Page 1 .
€17-3aouIN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND
(
KEITH COLEMAN (an individual)
REGINA HAMPTON-COLEMAN
(
(an individual)
PLAINTIFFS,
-
V'
.'
'
BOLAA. TINUBU (an individual)
OLUREMIS.TINUBU
,3:
(
(an individual)
DEFENDANTS.
5%"
a
(
(
~o
O
(
'
5:
N
1.
W
W»
Case No. CAE
MOTION FOR DEFAULT JUDGEMENT AND SPECIFIC PERFORMANCE
COMES NOW, Plaintiffs, Keith Coleman and Regina Hampton-Coleman, (hereinafter
"Plaintiffs"), and moves this court to enter an ORDER for default judgment and specific
performance against the defendants and states:
1.
A civil action for Specific Performance was filed on
2.
Defendants, Bola A. Tinubu and Oluremi S. Tinubu, (hereinafter "Defendants"), were
properly served with said civil action by serving their Attorney of record who advised
that he has been granted with authority to receive notice on his clients' behalf.
3.
On or about October 23, 2017, Plaintiffs through their Attorney sent via regular first class
mail a copy of the Civil Complaint, along with attachments.
4.
In addition, Plaintiff's Counsel attempted to contact Defendant's Counsel, on multiple
occasions to discuss the civil action and to date, calls and emails have not been returned.
5.
The Defendants failed to file an Answer or Notice the Court with an Intent to Defend
within the time allowed by law.
6. There are no material facts in dispute.
('39,,
to
(
10/23/2017. (See Exhibit
00.
C
A)
N"Page 2 mgmmfi
7.
Over 60 days have passed since the Defendant was served with the civil complaint. (See
Exhibits Attached)
WHEREFORE,
Plaintiffs is entitled to Default Judgment against the Defendants and as such
that
an
Order
for Specific Performance be signed or compensatory damages in the
request
amount of $750,000.00 be awarded and Attorney fees and cost be awarded to the Plaintiff as the
court sees fit.
Dated: January 19,
.
CHARDSON
Attorney for Plaintiffs
CERTIFICATE OF SERVICE
day of 11mm; 2018, a copy of the document titled Motion for
Default Judgment was sent irst Class ail to:
I hereby certify that on this
g
Brandon L. Wyatt Esq.
Wyatt Legal & Consulting
10903 lndian Head Hwy #Fort Washington, MD Email: bwyatt@4blegal.com
Dated: January
APRIL N. RICHARDSON
Attorney for Plaintiffs Page 3 (Bil/Mo H- ilk
Tl],
IN
ff
THE CIRCUIT COURT FOR PRINCE GEORGE'S
(
KEITH COLEMAN (an individual)
REGINA HAMPTON-COLEMAN
(
(an individual)
PLAINnFFs,
i
(
V
.
(
BOLA A. TINUBU (an individual)
OLUREMI s. TINUBU (an individual)
DEFENDANTS.
COUNTY, MARYLAND
.
a
(
,.j:
«a
(
Case No.
'
53.
(
.
24'!
'
.
4M 7((12%
.n_
¢W
°'A'
Civil Complaint
(Specific Performance)
1.
2.
Plaintiffs, Keith Coleman and Regina
Hampton-Coleman, (hereinafter "Plaintiffs"), are
individuals and at all times mentioned in this
complaint are residents of Washington DC,
who entered into a contract for real
estate that is situated in Prince
George's County,
Maryland.
Defendants, Bola A. Tinubu and Olurenu' S.
Tinubu, (hereinafter
"Defendan§é9§~m'iY-Windividuals and at all times mentioned in the
complaint are the owners of themalt't'
property located at 1708 Parkside Drive, Bowie, MD 2072!
(hereinafter "Ré§l'
in Prince George's
EVE-:5." 3: ')
County, MD specifically described as Woodmore South
521:3 83%L6t9,
Block D.
rm
3.
