FILED
17 AUG 14 AM 11:37

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KING COUNTY
SUPERIOR COURT CLERK
E-FILED
CASE NUMBER: 17-2-21360-8 SEA

SUPERIOR COURT OF THE STATE OF WASHINGTON
FOR KING COUNTY

WAHEED KAYODE LAWAL and TARA
KALEILANI LAWAL, husband and wife, and
the marital community thereof,

NO.
COMPLAINT FOR ASSAULT AND
BATTERY

Plaintiffs,
v.
SIGURD JOHNNY HANSEN and CLARK
ALLEN PEDERSON,
Defendants.
I.
1.1

PARTIES

Plaintiffs Lawal. Waheed Kayode Lawal and Tara Kaleilani Lawal are residents

of King County, Washington.
1.2

Defendant Hansen. Sigurd Johnny Hansen is a resident of King County,

Washington.
1.3

Defendant Pederson. Clark Allen Pederson is a resident of Clark County,

Washington.

COMPLAINT FOR ASSAULT AND BATTERY - 1

GORDON TILDEN THOMAS & CORDELL LLP
1001 Fourth Avenue, Suite 4000
Seattle, WA 98154
Phone (206) 467-6477
Fax (206) 467-6292

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II.
2.1

JURISDICTION AND VENUE

Subject Matter Jurisdiction. This Court has subject matter jurisdiction pursuant to

RCW 2.08.010.
2.2

Personal Jurisdiction. The Court has personal jurisdiction of all parties.

2.3

Venue. Venue in this county is proper pursuant to RCW 4.12.020.
III.

3.1

FACTS ENTITLING PLAINTIFF TO RELIEF

Mr. Lawal Picks Up Mr. Hansen, Mr. Pederson, and Their Wives. Waheed Lawal

is an Uber driver. On May 18, 2017, just before 2:00 am, Mr. Lawal arrived at 2228 NW Market
Street, Seattle, Washington to pick up four riders, Sigurd Hansen, Clark Pederson, and their
wives. Mr. Pederson is Mr. Hansen’s son-in-law. They told him they were going to 18361 8th
Avenue NW in Shoreline, Washington, the Hansen home. Mr. Pederson got in the car and sat in
the rear-middle seat. He immediately said “I don’t like the music he is playing. It’s horrible.”
Mr. Lawal turned off the music. Mr. Hansen finished his cigarette, dropped it, stomped it out
and then got into the car and sat behind the driver’s seat.
3.2

The Ride is Cancelled. After driving 0.3 miles, the Uber app alerted Mr. Lawal

that the trip had been cancelled. Mr. Lawal pulled over and explained to his passengers that their
ride was cancelled. Mrs. Hansen asked, “What can we do?” Mr. Lawal said, “If you can send a
new request, it will automatically pick me and we can continue the trip.”
3.3

Mr. Hansen and Mr. Pederson Respond. Mr. Hansen screamed: “NO!!!” He

pounded the back of Mr. Lawal’s seat with his fist, “JUST GET ME HOME!” Mrs. Hansen said,
“Ok, let me do it.” Mr. Hansen screamed, “NO! WE ARE NOT REQUESTING, JUST GET ME
HOME!” Mr. Lawal turned on the inside light of the car so he could see Mr. Hansen’s face. He

COMPLAINT FOR ASSAULT AND BATTERY - 2

GORDON TILDEN THOMAS & CORDELL LLP
1001 Fourth Avenue, Suite 4000
Seattle, WA 98154
Phone (206) 467-6477
Fax (206) 467-6292

