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IN THE COURT OF COMMON PLEAS OF LUCAS COUNTY, OHIO

PAULA PLAINTIFF 1234 Erie Street Sylvania, OH 43560 and PETER PLAINTIFF 1234 Erie Street Sylvania, OH 43560

Plaintiff,

v.

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) ) )

Case No. CI- __________________

JUDGE ______________________

COMPLAINT FOR BATTERY WITH JURY DEMAND

DAVID DEFENDANT 9876 Monroe Street Toledo, OH 43606

Defendant

) ) ) ) ) ) ) )

Gary Horn (0016297)


Dewey, Cheatham, and Howe Law Office

1796 Indian Wood Circle Maumee, OH 43537 (419) 866-0261 Attorney for Plaintiff

Now comes Plaintiff, Paula Plaintiff, by and through counsel, Gary Horn, and alleges and avers the following:

GENERAL ALLEGATIONS

1. That at all relevant times, Plaintiff, Paula Plaintiff, resided in Lucas County at 1234 Erie Street, Sylvania, OH 43560. 2. That at all relevant times, Defendant, David Defendant, resided in Lucas County at 9876 Monroe Street, Toledo, OH 43606. 3. That on October 15, 2012, Ms. Plaintiff was employed and working as a youth soccer referee at Pacesetter Park in Sylvania, OH. 4. That on October 15, 2012, during the course of the game, Ms. Plaintiff made a ruling of intentional tripping on Defendants son and issued him a yellow card. 5. That Defendant disputed the ruling. 6. That in conjunction with his dispute, Defendant entered the field of play and struck Ms. Plaintiff in the face. COUNT ONE: BATTERY 7. Ms. Plaintiff incorporates herein the allegations previously stated in Paragraphs 1 - 6 and further alleges that as a direct and proximate result of Defendant's conduct, Plaintiff suffered a dislodged tooth filling, nosebleed, and laceration to the lip. 8. Ms. Plaintiff further alleges that as a direct and proximate result of Defendant's conduct, she incurred medical and dental bills, lost wages, extreme emotional distress, pain and suffering, and loss of consortium with her husband, co-plaintiff, Mr. Plaintiff. 9. Mr. Plaintiff alleges that as a direct and proximate result of Defendant's conduct, Mr. Plaintiff suffered loss of consortium with his wife.

WHEREFORE, Plaintiff, Mrs. Plaintiff and co-plaintiff Mr. Plaintiff respectfully pray for judgment on the above mentioned count against Defendant, David Defendant, for an award of damages in a sum of money in excess of Forty-five Thousand, Seven Hundred and Fifty Dollars, adequate to compensate her for medical and dental expenses, lost wages, therapy, pain and suffering, loss of consortium, attorneys fees, court costs, and such other relief as the Court deems just and equitable.

Respectfully submitted, ___________________________ Gary Horn Attorney for Plaintiff

JURY DEMAND Now comes the Plaintiff and demands a jury on all issues triable by right before a jury. ___________________________ Gary Horn Attorney for Plaintiff

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