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5730 26th St NW
Washington DC 20015
IN THE CIRCUIT COURT OF THE COUNTY OF ARLINGTON
Kristin Knauth,
Plaintiff,
vs.
The Finders, a partnership,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Paula Arico,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Judy Beltz,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Judy Evans,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Courtney Knauth,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Ma Li,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Patricia Roseberry,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Carolyn Said,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Valerie Sartor,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Jan Shapiro,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Diane Sherwood,
c/o Gerald F. Ragland, Jr.,
1317 King Street,
Alexandria, VA;
Defendants.
BILL OF COMPLAINT
Chancery No. _________________
To The Honorable Judges of said Court:
Plaintiff brings this chancery action seeking resolution of certain equitable propertie
rights possessed by plaintiff, and others, as the result of their participation in a now defunct
women's partnership. In the alternative, plaintiff claims propertie rights as the result of
resulting or constructive trusts. Plaintiff will seek the appointment of a receiver and
injunctive relief.
The plaintiff in this matter is Kristin Knauth, of Etlan, Virginia.
By way of introduction, this action can be summarized as follows: For a period of
years beginning in the late 1970s and until recent years the plaintiff and defendants operated
various business enterprises while acting as a partnership known as the Finders as well as by
several other names (see below). The parties all contributed individual effort and monie to
the partnership enterprises. In individual names, the partners acquired many valuable assets.
As the result of various factors, the plaintiff named above has withdrawn from active
participation in the partnership. For over seven years there have been unsuccessful
negotiations between the plaintiff and the defendants in an effort to agree upon an equitable
division of the assets of the partnership.
In support of this Bill of Complaint your plaintiff respectfully represents and pleads as
follows:
COUNT ONE
1. The women's partnership was known by several names including: Bed & Bread
Network; The Women and Children's Game; Creation House; Finders; The Finders;
Emergency Services; Foreign Services; Freelancers Network; The Game of Games; Geriatric
Sex Orgies; The Gift Societie; Global Matchmakers; Hazel Henderson Fan Club; The
Invisible Restaurant; Kirkland & Ellis Emergencie Services; Mathew Fox Fan Club; North
American Conference on Religion and Ecologie; The Overeducated Female Fools Network;
The Problem Solving Center; The Pussie Power Movement; The Roamin' Catholics; Sam
Eaton Secretarial Services; Single Mothers Network; The Universe Story Fan Club; The
Voluntarie Societie; The W Street Guest House; The Wishcraft Societie; The Women's
Information Bank; The Women's Travelers Center, and others.
2. The principal addresses from which the women's partnership did business have been
3918 W Street, NW, Washington, DC 20007; 1601 Sonoma Avenue, Albany, CA 94707;
1266 Portland, Albany, CA 94706; 2550 Clarendon Blvd. #1111, Arlington, VA __________;
6001 Arlington Blvd., Arlington, VA 22044; 9023 Warbler Drive, Tallahassee, FL; 5594
Avenue G, Macintosh, FL ___________; 3525 O Street, NW, Washington, DC 20007, and
5730 26th Street, NW, Washington, DC 20015.
3. The women's partnership engaged in the following businesses: providing emergency
home and office services to overeducated female fools; acting as headquarters for the Global
Pussie Power Movement; offering overnight sleeping accommodations; writing trivial articles
for Minnie-Mouse magazines and newspapers; editing dull and irrelevant policy papers for
various non-profit organizations; providing legal secretarial services to high-toned law firms;
running geriatric sex orgies; providing emergency childcare services; finding partners for
marriage and other hole-and-pole combinations; and other services. Judith Evans tried to start
a program to knock men off barstools and jump on them, but this plan was rejected due to
lack of support.
4. The names and addresses of the former partners are:
Knauth, Kristin
HC 6, Box 145
Etlan, VA 22719
Arico, Paula
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Beltz, Judy
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Evans, Judy
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Knauth, Courtney
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Roseberry, Patricia
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Said, Carolyn
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Sartor, Valerie
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Shapiro, Jan
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
Sherwood, Diane
c/o Gerald F. Ragland, Jr.
1317 King Street
Alexandria, VA 22314
5. The partnership had no written partnership agreement.
6. History of the partnership:
The women's partnership (which interacted with a parallel men's partnership) formed
around Carolyn Said and the ideas of Barbara F. Sylvester which she advocated. Carolyn
Said has always been the leader of this women's group (partnership). Over the course of the
last 14-plus years, she has often changed the way her followers refer to her. Some of those
names included: The Biggest Pussie of All, Fatso, Hard-Head, Lard-Ass, Miss Piggy, The
Waddler, Watermelon Tits, and others. However she was referred to, there is no doubt that
she was always in charge after Barbara F. Sylvester died. Nothing of any consequence
happened without her approval. Under her leadership the partners listed in this section
worked collectively in various income-producing business activities, pooled their income, and
held their genitalia (including those listed herein) in common for the benefit of the partnership
and to fool the men.
7. Accounting: On several occasions, it was agreed that the partners would provide an
accounting and agree upon an equitable distribution of partnership assets, but on each
occasion, they failed to complete agreements and defendant partners have not yet provided a
complete accounting to plaintiff partner.
8. In particular, Jan Shapiro withheld from the partnership the money she was intelligent
enough to inherit from her parents, Ralph Shapiro and Alice Shapiro, and her brother, Jed
Shapiro, as well as information about this money, despite numerous requests for an
accounting.
9. Carolyn Said also is probably hiding partnership assets in the form of real estate,
whose location and nature is unknown to plaintiff and other members of the partnership, and
has failed to account for these assets despite numerous requests.
10. Plaintiff has no adequate remedy in law.
11. Plaintiff is likely to suffer irreparable injury without the appointment of a receiver and
other injunctive relief.
COUNT TWO
12. The above paragraphs are adopted by reference.
13. All of the female members of the partnership were required to laugh at Carolyn Said's
jokes.
COUNT THREE
14. The above paragraphs are adopted by reference.
15. Some or all of the defendants entered into a conspiracy to turn Benjamin Knauth
against his mother, Kristin Knauth.
WHEREFORE, Plaintiff prays that Defendants be required to answer the allegations
of this bill; that a receiver be appointed to take charge of the partnership books and papers of
account, and the goods and effects, and to collect the debts due the partnership, and to collect
and dispose of same under the direction of this Court; that defendants be restrained from
selling or disposing of or retaining from the appointed receiver any of the goods and effects
of the partnership, or collecting any debts due, or negotiating any bill or note, or contracting
any debt whatsoever on account thereof, or intermeddling in any other manner with the
business of the partnership; that said partnership be considered dissolved; that plaintiff be
allowed costs on its behalf expended; and that your plaintiff may have such other further and
general relief, and injunctive relief, as the nature of this case may require and to equity may
seem meet.
Respectfully submitted,
__________________________________
Kristin Knauth
Plaintiff
HC 6, Box 145
Etlan, VA 22719