroyed, damaged, and lost as a result of
Defendant's actions.
42. Plaintiffs mental anguish, humiliation, embarrassment, emotional
turmoil, and injury are ongoing in nature resulting in continued damage and injury.
43. Plaintiffs actual and compensatory damages are in excess of $25,000 as
a result of Defendant's criminal conversation with Plaintiffs wife. Plaintiffis entitled
to receive an award of actual and compensatory damages in an amount to be
determined at trial, but in no event less than $25,000.
FOURTH CLAIM FOR RELIEF PUNITIVE DAMAGES FOR CRIMINAL
CONVERSATION
44, The allegations contained in Paragraphs 1 through 43 above are
incorporated herein by reference as if fully set forth.
45. Defendant's actions are willful, aggravated, intentional, wanton,
malicious, and in reckless disregard of the rights of Plaintiff and with knowledge that
Plaintiff would be greatly distressed and humiliated thereby. Plaintiff is entitled to
receive an award of punitive damages in an amount to be determined at trial, but in
no event less than $25,000, on account of the aforesaid criminal conversation by
Defendant with Ms. Myrick.
FIFTH CLAIM OF RELIEF INTENTIONAL INFLICTION OF EMOTIONAL
-
DISTRESS
46. The allegations contained in Paragraphs 1 through 45 above are
incorporated herein by reference as if fully set forth.
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47. The acts of Defendant were willful and intentional and amounted to
extreme and outrageous conduct, exceeding all bounds tolerated by decent society.
48. Defendant's actions were intended to cause severe emotional distress to
Plaintiff.
49. Plaintiffhas suffered severe emotional distress by reason of Defendant's
actions.
50. On account of the aforesaid intentional infliction of emotional distress
upon Plaintiff, Plaintiff is entitled to have and recover compensatory damages in an
amount in excess of Twenty-Five Thousand Dollars ($25,000).
SIXTH CLAIM FOR RELIEF PUNITIVE DAMAGES FOR INTENTIONAL
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INFLICTION OF EMOTIONAL DISTRESS
51. The allegations contained in Paragraphs 1 through 50 above are
incorporated herein by reference as if fully set forth.
52. The actions of Defendant in intentionally inflicting emotional distress
upon Plaintiff were willful, aggravated, malicious, wanton, intentional, malicious,
and in reckless disregard for the rights of Plaintiff and entitle Plaintiff to punitive
damages in an amount in excess of Twenty-Five Thousand Dollars ($25,000).
WHEREFORE, Plaintiff respectfully requests that the Court:
1. Award Plaintiff actual and compensatory damages in an amount in
excess of $25,000 for alienation of affection;
2. Award Plaintiff actual and compensatory damages in an amount in
excess of $25,000 for criminal conversation;
3. Award Plaintiff actual and compensatory damages in an amount in
excess of $25,000 for intentional infliction of emotional distress upon Plaintiff;
4, Award Plaintiff punitive damages in excess of $25,000;
5. Allow a jury trial on all issues so triable;
5. Tax the cost of this action, including attorney's fees to the extent allowed
by law, to Defendant; and
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STATE OF NORTH CAROLINA
COUNTY OF WAKE VERIFICATION
I, BILLY STEVE MYRICK, JR., being first duly sworn, deposes and says
that I am the plaintiff in this action; that I have read the foregoing Complaint and
that the same is true of my own knowledge, except as to those matters and things
therein stated upon information and belief, and as to those I believe them to be true.
BILLY STEVE MYRICK, JR.
STATE OF NORTH CAROLINA
COUNTY OF WAKE
I certify that BILLY STEVE MYRICK, JR. personally appeared before me this day,
and I have seen satisfactory evidence of the principal's identify, by a current state or
federal identification with the principal's photograph in the for of a
; acknowledging to me that he voluntarily signed the foregoing
document for the purpose stated therein, the capacity indicated.
Date :
Official Sfgnature
¢ Notaty--__
of
yA Du Bree.
Notary's printed or typed name, Natary Public
(Official Seal) My commission expires:
SION Exp,
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6 Grant unto Plaintiff such other and further relief as the Court deems just
and proper.
This the (sr day of .2024.
THARRINGTON SMITH, L.L.P.
