Pleading Complain

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Attorneys for PlaintiffRANDY LAW | | SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN DIEGO RANDY LAW, Plaintiff, v.PIPER REED, Defendant. | CASE NO. Lawyering Skills 1 Complaint Filed: August 31, 2012Trial Date: TBDDiscovery Cutoff: Motion Cutoff: | Plaintiff Randy Law, for his cause of action against Defendant Piper Reed complains and alleges as follows: PARTIES 1. Plaintiff Randy Law (“Plaintiff”) is a twenty-four year old student, at all times herein mentioned, is a third student at Thomas Jefferson School of Law (“TJSL”) and resides in the city of San Diego, county of San Diego, state of California. 2. Defendant Piper Reed, an individual, is a twenty-six years old student, and is and at all times herein…show more content…
16. By the conduct alleged above, Defendant intended to hit the dart target but in her attempt penetrated the right arm of the plaintiff’s person, leaving him injured. The defendant carried out an act of battery. 17. Defendant engaged in battery as she directly or indirectly harmed the Plaintiff. 18. This conduct, as alleged above and which was unprivileged and unwanted by plaintiff, actually and proximately caused Plaintiff severe pain and embarrassment. 19. Defendant harmed Plaintiff because Plaintiff suffered from severe physical pain and humiliation. Defendant injured the Plaintiff’s mind and body, which was a result of unlawful conduct and consequent harm. Plaintiff suffered damages that will be proven at trial. 20. The conduct of Defendant proximately caused Plaintiff to suffer, and to continue to suffer, damages, including injuries to Plaintiff in an amount, which will be proven at trail. 21. The malicious and negligent conduct of Piper Reed was reckless disregard of Plaintiff’s rights, harm to physical well-being and invasion of personal space and therefore warrants the imposition of punitive damages. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for relief as follows: 1. General damages in a sum according to proof at trial; 2. Special damages in a sum according to proof at trial; 3. Interest; and 4.
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