CASE BRAIN: Strategic Decision Tree & Submission Inventory

Date: January 18, 2026 Objective: Regroup, prioritize filings, and evaluate leverage.

1. INVENTORY OF SUBMISSIONS (To Date)

Status	Item	Purpose
FILED	Emergency Supplemental Declaration (Consolidated)	Document initial removal harms and irreparable damage.
FILED	Declaration: Secondary Displacement (Otis)	Alert court to current homelessness crisis and predatory landlord.
PENDING	Response to Accounting/Surplus (8-9k)	Dispute their “fudged numbers” regarding home sale excess.
DRAFTING	Affidavit of Third Party Hardship	Document the “cascade” of impact on others.
PLANNED	ADA / Civil Rights Formal Complaints	Apply external administrative pressure on the Plaintiff.

Goal: Retrieve the ~$8.5k in excess sale proceeds.
Obstacle: Plaintiff has submitted a “fudged” accounting to zero out the surplus.
Action: Submit “Audit Response” detailing utility exploitation and bad faith property damage.

Path 1: File Motion to Dismiss (Total Dismissal)
- Pros: Forces them to restart (very expensive for them). Validates procedural errors.
- Cons: Might kill current “leverage” if the goal is a comprehensive settlement. Could reset everything (including your ability to claim current damages in this specific case number).
Path 2: File for Sanctions/Stay (Maintain Leverage)
- Pros: Keeps the current case open as a “vessel” for your damage claims. Forces them to “come to the table” to make the noise stop.
- Decision: Option 2 is generally better for settlement. Total dismissal lets them walk away and try again cleaner. Sanctions make them pay for their current mess.

Tactical Goal: Do NOT make the government agencies part of this case (don’t complicate the hearing).
Action: Send letter to Plaintiff: “I have filed formal complaints with HUD/Indiana Civil Rights Commission. Expect a call.”
Effect: Their legal costs jump $20k+ just to respond. This accelerates the “How much do you want to go away?” conversation.

Stabilize Housing: Secure hotel with kitchenette (4-week fund).
Finalize Surplus Response: Detail the 12/9 video evidence (Abbott tampering).
Re-verify Utilities: Document that Plaintiff is using power/water on Defendant’s dime.

Supplemental Damage Accounting: Total up hotel costs, food, time lost, work inability ($ amount).
Affidavits: Secure “Hardship” statements from affected third parties.
ADA/Civil Rights Letters: Send notice of filing to Plaintiff.

Liquid Damages: Hotel stays ( $250/ w k), F oo d ma r k u p s, St or a g e f ees ($ 300+/mo).
Property Loss: TV damage (Video 46), Fridge/Mold risk, Locks/Locksmith.
Labor/Opportunity Cost: Time lost preparing pro se (hundreds of hours), Inability to work due to instability.
Statutory Damages: ADA violations, Illegal removal procedures.