IFRA] SFRU
RIF
-
W
PM
{H.
mm
55.
Milli
On or about July 6. 20l 7, Plaintiffs
.
.
in ii! .
i???
and Defendants entered into
a ratified
ct
which Defendants agreed to sell and
co'n
Rm
i
Plaintiffs agreed to buy the real
property" escrgbed rm. 9 in paragraph 2 for the sum of
$733,000.00. PIaintifis gave Defendants $20,000,500 83:57 as
good faith deposit toward the purchase
price of the real property. The real property
would convey to the Plaintifi's
through settlement proceedings that were agreed
upon by
both parties on August 15, 20W. A
copy of the Greater Capital Area Association of
Realtors Sales Contract (hereinafter "Sales
Contract") is attached to this complaint as
(Exhibit A) and is incorporated by reference.
~
WPage 4 Tl:I The Sales Contract contained
.
r
a home inspection
contingency that allowed the Plaintiffs to
home inspection before being
to
obligated purchase the real estate. see page 1 l of
Sales Contract as Exhibit A
have
a
The home inspection identified a few areas of concern
and the parties agreed to continue
with the purchaSe of the home, with Defendants
agreeing to make certain repairs. see
Exhibit B Home Inspection
Contingency Notice And/0r Addendum
The Sales Cuntract contained an
appraisal contingency wherein both parties agreed that
the house did not appraise for the contracted
price of $733,000.00, then the Plaintifl's
were under no obligation to proceed with the
purchase of the real property. see page and I) of the Sales Contract as Exhibit A
if
.
The Plaintiffs had an Appraisal of the real
preperty wherein the real property appraised
for $700,000.00. see Exhibit C
Appraisal
8:
»
The Plaintiffs offered to purchase the real
property from the Defendants for the appraised
amount of $700,000.
The Plaintiffs provided the Defendants with an
Appraisal Notices And /0r Addendum
along with a copy of the Appraisal, which declined the
purchase of the real property for
the initial offer of $733,000.00 and it
requested a reduction to $700,000.00.
10. On
July 26, 2017 Defendant Bola A. Tinubu signed and authorized the reduction to
$700,000.00 and subsequently on July 27, 2017, Defendant Oluremi S.
Tinubu signed
and authorized the reduction of the real
property price to $700,000.00. see Exhibit D
Appraisal Notices/0r A ddendum
ll. Therefore, the agreed upon purchase price of $700,000.00 was
both parties.
fair, just and agreed to by
.
12. Subsequent to the Defendants
agreeing to the reduction in price, the Defendants notified
the Plaintiffs,
through their Realtor, that they no longer wanted to sell the real
property.
l3. The Plaintiffs advised the
.
Defendants, through their Realtor and their Attorney, of their
mtentions to proceed with the
closing on August 15, 20! 7 pursuant to the Sales Contract.
I4. On August 15, 2017, the Plaintiffs were
ready, willing and able to close on the real
property and Defendants, through their Attorney, made it clear that
they would not
participate in the sale of the real property, thus they breached their
contractual obligation.
15.
The selected title company advised the
Plaintiffs that the Defendants did not provide the
requisite information to proceed with the
closing on or before August 15, 2017.Page 5 Tl
m
16.
At all times relevant, it is understood that the
Defendants do not live in the real propetty
and that they live and reside in
Nigeria.
l7. Plaintiffs have performed all of the conditions of the
Sales Contract that are required to
be performed by Plaintiffs. Plaintiffs remain
ready, willing and able to perforrn all terms
of the
ageement applicable to Plaintiffs and to receive a
good and sufficient deed to the
real property as promised
by the Defendants.
l8. Plaintifi's have no adequate
remedy at law because the contact described in
paragaph
two was a contract for the sale of real
property and money damages are presumed
inadequate for its breach. Plaintiffs
denimentally relied upon Defendants agreement to
convey the property. It is the Plaintiff's intent to
occupy the real property as their new
primary residence for their family. The
majority of Plaintiffs' business opportunities and
n'ansactions occur in close
proximity to the residential property and thus provided
i
Plaintiffs" with a unique
opportunity to work and reside within
Plaintifl's have no other affordable or
equivalent options.
l9. Plaintiffs incorporate by reference
paragraphs [-18, inclusive,
a
three-mile radius.
as
if fully set forth.
