IN THE DISTRICT COURT

ELEVENTH JUDICIAL DISTRICT

FLATHEAD COUNTY, STATE OF MONTANA

ROBERT SAVOIE
Plaintiff,

v.

THE BANK OF NOVA SCOTIA;
JEAN-SÉBASTIEN PERREAULT;
AMHERST CHRYSLER (1999) LIMITED;
MIKE ALLEN;
JOHN RICHARD;
CTS TOM WOOD;
TOWN OF AMHERST, NOVA SCOTIA;

Defendants.

COMPLAINT AND DEMAND FOR JURY TRIAL

Amount in Controversy: $17,500,000 USD

Plaintiff ROBERT SAVOIE, appearing pro se, alleges as follows:

I. PARTIES

1. Plaintiff ROBERT SAVOIE is an entrepreneur and business operator with business interests connected to the State of Montana, United States. Plaintiff maintains a legal address at 1001 S. Main St., Suite 11519, Kalispell, Montana 59901.

2. Plaintiff owns and operates companies connected to the State of Montana.

3. As a result of the actions described in this Complaint and the resulting cancellation of Plaintiff’s passport, Plaintiff has been unable to return to Montana to reside there and manage his business operations for more than 1013 days and continuing.

4. Defendant The Bank of Nova Scotia (“Scotiabank”) is an international banking institution operating throughout North America.

5. Defendant Jean-Sébastien Perreault was at all relevant times employed by Scotiabank and acted within the scope of his employment as a fraud investigator or representative of the bank.

6. Defendant Amherst Chrysler (1999) Limited is an automobile dealership located in Amherst, Nova Scotia, Canada.

7. Defendant Mike Allen is the Owner and President of Amherst Chrysler and participated in communications and statements concerning Plaintiff.

8. Defendant John Richard is an employee or representative of Amherst Chrysler who participated in communications and statements concerning Plaintiff.

9. Defendant Constable Tom Wood was at all relevant times a police officer employed by the Amherst Police Department in Amherst, Nova Scotia, Canada.

10. Defendant Town of Amherst, Nova Scotia is a municipal corporation organized under the laws of the Province of Nova Scotia and operates and supervises the Amherst Police Department.

II. JURISDICTION AND VENUE

11. This Court has jurisdiction because Defendants’ conduct caused substantial economic and reputational harm affecting the Plaintiff’s business interests connected to the State of Montana.

12. At all relevant times, the Plaintiff maintained business interests and corporate activities connected to Montana, including a legal address located in Kalispell, Montana.

13. Defendants knew or reasonably should have known that their actions would interfere with the Plaintiff’s ability to conduct business activities connected to the United States and the State of Montana.

14. Defendants’ conduct was intentional and created foreseeable cross-border consequences affecting the Plaintiff’s ability to conduct business and manage his Montana-based business interests.

15. Venue is proper in this Court because the Plaintiff maintains business interests connected to Montana and suffered economic harm affecting those interests within this judicial district.

III. DISCOVERY DATE

16. Plaintiff discovered the misconduct underlying this action on or about November 20, 2024.

17. On that date Plaintiff received criminal disclosure materials after approximately 520 days of delay following repeated requests.

18. The disclosure materials revealed the factual basis of the accusations and the role played by Defendants in promoting or repeating false allegations.

19. Prior to that date Plaintiff did not possess sufficient information to fully understand the nature of the accusations or the involvement of the Defendants.

IV. SUMMARY TIMELINE OF EVENTS

1. August 2018 – Plaintiff purchased a 2018 Jeep Wrangler through a financing agreement approved by The Bank of Nova Scotia at Amherst Chrysler (1999) Limited.
2. 2018–2019 – The transaction proceeded normally, and Plaintiff continued his business activities connected to aviation and maritime brokerage operations.
3. 2020 – A civil repossession dispute later arose concerning the vehicle.
4. Rather than resolving the matter through ordinary civil procedures, Defendants began promoting allegations that Plaintiff had engaged in fraud and other criminal conduct.
5. These allegations were communicated to third parties including law enforcement authorities.
6. The civil dispute was transformed into criminal accusations.
7. As a result of this chain of events, Plaintiff’s Canadian passport was cancelled, preventing Plaintiff from traveling and managing business interests connected to the State of Montana.
8. Plaintiff did not obtain full disclosure concerning the basis of these allegations until November 20, 2024, approximately 520 days after repeated requests.
9. The disclosure revealed the extent to which Defendants promoted or repeated allegations that were exaggerated, unsupported, or false.

