Case Document 1-1 '3 ?Cnanc101504 KASHIYA NWANGUNIA and MOLLY SHAH and HENRY BROUSSEAU vs. DONALD J. TRUWIP SERVE: Donald J. Trump Filed 04/29/16 Page 1 of 22 PageID 5 JEFFERSON CIRCUIT COURT DIVISION osnei. Ir: ooua?r DWISELEH PLAINTIFF cfo The Trump Organization 725 Fifth Avenue New Yerk, New York 10022 DONALD J. TRUMP FOR PRESIDENT, IN C. ampv SERVE: CT Corporation System 4701 Cox Road, Suite 235 Glen Allen, Virginia 23060 MATTHEW JOHN ar?kla MATTHEW WARREN HEIMBACH SERVE: Matthew Heimbaeh 6045 B11de Avenue Cincinnati, Ohio 45224-2409 ALVIN BAIVIBERGER SERVE: Alvin R. Bamberger 4491 Fork Road Cincinnati, Ohio 45247 and DEFENDANT ?81* Banal. moment: new COURT CLERK ?31 KY DEFENDANTS Case Document 1-1 Filed 04/29/16 Page 2 of 22 PageID 6 VERIFIED COMPLAINT Plaintiffs, Kashiya Nwangurna, Molly Shah, and Henry Brcusseau, for their Complaint against the Defendants, Matthew John Heirnbach, Alvin Barnberger, Donald J. Trump for President, Inc, and Donald J. Trump, state the following: INTRODUCTION ?Peace is not absence ofcon?ici, it is the ability to handle con?ict by pecce?zi means. --Ronald Reagan Protesters from every side of the political spectrum have been a regular feature in American politics, and at American political rallies, since time immemorial. They regularly appear at public functions attended by the President of the United States, and in this campaign season, every candidate has seen his share of protesters. But one Donald J. Trump has decided to break with American tradition and the rule of law by inciting his supporters to physically attack protesters at his rallies and campaign appearances. Worse still, these attacks often carry with them the blatant stamp of racism, religious intolerance, misogyny, or any combination of the three. This is an action for incitement pursuant to Kentucky statutory law, and an action for common law assault, battery, negligence, gross negligence, and recklessness resulting from incidents facilitated, incited, encouraged, endorsed, and subsequently ratified by Defendant Trump at a campaign rally in Louisville, Kentucky, on March 1, 2016. JURISDICTION AND VENUE l. Jurisdiction is proper under Ky. Const. ?112 because the causes of action set forth below arise under Kentucky statutes and common law, the injuries occurred in Kentucky, the total damages claimed exceed the jurisdictional threshold of the Circuit Court, and the Plaintiffs all reside in Kentucky. Case Document 1-1 Filed 04/29/16 Page 3 of 22 PageID 7 2. Venue is proper because the injuries occurred in Jefferson County and the Plaintiffs reside in Jefferson County. PARTIES I. MATTHEW HEMACH 3. Defendant Matthew John Heimbach, elk/a Matthew Warren Heimbach, is a supporter of Defendant Donald J. Trump. 4. Heimbach has been described by the Southern Poverty Law Center as "the face of a new generation of white nationalists." 5. Heimbach is af?liated with the Traditionalist Worker Party, a recognized hate group and self-proclaimed political party which is ideologically opposed to, among other things, what it calls "miscegenation," different ethnicities living together in the same community and inter-marrying. Heirnbach himself has been quoted as saying, "It?s separation or mongrelization. I 6. Heimhach has even been banned outright from entering the United Kingdom, on the grounds that his presence may "foster hatred which might lead to inter-community violence in the Heimbach has been quoted as saying of Trump: "This is the ?rst time since Buchanan in the '905 and George Wallace in '68 where you have a guy outside the mainstream speaking to white interests." 3. Heirnbach and the Traditionalist Worker Party have actively been engaged in recruiting supporters of Donald Trump. In fact, Heimhach has even stated, "We have the potential to be able to work with so many of these millions of families to be able to then move 2 15f?! 3 Case Document 1-1 Filed 04/29/16 Page 4 of 22 PageID 8 them in our direction. Donald Trump is a gateway can then move them from civic nationalism and populism to nationalism for us-and these people are ready for our message." 