[郭文贵] 私人助理马蕊控告郭文贵强奸案诉状曝光(图)
103. As a result of the foregoing, Plaintiff was deprived of her liberty, was subjected to serious physical and emotional pain and suffering and was otherwise damaged and injured.
I04. As a direct and proximate result of 出e foregoing, Plaintiff has been damaged in an amount to be determined at trial but in no event less than $20 million.
I 05. The limitations on liability set forth in CPLR 160I do not apply to this action.
106. The limitations on liability set forth i.J.1 CPLR 1601 do not apply to this action by reason of one or more of the exemptions set forth in CPLR 1602.
AS ANO FOR A FOURTH CAUSE OF ACTION
(Negligent Infliction of Emotional Distress)
I 07. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
108. Defendant Kwok's conduct, in assaulting and battering Plaintiff, was careless and negligent as to the emotional health of Plaintiff, and did, in fact, cause severe emotional distress to Plaintiff.
109. The acts **1d conduct of Defendant Kwok was the direct and proximate cause of injury and damage to Plaintiff.
110. As a result of the foregoing, Plaintiff was deprived of her liberty, was subjected to serious physical and emotional pain and suffering, and was otherwise damaged and injured.
Ill. As a direct and proximate result of the foregoing, Plaintiff has been damaged in an amount to be detem1ined at trial but in no event less than $20 million.
112. The limitations on liability set forth in CPLR 1601 do not apply to this action.
113. The limitations on liability set forth in CPLR 1601 do not apply to this action by reason of one or more of the exemptions set forth in CPLR 1602.
AS AND FOR A FIFTH CAUSE OF ACTION
(Negligence)
114. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
115. As set forth above, Defendant Kwok engaged in a series of continuous and related acts of confinement, physical violence and sexual attacks against Plaintiff.
116. Defendant Kwok has physically detained Plaintiff, hit her, grabbed her and forcibly raped her.
117. At all relevant times, Defendant Kwok was Plaintiff's employer and thus had a duty to protect Plaintiff from injury while Plaintiff was performing the duties and responsibilities of her employment.
118. Defendant Kwok breached this duty by engaging in the conduct set forth in detail hereinabove.
119. As set forth above, Plaintiff was caused to be injured solely and wholly due to the negligence and carelessness of Defendant Kwok.
120. As a direct and proximate result of the foregoing, Plaintiff was subjected to great physical and emotional p**n and humiliation, was deprived of her liberty and was otherwise damaged and injured.
121. As a direct and proximate result of the foregoing, Plaintiff has been damaged in an amount to be determined at trial but in no event less than $20 million.
[物价飞涨的时候 这样省钱购物很爽]
已经有 2 人参与评论了, 我也来说几句吧
I04. As a direct and proximate result of 出e foregoing, Plaintiff has been damaged in an amount to be determined at trial but in no event less than $20 million.
I 05. The limitations on liability set forth in CPLR 160I do not apply to this action.
106. The limitations on liability set forth i.J.1 CPLR 1601 do not apply to this action by reason of one or more of the exemptions set forth in CPLR 1602.
AS ANO FOR A FOURTH CAUSE OF ACTION
(Negligent Infliction of Emotional Distress)
I 07. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
108. Defendant Kwok's conduct, in assaulting and battering Plaintiff, was careless and negligent as to the emotional health of Plaintiff, and did, in fact, cause severe emotional distress to Plaintiff.
109. The acts **1d conduct of Defendant Kwok was the direct and proximate cause of injury and damage to Plaintiff.
110. As a result of the foregoing, Plaintiff was deprived of her liberty, was subjected to serious physical and emotional pain and suffering, and was otherwise damaged and injured.
Ill. As a direct and proximate result of the foregoing, Plaintiff has been damaged in an amount to be detem1ined at trial but in no event less than $20 million.
112. The limitations on liability set forth in CPLR 1601 do not apply to this action.
113. The limitations on liability set forth in CPLR 1601 do not apply to this action by reason of one or more of the exemptions set forth in CPLR 1602.
AS AND FOR A FIFTH CAUSE OF ACTION
(Negligence)
114. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
115. As set forth above, Defendant Kwok engaged in a series of continuous and related acts of confinement, physical violence and sexual attacks against Plaintiff.
116. Defendant Kwok has physically detained Plaintiff, hit her, grabbed her and forcibly raped her.
117. At all relevant times, Defendant Kwok was Plaintiff's employer and thus had a duty to protect Plaintiff from injury while Plaintiff was performing the duties and responsibilities of her employment.
118. Defendant Kwok breached this duty by engaging in the conduct set forth in detail hereinabove.
119. As set forth above, Plaintiff was caused to be injured solely and wholly due to the negligence and carelessness of Defendant Kwok.
120. As a direct and proximate result of the foregoing, Plaintiff was subjected to great physical and emotional p**n and humiliation, was deprived of her liberty and was otherwise damaged and injured.
121. As a direct and proximate result of the foregoing, Plaintiff has been damaged in an amount to be determined at trial but in no event less than $20 million.
[物价飞涨的时候 这样省钱购物很爽]
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