EXHIBIT 1 

to Notice of Removal 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 1 of 21
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4 IN THE CIRCUIT COURT OF STATE OF OREGON 

5 FOR THE COUNTY OF MULTNOMAH 

5 TIMOTHY MEACHAM, Case No.: 15CV01985 

7 Plaintiff, SUMMONS 

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Vs. 

SPIRIT AIRLINES INC., and; KERRIE 

CONRAD, 

Defendants. 

13 TO: SPIRIT AIRLINES, INC. C/O CT CORPORATION SYSTEM 

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The Plaintiff, Timothy Meacham, has filed a Complaint against you for negligence 

and battery. If you do not file the appropriate legal paper with the above court in the 

16 time required (see below), Plaintiff may ask the court for a judgment against you that 

17 orders the relief he requested in the complaint. 

18 YOU ARE HEREBY REQUIRED to appear and defend the complaint filed against 

19 you in the above-entitled cause within 30 days from the date of service of this 

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summons on you, and if you fail to do so, Plaintiff will apply to the court for the relief 

demanded in the complaint. 

NOTICE TO THE DEFENDANT: READ THESE PAPERS CAREFULLY! 

You must "appear" in this case or the other side will win automatically. To 

24 "appear" you must file with the court a legal paper called a "response" or "motion." The 

25 "response" or "motion" must be given to the court clerk or administrator within 30 days 

Summons 

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ATTORNEYW!LltAM SALL, LL( 

420 SW WASHl>;GTON, Slim 400 

PORTIAND, OREGON 97204 

TEL (503} 477-8194 ff-AX {877)179"-0429 

filJJ Wrulit!'.?kA? COM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 2 of 21
1 along with the required filing fee. It must be in proper form and have proof of service 

2 on Plaintiff's lawyer (Attorney William Ball, LLC) or, if Plaintiff does not have a lawyer, 

3 proof of service on Plaintiff. The response or motion must be mailed or faxed to the 

4 Plaintiff's lawyer at the address listed on this document. Any subsequent papers must 

5 be mailed or faxed to the plaintiff's lawyer as well. If you have any questions, you 

6 should see a lawyer immediately. If you need help in finding a lawyer, you may call the 

7 Oregon State Bar's Lawyer Referral Service at (503) 684-3763 or toll-free in Oregon at 

8 (800) 452-7636. Or, you may visit the Oregon State Bar's website at www.osbar.org. 

9 I, the undersigned attorney of record for the plaintiff, certify that the foregoing is 

10 an exact and complete copy of the original summons in the above-entitled action. 

11 TO THE OFFICER OR OTHER PERSON SERVING THIS SUMMONS: You are hereby 

12 directed to serve a true copy of this summons, together with a true copy of the 

13 complaint mentioned therein, up on the defendant or other legal entities to who or 

14 which this summons is directed, and to make your proof of service upon a separate 

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similar document. 

Summons 

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Respectfully submitted, 

Plaintiff, Timothy Meacham 

By his attorney, 

/sf William Ball 

William Ball OSB 011558 

ATTORNEY WILLIAM BALL, LLC 

420 SW WASHINGTON, SUITE 400 

PORTLAND, OREGON 97204 

ATTORNEY WILLIAM BAU, UC 

<120 SW WASHHIGTON; svm 400 

PORTLAND, OREGON 97204 

TEL (503) 477~819'1 /FAX {877)1179<0429 

fu. 0t.W!1t@GMMt CbM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 3 of 21
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IN THE CIRCUIT COURT OF THE STATE OF OREGON 

FOR THE COUNTY OF MULTNOMAH 

6 TIMOTHY MEACHAM, Case No.: 15CV01985 

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Plaintiff, 

Vs. 

SPIRIT AIRLINES INC., and; KERRIE 

CONRAD, 

Defendants. 

COMPLAINT 

(NEGLIGENCE, BATIERY) 

PRAYER: $973,415 

ORS 21.160(1)(c) 

NOT SUBJECT TO MANDATORY 

ARBITRATION 

JURY TRIAL REQUESTED 

Plaintiff, Timothy Meacham, by and through his attorney, William Ball, alleges as 

16 follows: 

17 General Allegations Common to All Counts and Claims for Relief 

18 1. 

