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Civil complaint
ryan977ftw2
Filing username: ryan977ftw
SUPERIOR COURT OF RIDGEWAY
COUNTY OF RIDGEWAY
COUNTY OF RIDGEWAY
ryan977ftw2, Civil complaint
Plaintiff,
vs.
AngellicTerror,
Defendant.
Claims for Relief
COUNT I — WRONGFUL DEATH - 7 R. Stat. § 121.004
1. Plaintiff incorporates by reference all preceding allegations as though fully
set forth herein.
2. Pursuant to 7 R. Stat. § 121.004, wrongful death occurs when an individual
causes the death of another without lawful cause or justification.
3. At all times relevant to this action, Defendant was a member of the
Ridgeway National Guard (“RNG”) and was acting under the apparent
authority of said organization.
4. Defendant intentionally discharged a firearm at Plaintiff, causing fatal
bodily injuries and ultimately resulting in Plaintiff’s death.
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PAGE - 2 -
Civil complaint
5. Plaintiff alleges that Defendant lacked lawful justification for employing
deadly force and that Plaintiff’s conduct did not warrant such force under
the circumstances.
6. Defendant’s actions were the direct and proximate cause of Plaintiff’s
death.
7. Accordingly, Defendant is liable for wrongful death pursuant to 7 R. Stat. §
121.004, entitling Plaintiff to compensatory and punitive damages as
permitted by law.
COUNT II — CIVIL ASSAULT - 7 R. Stat. § 121.001
1. Plaintiff incorporates all preceding allegations by reference.
2. Under 7 R. Stat. § 121.001, assault consists of intentionally and voluntarily
causing another individual reasonable apprehension of imminent harmful
or offensive contact.
3. Defendant intentionally directed and discharged a firearm toward Plaintiff,
creating an imminent threat of serious bodily injury or death.
4. To the extent Plaintiff perceived Defendant’s threatening actions before
being struck, such conduct caused Plaintiff reasonable apprehension of
imminent harmful contact.
5. Defendant’s actions constituted civil assault, entitling Plaintiff to damages
permitted under Ridgeway law.
COUNT III — CIVIL BATTERY - 7 R. Stat. § 121.002
1. Plaintiff incorporates all preceding allegations by reference.
2. Pursuant to 7 R. Stat. § 121.002, battery consists of unconsented harmful
or offensive physical contact with another individual.
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Civil complaint
3. Defendant intentionally discharged a firearm, striking Plaintiff and inflicting
fatal bodily injuries.
4. Such contact was harmful, unconsented, and, as Plaintiff alleges,
unsupported by lawful justification.
5. Defendant’s actions therefore constituted civil battery and directly caused
Plaintiff’s injuries and death.
6. Plaintiff is entitled to compensatory and punitive damages as permitted by
applicable law.
COUNT IV — NEGLIGENCE - 7 R. Stat. § 121.301 — Pleaded in the Alternative
1. Plaintiff incorporates all preceding allegations by reference.
2. Defendant owed Plaintiff a duty to exercise reasonable care and refrain
from creating unreasonable and foreseeable risks of serious bodily harm.
3. Defendant breached this duty by employing deadly force in circumstances
where, as alleged, such force was unnecessary and unjustified.
4. It was reasonably foreseeable that discharging a firearm at Plaintiff would
result in serious bodily injury or death.
5. Defendant’s breach directly and proximately caused Plaintiff’s fatal injuries.
6. Accordingly, should the Court determine that Defendant’s actions were
negligent rather than intentional, Plaintiff seeks relief under 7 R. Stat. §
121.301.
Demand for Relief
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter
judgment in Plaintiff’s favor and against Defendant, awarding: A. Punitive damages of
$15,000 for wrongful death; B. Punitive damages of $4,000 for civil assault; C. Punitive
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Civil complaint
damages of $5,000 for civil battery; D. Alternatively, punitive damages of $5,000 for
negligence, if the Court finds such damages legally available; E. Compensatory
damages in an amount to be determined by the Court; F. Court costs and reasonable
attorney’s fees to the extent authorized by applicable law; and G. Such other and further
relief as this Honorable Court deems just and proper.
