TheLaw Of Willie W, Williams Law Business © Ral Exot Employment i {GENE SIMMONS, KISS CO-FOUNDER AND ROCK & BREWS SPOKESMAN, ‘SUED FOR SEXUAL MISCONDUCT December 15, 2017 ~Today, a radia/televsion broadcaster filed a lawsuit against KISS co- ‘founder and Rock & Brews spokesman, Gene Simmons, for unwarranted, unwanted sexual advances and touching, and battery, The lawsutt, fled under the pseudonym, “Jane Doe,” stems from an on-camera interview with the female host to promote the opering of anew location of Rock & Brews restaurant in San Bernardino County, California. Thelawsuit alleges that, during the interview, Mr. Simmons made several aggressive, unwanted sexual advances, despite Jane Doe's active and clear discouragement. The entre interview was captured on video. The lawsuit comes during the midst ofa troubling tour by the 68-year-old Simmons, as he ‘Promotes his new book, On Power. A couple of weeks following this incident, tr. Simmons earned a lifetime ban from FOX News studios fr allegedly exposing his torso to staff members and shouting: “Hey chicks, sue mel” By taunting women, through his bold and sexist statement, Mr. Simmons is acknowledging that he must, too, be held accountable for his offensive and violent behavior. Jane Doe decided to take him up on his offer of accountability. When interviewed recently on the TODAY Show, Mr, Simmons stated that he was glad that ‘women were speaking out against sexual harassment and that he “wanted theJackasses to €o 10 jall for being improper.” witnesses, including the camera technician, on the set were “mortified at the unbelievably, bizarre, sexually-charged antics and physical attack” that Mr. Simmons depicted on camera ‘This awsult, which has been filed in Los Angeles County Superior Court, names Mr. Simmons, Individually, and Rock & Brews restaurant because Mr. Simmons, at the time of the incident, was acting as the Global Spokesperson for the restaurant chain. The lawsuit aleges causes of action for: (1) sexual battery; (2) gender violence; (3) battery; (4) assault; (5) negligent retention or supervision: (6) ender discrimination (Unruh Act): and (7) negligent nflitin of emotional distress. (Py sonstane +) suyse49300 9527 Fivay iw a, Seite 14 Scho Caang, (491798 Wek: wuninlleviensoncen * mai vnw@Dwilewihensie-cm,1 16 ” 18 » | | ecm age Wale W, Wittams, Bar No, 233002 gainer ee Theltaw Oftes of Wile W. Willans coger Soest 932} ones Flac Suite 104 Lon Aneiee ao Cutnge CA 91730 bec 15 2017 SE elo gga iiewihiemaw som nai iat | Atigmey for PLAINTIFF JANE DOE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - STANLEY MOSK COURTHOUSE CIVIL UNLIMETED ‘DOE, anindiviaual, ~~ x 6e7126 PLAINTIFF, COMPLAINT FOR DAMAGES: 1, SEXUAL BATTERY IN iE KLBIN, aka GENE SIMMONS, en VIOLATION OF CAL. CIV. OCK & BREWS HOLDINGS, ‘CODE § 1708.5 Lg, a Celiforria limited lability company: 2, GENDER VIOLENCE IN |ROUK AND BREWS HOLDINGS, INC, « VIOLATION OF CAL. CIY. elhware corparation; ROCK & BREWS, LLC, CODE § 52, Cpliforia limited liability company; ROCK & ) 3. BATTERY 'WS FRANCHISING, LLC, a California 4 ASSAULT bility company, snd DOES 1-25, 5. NEGLIGENT RETENTION OR achive, SUPERVISION } 6. GENDER DISCRIMINATION (UNRUEACT) DEFENDANTS. 7. NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS DEMAND FOR JURY TRIAL a a PLAINTIFF JANE DOE, an individual, sues GENE KLEIN, aka GENE 'SIMMONS ("SIMMONS"); ROCK & BREWS HOLDINGS, LLC, a California limited labiity lcontpany: ROCK AND BREWS HOLDINGS, INC.,« Delaware corporation; ROCK & S, LLC, & California limited ability company; ROCK & BREWS FRANCHISING,a LLC, a California limited liability company (collectively, “ROCK & BREWS"); and DOES 1- 25, inclusive (collectively, “DEFENDANTS"), and in suppor thereof state as follows: PARTI 1, tall relevant times, PLAINTIFF JANE DOE (“PLAINTIFF”), who isa female, isa resident of he Slate of California. Due to both privacy and safety concems, PLAINTIFF sues under the pseudonym, “JANE DOE,” 2. DEFENDANT GENE KLEIN, aka GENE SIMMONS (“DEFENDANT SIMMONS") isan individual residing in and doing busines inthe State of California 3. DEFENDANT ROCK & BREWS HOLDINGS, LLC is a California limited lability company. PLAINTIFF is informed and believes, and on tat basis alleges, that it principal place of business is in Los Angeles County. 