1 Raymond J. Zolekhian, Esq.

SBN 244528
2
Elan Zektser, Esq. SBN: 236757
Brennan S. Huelse, Esq. SBN: 311467
3 OAKWOOD LEGAL GROUP, LLP
8124 W. 3rd Street., 2nd Floor
4 Los Angeles, CA 90048
5 Telephone: 310-205-2525
Facsimile: 310-773-5573
6
Attorneys for Plaintiffs
7 KARRI MAUREEN RYDER
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF RIVERSIDE
10

11
KARRI MAUREEN RYDER, individually, Case No.
12 and as successor-in-interest to MELISSA
MONIQUE BAUMAN, deceased, COMPLAINT FOR DAMAGES
13
Plaintiffs, 1. WRONGFUL DEATH BASED
14 v. ON NEGLIGENCE
2. DEPENDENT ADULT
15 NEGLECT
MFI RECOVERY CENTER; a nonprofit 3. INTENTIONAL
16 MISREPRESENTATION
corporation, COUNTY OF RIVERSIDE, and 4. BREACH OF DUTIES ARISING
17 DOES 1 through 25, inclusive, UNDER SPECIAL
RELATIONSHIP
18 Defendants.
19

20

21

22

23
Come now the plaintiff, KARRI RYDER as Successor in interest to Decedent, MELISSA
24
MONIQUE BAUMAN (hereinafter referred to as BAUMAN), and for causes of action against
25
the defendants, and each of them, complain and allege as follows:
26

27

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1
COMPLAINT FOR DAMAGES
 1

2 PRELIMINARY ALLEGATIONS
3 A. The Plaintiffs
4 1. At all times herein, including the date of her death on July 26, 2022, MELISSA
5 MONIQUE BAUMAN (hereinafter referred to as BAUMAN) was a resident of the
6 County of Riverside. At the time of her death BAUMAN was unmarried and did not have
7 any children.

8 2. At all times herein alleged BAUMAN, who was born on May 22, 1998, was between the
9 ages of 18 and 64 years old had physical and mental limitations that restricted her ability

10 to carry out normal activities and to protect her rights and was under the custodial care of

11 Defendants, and each of them, who owned, operated, managed or were employed by MFI

12 RECOVERY CENTER and was therefore a “dependent adult” within the meaning of

13
Welf. & Inst. Code §15610.23.

14
3. Plaintiff KARRI RYDER is the mother of and a successor in interest to BAUMAN,
thereby establishing her standing as a plaintiff for a portion of this action. At all times
15
herein, including the date of BAUMAN’S death, KARRI RYDER was a resident of the
16
County of Riverside.
17
4. BAUMAN sues through her Successor-in-Interest, KARRI RYDER, who has
18
complied with the requirements of Code of Civil Procedure section 377.32 and
19
Welfare and Institutions Code section 15657.3. An affidavit, as required by Code of
20
Civil Procedure section 377.32 will be filed with the court.
21
B. The Defendants
22
5. Plaintiffs are informed and believe, and thereupon allege, that at all times mentioned
23
herein Defendant MFI RECOVERY CENTER (“MFI”) is a California corporation with
24
its principal place of business located at 5870 Arlington Ave. Riverside, CA 92504. At all
25
relevant times MFI was in the business of providing custodial care as a sobering center
26
pursuant to §1250 of the California Health and Safety Code and was the licensee of the
27
facility known as ARLINGTON RECOVERY COMMUNITY & SOBERING
28
CENTER (“ARC”) located and doing business at 10001 County Farm Rd., Riverside,

2
COMPLAINT FOR DAMAGES
 1 CA 92503, and was subject to the requirements of federal and state law regarding the
2 operation of sobering center facilities. In connection with its operation of the ARC,
3 MFI provided custodial care to “dependent adults” as defined by Welf. & Inst. Code
4 §15610.23, including BAUMAN, and was responsible for meeting the basic needs of
5 the residents, including BAUMAN, and was subject to the requirements of federal
6 and state law. By virtue of the obtaining of a license and providing custodial and
7 other care to residents of the State of California, including BAUMAN, MFI
8 conducted business in the State of California at all times relevant to this action.