9. Heimbach is a Caucasian male and is approximately 25 years of age. 10. Heimbach is a resident of Ohio. II. ALVIN BAMBERGER 11. Defendant Alvin Bamberger is a supporter of Donald J. Trump. 12. Bamberger is a Caucasian male and is approximately 75 years of age. 13. Barnberger is a resident of Ohio. HI. DONALD J. RUNIP 14. Defendant Donald J. Trump was the former host of a popular reality television show from 2005?2015, a former part-owner of the Miss Universe pageant, an occasional featured guest of WWE's Wrestlemania, and is the current front-runner for the Republican nomination in the race for President of the United States of America. Trump has recently intimated that he may be planning to run for President of the United States on an independent-ticket if he is not the Republican nominee. 15. Trump is a resident of New York. IV. DONALD J. TRUMP FOR PRESIDENT, INC. 16. Defendant Donald J. Trump for President, Inc. (hereinafter, the "Trump Campaign?), is a corporation existing under the laws of Virginia. 17. The Trump Campaign contracted with the Kentucky International Convention Center which is a state agency owned and operated by the Kentucky State Fair Board, to conduct business at a public building in Kentucky, the campaign rally discussed below. Case Document 1-1 Filed 04/29/16 Page 5 of 22 PageID 9 V. WOW DEFENDANT 18. In addition to the above-named Defendants, there is an additional Defendant believed to be a Caucasian woman, who is responsible for punching Plaintiff Brousseau, as set forth in further detail below. 19. Upon information and belief, this unidenti?ed woman is af?liated with Defendant Heimbach and the Traditionalist Worker Party. 20. Upon information and belief, this unidenti?ed woman is a supporter of Donald J. Trump. VI. NWANGUNIA 21. At all times relevant to this Complaint, Plaintiff Kashiya Nwanguma was a 21- yearu-old college student majoring in Public Health. 22. Nwanguma is an African-American who was born and raised in the United States. 23. Nwanguma resides in Jefferson County, Kentucky. VII. MOLLY SHAH 24. At all times relevant to this Complaint, Plaintiff Molly Shah was a 36-year-old Caucasian mother and activist. 25. Shah is a former public?interest attorney and special-education teacher for the Jefferson County Public Schools. 26. Shah resides in Jefferson County, Kentucky. HENRY BROUSSEAU 27. At all times relevant to the events described in this Complaint, Plaintiff Henry Brousseau was a 17-year-old Caucasian high school student. 28. Brousseau resides in Jefferson County, Kentucky. Case Document 1-1 Filed 04/29/16 Page 6 of 22 PageID 10 FACTUAL BACKGROUND I. THE RALLY 29. On March 1, 2016, pursuant to an agreement between the Conunonwealth of Kentucky and Defendant Donald J. for President, Inc, a rally in support of Defendant Trump occurred in Louisville, Kentucky, at KICC (hereinafter "the Rally"). 30. At the Rally, as discussed in ?lrther detail below, individuals who attempted to peacefully protest Trump were forcibly removed by Trump's supporters, pursuant to Trump?s directives. 31. Tickets andfor entry to the event were not denied to people simply because they had political views which differed from Trump andfor his supporters. 32. Instead of allowing his own security, the Secret Service, or KICC security to remove protesters, Trump stopped his half-hour speech five different times to point out protesters and, in most cases, to tell his crowd of supporters to get 'em out of here. 33. Plaintiffs were some of the individuals Trump directed the crowd to get out of here." 34. On or around the time the injuries occurred to the Plaintiffs, as described below, Trump also stated: "Don't hurt 'em. If I say 'go get em,? I get in trouble with the press, the most dishonest human beings in the world." 35. Trump went on to state: "In the old days, which isn?t so long ago, when we were less politically correct, that kinda stuff wouldn't have happened. Today we have to be so nice, so nice. We always have to be so nice." Then Trump went into a discussion about waterboarding, and how it is "absolutely Case Document 1-1 Filed 04/29/16 Page 7 of 22 PageID 11 II. KASHIYA NWANGIW 36. At the time of the rally, Plaintiff Kashiya Nwanguma was a 21?year-old student attending classes at the University of Louisville. 