V. FACTUAL BACKGROUND

20. In August 2018 Plaintiff entered into a vehicle financing agreement for a 2018 Jeep Wrangler through Scotiabank at Amherst Chrysler.

21. Plaintiff provided truthful and lawful information during the financing transaction.

22. The vehicle later became the subject of a civil repossession dispute.

23. The dispute was civil in nature.

24. Despite this, Defendants characterized the situation as an allegation of false pretence, transforming a civil dispute into a criminal accusation.

25. Defendant Jean-Sébastien Perreault communicated accusations concerning Plaintiff to third parties.

26. These accusations included allegations that Plaintiff committed fraud, used aliases, and engaged in criminal conduct.

27. These allegations were false and made with reckless disregard for the truth.

28. The accusations were communicated to law-enforcement authorities and other parties.

29. As a result, the dispute escalated from a civil matter into criminal accusations.

30. These accusations triggered severe consequences affecting Plaintiff’s personal and professional life.

31. One consequence of this chain of events was the cancellation of Plaintiff’s Canadian passport.

32. As a direct consequence of the passport cancellation for more than 1013 days and continuing, Plaintiff has been unable to travel to the United States to manage his Montana-based business interests.

33. Plaintiff has suffered substantial financial losses and disruption of business opportunities.

Background of Plaintiff’s Business Activities

At all relevant times, Plaintiff ROBERT SAVOIE was engaged in international business activities related to aviation, yacht brokerage, and specialized transportation services.

Plaintiff was associated with and working for Bermuda Yacht and Sailboat Asset Management Ltd, an entity involved in maritime and aviation-related business activities. Plaintiff was also connected to Air Bermuda Inc., a corporate entity with a long-standing corporate presence.

Air Bermuda Inc. originated as 155175 Canada Inc., a corporation incorporated federally in Canada on April 9, 1987 under the Canada Business Corporations Act. The corporation later adopted the name Air Bermuda Inc. on May 15, 2008. The corporation remains active and in good standing under federal Canadian corporate records (Corporation No. 217874-5).

Air Bermuda Inc. was also registered in the Province of Quebec under the Quebec Enterprise Registry (NEQ 1165108185) on April 16, 2008. Corporate filings confirm that the company has maintained official registrations and corporate filings over time.

The Air Bermuda business identity has also been publicly identifiable through corporate registry records and an online presence, including the domain airbermuda.ca.

In addition to its Canadian corporate presence, related aviation-related corporate activities connected to Plaintiff have existed in the United States, including:

Air Bermuda Inc. (Montana)
Domestic Profit Corporation
Filing Number: D1408419
Status: Active – Good Standing
Registration Date: December 21, 2023
Principal Address:
1001 South Main Street, Suite 49
Kalispell, Montana 59901

Air Bermuda Inc. (Hawaii)
Domestic Profit Corporation
File Number: 252839 D1
Registration Date: August 25, 2015
Principal Address:
95-390 Kuahelani Ave, Suite 3AC – Unit #5011
Mililani, Hawaii 96789

These corporate registrations demonstrate that the Air Bermuda business identity has existed across multiple jurisdictions over time, including Canada and the United States.

Vehicle Transaction and Financing Application

During the purchase of a vehicle at Amherst Chrysler (1999) Limited, Plaintiff provided information relating to his employment and business activities as part of the financing application submitted to The Bank of Nova Scotia (Scotiabank).

The information used for the financing application was collected directly by dealership employee Jessica Allen, who handled the transaction and gathered Plaintiff’s information for submission to the lender.