9 6. As licensee of the defendant rehabilitation and recovery facility, MFI is responsible

10 for compliance with licensing requirements and the organization, management and

11 operation and control of the ARC. As such, MFI has responsibility for and undertakes

12 a substantial and ongoing caretaking and custodial relationship with its residents,

13
including the ARC, even though it is the licensee’s staff and delegated personnel who
actually provide for basic needs and comforts.
14
7. The COUNTY OF RIVERSIDE contracts MFI RECOVERY CENTER to provide
15
recovery and substance abuse services to dependent adults all across Riverside
16
County. The COUNTY OF RIVERSIDE routinely works with MFI RECOVERY
17
CENTER who runs community centers such as the ARC in Riverside. MFI
18
RECOVERY CENTER and COUNTY OF RIVERSIDE were responsible for
19
overseeing centers such as the ARC.
20
8. Despite being aware of several complaints made by former patients of MFI and also
21
being aware of other patient deaths that occurred at MFI facilities, the COUNTY OF
22
RIVERSIDE continued to allow MFI to provide its services to individuals in the
23
community of Riverside.
24
9. Additionally, MFI was constantly made aware that their facility was understaffed and
25
needed more support to be able to provide services to its patients, however, despite
26
the constant complaints from MFI’s own support staff regarding the understaffing at
27
the facility, MFI knowingly continued to run its operations at the ARC, thereby
28
placing its patients in danger.

3
COMPLAINT FOR DAMAGES
 1 10. The true names and/or capacities, whether individual, corporate, associate or
2 otherwise of Defendants DOES 1 through 25, inclusive, and each of them, are
3 unknown to plaintiffs, who therefore sues said Defendants by such fictitious names.
4 Plaintiffs are informed and believe, and thereupon allege, that each of the Defendants
5 named herein as DOES are legally responsible, negligently or in some other
6 actionable manner, for the events and happenings hereinafter referred to and
7 proximately caused the death of BAUMAN as hereinafter alleged. The Plaintiffs will
8 seek leave of Court to amend this Complaint to assert the true names and/or capacities

9 of such fictitiously named Defendants when the same have been ascertained.

10 11. Plaintiffs are informed and believe, and thereupon allege, that at all times mentioned

11 herein, Defendants, and each of them, including DOES 1 through 25, inclusive, and

12 each of them, were the agents, servants, employees and/or joint venturers of the

13
codefendants, and were, as such, acting within the course, scope and authority of said
agency, employment and or venture, and that each and every defendant, as aforesaid,
14
when acting as a principal, was negligent in the selection and hiring of each and every
15
other defendant as an agent, employee and/or joint venturer.
16
12. Plaintiffs are informed and believe, and thereupon allege, that at all times mentioned
17
herein Defendants, and each of them, including DOES 1 through 25, inclusive, were
18
acting for and on behalf of each of the other Defendants as their agents, servants,
19
representatives, employees, joint venturers and/or co-conspirators; that all acts,
20
conduct, and omissions herein alleged were perpetrated while said Defendants were
21
acting within the authorized course, scope, and purpose of said agency, employment,
22
joint venture and/or conspiracy; that all acts, conduct or omissions were subsequently
23
ratified by the respective principals and the benefits thereof accepted by said
24
principals; and that each Defendant as aforesaid, while acting as a principal, was
25
negligent in the selection, hiring, training, and/or supervision of each and every other
26
Defendant as its agent, servant and/or employee.
27
//
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//

4
COMPLAINT FOR DAMAGES
 1 C. Jurisdiction and Venue
2

3 13. This Court has jurisdiction over all causes of action asserted. Defendants are subject
4 to personal jurisdiction of this Court because each Defendant does business in County
5 of Riverside, State of California.
6 14. Venue is proper in the County of Riverside. Based on the facts, without limitation,
7 this Court is a court of competent jurisdiction. Defendants conducted substantial
8 business in California for years before and when this action was commenced,

9 including, without limitation, ownership, administration, management and/or

10 operation of MFI RECOVERY CENTER, and thus, are subject to personal

11 jurisdiction. The events or omission causing Plaintiffs’ claims arose in California; the

