Complaint | Filed: June 17, 2026
| Entered: June 17, 2026
Ritter et al v. Rubin et al
Contract: Other | New York Eastern
Amended Complaint
AMENDED COMPLAINT against Lead Safe Mama LLC, Tamara Rubin, filed by Eric Ritter, Spirochaete Research Labs LLC. (Attachments: # 1 Exhibit Advertising contract, signed Lead Safe Mama, LLC Invoice No. 2023041401, # 2 Exhibit Johannesen & Johannesen demand letter, June 6, 2024, # 3 Exhibit March 2024 Advertising Contract Agreement (the Replacement Instrument), drafted March 15, 2024, # 4 Exhibit Ninth Circuit Memorandum Disposition affirming the District of Oregons grant of summary judgment, Rubin v. State of Oregon, No. 22-35640 (9th Cir. Jan. 10, 2024), # 5 Exhibit Rubin email of August 27, 2023, with attached debt-and-expense spreadsheet, # 6 Exhibit Rubin post of April 7, 2023 (2023 Internet Archive captures and current version), with published page-view history, # 7 Exhibit Rubin post of April 23, 2023 (secured funding for the subway campaign), # 8 Exhibit Rubin post of June 27, 2023 (monthly shortfall), # 9 Exhibit Rubin newsletter of July 13, 2023, # 10 Exhibit Rubin email of September 5, 2023 transmitting Lead Safe Mama, LLC Invoice No. 2022EC04044, with the invoice, # 11 Exhibit Rubin Proposed Plan / Scenario #1 of August 29, 2023, with draft invoices, # 12 Exhibit Rubin solicitation email of August 25, 2023, # 13 Exhibit Rubin email of September 6, 2023, # 14 Exhibit Email exchange of March 16, 2024 (transmittal of the Replacement Instrument and Plaintiffs same-day reply), # 15 Exhibit Photographs of undeployed subway public-service-announcement panels, with the authenticating Declaration of Eric Ritter, # 16 Exhibit Lead Safe Mama, LLC Invoices No. 2022EC04042 (newsletter) and No. 2022EC04043 (video), # 17 Exhibit Lead Safe Mama, LLC Oregon Secretary of State Amended Annual Report, e-filed January 10, 2026, # 18 Exhibit Text-message excerpts (April 2023 loan election; March 16, 2024 refund-notice exchange), # 19 Exhibit Rubin email of August 28, 2023 (page-view figures), # 20 Exhibit June 2024 demand correspondence (June 17 letter; Rubins June 20 replies; Plaintiffs Jun... (truncated)