By:
Sonya E. DuBree (NCSB# 20928)
Post Office Box 1151
Raleigh, North Carolina 27602-1151
Telephone: (919) 821-4711
Facsimile: (919) 829-1583
Attorney for Plaintiff
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STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE WAKE COUNTY SUPERIOR COURT DIVISION 24CV015927-910 BILLY STEVE MYRICK, JR., ) Plaintiff, ) COMPLAINT Jury Trial Demanded Vv. CHRISTOPHER JOHN BLONK, ) Defendant. Plaintiff, complaining of Defendant, alleges and says: FIRST CLAIM OF RELIEF ALIENATION OF AFFECTIONS - 1. Plaintiff is a resident of Wake County, North Carolina, and has been a resident of North Carolina for more than six months prior to the filing of this Complaint. 2. Defendant is a resident of Wake County, North Carolina. 3. The acts complained of herein took place in North Carolina. A. On May 9, 1992, Plaintiff married Michelle Massey Myrick (Ms. Myrick) thereafter, Plaintiff and Ms. Myrick lived continuously together as husband and wife until their date of separation, April 1, 2022. Plaintiff and Ms. Myrick were divorced on May 3, 2024. Two children were born of the marriage of Plaintiff and Ms. Myrick. 5. Plaintiff and Ms. Myrick had a good and loving marriage with genuine love and affection existing between them. 6. As a direct result of the Defendant's actions, an almost thirty (80) year marriage was destroyed which has devasted, distraught, humiliated, depressed and caused the Plaintiff to suffer emotional pain and distress. 7. During the marriage of Plaintiff and Ms. Myrick, Defendant began pursuing a romantic and sexual relationship with Ms. Myrick to the detriment of the loving marriage that existed. By way of example: a. The parties enjoyed romantic getaways together. In fact, Plaintiff had taken Ms. Myrick to a hotel in Winston-Salem, North Carolina and took her to dine at the most affluent Italian restaurant in town. During this time, Plaintiff was unaware of Defendant's blatant seduction of Ms. 1 El ectroni cal lyFi led Date:5/21/2024 10:01 AM W ake CountyCl erkofSuperi orCourt Myrick had begun. Because of Defendant's influence, Ms. Myrick was distant and not interested in enjoying the Plaintiffs companionship because she was distracted by Defendant's influence. b. Up until Defendant's introduction to Ms. Myrick, the parties enjoyed a loving and robust sexual relationship. c. The parties enjoyed their grandson and caring for them together. d. The parties were planning for retirement and had purchased a beach house so that when the time came, they could reside at the Crystal Coast. 8. Defendant willfully sought to seduce, entice, and alienate the love and affection of Ms. Myrick from Plaintiff, even though Defendant was fully aware of the marriage between Plaintiff and Ms. Myrick. 9. Defendant is a friend of the Plaintiffs sister and his brother-in-law. 10. Ms. Myrick would visit her sister-in-law (Plaintiffs sister) and her husband and attend parties with them on a regular basis. 11. Defendant also attended these parties and would flirt and drink to excess with Ms. Myrick. 12. Prior to April 1, 2022, Defendant encouraged Ms. Myrick to attend parties without the Plaintiff, would get Ms. Myrick drunk and sexually entice Ms. Myrick. On one occasion, Defendant escorted Ms. Myrick outside the residence where the party was held and performed various sexual acts on Ms. Myrick, including but not limited to sexual intercourse. 13. Defendant and Ms. Myrick engaged in a romantic relationship as a result of Defendant's actions. 14. Defendant and Ms. Myrick engaged in a sexual relationship as a result of Defendant's actions. 15. Prior to April 1, 2022, Defendant invited Ms. Myrick to his home during the early morning hours to engage in sexual relations. 16. Prior to April 1, 2022, Defendant and Ms. Myrick engaged in sexual intercourse. 17. Prior to April 1, 2022, Defendant and Ms. Myrick engaged in sexual intercourse in North Carolina. 2 18. Ms. Myrick has admitted to the Plaintiff that she engaged in sexual intercourse and engaged in a romantic relationship with the Defendant in North Carolina prior to April 1, 2022. 19. Ms. Myrick has admitted to the Plaintiff that she engaged in sexual intercourse with other third parties in North Carolina prior to April 1, 2022. 20. Defendant's sexual and romantic relationship with Ms. Myrick has continued through the date on which this Complaint is executed, upon information and belief. 