4, DEFENDANT ROCK AND BREWS HOLDINGS, INC. is a Delaware Jcomoration. PLAINTIFF is informed and believes, and on tat basis alleges, tha its prineipal| place of business isin Los Angeles County 5. DEFENDANT ROCK & BREWS, LLC is a Califomia limited lisbility| Jcompany. PLAINTIFF is informed and believes, and on that bass alleges, that its principal place of business isin Los Angeles County 6, DEFENDANT ROCK & BREWS FRANCHISING, LLC is a Calforia| imited lability company. PLAINTIFF is informed and believes, and on that basis alleges, that ts principal place of business is in Los Angeles County. 7. DEFENDANTS Does 1 through 25, inclusive, are included in the| jous names. The true names and capacies are unknowm to PLAINTIFF. ] Complaint under When the tre names and capacities are ascertained, PLAINTIFF will amend this Complaint by inserting the true names and capacities herein, PLAINTIFF is informed and believes and thereupon alleges that each of the fictiiously named DEFENDANTS was and is responsible in some manner for the occurrences alleged herein, and that PLAINTIFF'S damages as alleged herein, were proximately caused by such DEFENDANTS.a 8 DEFENDANTS are subject to suit under California aw, ineluding under the California Code of Civil Procedure 9. Venue is proper because DEFENDANT SIMMONS resides in Los [Angeles County and the principal place of business of DEFENDANT ROCK & BREWS is in Los Angeles County. ‘The relief requested is within te jurisdiction of this Cour. STATEMENT OF FACTS 10, DEFENDANT SIMMONS is an intemationally renown bassist and co- founder ofthe rock band KISS. The band has 2old over 100 million CDs and DVDs worldwide, 11, Inaddition o his musical career, DEFENDANT SIMMONS is a member of the Executive Team of ROCK & BREWS, which is resturant chain based in Los Angeles ‘County. As a member ofthe Executive Team, DEFENDANT SIMMONS is one of two "Global Spokesmen” or "Rock & Roll Ambassadors." In this eapacity, DEFENDANT SIMMONS regularly travels to promote the ROCK & BREWS restaurants around the country. 12, ROCK & BREWS is in the midst of an aggressive expansion of its restaranis, Recently, ROCK & BREWS opened a locaton in San Bernardino County. In| conjunction with the opening, ROCK & BREWS conducted events in order to promote the restaurant. DEFENDANT SIMMONS, along with KISS co-founder (Le, Paul Staley), traveled tothe restaurant to conduct interviews and promote «grand opening event 13. PLAINTIFF DOE is a long-time on-air personality for a local rock: station, In addition to her presence on radio, PLAINTIFF DOE, for many years, has appeared on local television shows where she ha interviewed numerots prominent individuals. 14, PLAINTIFF DOE, through her emerging me interview with Mr. Stanley and DEFENDANT SIMMONS. PLAINTIFF DOE was not involved in the logistics ofthe interview, but arived there on November 1, 2017, to conduct the interview with her team. She was accompanied by another local rock band member and on-air ia company, was granted an personality, to assist with the interviews, She also brought a camera technician to film the! interviews, which were being filmed for possible use on pilot program focused on news for rock fans in the Inland Empire.1 15. When PLAINTIFF arrived atthe new San Bernardino County restaurant, 2 | there was « couch inthe "green room" designated fr the interview location, which was inside 2 | the restaurant. PLAINTIFF DOE sat between DEFENDANT SIMMONS and the male co- «| interviewer, who held a portable recording device to record the audio during the interview. : 16, Soon ater the interview commenced, DEFENDANT SIMMONS reached 5 || over and grabbed PLAINTIFF DOE's hand and, forcefully, placed it on his knee and held it on > ||his knee. Immediately, PLAINTIFF DOE, feeling that this was an unvanted sexual advance, nervously yet immediately, removed her hand from his knee. Despite feeling extremely + |] uncomfortable, PLAINTIFF DOE continued the interview. DEFENDANT SIMMONS, however, continued his unwanted, unwarranted sexual advances by reaching for PLAINTIFF 11 ||DOE’s hand again. PLAINTIFF DOE, however, was able to push his hand away with her elbow 12 | bore he touched her hand. » 17, ‘Throughout the interview, DEFENDANT SIMMONS turned standard | 11 |finterview questions into sexual innuendos, which made PLAINTIFF DOE extremely 15 |] uncomforable. DEFENDANT SIMMONS then made another attempt to grab PLAINTIFF 15 || DOE's hand and was successful in grabbing her hand. Upon feeling her hand, DEFENDANT | 17 J]SIMMONS then commented with a cooing sound, that she "must use lotion” and then 18 || proceeded with another sexual innuendo directed at PLAINTIFF DOE. PLAINTIFF DOE was 1s || visibly powerles, as demonstrated by moving her hands ina nervous fashion. 