19 Timothy Meacham, "Plaintiff" or "Meacham" herein, is an individual who resides 

20 in Grants Pass Oregon. 

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2. 

Spirit Airlines, ("Spirit") herein, is a Florida corporation doing business as a 

commercial passenger airline at Portland International Airport in Oregon. 

Complaint 

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ATTORNEY WILLIAM 6All, LLC 

420 SW WASHINGTON, sum 400 

PORTIAND, OREGON 97204 

TEL {503) 477·8194 /FAA (877)479--0429 8.o.Lt Wn 1 @GM.lll OOM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 4 of 21
l 3. 

2 Defendant, Kerrie Conrad ("Conrad"), at all material times was working at 

3 Portland International Airport in the scope of her duties as an agent for Spirit Airlines. 

4 4. 

5 The events giving rise to this action occurred on or about January 30, 2013, in 

6 Multnomah County at the Portland International Airport. 

7 5. 

8 On or about January 30, 2013, Meacham followed through with plans to take a short 

9 term vacation to Las Vegas with three others, Allison McDonouth ("Allison"), Sarah 

10 Torneby ("Sarah"), and Megan Torneby ("Megan") for Megan's 25th birthday. 

11 6. 

12 Meacham purchased his airline ticket on Spirit from Portland to las Vegas off of 

13 the website Expedia.com. 

M 7. 

15 Previously, in March 2010, Meacham had been seriously injured in an automobile 

16 accident when another car t-boned the car he was driving. Meacham suffered from a 

17 fracture of his l4-L5 vertebrae. Almost three years later, in January 2013, Meacham 

18 was feeling significant improvements with his back and was beginning to experience 

19 greater freedom with his ability to move about. He was excited about traveling on an 

20 airplane to Las Vegas because he was feeling better and had not had as many 

21 opportunities to travel. However, on the day in question, he was using a cane to walk, 

22 stand and to support much of his body weight in compensation for his broken back. 

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Complaint 

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ATIORNEY WILLIAM BALL, LLC 

420 SW we;1rnrroo, sum -4{)0 

PORTLAND, OREGON 97204 

TH {503) 477-8194 /FAY. (877}479--0429 

BN j Wit L@GMA!i roe 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 5 of 21
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Meacham met Allison, Sarah, and Megan at the Portland airport. They all 

3 proceeded to Spirit Airli.nes Gate D-2, and eventually boarded the airplane and took 

4 their seats. 

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9. 

At all material times hereto, Gate D-2 was managed and controlled by Spirit. 

10. 

Soon after boarding the Spirit plane and being seated, a Spirit supervisor, 

Conrad, came aboard the plane and ordered Allison, Sarah, Megan and Meacham to exit 

the plane. Conrad escorted the 4 individuals off of the plane. 

11. 

Meacham and his friends exited the Spirit Airline plane at Gate D-2. 

12. 

As Meacham was walking with his cane up the ramp on the jet way, Conrad 

pushed Meacham down. Without warning she shoved Meacham in the back. Conrad's 

push caused Meacham to fall forward, lose his balance and fall. He fell into the wall of 

the jet way and then fell to the ground. l/l{her) c;:onrad pushed Meacham down and 

caused him to fall, he was also helpless to naturally prevent his fall due to his disability. 

As a result, Meacham fell to the ground unnaturally causing him to injure, aggravate 

and otherwise exacerbate the injury to his back. He immediately began to suffer 

excruciating pain in his back to the extent he could be moved. 

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Complaint 

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ATTORNEY WILLIAM BALL, tlC 

420 SW WASHINGTON, sum 400 

PORTLAND, OREGON 97204 

TEL (503) 47l·Bl9<l /FAX {877}47S·0429 

Bf:!! Wp I @GM.AIL CQM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 6 of 21
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13. 

Meacham lay on the ground in a supine position until paramedics arrived. He had 

difficulty talking with the attending paramedics for several minutes due to the 

overwhelming pain. 

14. 

