WORDS OF WISDOM
I AM TOTALLY SUFFERING WITH THE TWO YEAR OLD TRAUMA...that continues till today... this is the anniversary of my ankle being broken by a former neighbor. I hired attorneys to file against him for my bills...he was let out of the case by filing a fraudulent bankruptcy, receiving Food Stamp assistance and yet enjoys his life everyday, lies and cheats ...... no one helped me..... traumatized!!!! I have now filed my own lawsuits! There is a special place in HELL for contemptuous garbage.
A section of the Complaint written by Barry Lakritz or his firm
COUNT I – CIVIL ASSAULT AND BATTERY AGAINST
DEFENDANT ALLAN KAPLAN
DEFENDANT ALLAN KAPLAN
Plaintiff hereby incorporates by reference the above numbered paragraphs, repeating and re-alleging same as though same were more fully set forth herein.
Defendant Allan Kaplan owed a duty to Plaintiff Jampel to refrain from touching or injuring Plaintiff against her will; said Defendant violated this duty, committing actionable assault and battery against Plaintiff.
More particularly, the falling onto and/or physical contact made to the personage of Plaintiff by said Defendant, when said Defendant fell onto Plaintiff’s body, constituted generalized physical acts of violence against Plaintiff, and also constituted an unconsented to touching of Plaintiff, thus constituting an actionable assault and battery.
Further, this unconsented to touching of Plaintiff by Defendant Allan Kaplan was intentional in that Defendant Kaplan intended to forcefully move towards Plaintiff and to touch Plaintiff in attempting to gain control of his dog, who was standing next to and/or in the immediate vicinity of Plaintiff Jampel.
Further, this unconsented to touching of Plaintiff by said Defendant was unprovoked and was not carried out in self-defense by said Defendant under any color of legal right.
Further, this assault and battery by said Defendant upon the Plaintiff was wrongful and without just cause.
As a proximate result of this civil assault and battery by Defendant Allan Kaplan upon your Plaintiff, Cynthia Jampel suffered the injuries and damages set out in Paragraphs 9, 10, 11 and 12 above, which are repeated and re-alleged as though same were more fully set forth herein.
WHEREFORE, PLAINTIFF, Cynthia Jampel prays that this Honorable Court enter Judgment against Defendants in an amount deemed fair and just by the trier of
Defendant Allan Kaplan owed a duty to Plaintiff Jampel to refrain from touching or injuring Plaintiff against her will; said Defendant violated this duty, committing actionable assault and battery against Plaintiff.
More particularly, the falling onto and/or physical contact made to the personage of Plaintiff by said Defendant, when said Defendant fell onto Plaintiff’s body, constituted generalized physical acts of violence against Plaintiff, and also constituted an unconsented to touching of Plaintiff, thus constituting an actionable assault and battery.
Further, this unconsented to touching of Plaintiff by Defendant Allan Kaplan was intentional in that Defendant Kaplan intended to forcefully move towards Plaintiff and to touch Plaintiff in attempting to gain control of his dog, who was standing next to and/or in the immediate vicinity of Plaintiff Jampel.
Further, this unconsented to touching of Plaintiff by said Defendant was unprovoked and was not carried out in self-defense by said Defendant under any color of legal right.
Further, this assault and battery by said Defendant upon the Plaintiff was wrongful and without just cause.
As a proximate result of this civil assault and battery by Defendant Allan Kaplan upon your Plaintiff, Cynthia Jampel suffered the injuries and damages set out in Paragraphs 9, 10, 11 and 12 above, which are repeated and re-alleged as though same were more fully set forth herein.
WHEREFORE, PLAINTIFF, Cynthia Jampel prays that this Honorable Court enter Judgment against Defendants in an amount deemed fair and just by the trier of
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