At the time the information was collected and transmitted to the lender, the transaction proceeded normally and without objection.

Absence of Fraud Concerns at the Time of the Transaction

At no point during the vehicle purchase process did Ms. Jessica Allen inform Plaintiff that any information provided was false or problematic. To Plaintiff’s knowledge, Ms. Allen never communicated that The Bank of Nova Scotia had raised any concern, suspicion, or allegation of fraud relating to the financing application.

The financing process moved forward in the ordinary course of business, and the transaction was completed without any indication that the lender or dealership believed the information provided by Plaintiff was improper.

Subsequent Events

Plaintiff later became aware that allegations were raised in connection with financing applications associated with another individual, René Marier, which occurred after Plaintiff’s own transaction. Plaintiff disputes any suggestion that differences between separate applications involving different individuals establish that Plaintiff provided false information in connection with his own financing application.

False Allegations and Resulting Harm

Despite the existence of legitimate corporate entities connected to Plaintiff’s aviation and maritime business activities, Defendants later made or relied upon allegations suggesting that Plaintiff’s employment and business information was false or misleading.

These allegations were based on comparisons between separate financing applications and other documents that were unrelated to Plaintiff’s transaction and involved different individuals and circumstances. In particular, certain statements relied upon applications associated with another individual, René Marier, which occurred after Plaintiff’s own transaction and did not accurately reflect Plaintiff’s business activities or employment at the time of the vehicle purchase.

Defendants nevertheless treated these unrelated discrepancies as evidence of wrongdoing by Plaintiff.

At the time of Plaintiff’s vehicle transaction, the financing application had been processed through the ordinary course of business by Amherst Chrysler (1999) Limited and submitted to The Bank of Nova Scotia, which reviewed and approved the financing. No fraud concern was raised by the dealership or the bank during the transaction or after the transaction.

Despite this, Defendants later characterized the situation as involving false or misleading information relating to Plaintiff’s.

These accusations were damaging to Plaintiff because they suggested that Plaintiff’s business activities were illegitimate when in fact Plaintiff had long-standing corporate entities involved in aviation and related services operating across multiple jurisdictions.

Damage to Plaintiff

As a direct and proximate result of Defendants’ actions and statements, Plaintiff suffered substantial harm including:

• damage to Plaintiff’s professional reputation
• interference with Plaintiff’s business activities and international ventures
• disruption of financial and commercial relationships
• significant emotional distress and personal hardship
• economic damages including lost opportunities connected to aviation and charter-related business activities

Defendants’ conduct created a false impression that Plaintiff’s corporate activities and employment information were fraudulent when in fact Plaintiff was engaged in legitimate business activities through registered corporate entities.

EXPANDED ALLEGATIONS CONCERNING SCOTIABANK AND JEAN-SÉBASTIEN PERREAULT

Role of Scotiabank and Its Fraud Investigator

At all material times, Defendant Jean-Sébastien Perreault was acting as a fraud investigator and representative of The Bank of Nova Scotia (Scotiabank) and was acting within the scope of his employment and authority.

Defendants’ statements accusing Plaintiff of fraud and criminal conduct constitute defamation per se because they falsely accuse Plaintiff of criminal activity.

As such, Scotiabank is vicariously liable for the acts, statements, and conduct of Perreault.

Origin of the Civil Dispute

In August 2018, the Plaintiff entered into a financing agreement with Scotiabank through Amherst Chrysler (1999) Limited for the purchase of a 2018 Jeep Wrangler.

The transaction was a standard consumer vehicle financing agreement.

At the time of the transaction:

• the Plaintiff held a valid driver's licence
• the Plaintiff provided accurate personal information
• the financing agreement was approved by Scotiabank through its normal lending procedures.

Escalation of a Civil Matter

In 2020 a civil repossession dispute arose concerning the vehicle.

Rather than addressing the matter as a civil contractual issue, representatives of Scotiabank began promoting a narrative that the Plaintiff had engaged in fraudulent conduct.