20. Defendants' failure and refusal to
perforrn its obligations under the contract consn'tute a
breach of contact and have
damaged Plaintifi's in the following manner:
2|. The contract between Plaintiffs and
Defendants provides for an award of reasonable
attorney's fees and costs that are incurred to enforce the contact
(See Exhibit A,
paragraphs 23, 26),
WHEREFORE, Plainn'tfs demand judgnent against Defendants as set forth below.
l. For an order of specific
performance that Defendants and its agents
specifically perforni
the contract and deliver the real
property as described in paragraph two;
In the event that the Court does
not order specific performance of the
contract, for
compensatory damages in the amount of $750,000.00 for breach
of contract;
For attomeys' fees in an amount determined
by the Court to be reasonable as authorized
by agreement and according to proof;
For costs of suit; and
For any and all other remedies and relief
the Court considers
proper and
Dated: October 6,
appropriate.Page 6 TI
Fl
A
RICHARDSON
may for Plaintifi's
CERTIFICATE OF SERVICE
I
hereby certify that on this Q9 day of October, 201.7, a
copy of the document titled Civil
Complaint in Coleman et al. v. Tinubu et al. was sent Email and F il'SI
Ciass Mail to:
Brandon L. Wyatt Esq.
Wyatt Legal & Consulting
10903 Indian Head Hwy #204Fort Washington, MD
Email: bwyatt@4blegal.com
Dated: October 6, 20!
APRIL N. RICHARDSON
Attorney for Plaintiffs
PDF Page 1
PlainSite Cover Page
PDF Page 2
.1
€17-3aou7
IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND
(
KEITH COLEMAN (an individual)
REGINA HAMPTON-COLEMAN
(
(an individual)
PLAINTIFFS,
-
V'
.'
'
BOLAA. TINUBU (an individual)
OLUREMIS.TINUBU
,3:
(
(an individual)
DEFENDANTS.
5%"
a
(
(
~o
O
(
'
5:
N
1.3
W
W»
Case No. CAE1732067
MOTION FOR DEFAULT JUDGEMENT AND SPECIFIC PERFORMANCE
COMES NOW, Plaintiffs, Keith Coleman and Regina Hampton-Coleman, (hereinafter
"Plaintiffs"), and moves this court to enter an ORDER for default judgment and specific
performance against the defendants and states:
1.
A civil action for Specific Performance was filed on
2.
Defendants, Bola A. Tinubu and Oluremi S. Tinubu, (hereinafter "Defendants"), were
properly served with said civil action by serving their Attorney of record who advised
that he has been granted with authority to receive notice on his clients' behalf.
3.
On or about October 23, 2017, Plaintiffs through their Attorney sent via regular first class
mail a copy of the Civil Complaint, along with attachments.
4.
In addition, Plaintiff's Counsel attempted to contact Defendant's Counsel, on multiple
occasions to discuss the civil action and to date, calls and emails have not been returned.
5.
The Defendants failed to file an Answer or Notice the Court with an Intent to Defend
within the time allowed by law.
6. There are no material facts in dispute.
('39,,
to
(
10/23/2017. (See Exhibit
00.
00
C2
A)
N"
PDF Page 3
mgmmfi
7.
Over 60 days have passed since the Defendant was served with the civil complaint. (See
Exhibits Attached)
WHEREFORE,
Plaintiffs is entitled to Default Judgment against the Defendants and as such
that
an
Order
for Specific Performance be signed or compensatory damages in the
request
amount of $750,000.00 be awarded and Attorney fees and cost be awarded to the Plaintiff as the
court sees fit.