20 18 Shorly after, DEFENDANT SIMMONS sbruptly reached over to 1 | PLAINTIFF DOE and forcibly Aicked/stuck PLAINTIFF DOE in the middle of her throat. 22 ||Upon observing the impact of the hit and the reaction of shock by the co-host, DEFENDANT 23 || SIMMONS provided an incoherent explanation for Hickingstriking her throat. Following this 24 ||bizare behavior, PLAINTIFF DOE did her best to prompily terminate the interview, but 25 || DEFENDANT SIMMONS continued 10 demonstrate his known power-raged persona by 2 || wanting to continue the interview. n 19. ‘The interview concluded, earlier than expected due to DEFENDANT] 28 || SIMMONS’ sexually-charged and physical actions. Following the interview, PLAINTIFF DOE2 agreed to take customary promotional pictures. As they were beginning to pose for a group picture, DEFENANT SIMMONS reached towards PLAINTIFF DOE's butocks and touched it Again, PLAINTIFF DOE kept her composure and discreetly moved away. They took the pictures, but PLAINTIFF DOE declined the invitation to "stay around." HIRST CAUSE OF ACTION (Sexual Battery ~ Violation of California Civil Code §§ 17085) (Against All DEFENDANTS) 20, PLAINTIFF re-alleges, and incorporates by reference as if fully set forth herein, paragraphs | through 19 above 21. Atal times mentioned in the Complaint, California Civil Code section 1708.5, was in fll force and effect, and was binding on DEFENDANT SIMMONS. Celifornia Civil Code Section 1708.5 provides: a) a person commits asexual battery who does any ofthe following: (1) acts withthe intent to cause a harmful or offensive contact with an intimate part of another, and 2 sexually offensive contact with that person direily or indirectly results, (2) acts withthe intent to cause a harmful or offensive contact with another by use of his or her intimate pan, and asexually offensive contact with that person dreily or indirectly results, (3) cts to cause an imminent apprehension of the conduet described in paragraph (1) or (2), and a sexually offensive contact with that person directly or indirectly results 22. Califomia Civil Code Section 1708.5 (d) defines “intimate part” as the sexual organ, anus, groin, or buttocks of any person, or the breast ofa female. 23. California Civil Code Section 1708.5 (1) defines “offensive contact” as a reasonable sense of personal dignity 24. ROCK & BREWS and DOES 1-25 are liable for DEFENDANT! |SIMMONS’ actions under the principles of respondeat superior, ROCK & BREWS and DOES 1-25 otherwise had advanced knowledge that DEFENDANT SIMMONS would engage in the unlawful conduct based on previous complaints and lawsuits alleging sexual misconductas 25, DEFENDANT SIMMONS commited the act of sexual battery in| siolation of California Civil Code Section 1708.5, when he touched her buttocks without her Jconsent and after she clearly rejected his sexual advances and unauthorized touching. This contact was sexually offensive 26, As a proximate result of DEFENDANT SIMMONS" unlawful conduct described above, PLAINTIFF has suffered severe emotional distress, humiliation, embarrassment, menial and emotional distress and anxiety in an amount according to proof at tsa. 27. As a proximate result of DEFENDANT SIMMONS’ unlawful conduct described above, PLAINTIFF has suffered ezonomic ham, loss of earings, and others damages, an amount according o proof at tial. 28. PLAINTIFF is informed and belioves, and on that bass alleges thet, DEFENDANT SIMMONS acted jous, and conscious dlisegard of| PLAINTIFF's rights and feelings. 29. PLAINTIFF is further informed and believes, and on that basis alleges willful, mali that, DEFENDANT SIMMONS intended to cause fear, physical injury and/or pain and suffering to PLAINTIFF. 