The Plaintiff pleads that Defendant Jean-Sébastien Perreault played a central role in promoting and communicating this narrative.

False Statements Communicated by Perreault

Perreault communicated statements to third parties suggesting that:

• the Plaintiff had provided false information in the financing application;
• the Plaintiff had engaged in fraudulent conduct;
• the Plaintiff was using multiple aliases;
• the Plaintiff was involved in unrelated criminal activity.

These statements were false, misleading, and unsupported by evidence.

The Plaintiff further pleads that these allegations were made recklessly or maliciously, without any reasonable investigation or verification.

Communications with Law Enforcement

The Plaintiff further pleads that Jean-Sébastien Perreault communicated these allegations to law enforcement authorities, including investigators involved in the Amherst police investigation.

These communications played a significant role in transforming a civil financial dispute into a criminal investigation and prosecution.

The Plaintiff pleads that these communications:

• exaggerated the nature of the dispute
• mischaracterized a civil repossession issue as criminal fraud
• encouraged law enforcement authorities to pursue criminal charges.

False Narrative of Criminal Conduct

The Plaintiff further pleads that Perreault repeated allegations that the Plaintiff was involved in stealing sailboats and transporting them to Panama, a statement that was later repeated in police documentation.

These allegations were entirely false and unsupported by evidence.

The Plaintiff has never been convicted of any such offence, nor has any credible evidence ever been produced supporting these allegations.

The Plaintiff pleads that the repetition of these statements was defamatory and malicious.

Lack of Verified Financial Loss

The Plaintiff further pleads that Scotiabank repeatedly asserted that it suffered a financial loss of approximately $41,000 in connection with the vehicle financing.

However:

• no detailed accounting was ever provided;
• no verified loss calculation was produced;
• the vehicle was repossessed and later resold.

Available records indicate the vehicle was resold in May 2021 for approximately $46,800, demonstrating that the Defendants suffered little or no financial loss.

The Plaintiff pleads that the alleged loss figure was inflated or fabricated and used to justify the escalation of legal action against the Plaintiff.

Vicarious Liability of Scotiabank

The Plaintiff pleads that all statements and actions taken by Jean-Sébastien Perreault were undertaken:

• within the course of his employment with Scotiabank;
• in furtherance of Scotiabank’s interests;
• using information obtained through his position at the bank.

Accordingly, The Bank of Nova Scotia is vicariously liable for all wrongful acts committed by Perreault.

Consequences of the Defendants’ Conduct

The Plaintiff pleads that the actions of Scotiabank and Perreault directly contributed to:

• the escalation of a civil dispute into criminal proceedings;
• the issuance of an arrest warrant;
• severe reputational harm;
• the denial of the Plaintiff’s Canadian passport.

As a result, the Plaintiff has been stranded outside Canada for more than 1013 days and counting, unable to travel freely or return to his business interests in Montana.

Malicious and Reckless Conduct

The Plaintiff pleads that the conduct of Scotiabank and Perreault was:

• reckless;
• malicious;
• undertaken with disregard for the truth;
• and motivated by an improper attempt to justify civil financial actions through criminal accusations.

This conduct constitutes defamation, malicious prosecution, abuse of process, and civil conspiracy.

ADDITIONAL ALLEGATIONS REGARDING INTERNAL COMMUNICATIONS AND DOCUMENTS

The Plaintiff pleads that the narrative portraying the Plaintiff as having engaged in fraudulent conduct did not originate from any verified complaint by Amherst Chrysler, but rather from internal communications and representations made by employees of Scotiabank, including Defendant Jean-Sébastien Perreault.

The Plaintiff further pleads that Scotiabank maintained internal records, communications, and investigative files relating to the Plaintiff and the financing of the 2018 Jeep Wrangler.

These records likely include:

• internal fraud investigation reports;
• internal communications between Scotiabank employees;
• communications between Scotiabank and Amherst Chrysler;
• communications between Scotiabank and law enforcement authorities;
• communications referencing allegations of fraud, aliases, or other criminal conduct attributed to the Plaintiff.