37. Nwanguma attended the Rally with the intention of peace?iily protesting Trurnp. 38. Nwangurna traveled to the Rally alone. She was not with a group at the time of her assault, did not enter with a group, and took no part in the group protests. 39. Nwangurna is not affiliated with the Black Lives Matter movement. 40. Supporters of Defendant Trump called a "nigger" and a "cunt" during the Rally. 41. Nwangurna heard a number of other racial and ethnic slurs used by Trump's supporters during the Rally. 42. Nwanguma did not intentionally make physical contact with any attendee of the Rally. 43. Nwanguma did not threaten, curse at, or use any form of offensive language toward any attendee of the Rally. - 44. Nwanguma held up a sign depicting Defendant Trump's face on the body of a pig. 45. ordered his sopporters to get [Nwanguma] out of here." 46. Nwanguma was thereafter violently assaulted by numerous protesters (as discussed ?irther below) until she was forced to leave the Rally. A video of this assault went viral soon thereafter, and is readily available to be viewed on the internet. 47. . At no point did a police of?cer come to Nwanguma?s aid, nor did they assist in her removal. Trump's supporters, upon Trump?s command, took it upon themselves to use physical force to remove her from the Rally. Case Document 1-1 Filed 04/29/16 Page 8 of 22 PageID 12 48. The most aggressive of those who assaulted Nwangurna were Defendants Heimbach and Bamherger. 49. Heirnbach, who is nearly twice Nwanguma's size, i?epeatedly shoved Nwangurna and shouted "leftist scorn" at her. 50. Eventually Heimbach returned to the crowd, and Bamberger began aggressively moving Nwanguma further through the crowd by shoving her and striking her. MOLLY SHAH - 51. Plaintiff Molly Shah attended the Rally with the intention of peacefully protesting Trump. 52. Shah did not intentionally make harmful physical contact with any attendee of the Rally. 53. Shah, like Nwanguma, heard numerous ethnic and racial slurs used by Trump supporters at the Rally. 54. Inside the Rally, Shah saw a group of 4?6 people standing wearing black t-shirts with the words "tradworkerorg" on them, which is the website for the Traditionalist Worker Party. One of these people was Defendant Heimbach. 55. 'Shah continued to observe this group over the course of three hours, and watched them talk to dozens of Trump supporters. At no time did she witness anyone involved in the Trump Campaign or KICC security approach them or question their presence. 56. Shah's group began to peacefully protest. When Trump told the audience to "get 'em out of here," Heimbach and his group rushed in and began physically assaulting?the protesters. Case Document 1-1 Filed 04/29/16 Page 9 of 22 PageID 13 57. Shah witnessed the Unknown Defendant who was with Heirnbach?s group punch Plaintiff Brousseau. 58. Shah began to walk out and was shoved hard from behind by Defendant Heirnhach. 59. As Shah continued to the back of the convention center, she was shoved and pushed by multiple Trump supporters. 60. As a result of the above-described incidents, Shah experienced pain and dif?culty sleeping for several days after the Rally. IV. HENRY BROUSSEAU 61. Plaintiff Henry Brousseau attended the Rally with the intention of peacefully protesting Trump. 62. Brousseau did not intentionally make lilEIIDqul physical contact with any attendee of the Rally. 63. Brousseau, who was a 17?year-old high-school student, began to peacefully protest. When Trump told the audience to "get ?em out of here," Heimbach and his group rushed in and began physically assaulting the protesters. 64. The Unknown Defendant, who is belieVed to be one of the Traditionalist Worker Party "comrades,? punched Brousseau in the stomach. 65. Since that time, Brousseau has experienced anxiety and nightmares. V. MATTHEW HEIMZBACH 66. Heimbach went to the Rally dressed in a Traditionalist Worker Party t-shirt and a red hat which said "Make America Great Again," a Tramp campaign slogan. Case Document 1-1 Filed 04/29/16 Page 10 of 22 PagelD 14 67. Upon information and belief, Heimbach went to the Rally with other Traditionalist Worker Party activists (which he calls ?comrades") in hopes of recruiting more members ?cm among Trump?s supporters. 