30. As a proximate result of DEFENDANT SIMMONS’ unlawful conduct, PLAINTIFF is entitled to recover punitive and exemplary damages according to proof at trial 31. PLAINTIFF also seeks declaratory relief as set forth below. SECOND CAUSE OF ACTION (Gender Violence ~ Violation of California Civil Code § 52.4) (Against All DEFENDANTS) 32. PLAINTIFF re-alleges and incorporates by reference as if fully set forth paragraphs 1 through 19 above. 33. Atal times mentioned above, California Civil Code section 52. full force and effect, and was binding on DEFENDANT SIMMONS. California Civil Code] ‘Section 52.4(c) defines "gender violence” as of the fellowing: (1) one or more acts thatwould constitute a criminal offense under state law that has as an element the use, attempted use, or threatened use of physical force against the person or property of another, committed at least in part based on the gender of the victim, whether or not those acts have tesulted in criminal complaints, charges, prosecution, or conviction, (2) a physical intrusion or physical invasion ofa sexual nature under coercive conditions, whether or not those acis have resulted in criminal complains, charges, prosecution, ar conviction, California Civil Code Section 52.4(@) provides: Not withstanding any other laws that may establish the Habilty ofan employer for the acts of an employee, this sectian does not establish any civil liability of a perton beceuse of hie ‘or her status as an employer, unless the employer personally committed an act of gender violence. 34. ROCK & BREWS and DOES 1-25 are liable for DEFENDANT, 'SIMMONS" actions under the principles of respondeat superior. ROCK & BREWS end DOES 1.25 otherwise had advanced knowledge that DEFENDANT SIMMONS would engige in the ‘unlawful conduct based on previous complaint and lawsuits alleging sexual misconduct. 35. PLAINTIFF further alleges that DEFENDANT SIMMONS violated F that constitute « criminal California Civil Code Section 52.4 by inflicting acts on PLAINTI offense understate law that has an element of use, attempted use, or threatened use of physical at least in part based on PLAINTIFF's gender, whether of| force aginst PLAINTIFF, com not those acts have resulted in criminal complaints, charges, prosecution, or conviction 36. _Asalleged above, DEFENDANT SIMMONS used physical force against PLAINTIFF by flicking her throat and touching her buttocks. DEFENDANT SIMMONS subjeted PLAINTIFF fo unlawful conduct 37. As a proximate result of DEFENDANT SIMMONS’ conduct, PLAINTIFF has suffered physical injury, severe emotional distess, humiliation, embarassment, mental and emotional distress, and anxiety, in an amount according to proof st vil2 Fy 38. Asa proximate result of DEFENDANT SIMMONS’ unlawful conduct, PLAINTIFF has suffered economic harm and other consequent 1 damages, in an amount according to proof a trial 39. PLAINTIFF is informed and believes, and on that basis alleges thet, DEFENDANT SIMMONS acted in a wilful, malicious, and conscious disregard for PLAINTIFF's rights and feelings. 40. PLAINTIFF is further informed and believes, and on that basis alleges| that, DEFENDANT SIMMONS intended to cause fear, physical injury and/or pain and suffering to PLAINTIFF. 41, As a proximate result of DEFENDANT SIMMONS? unlawful conduct, PLAINTIFF is entitled wo recover punitive and exemplary damages according to proof at tl 42. PLAINTIFF also seeks declaratory relief 43. PLAINTIFF has incurred and continues to incur legal expenses and atiomey fees. PLAINTIFF is presently unaware of the precise amount of these expenses and. fees. At the proper ime, PLAINTIFF will provide support for the precise amount sought ‘THIRD CAUSE OF ACTION (Battery) (Against All DEFENDANTS) 44, PLAINTIFF re-alleges and incorporates by reference as if fully set forth herein, paragraphs I through 19 above. 45, ROCK é& BREWS and DOES 1.25 are liable for DEFENDANT |SIMMONS’ actions under the principles of respondeat superior. ROCK & BREWS and DOES 1-25 otherwise hed advanced knowledge that DEFENDANT SIMMONS would engage in the ‘unlawful conduct based on previous complaints and lawsuits alleging sexual misconduct. 