In the AMR ambulance on the way to Providence hospital, Meacham rated his 

pain at the highest levels. Paramedics repeatedly administered strong pain medication 

to Meacham in order to alleviate the pain. 

15. 

Meacham was treated at Providence Hospital. He was released with prescriptions 

for pain medication for his neck, shoulders and back. 

16. 

On February 03, 2013, Meacham was still bed bound. While lying in bed in his 

home still in pain from the fall he was feeling drowsy and confused from the pain 

medication. The curtain over the window next to his bed caught on fire from a nearby 

candle. Feeling sleepy, drowsy, confused and having impaired judgment resulting from 

the pain medication, Meacham attempted to 13ut out the blazing curtains with his bare 

hands. He sustained severe burns to his right hand and first and second degree burns 

to his left hand. His right hand index finger was the worst, as it was completely 

blanched white with waxy texture. He had almost no sensation of the index finger and 

only slight sensation of his thumb and middle fingers. 

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Complaint 

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ATIORNE:l' WILLIAM BALL, LLC 

420 SW WMHmGTON, sum 400 

PORTI.AND, OREGON 9720<! 

TI:L (503) '177-8194 /FAX (877)479-0429 81>.i L Wt! I @&MJ,U WM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 7 of 21
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17. 

Meacham suffered exceptional pain from the burns. He was immediately taken to 

the Legacy Hospital Emergency Room for treatment for the burns. 

18. 

Meacham suffered severe pain to his hands for the next few months in 

recovering from the burns. He has permanent scaring on his right hand from the curtain 

fire in.his bedroom. He was also bed bound while recovering from his ourns due to his. 

back injury. 

19. 

Meacham's back pain has continued from when he was pushed to date. It will 

continue indefinitely. Every day since Conrad pushed him, Meacham's life has been 

diminished. Meacham suffers constant back pain from the fall. He has had trouble 

using his left hand since he was pushed down. He has trouble sleeping, moving about, 

and engaging in everyday daily living activities. He uses a special bed. He requires the 

assistance of others to prepare his meals, clean, prepare his laundry and organize his 

things. He still requires the use of a cane most of the time. 

FIRST CLAIM FOR RELIEF -,Negligence 

Count I -Premises and Invitee liability as to Defendant Spirit 

20. 

Plaintiff reasserts and re-alleges each and every allegation contained in the 

preceding paragraphs of this complaint, and incorporates them herein by reference as 

though set forth herein at length. 

Complaint 

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ATIORNEYWilUAM BALL, LLC 

420 SW WASHINGTON, SUIT( 400 

PORTLAND, OREGON 97204 

TEL (503) 477·8194 /FAX (877)479-0429 BAU WUJ@GMMI COM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 8 of 21
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Meacham, a customer of Spirit, was a business invitee of Spirit The invitation 

to Meacham to purchase a ticket to fly on Spirit from Portland to Las Vegas was 

expressly and/or impliedly given to Meacham by an agent of Spirit. Meacham's 

presence on Spirit's property was in the economic interest of the defendant Spirit. 

22. 

At all material times hereto, Spirit owed Meacham a duty to exercise reasonable 

care in protecting Meacham from unreasonable risks of harm while on the defendant's 

premises, including the acts of defendant's employees, and agents. Spirit failed to 

make its premises reasonably safe for Meacham. Spirit breached its duty to Meacham 

to act as a reasonable careful person would act under similar circumstances when 

Conrad pushed him and forced him to fall to the ground while he was disabled and 

using a cane. 

23. 

Spirit knew or should have known at the time of Meacham's injuries that 

pushing him down, putting hands on him and pushing him could cause injury to 

Meacham. Spirit's agents did not use reasonable care because Meacham was safe 

when he began walking up the jet way at gate D-6 and defendant's agent elevated the 

risk of harm to Meacham by pushing him, putting her hands on him, an.d causing him 

to fall while disabled and using a cane. 

24. 