68. As described above, Heimbach personally physically attacked Plaintiffs Nwanguma and Shah. Nwanguma's assault and battery was captured on video. 69. Afterwards, Heimbach wrote and spoke extensively about the Rally, admitting to his role in the physical altercation and implying that Nwanguma had initiated it. 70. in one blo post, Heimbach stated: Now there?s some viral footage of several heated moments in Louisville. One features yours truly helping the crowd drive out one of the women who had been pushing, shoving, barking, and screaming at the attendees for the better part of an hour. I'll avoid any additional Trump events to ensure that I don't become a distraction, but the entire point of the BLM's tactics is to push people until they push back. It won?t be me next time, but White Americans are getting fed up and they're learning that they must either push back or be pushed down. 71. Despite the fact that multiple videos exist of the entire Rally, there is no videographic evidence of Nwanguma Or any other Plaintiff "shoving, barking, and screaming" at attendees, because that simply did not happhn. 72. In an interview with "Radio Aryan," Heirnbaeh stated he was refraining from attending further rallies "because I want Donald Trump to continue to destroy the established Republicans, make the Jews around the world quake in their boots, and make leftists angry." VI. ALVIN 73. Defendant Alvin Bamberger shoved Nwanguma, and continued to shove her repeatedly while she was exiting the Rally. 74. During the rally on March 1, 2016, Bamberger was wearing a uniform associated with the Kerean War Veterans Association 1 0 Case Document 1-1 Filed 04/29/16 Page 11 of 22 PagelD 15 75. Subsequently, after concerns were raised about Bamberger?s behavior and affiliation with KWVA, Barnberger wrote a letter to the KWVA admitting his role in the assault and battery of Nwanguma. 7'6. In the letter, Bamberger writes: "Tnunp kept saying 'get them out, get them out' and people in the crowd began pushing and shoving the protesters, . . . I physically pushed a young woman down the aisle toward the exit, an action I sincerely regre 77. Bamberger said he learned only afterwards that some of the Trump supporters "standing right next to [him] were members of a white supremacy group." 78. Upon information and belief, the "white supremacy group" Bamberger refers to is the Traditionalist Worker Party, one of whom was Defendant Heimbach. Bamberger also calls them a "hate group." 79. "Unfortunately my state of mind after being knocked down and hurt[ing] myself, and being caught between a group of white supremacists and Black Lives Matter protesters contributed to my behavior however, there is no excuse for my actions," Bamberger wrote. VII. DIRECTIVES 80. As discussed above, and as admitted to by Defendant maberger in his letter, the actions taken against Plaintiffs by Defendants and other attendees of the Rally were pursuant to the explicit directives given by Defendant Trump. Speci?cally, Trump's repeated order to "get them out" was directed to his supporters, and could have no other reasonable meaning but to remove protesters, including the Plaintiffs, using unwanted, harmful physical force. 82. Each time he said, "get them out," Trump intended for his supporters to use unwanted, harmful physical force' to remove protesters, including the Plaintiffs; knew or 11 Case Document 1-1 Filed 04/29/16 Page 12 of 22 PagelD 16 reasonable should have known that his supporters would act upon his orders, and watched as his supporters physically removed and accosted Plaintiffs at the Rally. THE AFTERMATH 33. All plaintiffs have ?led reports with the Louisville Metro Police Department. As of the ?ling of this Complaint, the incident described above - much of which was captured on video and occurred in the presence of thousands of witnesses - has been under investigation for approximately a month with no arrests. IX AND ENDORSEBIENT OF VIOLENCE AT SMAR EVENTS 84. The Rally referred to above is not the first or last incident of its kind. 85. At a Trump rally held on November 21, 2015 in Birmingham, Alabama, a protester was attacked, "roughed up." Trump commented on this incident, stating that the protester "started screaming by himself" and "he should have been, maybe he should have been roughed up." Trump further stated that "it was absolutely disgusting what [the protester] was doing," in, protesting against Trump. 