[郭文贵] 私人助理马蕊控告郭文贵强奸案诉状曝光(图)
83. As a direct and proximate result of the foregoing, Plaintiff was subjected to great physical and emotional pain and humiliation, was deprived of her liberty and was otherwise damaged and injured.
84. 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.
85. The limitations on liability set forth in CPLR 1601 do not apply to this action.
86. 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 SECOND CAUSE OF ACTION
(Assault)
87. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
88. As set forth above, Defendant Kwok engaged in a series of continuous and related acts of confinement, physical violence and sexual attacks against Plaintiff.
89. Defendru1t Kwok has physically detained Plaintiff, hit her, grabbed her and forcibly raped her.
90. Defendant Kwok's acts constitute fill assault upon Plaintiff in that DefendaJ1t Kwok intentionally threatened to **d did in fact physically attack aJ1d injure Plaintiff.
91. Defendant Kwok's wrongful bodily contact constituted a grievous affront to Plaintiff.
92. Defendant Kwok's threatened and actual wrongful bodily contact was intentional, unauthorized, m1d grossly offensive in nature.
93. Defendant Kwok's threatened and wrongful bodily contact was unwarranted, without any just cause or provocation and Defendant Kwok knew at all times that his actions were without the consent of the Plaintiff.
94. The injuries sustained by Plaintiff were caused wholly and solely by reason of the conduct described and Plaintiff did not contribute thereto.
95. As a direct and proximate result of the foregoing, Plaintiff was subjected to great physical and emotional pain and humiliation, was deprived of her liberty and was otherwise damaged and injured.
96. 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 Jess than $20 million.
97. The limitations on liability set forth in CPLR 1601 do not apply to this action.
98. 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 CPLR 1602.
AS AND FORA THIRD CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
99. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
100. Defendant Kwok's conduct, by confining, forcibly raping and physically battering Plaintiff, without provocation or justification, was extreme, outrageous, and utterly intolerable in a civilized community and was otherwise conduct that exceeded all reasonable bounds of decency.
101. Defendant Kwok's conduct, desc1-ibed above, was intended to and did cause severe emotional distress to Plaintiff.
102. Defendant Kwok's conduct was tl1e direct and proximate cause of injury and damage to Plaintiff.
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84. 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.
85. The limitations on liability set forth in CPLR 1601 do not apply to this action.
86. 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 SECOND CAUSE OF ACTION
(Assault)
87. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
88. As set forth above, Defendant Kwok engaged in a series of continuous and related acts of confinement, physical violence and sexual attacks against Plaintiff.
89. Defendru1t Kwok has physically detained Plaintiff, hit her, grabbed her and forcibly raped her.
90. Defendant Kwok's acts constitute fill assault upon Plaintiff in that DefendaJ1t Kwok intentionally threatened to **d did in fact physically attack aJ1d injure Plaintiff.
91. Defendant Kwok's wrongful bodily contact constituted a grievous affront to Plaintiff.
92. Defendant Kwok's threatened and actual wrongful bodily contact was intentional, unauthorized, m1d grossly offensive in nature.
93. Defendant Kwok's threatened and wrongful bodily contact was unwarranted, without any just cause or provocation and Defendant Kwok knew at all times that his actions were without the consent of the Plaintiff.
94. The injuries sustained by Plaintiff were caused wholly and solely by reason of the conduct described and Plaintiff did not contribute thereto.
95. As a direct and proximate result of the foregoing, Plaintiff was subjected to great physical and emotional pain and humiliation, was deprived of her liberty and was otherwise damaged and injured.
96. 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 Jess than $20 million.
97. The limitations on liability set forth in CPLR 1601 do not apply to this action.
98. 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 CPLR 1602.
AS AND FORA THIRD CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
99. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as if fully set forth herein at length.
100. Defendant Kwok's conduct, by confining, forcibly raping and physically battering Plaintiff, without provocation or justification, was extreme, outrageous, and utterly intolerable in a civilized community and was otherwise conduct that exceeded all reasonable bounds of decency.
101. Defendant Kwok's conduct, desc1-ibed above, was intended to and did cause severe emotional distress to Plaintiff.
102. Defendant Kwok's conduct was tl1e direct and proximate cause of injury and damage to Plaintiff.
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