STATE OF MISSOURI
JOHN NMN DOE,)
) Cause No.:
Serve Defendant at:)
Missouri Division of )
505 Washington Avenue)
St. Louis, Missouri 63101)
Serve between 9:00 a.m. and)
4:00 p.m. Monday through Friday)
PETITION FOR DAMAGES FOR ASSAULT AND BATTERY
COMES NOW Plaintiff, MARY MARSDEN, and for her cause of action against Defendant, states to the Court as follows:
COUNT I - ASSAULT AND BATTERY
1.Plaintiff is a resident of the City of St. Louis, Missouri.
2.Defendant is a resident of Jefferson County, Missouri but is employed at the Missouri Division of Employment Security which is located in the City of St. Louis, Missouri and is the place where the wrong complained of took place.
3.On or about February 28, 1997, at approximately 4:20 p.m. in the offices of the Missouri Division of Employment Security located at 505 Washington Avenue, in the City of St. Louis, Missouri 63101, Defendant, John Doe, came up behind the Plaintiff who was then sitting at her desk and wrapped the fingers of his hands around her face and tried to push his fingers into her mouth. Defendant is a very large man and Plaintiff was unable to free herself from his vise-like grip. Defendant pulled Plaintiff's head back during his attack on her and caused her to suffer physical pain, emotional trauma and extreme fear for her life.
4.Defendant's touching of Plaintiff was in no way the type of touching which could be described as socially acceptable or privileged.
5.Defendant's touching of Plaintiff was unlawful and placed Plaintiff in great apprehension and fear of her safety and was without any justification.
6. As a direct and proximate result of Defendant's actions Plaintiff suffered severe...