86. On February 1, 2016 at a rally in Cedar Rapids, Iowa, Trump instructed those in the crowd to "knock the crap out of? anyone who was getting ready to throw a tomato." Trump followed this instruction by saying, ?Seriously. Okay? Just knock the hell. Trump continued by ensuring the crowd that if and when they took heed of his instruction, he would cover their legal fees: promise you, I will pay for the legal fees. I promise. I promise." 87. On February 22, 2016 at a rally in Las Vegas, Nevada, Trump responded to a protester by alluding to the fact that protesters had it too easy in present times. He expressed his desire for the way things once were: love the old days. You know what they used to do to guys like that when they were in a place like this? They'd be carried out on a stretcher, folks." 12 Case Document 1-1 Filed 04/29/16 Page 13 of 22 PagelD 17 88. Trump told his supporters that he would like "to punch [the protester] in the face." 89. On March 4, 2016, at a rally in Warren, Michigan, Trump gave the instruction to remove the protester. In doing so, anmp added the disclaimer that those removing him should not hurt him. However, this disclaimer was overshadowed by anmp?s immediately following statement: "If you do [hurt him], I?ll defend you in court. Don't worry about it. 90. On March 8, 2016, Breitbart reporter Michelle Fields was grabbed and thrown to the ground at a Trump press conference. Fields made allegations that she was gabbed by Campaign Manager. Subsequently, Fields ?led a police report. Trump's response was that Fields "made the story up." Trump's Campaign Manager has since been arrested for assault. 91. On March 9, 2016 at a rally in Fayetteville, North Carolina, Trump, again, Spoke of the "good 'old days" when protesters were treated "very, very rough." asserted that such treatment deterred the protesters from doing it ?again so easily." 92. On March 11, 2016 at a rally in St. Louis, Missouri, Trump claimed that ?part of the problem and part of the reason it takes so long" to remove those protesting was peeple are too averse to hurting each other. Essentially, Trump advocated that more violence would help to cure the problem. 93. On March 19, 2016, at a rally in Arizona, a protester was punched and kicked repeatedly after being pointed out and described as "disgusting" by Trump from the stage. 94. On March 29, 2016 at a rally in Janesville, Wisconsin, a 15-year-old female protester was pepper sprayed in the face and sexually assaulted by two unidenti?ed Trump supporters. As the protester left the rally Trump's supporters erupted with "Hell Yeah," name calling, "goddamn communist, nigger lover," Cries of victory, and an echo of Trump?s usual response to protesters: get 'em out of here!" 13 Case Document 1-1 Filed 04/29/16 Page 14 of 22 PagelD 18 95. Despite this persistent, unmistakable pattern of violence andfor threats of violence at his rallies, neither Trump himself nor Donald J. Trump for President, Inc., have taken adequate measures to ensure that further assaults on protesters are eliminated or at least minimized, and in fact, Trump has continued to encourage the continuation and escalation of such violence in the same manner during the past few months. CAUSES OF ACTION COUNT I BATTERY 96. The Plaintiff incorporates by reference, as if set forth fully herein, each and every avennent, allegation, or statement contained in the previous paragraphs of this Veri?ed Complaint. 97. As detailed in above paragraphs, Defendants Heimbach, Bamberger, and Unknown Defendant, without privilege or provocation, intentionally, maliciously, wantonly andfor recklessly made numerous offensive and/or harmful contacts with the persons of the Plaintiffs. 