Dated: January 19, 2018
.
CHARDSON
Attorney for Plaintiffs
CERTIFICATE OF SERVICE
7
day of 11mm; 2018, a copy of the document titled Motion for
Default Judgment was sent irst Class ail to:
I hereby certify that on this
g
Brandon L. Wyatt Esq.
Wyatt Legal & Consulting
10903 lndian Head Hwy #204
Fort Washington, MD 20744
Email: bwyatt@4blegal.com
Dated: January
2018
APRIL N. RICHARDSON
Attorney for Plaintiffs
2
PDF Page 4
(Bil/Mo H- ilk
Tl],
IN
ff
THE CIRCUIT COURT FOR PRINCE GEORGE'S
(
KEITH COLEMAN (an individual)
REGINA HAMPTON-COLEMAN
(
(an individual)
PLAINnFFs,
i
(
V
.
(
BOLA A. TINUBU (an individual)
OLUREMI s. TINUBU (an individual)
DEFENDANTS.
COUNTY, MARYLAND
.
a
(
,.j:
«a
(
Case No.
'
53.
(
.
24'!
'
.
4M 7((12%7
.n_
¢W
°'A'
Civil Complaint
(Specific Performance)
1.
2.
Plaintiffs, Keith Coleman and Regina
Hampton-Coleman, (hereinafter "Plaintiffs"), are
individuals and at all times mentioned in this
complaint are residents of Washington DC,
who entered into a contract for real
estate that is situated in Prince
George's County,
Maryland.
Defendants, Bola A. Tinubu and Olurenu' S.
Tinubu, (hereinafter
"Defendan§é9§~m'iY-W7
individuals and at all times mentioned in the
complaint are the owners of themalt't'
property located at 1708 Parkside Drive, Bowie, MD 2072!
(hereinafter "Ré§l'
in Prince George's
EVE-:5." 3: ')
County, MD specifically described as Woodmore South
521:3 83%L6t9,
Block D.
rm
3.
IFRA] SFRU
RIF
-
W
PM
{H.563
mm
55.93
Milli
On or about July 6. 20l 7, Plaintiffs
.
.
in ii! .
i???
and Defendants entered into
a ratified
ct
which Defendants agreed to sell and
co'n
Rm
i
Plaintiffs agreed to buy the real
property" escrgbed rm. 9 99
in paragraph 2 for the sum of
$733,000.00. PIaintifis gave Defendants $20,000,500 51351
83:57 as
good faith deposit toward the purchase
price of the real property. The real property
would convey to the Plaintifi's
through settlement proceedings that were agreed
upon by
both parties on August 15, 20W. A
copy of the Greater Capital Area Association of
Realtors Sales Contract (hereinafter "Sales
Contract") is attached to this complaint as
(Exhibit A) and is incorporated by reference.
~
W
PDF Page 5
Tl:I 9
The Sales Contract contained
.
r11
a home inspection
contingency that allowed the Plaintiffs to
home inspection before being
to
obligated purchase the real estate. see page 1 l of
Sales Contract as Exhibit A
have
a
The home inspection identified a few areas of concern
and the parties agreed to continue
with the purchaSe of the home, with Defendants
agreeing to make certain repairs. see
Exhibit B Home Inspection
Contingency Notice And/0r Addendum
The Sales Cuntract contained an
appraisal contingency wherein both parties agreed that
the house did not appraise for the contracted
price of $733,000.00, then the Plaintifl's
were under no obligation to proceed with the
purchase of the real property. see page 10
and I) of the Sales Contract as Exhibit A
if
.
The Plaintiffs had an Appraisal of the real
preperty wherein the real property appraised
for $700,000.00. see Exhibit C
Appraisal
8:
»
9
The Plaintiffs offered to purchase the real
property from the Defendants for the appraised
amount of $700,000.
The Plaintiffs provided the Defendants with an
Appraisal Notices And /0r Addendum
along with a copy of the Appraisal, which declined the
purchase of the real property for
the initial offer of $733,000.00 and it
requested a reduction to $700,000.00.
