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Complaint: The document begins with a formal complaint outlining the legal grievances filed by the plaintiff against the defendants.
Parties: Introduces the involved parties including the plaintiff and defendants, along with their legal and personal identifications.
General Allegations: Details the general allegations concerning the activities and relationships between the parties involved in the lawsuit.
Count I: Assault and Battery: Outlines specific allegations of assault and battery against Defendant Jeffrey E. Rash, including factual and legal assertions.
Count II: Negligence and Gross Negligence: Describes charges of negligence and gross negligence against the defendants, with an emphasis on duty of care violations.
Count III: Negligence from Special Relationship: Addresses negligence stemming from the special relationship between the parties, focusing on custody and supervisory duties.
Count IV: Vicarious Liability: Charges the defendants with vicarious liability for the actions of their agents within the scope of employment.
Count V: Negligent Retention: Accuses the defendants of negligent retention of Jeffrey Rash, elaborating on the risks and harms facilitated.
Count VI: Assault under New York Law: Details accusations of assault and battery specific to incidents occurring in New York under applicable state laws.
Count VII: Negligence under New York Law: Covers charges of negligence, including gross negligence, relating to events in New York and the associated responsibilities of the defendants.
Count VIII: Breach of Duty under New York Law: Discusses the breach of duty allegations related to special relationships and failures of oversight as per New York law.
Count IX: Vicarious Liability under New York Law: Addresses vicarious liability specifically under New York jurisdiction, emphasizing the legal theories supporting it.
Damages: Summarizes the sought damages, narrating the sufferings and financial implications on the plaintiff.
Jury Demand: Formally demands a jury trial for the case, outlining issues for determination.
Uploaded: 2021AUG13 13:24 Filed By:KVANBOENING on behalf of Bar# 92109 KBINIAZAN Reference: EF-88799