ASHRAFI SNEDDEN AND FRIENDS, LLP Benno Ashrafi, Section B2 (Bar No. 101001) Mark Geragos (Bar No. 204540) 2 865 South Figueroa Street, 10th Floor Los Angeles, California 90017-2543 3 (213) 624-7707 1 4 Attorneys for Plaintiff Andrew Calkins 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 1. Plaintiff Andrew Calkins ("Calkins") is an individual who, at all 24 material times, resided at 777 XYZ Street, Los Angeles, California, 90017. 2. Defendant San Bernardino Stock Show, Inc ("SBSS") is a corporation 25 26 with its principal place of business at 3803 Cowgirl Drive, San Bernardino, California, 27 90210. 28
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SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES
ANDREW CALKINS,
) ) Plaintiff, ) ) v. ) ) SAN BERNARDINO STOCK SHOW, INC., ) ) Defendants. ) ) ) ) ) )
CASE NO. ABC1234 Dept: TBA Judge: TBA COMPLAINT FOR: (1) Negligent Infliction of Emotional Distress Filing Date: January __, 2004 Trial Date: None set
THE PARTIES
COMPLAINT
1 2 3 4 5 6 7 accident. 8 9 injured. 10 11 12 13 14 15 7. 8. Calkins is the father of the injury victim. Calkins was in the audience at the time of the accident and was then CAUSE OF ACTION (Negligent Infliction of Emotional Distress Against SBSS) 6. As a result of the accident the plaintiff’s daughter was severely 3. 4. 5. San Bernardino Stock Show, Inc. is a corporation. In or about September 2003, SBS held a sheep riding contest. During the contest, the defendant acted negligently leading to an STATEMENT OF FACTS
16 aware of the injury taking place 17 9. Calkins continues to suffer from sleeplessness, headaches, upper back
18 pains and other emotional distress as a result of the San Bernardino Stock Show’s negligent 19 conduct. In an effort to address these symptoms, Calkins has frequently consulted a general 20 physician and a psychologist, incurring substantial medical expense. 21 22 23 24 25 26 27 28
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PRAYER FOR RELIEF
1.
On the First and only Cause of Action For: (a) Special damages of $30,000; (b) General damages of $1,000,000; (c) Attorneys' fees and costs; and
2
COMPLAINT
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
(d) Such other and further relief as the Court may deem just
DATED: January 10, 2004 ASHRAFI SNEDDEN AND FRIENDS, LLP
By Benno Ashrafi Attorneys for Plaintiff Andrew Calkins
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3
COMPLAINT