Spirit breached its duty to Meacham when its agent became emotionally out of 

Complaint 

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AITORNEY WILLlAM BALL, LLC 

420 SW WASHINGTON, sum 400 

PORTLAND, OREGON 97204 

ifL (503) "177-8194 /FAX (877)479-0429 BAll W!!!@XiMA!l WM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 9 of 21
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control thereby creating an unreasonable risk of harm to Meacham under the 

circumstances. Defendant also breached its duty to exercise reasonable care by 

eliminating the condition creating the risk of harm, i.e., remaining calm, not becoming 

physical with Meacham, and allowing him to walk up the jet way on his own accord 

and without physical force. 

25. 

Spirit breached its duty to Meacham to warn him of-the risk of harm, i.e., that 

its employee could become emotionally out of control and was going to get physical 

with him while he was relying on the use of a walking aid. 

26. 

Spirit failed to use reasonable care in protecting Meacham from injury by failing 

to reasonably and adequately train and supervise its employees, agents ·and security 

personnel regarding safe procedures for controlling conflict without physical escalation, 

and assisting disabled people using canes. 

27. 

Meacham had a bodily condition that predisposed him to be more subject to 

injury than a person in normal health. Spir,it is liable for any and all injuries and 

damages that have been suffered by Meacham as the result of its own negligence, even 

though those injuries, due to the prior condition, may have been greater than those 

that would have been suffered by another person under the same circumstances. 

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Complaint 

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ATIORNEYWJU..IAM SALL, LLC 

420 SW WAS!ilr>GTON, SUITT 400 

PORTLAND, OREGON 97204 

TEL (503) 477-8194 /FAX {877)47S-0429 

8(\Ll W!n@GMA!l (QM 

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28. 

The injuries which Meacham sustained as the result of the negligence of Spirit 

aggravated a preexisting injury and/or disability of his. 

29. 

Spirit's employees, or agents, in committing the aforesaid actions, caused 

Meacham to sustain serious bodily injuries as set forth above. Meacham's injuries were 

due the Defendants' negligence. 

30. 

The incident in question and Meacham's resulting injuries were directly and 

proximately caused by the negligence of the Defendants. 

31. 

Spirit's negllgence caused Meacham's injuries and will into the indefinite future 

continue to cause him pain and suffering, discomfort, humiliation, disruption of life, 

emotional distress, emotional injury, worry, and interference with his normal daily living 

activities, all to his non-economic damages in the amount of $900,000. 

32. 

As a direct result of Spirit's negligence, Meacham incurred direct economic 

damages of not less than $73,914 in medical, treatment and care expenses. Meacham 

will continue to incur medical and related treatment expenses up to and through the 

time of trial. 

Complaint 

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33. 

ATIORNEY WllUAM BALL, LlC 

420 SW Wl&iINGTO!'l, surn400 

PORTlANO, OREGON 97204 

TEL (503) 477·8194/FAX (877)419·0429 BN! Wt'!@:GM.l!! ctlM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 11 of 21
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Meacham will continue to incur medical costs for treatment, surgery, chiropractic 

2 care, and massage therapy, He will also require the help of an in-home care provider to 

3 help him with his daily living activities. As a direct result of defendants' negligence, 

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Meacham will incur future medical costs in the amount to be determined at trial for the 

remainder of his life. 

Count II -Common Carrier liability as to Defendant Spirit 

34, 

Plaintiff incorporates the preceding paragraphs of this Complaint and makes 

them a part of this Cause of Action as if set forth in exact words and figures herein. 

35. 

At all material times hereto, Spirit had the duties of a common carrier. As a 

common carrier Spirit owed Meacham the highest degree of care and skill practicable 

for it to exercise under the circumstances. As a common carrier, Spirit had a heightened 

duty to ensure Meacham's safety, who was disabled, using a cane, and recognizably 

and exceptionally vulnerable to injury. 

36. 

Spirit breached its duty to Meacham when Conrad pushed him down, put her 

hands on Meacham, pushed him, and/or otherwise caused him to lose his balance while 

he was disabled and using a cane, fall into the nearby wall and fall to the floor in 

excruciating pain from injuring his broken back. 

