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Tushar Singh v. Vegasstars LLC dba Dirty and Top Flyte Security LLC

Tushar Singh v. Vegasstars LLC dba Dirty and Top Flyte Security LLC

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Published by Law Works LLC
Tushar Singh suit against Portland's Dirty Night Club and Top Flyte Security LLC after being assaulted by security agent at Dirty Night Club
Tushar Singh suit against Portland's Dirty Night Club and Top Flyte Security LLC after being assaulted by security agent at Dirty Night Club

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Published by: Law Works LLC on Oct 20, 2011
Copyright:Attribution Non-commercial

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10/20/2011

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Page1-COMPLAINT (Negligence/Assault and Battery)
 
1234567891011121314151617181920212223242526IN THE CIRCUIT COURT OF THE STATE OF OREGONFOR THE COUNTY OF MULTNOMAHTUSHAR SINGH,Plaintiff,v.VEGASSTARS LIMITED LIABILITYCOMPANY dba DIRTY andTOP FLYTE SECURITY LLC,Defendants. No.COMPLAINT(Assault and Battery/Negligence)Amount of prayer: $530,000Filing Fee: $ 879.00(Not subject to mandatory arbitration)Plaintiff alleges:1.Plaintiff, Tushar Singh, is a resident of Washington County, Oregon.2.At all material times, defendant Vegasstars Limited Liability Company, dba Dirty(herinafter “Dirty”) was doing business in Multnomah County, Oregon3.At all material times, Top Flyte Security LLC (hereinafter “Top Flyte Security”)offered security services to Dirty and was doing business in Multnomah County, Oregon..4.At all material times, Christopher Lenahan was the primary member/owner of Dirty.5.At all material times, Top Flyte Security provided security service personnel to Dirty.6.On August 14, 2011, Tushar Singh was a patron at Dirty, enjoying an evening of dancing with friends. Tushar Singh was wearing a turban on his head.
 
Page2-COMPLAINT (Negligence/Assault and Battery)
 
12345678910111213141516171819202122232425267. Near closing time, Tushar Singh passed behind a person working for and on behalf of defendants.8.Without justification, the security personnel made uninvited physical contact withTushar Singh, charged Tushar Singh, and forced Tushar Singh’s head onto a dancing platform, causing a cut deep into Tushar Singh’s head. Upon information and belief, Tushar Singh was the only person wearing a turban who left Dirty with serious head wounds thatnight.9.Defendants, jointly and severally, owed a duty to Tushar Singh to ensure that he wasnot hurt by defendants’ agents while a patron at Dirty. Defendants, jointly and severally breached that duty and were negligent in causing injury to Tushar Singh while he was atDirty and/or in failing to properly train their security agents not to engage with patrons in away that resulted in bodily injury.10.As a result of defendants’ negligence, Tushar Singh suffered approximately 30stitches to his face, permanent scarring, head trauma, and resulting anxiety.11.As a direct and proximate result of defendants’ negligence, Tushar Singh has sufferedand will suffer economic damages in terms of medical expenses in an amount to be proven attrial, but in an amount not more than $30,000.12.As a direct and proximate result of defendants’ negligence, Tushar Singh has sufferedand will suffer non-economic damages related to his pain and suffering in an amount to be proven at trial, but not more than $500,000.////
 
Page3-COMPLAINT (Negligence/Assault and Battery)
 
1234567891011121314151617181920212223242526WHEREFORE, plaintiff prays for judgment against defendants for $30,000 economicdamages and $500,000 non-economic damages, plus his costs and disbursements for thislitigation. Plaintiff notifies defendants of his intent to amend the complaint to add a claim for  punitive damages.DATED: October 20, 2011.LAW WORKS LLC Lake James H. Perriguey OSB No. 983213Plaintiff’s attorney

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