12 Decedent resided in California at the time of her death and to the allegations in this

13
Complaint; Defendants’ liability arose in California and the acts upon which this
action is based occurred in Riverside County.
14
FACTUAL ALLEGATIONS
15
15. On July 23, 2022, BAUMAN asked her mother, Plaintiff KARRI RYDER to take her
16
to the Arlington Recovering Community & Sobering Center (“ARC”). BAUMAN
17
had recently relapsed from her recovery and once again wanted to achieve sobriety.
18
16. Plaintiff picked up BAUMAN on July 24, 2022 from Islands restaurant in Riverside
19
Plaza and took BAUMAN to the ARC to voluntarily seek assistance, help, and
20
supervision in obtaining sobriety.
21
17. Plaintiffs are informed and believe, and thereupon allege, that due to her longstanding
22
history of drug abuse with methamphetamine, heroin and fentanyl, BAUMAN was a
23
person who was particularly vulnerable to custodial neglect and needed to be
24
protected from matters which could pose a hazard to her health and safety. This was
25
the true reason BAUMAN and KARRI RYDER turned to the ARC, because they
26
trusted and needed the assistance of MFI, the COUNTY OF RIVERSIDE and its
27
employees.
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5
COMPLAINT FOR DAMAGES
 1 18. Plaintiffs are informed and believe, and thereupon allege, that upon accepting
2 BAUMAN as a patient at and under the custodial care of the ARC, MFI had the
3 obligation to ensure it was apprised and familiarized with BAUMAN’s longstanding
4 history of drug abuse.
5 19. Plaintiffs are informed and believe; MFI knew or should have known by way of its
6 own inquiry into BAUMAN’s prior history of abuse and recurring conditions that
7 BAUMAN was a person highly susceptible to succumbing to her urges to use drugs
8 and/or alcohol and would likely seek out help in obtaining them however possible.

9 20. Plaintiffs are informed and believe, and thereupon allege, that pursuant to their own

10 set procedures as well as industry standards, that MFI staff needed to check on

11 BAUMAN every 30 minutes to ensure that she was in stable condition especially

12 since BAUMAN was in the early stages of her detox.

13
21. MFI provided its detox observation log to law enforcement. In those logs, MFI list all
of the times that a staff member from MFI checked in on BAUMAN. Although the
14
checkups are supposed to be every 30 minutes, there were over 20 times in which the
15
MFI staff was late in performing the 30-minute checkups on BAUMAN.
16
22. Additionally, on September 13, 2022, a warrant was issued to allow detective Brazil
17
the viewing of the surveillance footage from MFI. This surveillance video showed
18
each and every time an MFI employee conducted a check in on BAUMAN.
19
23. During law enforcement’s investigation, Detectives obtained surveillance of MFI
20
RECOVERY CENTER. The surveillance obtained by Detectives were focused on
21
Plaintiff’s room and had a clear view of any employees of MFI RECOVERY
22
CENTER physically checking on Plaintiffs safety and wellbeing as required by
23
industry standards and MFI’s own policies and procedures.
24
24. Surveillance clearly showed that MFI RECOVERY CENTER had falsified the check
25
logs. Despite logs indicating MFI RECOVERY CENTER employees checked on
26
Plaintiff at 3:38 a.m. and 4:59a.m., video evidence clearly showed this to be false.
27
BAUMAN was then found deceased at 5:58 am.
28

6
COMPLAINT FOR DAMAGES
 1 25. The logs indicate that they were modified on October 12, 2022, two months after
2 Plaintiff’s death.
3 26. Plaintiffs are informed and believe, and thereupon allege, that at around 5:58 a.m.,
4 while still a patient at and under the custodial care of the MFI, medical assistant,
5 Minerva Cardena, found BAUMAN unresponsive in the BAUMAN’s dorm room at
6 the ARC.
7 27. Plaintiffs are informed and believe, and thereupon allege, that although the MFI
8 employees at the ARC knew or should have known that BAUMAN – as well as any

9 of their other residents – could have at any time sought to obtain illicit drugs -

10 including fentanyl – and that they should be prepared to offer treatment that would

11 address a fentanyl overdose. At no time after BAUMAN was found unresponsive in

12 her door room, while still a patient at and under the custodial care of the ARC, did