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Complaint 

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ATTORNEY WILLIAM BAlL, LLC 

'120 SW WA...<..H!NGTOI>, S.1.iITT -400 

PORTLAtlD, OREGON 97204 

TEL (SOJ) 477·8t94 /FAX (877)479-0429 

!>At.LWll'@GMAll COM 

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37. 

At the time and place of the injury, Spirit was in breach of their duties in one or 

more of the following particulars: 

(a) Pushing the plaintiff down; 

(b) Pushing Plaintiff in the back; 

(c) Conrad putting her hands on Meacham, applying enough pressure to cause 

him to fall; 

(d) In Spirit failing to provide a safe environment for deplaning, and; 

(e) In Spirit failing to instruct its employees in a safe and proper method for 

removing disabled passengers from the plane and into the boarding area. 

38. 

Meacham had a bodily condition that predisposed him to be more subject to 

injury than a person in normal health. Spirit is liable for any and all injuries and damage 

that have been suffered by Meacham as the result of its own negligence, even though 

those injuries, due to the prior condition, may have been greater than those that would 

have been suffered by another person under the same circumstances. 

39. 

The injuries which Meacham sustained as the result of the negligence of Spirit 

aggravated a preexisting injury and/or disability of his. 

Complaint 

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40. 

ATIORNEY W!lllAM SALL, LLC 

420 SW WASKlNGTOti, sum 40G 

PORTLAND, OREGON 97204 

TEL {503) 477·8194 /FAX (877}479'0429 

BAtLW!tl@GMAil. WM 

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Spirit's employees, or agents, in committing the aforesaid actions, caused 

Meacham to sustain serious bodily injuries as set forth above. Meacham's injuries were 

due the Defendants' negligence. 

41. 

The incident in question and Meacham's resulting injuries were directly and 

proximately caused by the negligence of the Defendants. 

42. 

Spirit's negligence caused Meacham's injuries and will into the indefinite future 

continue to cause him pain and suffering, discomfort, humiliation, disruption of life, 

emotional distress, emotional injury, worry, and interference with his normal daily living 

activities, all to his non-economic damages in the amount of $900,000. 

43. 

As a direct result of Spirit's negligence, Meacham incurred direct economic 

damages of not less than $73,914 in medical and care expenses. Meacham will 

continue to incur medical and related care expenses up to and through the time of trial. 

44. 

Meacham will continue to incur medical costs for treatment, chiropractic care, 

and massage therapy. He will also continue to require the help of an in-home care 

provider to help him with his daily living activities. As a direct result of defendants' 

negligence, Meacham will incur future medical costs in the amount to be determined at 

trial for the remainder of his life. 

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Complaint 

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ATTORNEY WILLIAM BALL, LLC 

420 SW WASMlNGTON, sum 400 

POR.11.AND, OREGON 97204 

TEL {503) 4n·Sl94 /FAX (877)47'P0"129 

&q _W!tl@GMNLCOM 

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Count III -Negligence as to Spirit and Conrad 

45. 

Plaintiff reasserts and re-alleges each and every allegation contained in the 

preceding paragraphs of this complaint, and incorporates them herein by reference as 

though set forth at length. 

46. 

Spirit, its employees and agents, owed Meacham a duty of reasonable care. 

47. 

Conrad owed Meacham a duty of reasonable care. 

48. 

Spirit and Conrad breached their duty to Meacham to act as a reasonable careful 

person would act under similar circumstances when Conrad pushed him down, put her 

hands on Meacham, pushed him, and/or otherwise caused him to lose his balance, fall 

into the nearby wall and fall to the floor in excruciating pain from injuring his broken 

back. 

49. 

In addition, Spirit failed to use reasonable care in protecting Meacham from 

injury by failing to reasonably and adequately train its employees, agents, and security 

personnel in assisting vulnerable, disabled passengers using canes. 

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complaint 

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AITORNEY WILLIAM BALL, LLC 

420 SW WASHlNGTOtJ, SiJITT 41){) 

PORTlAND, OREGON 97204 

TEL (503} 477•8194 /Ff.:/; (877)47!HJ419 

Blll W!i 1@GMA!l ITTM 

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50. 