The Plaintiff pleads that these internal communications and records will demonstrate that the allegations communicated to law enforcement and other third parties were unverified, exaggerated, or knowingly false.

The Plaintiff further pleads that Scotiabank refused to provide the Plaintiff with access to these records despite multiple requests, including at least five separate requests, including requests made while the Plaintiff was stranded outside Canada due to the cancellation of his passport.

The Plaintiff offered multiple reasonable alternatives to verify his identity and obtain his personal records, including appearing before Canadian consular officials, international Scotiabank branches, and verified remote identification procedures true Notarize.Com.

All such proposals were refused by Scotiabank.

The Plaintiff pleads that this refusal was deliberate and was intended to prevent the Plaintiff from obtaining documents that would reveal the role played by Scotiabank employees, including Defendant Jean-Sébastien Perreault, in promoting or repeating false allegations.

The Plaintiff will seek full production of these internal communications and investigative records during the discovery process.

EXTENDED ALLEGATIONS CONCERNING AMHERST CHRYSLER, MIKE ALLEN, AND JOHN RICHARD

Role of Amherst Chrysler and Its Representatives

At all material times, Defendant Amherst Chrysler (1999) Limited acted through its employees and representatives, including Mike Allen and John Richard.

The Plaintiff pleads that Amherst Chrysler and its employees participated in the dissemination of allegations suggesting that the Plaintiff had engaged in fraudulent conduct in relation to the financing of a 2018 Jeep Wrangler.

Absence of Verified Financial Loss

The Plaintiff pleads that Amherst Chrysler has never produced any verified evidence demonstrating that it suffered any financial loss in connection with the transaction involving the Plaintiff.

The vehicle in question was repossessed and later resold.

Publicly available dealership records indicate that the vehicle — a 2018 Jeep Wrangler Unlimited Sahara — was resold in approximately May 2021 for approximately $46,800 CAD, with an odometer reading of approximately 6,619 kilometers.

This resale price was close to the original purchase price of approximately $48,345 CAD, in addition to a $10,000 payment made by the Plaintiff at the time of the transaction.

These facts strongly indicate that Amherst Chrysler did not suffer a significant financial loss.

Despite this, Amherst Chrysler and associated parties allowed or encouraged the narrative that the Plaintiff had caused substantial financial damage.

Participation in the False Narrative

The Plaintiff pleads that statements attributed to employees of Amherst Chrysler contributed to the escalation of a civil financing dispute into criminal accusations.

These statements were repeated by third parties, including representatives of Scotiabank and law-enforcement authorities.

The Plaintiff pleads that Amherst Chrysler employees either:

• provided misleading information;
• failed to correct false information;
• or allowed exaggerated claims to be communicated to third parties.

Recorded Conversation of November 22, 2024

On November 22, 2024, two days after receiving the long-awaited disclosure (approximately 520 days after it was requested), the Plaintiff placed a telephone call to Amherst Chrysler seeking clarification regarding the alleged financial loss and the basis of the accusations.

During that conversation, Mike Allen, an employee of Amherst Chrysler, stated that he did not recall the Plaintiff and had no knowledge of any financial loss or wrongdoing involving the Plaintiff.

Mike Allen further indicated that he was unaware of any damages or complaint involving the Plaintiff, despite the fact that serious criminal allegations had been made and were being relied upon by authorities.

This admission is significant because it demonstrates that the purported “victim” of the alleged fraud had no clear recollection of any wrongdoing and no knowledge of any loss.

Lack of Complaint by Amherst Chrysler

The Plaintiff further pleads that Amherst Chrysler did not submit a clear and verified victim statement identifying a financial loss attributable to the Plaintiff.

The Plaintiff is unaware of any sworn statement from Amherst Chrysler establishing:

• the existence of a financial loss;
• the amount of such loss;
• or the factual basis for any allegation of fraud.

The absence of such documentation strongly suggests that the narrative portraying Amherst Chrysler as a victim was unsupported by evidence.

Inconsistency Between Allegations and Reality

The Plaintiff pleads that the continued portrayal of Amherst Chrysler as a victim is inconsistent with the available evidence.

