Mondello Case

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V. Causes of Action A. Claims against Mondello a. Threat of Bodily Injury 5.01 Cleaver hereby adopts by reference the allegations contained in Section IV (“Facts”) hereinabove, and incorporates the allegations as if fully set forth at length herein. 5.02 Cleaver would show that Mondello intentionally threatened Cleaver with imminent bodily injury by brandishing a shovel and informing Cleaver he should leave. If Cleaver failed to comply Mondello threatened harm by specifically stating she would “kick [Cleaver’s] ass.” As a result of Mondello’s actions, Cleaver became apprehensive which caused injury. 5.03 Cleaver seeks damages within the jurisdictional limits of this Court. b. Infliction of Bodily Injury 5.04 Cleaver hereby adopts by reference …show more content…

Cleaver would show that Mondello’s fist came into contact with Cleaver’s nose. Additionally, Mondello caused the shovel to come into contact with Cleaver’s left kneecap. Mondello caused Cleaver bodily injury by breaking Cleaver’s nose and left knee cap. Mondello’s action resulted in $60,000 in medical bills and $5,000 in property damage. 5.06 Cleaver seeks damages within the jurisdictional limits of this …show more content…

Claim against George Klooney a. Negligence 5.15 Cleaver hereby adopts by reference the allegations contained in Section IV (“Facts”) hereinabove, and incorporates the allegations as if fully set forth at length herein. 5.16 Cleaver would show that Klooney owed and breached his legal duty to act as an emergency responder. Courts have interpreted this duty to include: taking necessary action to prevent harm; performing a thorough assessment of the patient and situation; providing appropriate treatment; and transporting to an appropriate receiving facility when warranted. 5.17 Cleaver would show that Klooney breached his duty by leaving him outside of the ambulance on a stretcher with knowledge of the hostile situation based on Cleaver’s political affiliation; failing to perform a thorough assessment of Cleaver when he was bleeding profusely from the nose; and refusing to transport to Mercy. Klooney’s breach of duty proximately caused further injury to Cleaver since he was left open to attach by Mondello, which resulted in a broken knee cap and pain and suffering. 5.18 Cleaver seeks damages within the jurisdictional limits of this Court. D. Claim against Geico, Inc. a. Bad

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