13
anyone from MFI administer Narcan, Epinephrine or any other type of Opioid
overdose treatment to BAUMAN to attempt to resuscitate her prior to the arrival of
14
the emergency personnel.
15
28. Plaintiffs are informed and believe, and thereupon allege, that emergency personnel
16
from the Riverside Police Department were summoned but were unable to resuscitate
17
BAUMAN, and at approximately 6:31 a.m. on July 26, 2022, she was pronounced
18
dead.
19
29. The Perris Forensic Center performed an autopsy, including toxicology testing, and
20
concluded that BAUMAN’s death was caused by a fentanyl overdose.
21
30. Plaintiffs are informed and believe, and thereupon allege, that whether it was a matter
22
of choice or indifference, and despite knowing that an individual like BAUMAN
23
would be particularly vulnerable to custodial neglect and needed to be protected from
24
matters which could pose a hazard to her health and safety, MFI failed to assign staff,
25
personnel and/or security sufficient to properly monitor BAUMAN’S behavior while
26
she was a resident at their facilities and under their custodial care.
27
31. COUNTY and MFI were on notice that the ARC had received various complaints
28
from other individuals who had received care at the ARC.

7
COMPLAINT FOR DAMAGES
 1

2 FIRST CAUSE OF ACTION- WRONGFUL DEATH BASED ON NEGLIGENCE

3 (Against All Defendants)
4 32. Plaintiffs repeat and re-allege Paragraphs 1 through 31 inclusive and incorporate them
5 as if fully set forth herein by reference.
6 33. Plaintiffs are informed and believe, and based thereupon allege, that at all relevant
7 times hereto, Defendants, and each of them, had a substantial caretaking and custodial
8 relationship involving BAUMAN, involving an ongoing responsibility to supervise

9 her and oversee her safety and welfare while she remained in their custody.

10 34. Plaintiffs are informed and believe, and based thereupon allege, that at all relevant

11 times hereto, Defendants, and each of them, failed to use the degree of care that a

12 person or facility in the same situation would have used in providing BAUMAN

13
supervision and overseeing her safety and welfare while he remained in their custody.
35. As a direct and proximate result of the wrongful acts, conduct, or omissions of
14
Defendants, and each of them, which proximately caused the overdose and death of
15
BAUMAN, she thereafter endured physical pain, suffering and severe emotional
16
distress, including having the presence of mind after to understand that her overdose
17
and the lack of immediate medical care being rendered to her were rapidly leading to
18
her death, all to her general damages in an amount to be proven at trial.
19
36. As a result of the above-alleged acts, Defendants, and each of them, breached their
20
duties to BAUMAN and Plaintiffs. As a direct and proximate result of the wrongful
21
acts, conduct, or omissions of Defendants, and each of them, which proximately
22
caused the death of BAUMAN, Plaintiffs have been deprived of love, affection, care,
23
society, service, comfort, support, right to support, companionship, solace, moral
24
support, expectations of future support, and counseling, as well as other benefits and
25
assistance of BAUMAN and have sustained pecuniary loss in an amount to be proven
26
at trial.
27
37. The above acts by Defendants were reckless and despicable conduct carried on by
28
them with a willful and conscious disregard of the rights and safety of BAUMAN.

8
COMPLAINT FOR DAMAGES
 1 Further, said conduct subjected Plaintiffs and BAUMAN to cruel and unjust hardship
2 in conscious disregard of their rights. Such conduct amounted to recklessness,
3 oppression, malice and/or fraud thus entitling Plaintiffs to punitive and exemplary
4 damages in a sum sufficient to punish Defendants in order to effectuate the purpose of
5 Civil Code §3294.
6

7 SECOND CAUSE OF ACTION-DEPENDENT ADULT NEGLECT

8 (Against all Defendants)

9 38. Plaintiffs repeat and re-allege Paragraphs 1 through 37 inclusive and incorporate them

10 as if fully set forth herein by reference.

11 39. Plaintiffs are informed and believe, and based thereupon allege, that at all relevant

12 times hereto, Defendants, and each of them, had a substantial caretaking and custodial

13
relationship involving BAUMAN involving an ongoing responsibility for her basic
needs, which an able-bodied and fully competent adult would ordinarily be capable of
14
managing without assistance. As such, Defendants, and each of them, had direct care
15
and custody of BAUMAN, who was a dependent adult under Welf. & Inst. Code
16
§15600, et seq.
17
40. Plaintiffs are informed and believe, and based thereupon allege, that at all relevant
18
times hereto, Defendants, and each of them, failed to use the degree of care that a
19
person in the same situation would have used in providing for BAUMAN’s basic
20
needs.
21
41. On July 26, 2022, Defendants, and each of them, breached their duties to BAUMAN.
22
As a direct and proximate result of the reckless and wrongful acts, conduct, or
23
omissions of Defendants, and each of them, which proximately caused the drug
24
overdose and subsequent death of BAUMAN, she thereafter endured physical and
25
emotional pain and suffering, including having the presence of mind to understand
26
that due to the effects of the drugs she was allowed to obtain and consume, and the
27
lack of immediate medical care being rendered to her, she was slowly dying.
28

