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1 but not limited to failing to supervise and train their employees and by engaging in a

2 cheating scheme. The Defendant Astros ’ sign stealing scheme involved the use of a
3 camera positioned in center field to steal signs. Te am personnel from the Defendant
4 Astros would watch the feed in a hallway between the clubhouse and dugout and
5 would relay what was coming to the hitter by hitting a garbage can. A “bang” usually
6 meant that an off -speed pitch was coming, and the Defendant Astros’ personnel did
7 not make any noise when a fastball was coming.
8 75. As a direct and proximate result of Defendants’ wrongful conduct,
9 Plaintiff Bolsinger ’s prospective economic relationships, including his relationship
10 with the Toronto Blue Jays, was disrupted, and Plaintiff Bolsinger incurred special
11 and general damages in an amount to be proven at trial.
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13 PRAYER FOR RELIEF
14 WHEREFORE, Plaintiff prays for judgment as follows:
15 1. For past and future general damages in an amount to be determined by
16 proof at trial;
17 2. For past and future special damages in an amount to be determined by
18 proof at trial;
19 3. For punitive and exemplary damages against the Defendants;
20 4. For costs of suit;
21 5. For reasonable attorney’s fees and costs as provided by statute; and
22 6. For such other and further relief as the Court deems just and proper.
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COMPLAINT FOR DAMAGES