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explained again, saying calmly: “Your trip has been cancelled, sir. I will not get paid if I
continue this trip.” Mr. Hansen screamed, “Just f___ing get me home! I don’t care!” Mr. Lawal
remained calm. Mr. Pederson brought out a $100 bill and said, “Ok, ok, have this and go!” Mr.
Lawal told Mr. Pederson: “Uber doesn’t allow me to take cash.” Mr. Hansen got madder,
snatched the money from Mr. Pederson and screamed at Mr. Lawal: “Do you want to make
money or not?” Mr. Lawal asked: “What?” Mr. Hansen screamed: “DO YOU WANT TO
MAKE MONEY OR NOT, ANSWER ME!” Mr. Lawal replied: “Of course I want to make
money, that’s why I’m on the road driving in the middle of the night. However, I don’t want to
make money that is against Uber Partner Policy.” Mrs. Pederson pled with Mr. Hansen: “Stop!
You can’t do this, it’s not right.” She looked at Mr. Lawal and said: “I’m so sorry!”
Mr. Hansen screamed in an enraged voice: “YOU ARE STUPID, YOU’RE A F___ING
ASS___, YOU’RE DISGUSTING!” and other profanities. He then screamed: “F___ YOU,
SONOFABITCH, (extending both his middle fingers). F___ YOU! EVERYONE GET OUT
OF THE CAR!” Mrs. Pederson immediately got out and left. As they were getting out, Mr.
Hansen and Mr. Pederson started pounding the back of Mr. Lawal’s car seat and spitting on his
head and his seat. Mrs. Hansen, looking terrified, shouted: “Stop, you can’t do that.”
Mr. Lawal turned to face them and Mr. Pederson spit right in his face. Mr. Pederson then
yelled: “NO, WE NEED TO F___ HIM UP. HE’S F___ING STUPID! F___ YOU!” Mr.
Hansen and Mr. Pederson were both screaming profanities the entire time; Mr. Hansen’s voice
was much louder. Mr. Hansen and Mr. Pederson finally got out of Mr. Lawal’s car, slammed
both of the car doors and started punching and kicking the car. They elbowed the windows
attempting to smash them.

COMPLAINT FOR ASSAULT AND BATTERY - 3

GORDON TILDEN THOMAS & CORDELL LLP
1001 Fourth Avenue, Suite 4000
Seattle, WA 98154
Phone (206) 467-6477
Fax (206) 467-6292

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Mrs. Hansen remained in the car and asked Mr. Lawal: “What am I supposed to do? Am
I getting out too?” She sincerely apologized with her hand on her heart and said: “I’m so sorry.”
Mr. Hansen then opened the door and yelled at her: “Get out of the car, NOW!” He unbuckled
her, grabbed her by the knees and dragged her out of the car, slamming the door shut. Mr.
Hansen then opened the door and grabbed her purse that she left on the seat, and slammed it
again. He then opened it a third time and slammed it again.
While Mr. Hansen was pulling his wife out of the car, Mrs. Pederson sat down in the
backseat and apologized again, saying: “I’m so sorry, I’m so sorry!” Mr. Lawal nodded at her
and said: “Thank you so much, I appreciate that.” Once she got out, Mr. Lawal was finally able
to lock the doors. Mr. Hansen attempted to open the car doors. Mr. Lawal thought he was going
to be attacked. As Mr. Lawal was driving off, the defendants kicked the body of Mr. Lawal’s
car. Both of them shouted: “F___ YOU!” and flipped him off. Mr. Lawal drove a few blocks
away and called 911.
3.4

Assault and Battery. The actions of Mr. Hansen and Mr. Pederson constitute

assault and battery.
3.5

Damages. As a result of the foregoing, Mr. Lawal and his wife have been

damaged in an amount to be proved at trial including, without limitation: bodily injuries, lost
earnings, property damage, emotional distress, pain and suffering, and loss of consortium.
IV.

PRAYER FOR RELIEF

As a result of the foregoing, plaintiffs pray for the following relief:
4.1

Money Damages. For money damages in an amount to be proved at trial.

4.2

Prejudgment Interest. For prejudgment interest on all liquidated sums.

COMPLAINT FOR ASSAULT AND BATTERY - 4

GORDON TILDEN THOMAS & CORDELL LLP
1001 Fourth Avenue, Suite 4000
Seattle, WA 98154
Phone (206) 467-6477
Fax (206) 467-6292

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4.3

Attorneys’ Fees and Costs. For plaintiffs’ statutory attorneys’ fees and costs.

4.4

Further Relief. For such other relief as the Court deems just and equitable.

DATED this 14th day of August, 2017.
GORDON TILDEN THOMAS & CORDELL LLP
Attorneys for Plaintiff
By

s/Jeffrey I. Tilden
Jeffrey I. Tilden, WSBA #12219
1001 Fourth Avenue, Suite 4000
Seattle, Washington 98154
Telephone: (206) 467-6477
Facsimile: (206) 467-6292
Email: jtilden@gordontilden.com

PERKINS COIE LLP
Attorneys for Plaintiff
By

s/Harry H. Schneider, Jr.
Harry H. Schneider, Jr., WSBA #9404
1201 Third Avenue, Suite 4900
Seattle, Washington 98101
Telephone: (206) 359-8508
Facsimile: (206) 359-9508
Email: HSchneider@perkinscoie.com

COMPLAINT FOR ASSAULT AND BATTERY - 5

GORDON TILDEN THOMAS & CORDELL LLP
1001 Fourth Avenue, Suite 4000
Seattle, WA 98154
Phone (206) 467-6477
Fax (206) 467-6292