9
COMPLAINT FOR DAMAGES
 1 42. On July 26, 2022 Defendants, and each of them, breached their duties to BAUMAN.
2 As a direct and proximate result of the reckless and wrongful acts, conduct, or
3 omissions of Defendants, and each of them, which proximately caused the death of
4 BAUMAN, Plaintiffs have been deprived of love, affection, care, society, service,
5 comfort, support, right to support, companionship, solace, moral support,
6 expectations of future support, and counseling, as well as other benefits and
7 assistance of BAUMAN, and have sustained pecuniary loss in an amount to be
8 proven at trial.

9 43. The above acts by Defendants were reckless and despicable conduct carried on by

10 them with a willful and conscious disregard of the rights and safety of BAUMAN.

11 Further, said conduct subjected Plaintiff and BAUMAN to cruel and unjust hardship

12 in conscious disregard of their rights. Such conduct amounted to recklessness,

13
oppression, malice and/or fraud thus entitling Plaintiffs to punitive and exemplary
damages in a sum sufficient to punish Defendants in order to effectuate the purpose of
14
Civil Code §3294.
15
44. The above acts by Defendants were reckless and despicable conduct carried on by
16
them with a willful and conscious disregard of the rights and safety of BAUMAN.
17
Further, said conduct subjected Plaintiff and BAUMAN to cruel and unjust hardship
18
in conscious disregard of their rights. Such conduct amounted to recklessness,
19
oppression, malice and/or fraud thus entitling Plaintiffs to attorney’s fees and costs
20
from Defendants pursuant to Welf. & Inst. Code §15657(a).
21

22
THIRD CAUSE OF ACTION- INTENTIONAL MISREPRESENTATION
23
(Against MFI RECOVERY CENTER)
24
(Civil Code Section 1710(1))
25

26
45. Plaintiffs repeat and re-allege Paragraphs 1 through 31 inclusive and incorporate them
27
as if fully set forth herein by reference.
28

10
COMPLAINT FOR DAMAGES
 1 46. Defendant, MFI RECOVERY CENTER had a duty to physically check on Plaintiff
2 every 30 minutes. This duty was set by Industry Standards as well as internal
3 standards set by MFI.
4 47. MFI RECOVERY CENTER has a policy for their employees to log each time they
5 checked on patients to ensure that the patients were receiving the proper care for their
6 safety and survival.
7 48. MFI RECOVERY CENTER provided their physical check logs of Plaintiff for the
8 date July 26, 2022.

9 49. The logs indicate that an employee of MFI RECOVERY CENTER checked on

10 Plaintiff during the following times: 12:03 a.m., 1:10a.m., 1:44a.m., 2:56 a.m., 3:38

11 a.m. 4:24 a.m. and 4:59 a.m.

12 50. During law enforcement’s investigation, Detectives obtained surveillance of MFI

13
RECOVERY CENTER. The surveillance obtained by Detectives were focused on
Plaintiff’s room and had a clear view of any employees of MFI RECOVERY
14
CENTER physically checking on Plaintiffs safety and wellbeing as required by
15
industry standards and MFI’s own policies and procedures.
16
51. Surveillance clearly showed that MFI RECOVERY CENTER had falsified the check
17
logs. Despite logs indicating MFI RECOVERY CENTER employees checked on
18
Plaintiff at 3:38 a.m. and 4:59a.m., video evidence clearly showed this to be false.
19
52. The logs indicate that they were modified on October 12, 2022, two months after
20
Plaintiff’s death.
21
53. MFI RECOVERY CENTER intentionally misrepresented their actions to avoid law
22
enforcement and/or Plaintiff knowing that they had failed to properly observe
23
Plaintiff.
24
54. Plaintiff’s health, strength, and activity has caused, and continues to cause Plaintiff
25
severe, permanent, mental, physical and nervous pain and suffering.
26
//
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//
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//

11
COMPLAINT FOR DAMAGES
 1 FOURTH CAUSE OF ACTION- Breach of Duties Arising under Special
2 Relationship
3 (Against County of Riverside)
4

5 55. Plaintiff hereby incorporate by this reference all paragraphs of this complaint as if
6 fully set forth herein.