98. As a result of these harmful contacts, Plaintiffs suffered injuries in excess of the jurisdictional limits of this Court. COUNT II ASSAULT 99. The Plaintiff incorporates by reference, as if set forth fully};r herein, each and every averment, allegation, or statement contained in the previous paragraphs of this Veri?ed Complaint. 100. By attacking Plaintiffs, Defendants Heirnbach, Bamberger, and Unknown Defendant, intentionally, maliciously, wantonly and/or recklessly caused Plaintiffs to experience 14 Case Document 1-1 Filed 04/29/16 Page 15 of 22 PagelD 19 i apprehension and fright of an immediate harmful andfor offensive contact. 101. As a result of this apprehension and ?ight, Plaintiffs suffered injuries in excess of the jurisdictional limits of this Court. COUNT INCITEMENT 102. The Plaintiff incorporates by reference, as if set forth fully herein, each and every avennent, allegation, or statement contained in the previous paragraphs of this Veri?ed Complaint. 103. As set forth in the description of the events at the Rally above, Defendant Trump, acting individually and as an agent of the Trump Campaign, incited a not as de?ned under the Kentucky penal code, KRS 525.040 and KRS 525.010. 104. In directing his supporters to eject peaceful protesters using harrn?? physical force, intended to create a public disturbance involving an assemblage of ?ve or more persons which by tumultuous and violent conduct created grave danger of damage or injury. 105. As a result of Trump's violation of the aforementioned statutes, Plaintiffs were harmed and have the right to recover pursuant to KRS 446.070. 106. Trump's speech, as set forth above, was calculated to incite violence against the Plaintiffs and others, and does not constitute speech protected by the First Amendment to the United States Constitution or any analogous provision in the Kentucky Constitution. COUNT IV AGENCYNICARIOUS LIABILITY 107. The Plaintiff incorporates by reference, as if set forth fully herein, each and every avernrent, allegation, or statement contained in the previous paragraphs of this Veri?ed Complaint. 15 Case Document 1-1 Filed 04/29/16 Page 16 of 22 PagelD 20 108. At all times pertinent to the claims set forth above, Defendants Heimbach, Bamberger, and Unknown Defendant were acting as agents of Defendant Trump andfor the Trump Campaign. 109. The Trump Campaign is liable under a theory of respondent superior or is otherwise vicariously liable for both the actions of Donald Trump himself and Trump's agents at a Trump Campaign event such as the Rally in question. 110. If the Trump Campaign andfor Trump himself is not jointly and severally liable fer the actions of I-Ieimbach and Bamberger, they should at least be apportioned fault for their actions as described above. 111. Defendant Trump and the Trump Campaign made no effort to suppress other offensive speech - racial and ethnic slurs, speech promoting racial apartheid, and speech unequivocally courting members for recognized hate groups but selectively targeted the protesters for physical violence because of the content of their speech. 112. Trump knew or should have known based on the prior actions of his supporters at the above-described rallies that occurred prior to the Rally, that when he used the phrase ?get'em out of here? it was reasonable foreseeable that his supporters would physically assault Plaintiffs while they were being removed. 113. Trump's statements and cements during the Rally called for and sanctioned the physical abuse of Plaintiffs by Heirnbach, Bamberger, and Unknown Defendant. 114. Trump's inducement and encouragement of Heimbach, Bamberger, and/or Unknown Defendant to remove Plainti?s from the Rally by way of physical force was a substantial factor in causing the Plaintiffs? injuries 115. Trump knew or should have known that by encouraging members of the audience, 16 Case Document 1-1 Filed 04/29/16 Page 17 of 22 PagelD 21 including Heirnbach, Barnberger, and/or Unknown Defendant, to "get [Plaintiffs] cut of here," these individuals would physically aSSault the Plaintiffs. COUNT NEGLIGENCE, GROSS NEGLIGENCE, AND 116. The Plaintiff incorporates by reference, as if set forth hilly herein, each and every averment, allegation, or statement contained in the previous paragraphs of this Veri?ed Complaint. 