46, As explained in more detail above, DEFENDANT SIMMONS not only acted with the inter: to make a harmful end offensive contact with PLAINTIFF but, infact, [engaged inthe offensive and unwelcome contact with PLAINTIFF by grabbing her hand twice, flicking her throat, and touching her buttocks.1 47. Atall times mentioned in this Complaint, PLAINTIFF didnot consent to 2 ||such contact by DEFENDANT SIMMONS and found the conact to be offensive to her 2 | personal sense of dignity. 4 48, As. proximate result of DEFENDANTS" unlawful conduct, PLAINTIFF 5 |) nas suffered physical injury, severe emotional distress, humiliation, embarrassment, mental and « |] erotional distress, and other consequential damages, in an amount secording to proof at tril, 7 49. PLAINTIFF is informed and believes, and on that basis alleges that, ¢ |] DEFENDANTS acted ina wilfl, malicious, and conscious disrgard for PLAINTIFF's rights «|| and fetings. 10 50, Asa proximate result of DEFENDANTS" unlawful condvet, PLAINTIFF 12 [fis entited to recover punitive and exemplary damages according o proof a ial 2 FOURTH CAUSE OF ACTION a (Assaul u (Against All DEFENDANTS) 8 51. PLAINTIFF re-alleges and incorporates by reference as if fully set forth 26 || nein, paragraphs 1 through 19 above. 52. ROCK & BREWS and DOES 1-25 are lisble for DEFENDANT 18 || SIMMONS: actions under the principles of respondeat superior. ROCK & BREWS and DOES 15 ||1-25 otherwise had advanced knowledge that DEFENDANT SIMMONS would engage inthe 20 | uninwful conduct based on previous complaints and Iawsuils alleging sexual misconduct a 53. Based on his conduct, PLAINTIFF believes that DEFENDANT 22 || SIMMONS touched PLAINTIFF with the intent to cause harm or offend her. 2 ‘54, Atal times mentioned in the Complaint, PLAINTIFF did not consent to 2 || such contact by DEFENDANT SIMMONS and found the contct to be offensive to her 2s || personal sense ofeigity. a 55. As explained in more detil above, DEFENDANT SIMMONS caused 27 [PLAINTIFF appretension that he would subject her to further intentional invasions of her right 28 || tobe fiee from offensive and harmful contact.1 56. Asa proximate result of DEFENDANTS! unlawful conduct, PLAINTIFF 2 |} has suffered physical injury, severe emotional distress, humiliation, embarrassment, mental and 3 || emotional distress, and other consequential damages, in an amount according to proof at tril ‘ 57. PLAINTIFF is informed and believes, and on that basis alleges that, 5 || DEFENDANTS acted in a willful, malicious, and conscious disregard for PLAINTIFF rights 3 || and feetngs. , 58. Asa proximate result of DEFENDANTS unlawful conduct, PLAINTIFF » | is eauted to recover punitive and exemplary damages according to proof a tal > EIETH CAUSE OF ACTION (Nesligent Retention or Supervision) " (Against DEFENDANT ROCK & BREWS) » 59, PLAINTIFF realleges and incorporates by reference as if fully set forth 1 | herein, paragraphs | through 19 above. u 60, ROCK & BREWS, by and through ther agents, servants and employees, 1+ ||knew oF reasonably should have known of DEFENDANT SIMMONS’ long and well-known 16 || history of abusing and sexually harassing women based on sex. ROCK & BREWS and DOES 27 |]1-25 otherwise had advanced knowiedge that DEFENDANT SIMMONS would engage inthe 1 || unlawfil conduct based on previous complaints and lawsuits alleging sexial misconduct. 13 61, DEFENDANT ROCK & BREWS negligently etined and/or supervised 10 || DEFENDANT SIMMONS in the position of trust and authority as principal and one of their 2 ||+Rock & Roll Ambassadors” where he was able to commit the wrongful ats that violated c 22 ||law against PLAINTIFF. a 62, DEFENDANT ROCK & BREWS had a mandatory duty to contol 24 || DEFENDANT SIMMONS in his interactions with women during interviews taking place within 25 |) the course and scope ofhis employment in order to prevent the reasonably foreseeable harm that 2 | he would sexually harass and/or sexually assault them, n 63. DEFENDANT ROCK & BREWS' negligence in supervising andlor 1g DEFENDANT SIMMONS was a substantial factor in causing PLAINTIFF'S harm,™ 26 64, Asa proximate result of DEFENDANT ROCK & BREWS’ unlawful conduct, PLAINTIFF has suffered emotional distress, humiliation, embarrassment, and economic harm, in an amount according to proof at trial 65, PLAINTIFF is informed and believes, and on that basis alleges that, DEFENDANT ROCK & BREWS acted in a conscious disregard for PLAINTIFF'S sights and, feelings. DEFENDANT ROCK & BREWS were aware of the probable harmful consequences lof retaining or adequately supervising DEFENDANT SIMMONS and allowing him to meet ‘vith women in the postion of trust and authority asa principal and one oftheir “Rock & Roll Ambassadors.” DEFENDANT ROCK & BREWS acted with knowledge and/or reckless disregard for the fact that DEFENDANT SIMMONS’ conduct was certain to cause injury andlor harm and humiliation to PLAINTIFF. 