SUPERIOR COURT OF THE DISTRICT OF COLUMBIA, RECEIVED Civil Clerk's Office Civil Division Nov 2 5 2008 Superior Cour ot the District of Columbia Washington, D.C. Estate of ROBERT E. WONE, by KATHERINE E. WONE, as Personal Representative, 10415 Graystone Court Oakton, VA 22124, Civil Action No. Plaintiff, v. COMPLAINT JOSEPH R. PRICE, 1509 Swann Street, NW JURY TRIAL DEMANDED Washington, D.C. 20009 (Last known address), VICTOR ZABORSKY, 1509 Swann Street, NW Washington, D.C. 20009 (Last known address), and DYLAN WARD, 550 NE 94th St, Miami Shores, FL 33138, Defendants. NATURE OF ACTION 1. Thisis a civil action for damages under the laws of the District of Columbia for wrongful death, negligence, spoliation of evidence, and conspiracy. 2. This action arises from Defendants’ conduct prior to, during, and following the murder of Robert E, Wone on August 2, 2006, while he was a guest at Defendants’ home located at 1509 Swann Street, NW, in Washington, D.C. This lawsuit is based on Defendants’ intentional, reckless, and/or negligent acts that caused the death of Robert Wone, Defendants’negligent failure to rescue Robert Wone after he was injured, Defendants’ destruction of evidence of Robert Wone’s murder, and Defendants’ conspiracy to destroy evidence and obstruct the police investigation into Robert Wone’s murder. JURISDICTION AND VENUE 3. Jurisdiction is vested in this Court pursuant to D.C. Code § 11-921 (1981 ed. as amended). Jurisdiction is also vested pursuant to the Survival Act, D.C. Code § 12-101. 4. This Court has personal jurisdiction over the Defendants pursuant to D.C. Code §§ 13-422 and 13-423(a)(3). 5. Venue in this Court is proper because a substantial part of the events or omissions giving rise to this action occurred in the District of Columbia. PARTIES AL Plaintiff 6. Plaintiff Katherine E. Wone is the Personal Representative of the estate of her deceased husband, Robert Wone, who was murdered while he was a guest in Defendants’ home. Katherine Wone is a resident and citizen of the Commonwealth of Virginia. She was married to Robert Wone from June 7, 2003 until his death in August 2006. 7. Robert Wone was, at all relevant times, a resident and citizen of the Commonwealth of Virginia. Prior to his murder, Robert Wone was a successful lawyer practicing in the District of Columbia as the General Counsel for Radio Free Asia. He was an active member of the community who served on the board of several non-profit organizations and was president-elect of the Asian Pacific American Bar Association. He was a loving and caring husband to Plaintiff Katherine Wone.B. Defendants 8. Defendant Joseph Price, an attorney, was until recently a resident and citizen of the District of Columbia, residing at 1509 Swann Street, NW. Defendant Price and Robert Wone first met and became friends in the 1990s when they were undergraduate students at the College of William and Mary. On or about November 20, 2008, Defendant Price was indicted for obstruction of justice in connection with Robert Wone's murder. 9. Defendant Victor Zaborsky was until recently a resident and citizen of the District of Columbia, residing at 1509 Swann Street, NW. On or about November 20, 2008, Defendant ‘Zaborsky was indicted for obstruction of justice in connection with Robert Wone’s murder. 10. Defendant Dylan Ward is a resident and citizen of Florida, residing at $50 NE 94th Street, Miami Shores. At the time of Robert Wone’s murder on August 2, 2006, Ward resided at 1509 Swann Street, NW, in Washington, D.C. Defendant Ward’s bedroom was on the same floor as the guestroom where Robert Wone’s body was discovered. On or about November 20, 2008, Defendant Ward was indicted for obstruction of justice in connection with Robert ‘Wone’s murder. 11. Defendants Price and Zaborsky are domestic partners. Defendants Price and ‘Ward were involved in a personal, intimate relationship at the time of Robert Wone’s murder. FACTS A Robert Wone’s Murder 12. Sometime during the evening of August 2, 2006, Robert Wone arrived at 1509 Swann Street, NW, as Defendants’ invited guest. Robert Wone had previously made plans with Defendant Price to spend the night as a guest at Defendants’ home. 13. At 11:49 PM, Defendant Zaborsky called 9-1-1 to report that Robert Wone had been stabbed. Less than 6 minutes into the 9-1-1 call, two emergency medical service (“EMS”) 3.