117. Defendants Trump and the Trump Campaign had a duty under Kentucky common law to provide adequate security in order to ensure the safety, protection, and well-behig of Rally attendees and the general public in connection with the Rally. 113. Defendants Trump and the Trump Campaign breached the duties identi?ed above, through their negligent, grossly negligent, andfor reckless actions, as set forth in this Complaint. 119. In addition, Defendants Trump and the Trump Campaign acted with the absence of even slight care, thus constituting gross negligence andfor recklessness under Kentucky common law. 120. Trump and the Trump campaign knew or should have known that relying on the crowd of Trump supporters to provide security, including making them responsible for ejecting peaceful protesters ?'om the crowd, was an inadequate and entirely reckless, or at least negli gent! grossly negligent, way in which to provide security. 121. Trump and the Trump Campaign knew or should have known that by encouraging members of the audience, including Heimbach, Bamberger, and/or Unknown Defendant, to get [Plaintiffs] out of here, these individuals would physically attack the Plaintiffs. 122. In paiticular, the directive to eject a Black woman, when several members of a group that Trump knew or should have known was a recognized hate gremlp were present in the 17 Case Document 1-1 Filed 04/29/16 Page 18 of 22 PagelD 22 audience, was entirely reckless, or at least negligent! grossly negligent. 123. As a direct and proximate result of Defendants' breach of their duties, Plaintiff has suffered losses in excess of the jurisdictional limits of this Court. COUNT VI PUNITIVE DAMAGES 124. The Plaintiff incorporates by reference, as if set forth fully herein, each and every avennent, allegation, or statement contained in the previous paragraphs of this Veri?ed Complaint. 125. Defendants acted toward Plaintiff with oppression andJor malice, and with knowledge that serious harm would likely arise ?om their conduct, thus entitling Plaintiff to recover punitive damages. DEMAND FOR RELIEF WHEREAS, Plaintiffs pray as follows: A. That the Court award compensatory damages to them as against all Defendants for physical injuries, emotional distress, humiliation, and mental anguish; B. That the Court award punitive damages as against all Defendants, in an amount that will deter such conduct by defendants in the future; C. For pro?judgment and post-judgment interest and recovery of their costs; and E. For any and all other relief to which they may he entitled. 18 Case Document 1-1 Filed 04/29/16 Page 19 of 22 PagelD 23 DANIEL .1. CANON, PS DAVID N. WARD CLAY DANIEL WALTON Sc ADAMS, PLC 101 Meidmger Tower 462 South Fourth Street Louisville, Kentucky 40202 (502) 561-2005 dan@justiceky.com david@justiceky.com Counselfor Plainn' 3 GREGORY A. BELZLEY CAMILLE BATHURST BELZLEY BATHURST ATTORNEYS P.O. Box 278 Pr05pect, Kentucky 40059 (502) 228-5034 gbelzley@aul.com ounsel for Plainry? 19 Case Document 1-1 Filed 04/29/16 Page 20 of 22 PagelD 24 VERIFICATION I, Kashiya Nwanguma, state that I have read the foregoing, and the statements contained therein ma?a/Q Kashiya Nwanguma are true to the best of my knowledge and belief. Subscribed and sworn to before me by KASHIYA NWANGUMA on this day of March, 2016, to be her free act andvoluntaryr deed. My commission upheam m/Qb 806%- Qanmo/ NOTM UBLIC, KY STATE AT LARGE 20 Case Document 1-1 Filed 04/29/16 Page 21 of 22 PagelD 25 VERIFICATION I, MolIy Shah, state that I have read the foregoing, and the stateme?ts contained therein are true to the best of my knowledge and belief. Molly Sh 11 515?. Subscribed and sworn to before me by MOLLY SHAH on this 5} day of March, 2016, to be her ??ee act and voluntary deed. My commission expires: I TARY LIC, STATE AT LARGE 21 Case Document 1-1 Filed 04/29/16 Page 22 of 22 PagelD 26 VERIFICATION I, Henry Brousseau, state that I have read the foregoing, and the statements contained therein are vie Brousseau true to the best of my knowledge and belief. Subscribed and sworn to before me by HENRY BROUSSEAU on this 3\ day of March, 2016, to be his free act and voluntary deed. My commission eXpires: got any NOTABMPUB LIC, KY STATE AT LARGE 22