In particular:

• the vehicle was recovered;
• the vehicle was resold;
• no verified loss has been produced;
• and Amherst Chrysler representatives have acknowledged uncertainty regarding the alleged events.

These facts strongly undermine the credibility of the allegations that were used to justify the escalation of legal action against the Plaintiff.

Harm Caused by the Defendants’ Conduct

Despite the absence of verified loss and the lack of clear recollection by Amherst Chrysler representatives, the Plaintiff was subjected to serious allegations and legal consequences.

These allegations contributed to:

• severe reputational damage;
• the escalation of a civil dispute into criminal proceedings;
• and the eventual cancellation of the Plaintiff’s passport.

As a result, the Plaintiff has now been unable to travel freely for more than 1013 days and counting, preventing him from returning to Montana to manage his business interests.

The Plaintiff pleads that Amherst Chrysler, together with its owner & President Mike Allen and John Richard, participated in or allowed the promotion of a narrative portraying the Plaintiff as having committed fraud despite the absence of verified financial loss and despite later admissions demonstrating uncertainty regarding the alleged events.

The Plaintiff pleads that this conduct was negligent, reckless, and contributed to the serious damages suffered by the Plaintiff.

ADDITIONAL ALLEGATIONS CONCERNING CONSTABLE TOM WOOD AND THE TOWN OF AMHERST

The Plaintiff pleads that Constable Tom Wood, acting as a police officer of the Amherst Police Department, participated in the investigation that transformed a civil financial dispute into criminal accusations against the Plaintiff.

The Plaintiff pleads that Constable Tom Wood relied upon and repeated allegations originating from third parties, including representatives of Scotiabank, without conducting an adequate investigation to verify the accuracy of those allegations.

The Plaintiff further pleads that the investigation conducted by Constable Tom Wood contained serious irregularities, including:

• reliance on unverified statements;

• failure to confirm whether any financial loss actually occurred;

• failure to obtain clear victim statements establishing fraud;

• repetition of exaggerated or unsupported allegations.

• intentional service of the summons to appear at an incorrect address despite knowledge of the Plaintiff’s correct address.

The Plaintiff pleads that these investigative actions contributed directly to:

• the escalation of the dispute into criminal proceedings;

• the issuance of an Public Interest arrest warrant;

• Severe reputational harm to the Plaintiff;

• and the cancellation of the Plaintiff’s Canadian passport for more than 1013 days.

The Plaintiff further pleads that the Town of Amherst is vicariously liable for the actions of Constable Tom Wood, who was acting within the course and scope of his employment as a municipal police officer.

Conclusion

VI. CAUSES OF ACTION

COUNT I – DEFAMATION

27. Plaintiff incorporates all previous paragraphs.
28. Defendants, individually and collectively, including representatives of Scotiabank, Amherst Chrysler, and members of the Amherst Police Department, made or repeated false statements
29. These statements were communicated to third parties.
30. The statements harmed Plaintiff’s reputation and professional standing.
31. Defendants acted negligently or with reckless disregard for the truth.
32. Plaintiff suffered damages as a result.

COUNT II – TORTIOUS INTERFERENCE WITH BUSINESS

33. Plaintiff incorporates all previous paragraphs.
34. Plaintiff maintained business interests connected to Montana United States.
35. Defendants’ conduct interfered with Plaintiff’s ability to conduct business.
36. Defendants’ actions caused economic loss.

COUNT III – NEGLIGENCE

37. Plaintiff incorporates all previous paragraphs.
38. Defendants owed Plaintiff a duty to act with reasonable care when making accusations and representations.
39. Defendants breached this duty.
40. Plaintiff suffered damages as a result.

COUNT IV – CIVIL CONSPIRACY

41. Plaintiff incorporates all previous paragraphs.
42. Defendants acted together in promoting and repeating false allegations.
43. Defendants’ coordinated actions escalated a civil dispute into criminal accusations.
44. These actions caused severe harm to Plaintiff.

