Civil Tort Complaint Example

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Circuit Court of the State of Oregon
Multnomah County
Roy Keane)
Plaintiff ) Roy Keane’s
vs.)First Amended
)Complaint
Bryce Caldwell)
Defendant)Assault, Battery, and Intentional
)Infliction of Emotional Distress
)
)
)Not Subject to Mandatory
)Arbitration

Plaintiff, Roy Keane by his attorney, Walter Meier files his Complaint against defendants as follows: Claim 1 – Assault
1.
Plaintiff, Roy Keane accompanied his wife to an NHL pre-season game at the Rose Garden in Multnomah County on September 16th, 2011. 2.
As plaintiff and his wife attempted to leave the stadium after the match, they encountered defendant, Bryce Caldwell. 3.
Plaintiff had a heated conversation with defendant, Bryce Caldwell concerning the match.

4.
Defendant purposefully approached Plaintiff and his wife and intentionally punched Plaintiff in the face. 5.
Plaintiff clearly saw and apprehended the punch before impact. 6.
The Plaintiff suffered damages from the wrongful assault by Bryce Caldwell including, pain and suffering, emotional distress, and other damages.

Claim 2- Battery
7.
Plaintiff realleges paragraphs 1 through 6 of Claim One as paragraph number 7 of Claim Two. 8.
Plaintiff became unconscious upon impact of the first punch, and dropped to the ground. 9.
While Plaintiff lay unconscious, Defendant Caldwell continued to kick and punch Plaintiff in the ribs, stomach, chest, and head. 10.
Over the course of the attack, Plaintiff sustained damage to his spleen, multiple hemorrhages, a broken nose, a broken cheekbone, three broken ribs, and permanent damage to his left eye.
11.
Defendant Caldwell ended the attack after Mrs. Keane and several bystanders restrained him. 12.
Plaintiff was hospitalized for a month following the attack. 13.
Plaintiff continues to experience seizures and his left eye is permanently damaged. 14.
Due to his injuries,...
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