10. On
July 26, 2017 Defendant Bola A. Tinubu signed and authorized the reduction to
$700,000.00 and subsequently on July 27, 2017, Defendant Oluremi S.
Tinubu signed
and authorized the reduction of the real
property price to $700,000.00. see Exhibit D
Appraisal Notices/0r A ddendum
ll. Therefore, the agreed upon purchase price of $700,000.00 was
both parties.
fair, just and agreed to by
.
12. Subsequent to the Defendants
agreeing to the reduction in price, the Defendants notified
the Plaintiffs,
through their Realtor, that they no longer wanted to sell the real
property.
l3. The Plaintiffs advised the
.
Defendants, through their Realtor and their Attorney, of their
mtentions to proceed with the
closing on August 15, 20! 7 pursuant to the Sales Contract.
I4. On August 15, 2017, the Plaintiffs were
ready, willing and able to close on the real
property and Defendants, through their Attorney, made it clear that
they would not
participate in the sale of the real property, thus they breached their
contractual obligation.
15.
The selected title company advised the
Plaintiffs that the Defendants did not provide the
requisite information to proceed with the
closing on or before August 15, 2017.
PDF Page 6
Tl
m
16.
At all times relevant, it is understood that the
Defendants do not live in the real propetty
and that they live and reside in
Nigeria.
l7. Plaintiffs have performed all of the conditions of the
Sales Contract that are required to
be performed by Plaintiffs. Plaintiffs remain
ready, willing and able to perforrn all terms
of the
ageement applicable to Plaintiffs and to receive a
good and sufficient deed to the
real property as promised
by the Defendants.
l8. Plaintifi's have no adequate
remedy at law because the contact described in
paragaph
two was a contract for the sale of real
property and money damages are presumed
inadequate for its breach. Plaintiffs
denimentally relied upon Defendants agreement to
convey the property. It is the Plaintiff's intent to
occupy the real property as their new
primary residence for their family. The
majority of Plaintiffs' business opportunities and
n'ansactions occur in close
proximity to the residential property and thus provided
i
Plaintiffs" with a unique
opportunity to work and reside within
Plaintifl's have no other affordable or
equivalent options.
l9. Plaintiffs incorporate by reference
paragraphs [-18, inclusive,
a
three-mile radius.
as
if fully set forth.
20. Defendants' failure and refusal to
perforrn its obligations under the contract consn'tute a
breach of contact and have
damaged Plaintifi's in the following manner:
2|. The contract between Plaintiffs and
Defendants provides for an award of reasonable
attorney's fees and costs that are incurred to enforce the contact
(See Exhibit A,
paragraphs 23, 26),
WHEREFORE, Plainn'tfs demand judgnent against Defendants as set forth below.
l. For an order of specific
performance that Defendants and its agents
specifically perforni
the contract and deliver the real
property as described in paragraph two;
In the event that the Court does
not order specific performance of the
contract, for
compensatory damages in the amount of $750,000.00 for breach
of contract;
For attomeys' fees in an amount determined
by the Court to be reasonable as authorized
by agreement and according to proof;
For costs of suit; and
For any and all other remedies and relief
the Court considers
proper and
Dated: October 6, 2017
appropriate.
PDF Page 7
TI
Fl
A
RICHARDSON
may for Plaintifi's
CERTIFICATE OF SERVICE
I
hereby certify that on this Q9 day of October, 201.7, a
copy of the document titled Civil
Complaint in Coleman et al. v. Tinubu et al. was sent Email and F il'SI
Ciass Mail to:
Brandon L. Wyatt Esq.
Wyatt Legal & Consulting
10903 Indian Head Hwy #204Fort Washington, MD 20744
Email: bwyatt@4blegal.com
Dated: October 6, 20! 7
APRIL N. RICHARDSON
Attorney for Plaintiffs
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