21. Upon information and belief, while Plaintiff and Ms. Myrick were still living together and husband and wife in their marital residence, Defendant repeatedly contacted Ms. Myrick for the purpose of perpetuating a romantic and sexual relationship with Ms. Myrick. 22. Defendant alienated the love and affection of Ms. Myrick from Plaintiff and deprived Plaintiff of companionship, financial consortium, financial contribution, assistance, love, and society of his wife. 23. Defendant was the proximate cause of the deterioration and ultimate destruction of Plaintiffs marriage. 24. Upon information and belief, Defendant enticed and encouraged Ms. Myrick to leave and seek divorce from Plaintiff. 25. Defendant's actions intentionally cultivated and developed an emotional relationship with Ms. Myrick, all while knowing that Ms. Myrick was married to Plaintiff and residing with Plaintiff in the marital residence. 26. Defendant's actions enticed Ms. Myrick to constructively and actually abandon Plaintiff for the purpose of continuing his romantic relationship with Ms. Myrick. 27. Defendant's actions were willful, wanton, and malicious. Defendant deliberately set out to destroy Plaintiffs relationship with his wife and/or he acted with reckless disregard for Plaintiffs marriage. 28. While pursuing Ms. Myrick romantically and sexually, Defendant knew that Ms. Myrick was married to Plaintiff. 29. Defendant's actions have wantonly, wrongfully, and maliciously deprived Plaintiff of his wife's love and attention and have injured and destroyed the marital relationship that previously existed between Plaintiff and his wife. 3 30. Despite the best efforts of Plaintiff, Plaintiff was unable to reconcile the marriage during the entire period that Defendant openly and willfully pursued his wife. Defendant's actions have caused permanent and irreconcilable damage to the marriage of Plaintiff and Ms. Myrick. 31. Defendant, both openly and clandestinely, wrongfully and maliciously attempted to injure and did injure Plaintiff and the marital relationship existing between Plaintiff and Ms. Myrick and attempted to alienate and did alienate the affections of Plaintiffs wife from Plaintiff. 32. Plaintiff has suffered economic and emotional damage due to Defendant's wrongful interference in Plaintiffs marital relationship. 33. Asa result of Defendant's acts, the genuine love and affection which previously existed between Plaintiff and Ms. Myrick was alienated and destroyed. In addition, Plaintiff has been wrongfully deprived of the company, affections, consortium, society, love, assistance, and services of his spouse, has suffered loss of support, injury to his feelings and reputation, and has had his marital relationship destroyed. Moreover, Plaintiff has suffered great mental and emotional anguish and humiliation. 34. Defendant's actions have resulted in Plaintiff suffering substantial economic damages. Defendant's actions caused and continue to cause Plaintiff to suffer great mental anguish, humiliation, injury to his emotional health and loss of assistance and financial support of his spouse. 35. Plaintiffs actual and compensatory damages are in excess of $25,000 as a result of Defendant's alienation of affections of Plaintiffs wife. Plaintiffis entitled to receive an award of actual and compensatory damages in an amount to be determined at trial, but in no event less than $25,000. SECOND CLAIM FOR RELIEF PUNITIVE DAMAGES FOR ALIENATION - OF AFFECTIONS 36. The allegations contained in Paragraphs 1 through 35 above are incorporated herein by reference as if fully set forth. 37. Defendant's actions are willful, aggravated, intentional, wanton, malicious, and in reckless disregard of the rights of Plaintiff and with knowledge that Plaintiff would be greatly distressed and humiliated thereby. Plaintiff is entitled to receive an award of punitive damages in an amount to be determined at trial, but in no event less than $25,000, on account of the aforesaid alienation of affections by Defendant. 4 THIRD CLAIM OF RELIEF CRIMINAL CONVERSATION - 38. The allegations contained in Paragraphs 1 through 37 above are incorporated herein by reference as if fully set forth. 39. During the course of Plaintiffs marriage to Ms. Myrick and prior to April 1, 2022, Defendant engaged in sexual intercourse with Ms. Myrick in North Carolina. 40. The exclusive rights and privileges of the Plaintiffs marriage were invaded by Defendant and Plaintiff suffered shame and embarrassment caused by the loss of the affection of his spouse and the disgrace of the acts described herein. 