7 56. Pursuant to Government Code Sections 815.2(a) and 820 and Evidence Code Section
8 669, the County of Riverside’s employees are liable for violating the Duty Arising under

9 Special Relationship doctrine.

10 57. A special relationship was established between defendants, on the one hand, and

11 plaintiffs, on the other hand, by virtue of defendants having entered upon the task of

12
purporting to protect dependent adults receiving services at MFI, a county sponsored

13
program. Defendant County of Riverside entered into a special relationship with
BAUMAN upon taking custody of BAUMAN and declaring her to be dependents of the
14
County. Both defendants special relationship with BAUMAN stems from their control
15
over the placement of BAUMAN at the ARC, a County of Riverside sponsored
16
community facility that was run and operated by MFI, who was directly contracted by the
17
County of Riverside to run the ARC. These special relationships include reliance and
18
dependence on the part of BAUMAN and Plaintiff, who reasonably believed that
19
defendants would take meaningful steps to protect BAUMAN and ensure that she was
20
provided the necessary care that BAUMAN needed to aide in her recovery process.
21
58. Defendants increased the danger to BAUMAN by ratifying MFI’s egregious conduct in
22
allowing MFI to continue to remain open when it continuously demonstrated it was
23
severely understaffed, the staff lacked the training necessary to administer Narcan, and
24
also not properly conducting the check ins that were mandatory. This led others,
25
including mandated reporters and MFI employees, to refrain from taking any further
26
steps to protect BAUMAN. As a result of the special relationship, defendants owed a
27
duty to exercise reasonable care. Defendants breached that duty, as discussed above, by
28
failing to take meaningful steps to protect patients from abuse and neglect. Defendants

12
COMPLAINT FOR DAMAGES
 1 knew that patients at MFI were being abused and neglected, that the abuse and neglect
2 were almost certain to continue, that the patients would suffer lasting damage as a result
3 and that these patients needed help, but defendants willfully chose to do nothing because
4 that was the easier course to take. Defendants never considered trying to remove MFI or
5 put a stop to MFI’s operations at the ARC until after BAUMAN’S death.
6 59. As a result of Defendants’ violation of the Special Relationship doctrine, BAUMAN
7 and RYDER sustained injuries and damages.
8 PRAYER FOR DAMAGES

9 WHEREFORE, Plaintiffs pray judgment against defendants, and each of them, as follows:
10 1. For general damages sustained by decedent Melissa Monique Bauman from the pain and
11 suffering he sustained from between the time he overdosed until the time of her ultimate
12 death;
13
2. For general damages sustained by Plaintiff for the loss of love, affection, care, society,
14
service, comfort, support, right to support, companionship, solace, moral support,
15 expectations of future support and counseling which will be stated according to proof,
16 which sum is in excess of $10,000,000;
17
3. 3.Attorney’s Fees in an amount according to proof pursuant to Welf. & Inst. Code
18
§15657(a)(as to the Second Cause of Action only);
19
4. For costs of suit incurred herein;
20
5. For prejudgment interest, according to proof, from each and every Defendant;
21

22 6. For damages for Plaintiffs' other economic losses, according to proof;

23 7. For punitive and exemplary damages against MFI; and

24
8. For such further and other relief as the Court deems just and proper.
25
Dated: February 8, 2023 OAKWOOD LEGAL GROUP, LLP
26

27

28
Elan B. Zektser, Esq.
ATTORNEY FOR KARRI RYDER

13
COMPLAINT FOR DAMAGES
 1 DEMAND FOR JURY TRIAL
2

3 Pursuant to Code of Civil Procedure section 631, Plaintiff demands a jury trial on all
4 issues so triable.
5

6 Date: February 8, 2023 OAKWOOD LEGAL GROUP, LLP

7

9 By: ___________________________

10 Elan Zektser
Attorney for Plaintiff
11 KARRI RYDER
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COMPLAINT FOR DAMAGES