Plaintiff illegally evicted Defendant under Ky. Rev. Stat. Ann. § 383.655. Plaintiff filed Case No. 16-S-00013 in an attempt to conceal her illegal actions a month after the illegal eviction once the involvement of the Kentucky Equality Federation was made known to the County Attorney, who has also served as the personal attorney of Plaintiff and her spouse.

1. COMMONWEALTH OF KENTUCKY
COURT OF JUSTICE
CASE NO. 16-S-00013
DISTRICT SMALL CLAIMS
CLAY COUNTY DISTRICT COURT
JOSHUA MELTON,
Individually
JAMES RAYMOND FELTNER
Spouse
DEFENDANTS,
v.
ESTHER THOMPSON
Individually
PLAINTIFF.
SMALL CLAIMS
KRS 24A.290 COUNTERCLAIM
Comes Defendants Joshua Melton and his spouse, James Raymond Feltner, whose
mailing address is 108 T Street Manchester, KY 40962 filing with counterclaim under
KRS 24A.290 against Plaintiff Esther Thompson who owns another business at 500
Railroad Avenue Manchester, KY 40962.
Plaintiff illegally evicted Defendant under Ky. Rev. Stat. Ann. § 383.655.
Plaintiff filed Case No. 16-S-00013 in an attempt to conceal her illegal actions a month
after the illegal eviction once the involvement of the Kentucky Equality Federation was
made known to the County Attorney, who has also served as the personal attorney of
Plaintiff and her spouse.
Defendant was illegally evicted by Plaintiff, with Plaintiff stating “she owned the
police” with the assistance with Manchester Police Officer Jeff Couch on July 14, 2016
in the County of Clay, a subdivision of the Commonwealth of Kentucky. Witness
statements are attached hereto.
Plaintiff has also willfully violated Kentucky Revised Statues, including but not
limited to KRS 383.660, KRS 383.615, KRS 383.660, and the Kentucky Fire Code.

2. Plaintiff called Defendants “faggots,” and stated she should have never rented to
them. This was reported by the Kentucky Equality Federation to the U.S. Attorney for
the Eastern District of Kentucky for violating provisions of the U.S. Matthew Shepard
and James Byrd Jr. Hate Crimes Prevention Act.
Plaintiff has on multiple occasions entered the leases premises thereby violating
KRS 383.615 and KRS 383.670 by entering the leased property without notice; she
violated the Defendant’s privacy and personal security. Had Defendant been home, being
armed, the Plaintiff could have been wounded under the U.S. Castle Doctrine, in
Kentucky law known as KRS 503.055.
Plaintiff is in violation of KRS 383.595(1). Additionally, Plaintiff is in violation
of the Commonwealth’s Fire Code by failing to maintain working smoke detectors, the
Kentucky Public Protection Cabinet’s Department of Housing, Buildings & Construction
has been notified of this violation.

3. RELIEF FOR DEFENDANT
Plaintiff has violated the laws of this Commonwealth and too often landlords run
amok believing tenants have no legal recourse.
Defendant claims the following sum from Plaintiff for damages brought about by
the above Complaint and moves this Honorable Court to order Plaintiff to pay
Defendants three (3) month’s rent at $425.00 per month and refund the July 2016 with a
rent payment total of $1,700.00 in addition to $800.00 in legal fees as permitted under
Ky. Rev. Stat. Ann. § 383.655. The payment is requested in court before the end of the
business day or as soon as permitted under the laws of the Commonwealth.
Restrain the Plaintiff from entering any derogatory comments into state and
national lease/rental databases.
a) Additionally, Defendant’s, both citizens of this Commonwealth, moves this
Honorable Court to the following on behalf of the Commonwealth and her
citizens for violating the Kentucky Landlord/Tenant relationship:
i. Plaintiff requests this Honorable Court fine Plaintiff whatever amount
the court deems appropriate for willful and malicious violations of
Kentucky law, made payable to the Kentucky State Treasurer and not
the Defendants, thus not violating this small claims order.
The Defendants also request court costs.
Defendant requests this be set for a hearing on ________________________________.
Respectfully submitted pro se by the Defendants this 8th
day of August, 2016, in the 225th
year of the Commonwealth.
JOSHUA MELTON
108 T Street
Manchester, KY 40962
PH: (606) 813-6913
___________________________________
Joshua Melton, Defendant, Pro Se
JAMES RAYMOND FELTNER
108 T Street
Manchester, KY 40962
PH: (606) 813-6913
___________________________________
James Raymond Feltner, Defendant, Pro Se

4. COMMONWEALTH OF KENTUCKY
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the Motion was placed in the U.S. Mail with
postage paid to the following:
Esther Thompson
500 Railroad Ave
Manchester, KY 40962
This 8th
day of August, 2016, in the 225th
year of the Commonwealth.
___________________________________
Joshua Melton, Defendant
___________________________________
James Raymond Feltner, Defendant