66. Asa proximate result of DEFENDANT ROCK & BREWS negligence, PLAINTIFF is led to recover punitive and exemplary damages according to proofat trial. ‘SIXTH CAUSE OF ACTION (Gender Discrimination-Unrub Civil Rights Act) (Against all DEFENDANTS) 67. PLAINTIFF re-alleges and incorporates by reference as if fully set forth herein, paragraphs 1 trough 19 above. 68 Atall times mentioned above, California Civil Code §§ $1, er ep, was in ful force and effect and was binding on DEFENDANTS. This statute requires DEFENDANTS to refain from discriminating against any person in this state onthe basis of sex, among other things. 69, _Asexplained above, DEFENDANTS treated PLAINTIFF differently than others based on her gender (ie. female) and did not engage inthe same conduct with ber male [co-host . Such discrimination isin violation of California Civil Code §§ 51, er seq. and has resulted in damage and injury to PLAINTIFF. 70, Asa proximate result of DEFENDANTS’ willful, knowing and intentional discrimination, PLAINTIFF has suffered hares, humiliation, embarrassment, emotional distress,aw nb and mental and physical pain and anguish, PLAINTIFF is thereby entitled to general and compensatory damages in amounts to be proven at trial Tl. PLAINTIFF bas incurred and continues to incur legal expenses and attomey fees. Plaintiff is presently unaware ofthe precise amount of these expenses and fees. At the proper time, PLAINTIFF will provide support for the precise amount sought SEVENTH CAUSE OF ACTION (Negligent Infliction of Emotional Distress) (Against all DEFENDANTS) 7. PLAINTIFF re-alleges and incorporates by reference as if fully set forth herein, paragraphs 1 through 19 above. 73, At all relevant times, DEFENDANTS owed PLAINTIFF a duty to act with reasonable care. 74, Atall relevant times, DEFENDANTS kaew that harm andlor injury tothe PLAINTIFF was reasonably foreseeable if such duty of care were breached. 75. tall relevant times, DEFENDANT had the power, ability, authority and Jduty t0 stop engaging in the conduct described herein and te intervene to prevent or prohibit such conduct. 76. Atall relevant times, DEFENDANTS knew, or reasonably should have_ known, that the conduct described herein would and did proximately result in physical and! ‘emotional distress to PLAINTIFF, 77. Despite said knowledge, power, and duty, DEFENDANTS breached thir duty to PLAINTIFF, and thereby negligently filed to act so as to stop engaging in the conduct described herein, 78. AS a direct and legal result of DEFENDANTS” negligent acts, PLAINTIFF suffered significant physical injury, pain and suffering and extreme and severe mental anguish and emotional distress.2 DEI RY TRIAL PLAINTIFF hereby demands jury tal as 10 all matters alleged in this Corgplin to which PLAINTIFF ia entitled to jury tral, For All Causes of Action: PRAYER FOR RELIEF WHEREFORE, PLAINTIFF prays for relief egsinst DEFENDANTS as follows: |. For a money judgment representing compensatory damages including consequential damages, lost wages, eninge, and all other suns of money, together with interest on these emounts, ecaording to proof, 2% For en award of money judgment for mental pala end aaguish and severe ‘motional distres, humiliation, and embarassment, uccordng to proof, 3. Por prejudgment and post judgment interest and 4. For such other and further relief asthe Court nay deen just and proper. For{cmuses of Action One Through Five: - {Cause of Aston Two and Six 5. For punitive and exemplary damages according to proof; 5. Forreasonable attorneys! fees and costs; Dessaert5,2017 Te Lev oes of Wile W. Wiis pr Dh Willie W. Williams Attomey for Plaisift