Filing 85598510 E-Filed 02/27/2019 02:46:47 PM IN THE CIRCUIT COURT, FOURTH IUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: 16-2019-CA-1555 DIVISION: CV-B CAYLA GRIFFIN, Plaintiff, Case 0.: VS. ALBANESE ENTERPRISE, INC. DIBIA PARADISE Defendant. COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, Cayla Grif?n, brings this action seeking monetary damages, attorney?s fees, and costs against Defendant and alleges the following: 1. This is an action for damages brought pursuant to Florida Law. JURISDICTION AND VENUE 2. Jurisdiction in this court is proper, pursuant to Fla. Stat., because Plaintiff seeks damages in excess of$15,000. 3. Venue in this Court is proper, pursuant to ?47.011 Fla. Stat, because the cause of action arose in this county. PARTIES 4. Plaintiff, Cayla Grif?n, is a resident of Jacksonville, Duval County, Florida and a citizen of the United States. ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 02/28/2019 09:06:34 AM 5. Defendant, Albanese Enterprise, Inc. ?Paradise? is a for-pro?t corporation, organized and existing under the laws of the State of Florida, with its principal place of business in Jacksonville, Florida. FACTUAL ALLEGATIONS 6. Defendant Albanese Enterprise DIBIA ?Paradise? (hereinafter referred to as ?Paradise?) owns and operates Paradise Gentleman?s Club, located on Baymeadows Road in Jacksonville, Florida. 7. in February 2018, Plaintiff worked at Paradise as a dancer. 8. On February 26, 2018, at about 8:00 P.M., Plaintiff arrived at Paradise Gentleman?s Ciub for her shift. 9. Plaintiff began working her shift for that night. 10. Whiie Plaintiff was speaking to a co-worker in the back room of the establishment, Markus Bruski, a bouncer employed by Paradise, approached Plaintiff. ll. Bruski informed Plaintiff that the club?s owner had said that Plaintiff had been ?red from Paradise the previous night. 12. Plaintiff replied that she still worked for Paradise and the owner did not fire her. 13. Bruski then called the police to remove Plaintiff from the establishment. 14. Plaintiff replied that she would wait for the poiice to come, in hopes that that misunderstanding would be resolved. 15. Bruski then grabbed Plaintiff and threw her out the back do or of the establishment. 16. Plaintiff ianded on the ground outside, wearing only her lace underwear. Plaintiff clothes, cell phone, and wailet remained in the establishment. 18. Plaintiff then circled around the front door of the establishment, where she attempted to obtain her belongings from a co-worker. 19. George Malcom, another bouncer employed by Paradise, approached Plaintiff at the front door of the establishment. 20. Plaintiff is small in stature, weighing approximately one-hundred pounds. By contrast, the bouncers employed by paradise are iarge, muscular males. While Plaintiff was speaking to Malcolm, Malcolm struck Plaintiff in the and mouth. 22. Bruski also emerged from the front do or and struck Plaintiff against her will. 23. Maicolm and Bruski?s blows caused Plaintiff to fall to the ground and hither head on the concrete. 24. Their blows also knocked out several of Plaintiffs teeth and caused Piaintiff?s face to bleed. 25. A bystander who witnessed the commotion brought Plaintiff to his truck to clean the blood off of her. 26. As a result of the bouncers? actions, Plaintiff suffered ?actares in her right medial orbital wali and ?oor, cervicalgia in her neck, hematoma on her face, lacerations on her lips, broken teeth, and a concussion. COUNT I (Paradise) 27. Paragraphs 1 through 26 above are realleged and incorporated by reference herein. 28. George Malcolm and Markus Braski, employees of Paradise, actually and intentionally struck Plaintiff against her will, without legal justi?cation. 29. Paradise, having given these employees the authority to use force against Plaintiff, is liable for use of such authority. Malcolm and Bruski?s intentional acts were carried out under the scope of employment as bouncers at Paradise. 30. As a result of the above, Plaintiff suffered damages, including, but not limited to, severe pain and suffering, physical injuries, mental anguish and emotional distress. WHEREFORE, Plaintiff, Cayla Grif?n, demands judgments against Paradise for: actual and compensatory damages; costs; and any other relief this Court deems just and prop er. DENIAND FOR JURY TRIAL Plaintiff, Cayla Grif?n, hereby demands trial by jury on all issues so triable. DATED this Z?pday of February 2019. Respectfully submitted, Marx 141%? Win. J. Sheppard, Esauire Florida Bar No.: 109154 Elizabeth L. White, Esquire Florida Bar No.: 314560 Matthew R. Kachergus, Esquire Florida Bar No.: 503282 Bryan E. DeMaggio, Esquire Florida Bar No.: 055712 Jesse B. Wilkison, Esquire Florida Bar No.: 118505 Camille E. Sheppard, Esquire Florida Bar No.: 124518 Sheppard, White, Kachergus DeMaggio, PA. 215 Washington Street Jacksonville, Florida 32202 Telephone: (904) 356-9661 Facsimile: (904) 356-9667 Email: she law she ardwhite.com COUNSEL FOR PLAINTIFF