Professional Documents
Culture Documents
LEANDER STOCKS,
2359 24th Street, S.E., #1801
Washington, DC 20020
Plaintiff,
v.
to 28 U.S.C. 1332(a).
2.
423, 13-423(a).
3.
District of Columbia through advertising on Washington, D.C. television stations with the
aim of attracting District of Columbia residents to Maryland Live! Casino #777.
4.
District of Columbia residents through a persistent course of conduct within the District
of Columbia and thereby avail themselves of the benefits, protections and obligations
imposed pursuant to the laws of the District of Columbia.
PARTIES
1.
been a resident of Washington, DC at all times relevant to the cause of action herein.
2.
At all times relevant to the cause of action herein, Defendant, The Cordish
Companies, Inc., is a Maryland corporation with its corporate office and headquarters in
Baltimore, Maryland.
3.
At all times relevant to the cause of action herein, Defendant, PPE Casino
Live! Casino #777 is a gambling and entertainment venue located in Hanover, Maryland
that catered to, among others, the Washington, DC and Baltimore, MD metropolitan
communities.
5.
At all times relevant to the cause of action herein Maryland Live! Casino
At all times relevant to the cause of action herein, PPE Casino Resorts
Maryland, LLC is owned, operated or managed by The Cordish Companies, Inc., as its
affiliate or subsidiary.
7.
At all times relevant to the cause of action herein, The Cordish Companies
Inc., through its affiliate or subsidiary, PPE Casino Resorts Maryland, through Maryland
Live Casino #777 consistently and purposefully conducted business in Washington, DC
soliciting, attracting, enticing or otherwise drawing District residents to patronize
Defendant Maryland Live! Casino #777s gaming facility.
STATEMENT OF CLAIMS
COUNT I
1.
roulette wheels when the Defendants employee operating the device negligently caused
the wheels hard ball to become airborne and strike the Plaintiff just above the left eye at
high velocity.
3.
That initial impact caused a sharp and severe pain followed by general
4.
Once in the private room, Plaintiff was able to lie down on a bench to wait
for the pain above his eye to subside and for a cold compress to apply to the bruised area.
5.
procedure was immediate blurred vision, increased pain and discomfort in the affected
area, overwhelming disorientation and pronounced loss of physical coordination.
7.
Attempting to rise from the bench in this distressed physical and mental
state, the Plaintiff experienced severe disorientation that caused him to fall forward,
violently hit the front and top of his head against the hardwood door to the room, and lose
consciousness.
8.
The injuries sustained in the fall required that the Plaintiff be taken to a
local hospital emergency room where he was evaluated and treated for the concussion
sustained in the fall and the contusion resulting from being struck by the roulette wheel
ball.
9.
December 15, 2013, Plaintiff has continued to suffer bouts of blurred vision, occasional
loss of coordination and regular episodes of post-traumatic headaches to the present, this
despite repeated medical evaluations and treatment.
10.
blurred vision and loss of coordination are the result of both negligent and willful
misconduct by the Defendant Maryland Live! Casino #777s employees, to wit:
Defendants negligent operation of its roulette wheel that caused Plaintiff to sustain the
contusion above his eye; and, Defendants willfully aggressive and unwelcomed
administration of an unknown liquid directly into Plaintiffs eye, which caused him to
suffer, among other things, a syncopal episode leading to his fall and ensuing concussion.
11.
COUNT II
1.
Plaintiff reiterates herein all of the allegations set forth in Count I above
unwelcomed, unwanted and willful act of placing unidentified liquid directly into
Plaintiffs eye amounted to a battery to his person done in wanton and reckless disregard
for plaintiff's rights to be free of unsolicited medical treatment and/or other batteries to
his person and rise therefore to the level of malice.
3.
COUNT I
WHEREFORE, Plaintiff Leander Stocks demands judgment against Defendants
for Count I as follows:
1.
Prays for judgment against the Defendants in the amount of One Hundred
Plaintiff prays for interest at a rate determined by the jury on the principal
amount or a portion thereof, as set by the jury, for a term commencing December 15,
2013;
3.
4.
Plaintiff reserves his right to amend his Complaint up to and including the
Such other and further relief as the Court deems just and proper.
COUNT II
the amount of One Hundred Fifty Thousand ($150,000.00) Dollars plus pre-judgment and
post-judgment interest;
2.
Plaintiff prays for interest at a rate determined by the jury on the principal
amount or a portion thereof, as set by the jury, for a term commencing December 15,
2013;
3.
4.
Plaintiff reserves his right to amend his Complaint up to and including the
Such other and further relief as the Court deems just and proper.
JURY TRIAL DEMAND
/s/
Deborah D. Wright 429549
Law Office of Deborah D Wright
P.O. Box 34314
Washington, DC 20043
202.251.0677 (o)
202.688.1841 (f)
ddwright165@gmail.com
Dated: February 25, 2015