COUNT V – MALICIOUS PROSECUTION

45. Plaintiff incorporates all previous paragraphs as if fully set forth herein.
46. Defendants, individually and collectively, caused or substantially contributed to the initiation of criminal proceedings against Plaintiff.
47. These proceedings were initiated based on allegations that Plaintiff had committed fraud and other criminal acts.
48. Defendants lacked probable cause to make or promote these allegations.
49. Defendants acted with malice or reckless disregard for the truth.
50. The criminal proceedings were based on exaggerated, false, or unsupported claims concerning a civil vehicle financing dispute.
51. As a direct and proximate result of Defendants’ conduct, Plaintiff suffered severe damages including:

COUNT VI – ABUSE OF PROCESS

52.Defendants’ conduct constitutes malicious prosecution under applicable law.

53. Plaintiff incorporates all previous paragraphs.
54. Defendants used legal and investigative processes for an improper purpose.
55. Rather than resolving a civil financing dispute through normal civil remedies, Defendants promoted and encouraged the use of criminal allegations.
56. These allegations were used as a means of pressure and leverage in a civil financial dispute.
57. The misuse of legal processes caused significant harm to Plaintiff.
58. Defendants’ conduct constitutes abuse of process.

COUNT VII – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

59. Plaintiff incorporates all previous paragraphs.
60. Defendants engaged in extreme and outrageous conduct.
61. Defendants knowingly promoted or repeated allegations portraying Plaintiff as a criminal.
62. These allegations were communicated to third parties including law enforcement authorities.
63. Defendants knew or should have known that such accusations could cause severe personal and professional harm.
64. As a result, Plaintiff suffered severe emotional distress, reputational damage, and disruption of his life and business operations.
65. Defendants’ conduct was intentional, reckless, and outrageous.

VII. DAMAGES

45. As a direct result of Defendants’ actions, Plaintiff suffered substantial damages.
46. Plaintiff’s passport has been cancelled for approximately 1013 days and counting, preventing him from traveling freely.
47. Plaintiff has been unable to return to Montana to manage property and business activities.
48. Plaintiff has suffered severe reputational harm.
49. Plaintiff has suffered economic losses and lost business opportunities.
50. Plaintiff has suffered emotional distress and disruption of his personal life.
51. Defendants acted with malice and reckless disregard for the truth.

PUNITIVE CONDUCT ALLEGATIONS

52. Plaintiff pleads that the conduct of Defendants described in this Complaint was willful, malicious, reckless, and undertaken with conscious disregard for the rights and reputation of the Plaintiff.
53. Defendants knew, or reasonably should have known, that the allegations communicated about the Plaintiff were unverified, exaggerated, or unsupported by credible evidence, yet they continued to repeat and promote those allegations.
54. Defendants further knew, or should have known, that portraying the Plaintiff as having engaged in criminal fraud would cause severe reputational, economic, and personal harm, including interference with Plaintiff’s ability to conduct business and travel internationally.
55. Despite this knowledge, Defendants continued to promote and repeat the allegations, allowing them to escalate into criminal accusations and legal consequences.
56. Such conduct demonstrates reckless disregard for the truth and for the rights of the Plaintiff.
57. Accordingly, Plaintiff seeks punitive damages in an amount sufficient to punish Defendants and deter similar conduct in the future.

 

VIII. RELIEF REQUESTED

WHEREFORE, Plaintiff respectfully requests judgment against Defendants as follows:

1.  Compensatory damages in an amount not less than $17,500,000 USD;

2. Punitive damages in an amount to be determined by the jury sufficient to punish Defendants and deter similar misconduct.
3. Costs of litigation and court costs;
4. Any other relief the Court deems just and proper.

 

VII. DEMAND FOR JURY TRIAL

Plaintiff hereby demands trial by jury on all issues so triable.

 

IX. PRAYER

Plaintiff respectfully asks this Court to enter judgment in his favor and grant all appropriate relief.

 

DATED:
Respectfully submitted,

 

 

 

ROBERT SAVOIE
Plaintiff – Pro Se