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Civil complaint filed against landlord for sexual harassment, battery

A civil complaint against Dick Smith, landlord, who is being sued for damages and other relief related to sexual and physical assault [see also Sexual harrassment, battery pervade homespace; civil suit imminent] is posted to Scribd.com:

Civil Complaint v. Richard Smith by James Alan Bush


The complaint was filed electronically today:



The complaint is well-structured and contains all of the necessary elements for bringing such a case to trial. It presents my case clearly and ties all of the factual allegations to specific legal claims; specifically:

  • The introductory sections (Parties, Jurisdiction and Venue, Applicable Laws) are properly formatted and contain the necessary information.
  • The Factual Allegations section is detailed and chronological, covering the incidents of sexual misconduct, violence, and uninhabitable conditions:

  • The Causes of Action are clearly stated, with five distinct counts that align with the factual allegations.
  • The Prayer for Relief is comprehensive, including requests for various forms of damages, injunctive relief, and other appropriate remedies.
I expect success on some level for the effort.