41. The marital bed was dishonored, domestic comfort, was destroyed, and the right to conjugal fellowship of the Plaintiff's spouse and her company, cooperation, and aid were substantially and actually destroyed, damaged, and lost as a result of Defendant's actions. 42. Plaintiffs mental anguish, humiliation, embarrassment, emotional turmoil, and injury are ongoing in nature resulting in continued damage and injury. 43. Plaintiffs actual and compensatory damages are in excess of $25,000 as a result of Defendant's criminal conversation with Plaintiffs wife. Plaintiffis entitled to receive an award of actual and compensatory damages in an amount to be determined at trial, but in no event less than $25,000. FOURTH CLAIM FOR RELIEF PUNITIVE DAMAGES FOR CRIMINAL CONVERSATION 44, The allegations contained in Paragraphs 1 through 43 above are incorporated herein by reference as if fully set forth. 45. Defendant's actions are willful, aggravated, intentional, wanton, malicious, and in reckless disregard of the rights of Plaintiff and with knowledge that Plaintiff would be greatly distressed and humiliated thereby. Plaintiff is entitled to receive an award of punitive damages in an amount to be determined at trial, but in no event less than $25,000, on account of the aforesaid criminal conversation by Defendant with Ms. Myrick. FIFTH CLAIM OF RELIEF INTENTIONAL INFLICTION OF EMOTIONAL - DISTRESS 46. The allegations contained in Paragraphs 1 through 45 above are incorporated herein by reference as if fully set forth. 5 47. The acts of Defendant were willful and intentional and amounted to extreme and outrageous conduct, exceeding all bounds tolerated by decent society. 48. Defendant's actions were intended to cause severe emotional distress to Plaintiff. 49. Plaintiffhas suffered severe emotional distress by reason of Defendant's actions. 50. On account of the aforesaid intentional infliction of emotional distress upon Plaintiff, Plaintiff is entitled to have and recover compensatory damages in an amount in excess of Twenty-Five Thousand Dollars ($25,000). SIXTH CLAIM FOR RELIEF PUNITIVE DAMAGES FOR INTENTIONAL - INFLICTION OF EMOTIONAL DISTRESS 51. The allegations contained in Paragraphs 1 through 50 above are incorporated herein by reference as if fully set forth. 52. The actions of Defendant in intentionally inflicting emotional distress upon Plaintiff were willful, aggravated, malicious, wanton, intentional, malicious, and in reckless disregard for the rights of Plaintiff and entitle Plaintiff to punitive damages in an amount in excess of Twenty-Five Thousand Dollars ($25,000). WHEREFORE, Plaintiff respectfully requests that the Court: 1. Award Plaintiff actual and compensatory damages in an amount in excess of $25,000 for alienation of affection; 2. Award Plaintiff actual and compensatory damages in an amount in excess of $25,000 for criminal conversation; 3. Award Plaintiff actual and compensatory damages in an amount in excess of $25,000 for intentional infliction of emotional distress upon Plaintiff; 4, Award Plaintiff punitive damages in excess of $25,000; 5. Allow a jury trial on all issues so triable; 5. Tax the cost of this action, including attorney's fees to the extent allowed by law, to Defendant; and 6 STATE OF NORTH CAROLINA COUNTY OF WAKE VERIFICATION I, BILLY STEVE MYRICK, JR., being first duly sworn, deposes and says that I am the plaintiff in this action; that I have read the foregoing Complaint and that the same is true of my own knowledge, except as to those matters and things therein stated upon information and belief, and as to those I believe them to be true. BILLY STEVE MYRICK, JR. STATE OF NORTH CAROLINA COUNTY OF WAKE I certify that BILLY STEVE MYRICK, JR. personally appeared before me this day, and I have seen satisfactory evidence of the principal's identify, by a current state or federal identification with the principal's photograph in the for of a ; acknowledging to me that he voluntarily signed the foregoing document for the purpose stated therein, the capacity indicated. Date : Official Sfgnature ¢ Notaty--__ of yA Du Bree. Notary's printed or typed name, Natary Public (Official Seal) My commission expires: SION Exp, 8 6 Grant unto Plaintiff such other and further relief as the Court deems just and proper. This the (sr day of .2024. THARRINGTON SMITH, L.L.P. By: Sonya E. DuBree (NCSB# 20928) Post Office Box 1151 Raleigh, North Carolina 27602-1151 Telephone: (919) 821-4711 Facsimile: (919) 829-1583 Attorney for Plaintiff 7