STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
IvanKrizan,
Plaintiff,
v.
Icecreaman2019,
Defendant.
Case Number: RSC-CV-3392
Presiding: Hon. bommes
CIVIL COMPLAINT
CIVIL COMPLAINT
PLAINTIFF, IvanKrizan, by and through the undersigned counsel, alleges the
following:
JURISDICTION & VENUE
1. The court has jurisdiction to hear “all civil and criminal cases or controversies.”
Ridgeway State Constitution Article V, Section IV.
2. Venue is proper as the tortious actions alleged herein took place in Ridgeway County,
Ridgeway.
PARTIES
3. IvanKrizan (“Plaintiff”) is a resident of Ridgeway County. He is also a citizen of the State
of Ridgeway—his place of business and personal home address is unknown; but it is
understood that he resides within the applicable jurisdiction as hereinafter referenced and
applied in this case. Plaintiff is a delivery driver employed by a business entity referred to
as StudsPerSecond.
4. Icecreaman2019 (“Defendant”) is a resident of Ridgeway County. He is also a citizen of
the State of Ridgeway—his personal home address is unknown; but it is understood that
he resides within the applicable jurisdiction as hereinafter referenced and applied in this
case.
FACTS
5. On or about August 4, 2024, Plaintiff completed his duties as a delivery driver and was
en route to the Milton warehouse in a Rotero service vehicle provided by
StudsPerSecond.
6. While departing from Palmer City in the right lane of a road, Plaintiff briefly stopped his
vehicle to comply with a stop sign. The Defendant was in another vehicle positioned in
the adjacent left lane.
7. Defendant promptly exited his vehicle and approached Plaintiff's vehicle in the right lane
on foot. Upon reaching Plaintiff’s vehicle, Defendant began jumping near its entrance.
8. After being unable to enter the Plaintiff’s vehicle, the Defendant drew a firearm and
aimed it at Plaintiff through the open entrance of his vehicle. Defendant then discharged
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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multiple rounds of ammunition at the Plaintiff, resulting in grievous bodily harm to the
Plaintiff and damage to his vehicle.
9. Plaintiff, fearing for his life, rapidly performed a right turn and drove toward the Milton
warehouse to escape the Defendant.
10. As Plaintiff attempted to flee, Defendant reloaded his weapon and maliciously pursued
him on foot, firing numerous shots into the rear of the Plaintiff’s vehicle.
FIRST CAUSE OF ACTION
BATTERY - 1 R. Stat. § 3102
1. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
2. Pursuant to 1 R. Stat. § 3102, “Any individual who brings unconsented harmful or
offensive contact against another person is battery and shall be liable for punitive
damages up to $4,500.” Id.
3. Defendant, by discharging a firearm at Plaintiff without consent and thereby causing
grievous bodily harm, committed “unconsented offensive or harmful offensive contact
against another person…” Id., making Defendant liable for battery.
SECOND CAUSE OF ACTION
ASSAULT - 1 R. Stat. § 3103
4. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
5. Pursuant to 1 R. Stat. § 3103, “Any individual who intentionally and voluntarily caused
reasonable apprehension of an immediate harmful or offensive contact is assault and shall
be liable for punitive damages up to $3,500.” Id.
6. Defendant, by knowingly and willingly brandishing a firearm and discharging
ammunition at Plaintiff and his vehicle, has “caused reasonable apprehension of an
immediate harmful or offensive contact…” Id., making Defendant liable for assault.
RELIEF
WHEREFORE, Plaintiff requests the court to grant relief to redress the injury as follows:
a. In the form of punitive damages:
i. For the first cause of action (Assault), $3,500 in relief.
ii. For the second cause of action (Battery), $4500 in relief.
b. In the form of declaratory relief, a declaration affirming Defendant’s liability for the
causes of actions stated herein.
c. Awarding Plaintiff reimbursement for attorneys’ fees, litigation costs, and any other
expenses incurred in the prosecution of this action, inclusive of applicable filing fees and
any other necessary expenditures related thereto.
d. Any other relief that the Court deems necessary.
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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August 14, 2024 Respectfully submitted,
Lnv_isible
Counsel of Record
Clarke, Feelings & Associates, LLP.
Junior Associate
R. Bar. No. 25108
Attorney for Plaintiff