Spirit and Conrad failed to exercise their duty of reasonable care to Meacham 

when Conrad caused physical injury to Meacham as described above, and particularly in 

regards to the unwarranted and extreme use of physical force. 

51. 

Meacham had a bodily condition that predisposed him to be more subjectto 

injury than a person in normal health. The defendants are liable for any and all injuries 

and damage that have been suffered by Meacham as the result of their own negligence, 

even though those injuries, due to the prior condition, may have been greater than 

those that would have been suffered by another person under the same circumstances. 

52. 

The injuries which Meacham sustained as the result of the negligence of the 

defendants aggravated a preexisting injury and/or disability of his. 

53. 

It was reasonably foreseeable that by Conrad putting her. hands on Meacham 

that it would cause him harm. Under the circumstances, Conrad knowing that 

Meacham was walking with the aid of a walking cane, it was unreasonable for her to 

push him down or otherwise put her hands on Meacham without first warning or asking 

him, pushing him to such a degree so as to cause him to fall or lose his bala.nce. 

54. 

It was reasonably foreseeable that Spirit's employee's negligent conduct in 

causing Meacham to fall and injure his back that Meacham would experience 

Complaint 

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ATIORNtv WllllAM BALL, llC 

420 SW WASHlllGTON, sum 400 

PORTlAtlD, OREGON 97204 

1EL {503) 477·8194 /FA.X (Sn)479'0429 BM I W!U@G!1Aft 000 

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exceptional pain and suffering, have to take pain medications, and as a result suffer 

additional injury. 

55. 

At the time and place of the injury, Spirit and Conrad were in breach of their 

duties in one or more of the following particulars: 

{f) Pushing the plaintiff down; 

(g) Pushing Plaintiff in the back; 

(h) Conrad putting her hands on Meacham, applying enough pressure to cause 

him to fall; 

(i) In Spirit failing to provide a safe environment for deplaning, and; 

(j) In Spirit failing to instruct its employees in a safe and proper method for 

removing disabled passengers from the plane and into the boarding area. 

56. 

As a result of defendants' negligence, Meacham sustained the following serious 

and permanent injuries: 

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Complaint 

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a. Further injuring Meacham's broken back; 

b. Reinjuring Meacham's broken back; 

c. Serious, debilitating back pain; 

d. Serious, debilitating leg pain; 

e. Serious, debilitating neck pain 

f. Burning his hand; 

g. Permanent scaring to his right hand. 

ATTORNEYWILUAM BALL, LL( 

420 SW WMH!flGTIJN, SlJITT '!00 

PORTLAND, OREGON 9720'! 

TI:L (SIH) 477-f!l94 /fAX {877)479-0429 

BAH WP !@;jMAt;,mK 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 17 of 21
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57. 

The incident in question and Meacham's resulting injuries were directly and 

proximately caused by the negligence of the Defendants. 

58. 

Spirit's negligence caused Meacham's injuries and will into the indefinite future 

continue to cause him pain and suffering, discomfort, humiliation, disruption of life, 

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emotional distress, emotional injury, worry, and interference with his normal daily living · 

activities, all to his non-economic damages in the amount of $900,000. 

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59. 

As a direct result of Spirit's negligence, Meacham incurred direct economic 

damages of not less than $73,914in medical and care expenses. Meacham will continue 

to incur medical and related treatment expenses up to and through the time of trial. 

60. 

Meacham will continue to incur medical costs for treatment, chiropractic care, 

and massage therapy. He will also require the help of an in-home care provider to help 

him with his daily living activities. As a direct result of defendants' negligence, Meacham 

will incur future medical costs in the amount to be determined at trial for the remainder 

of his life. 

61. 

Defendants are joint and severally liable for the damages their negligence caused 

ATIORNEY WlLUAM BALL, LlC 

'120 SIN WASHmGTOll, svm 400 

PORTLAflD, OREGON 971M 

TEL (503) 477·8194 /FAY. {Bn)479-0429 

SA!! WJ![®GMA!l COM 

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SECOND CLAIM FOR RELIEF - Battery, Spirit and Conrad 

62, 

Plaintiff reasserts and re-alleges each and every allegation contained in the 

preceding paragraphs of this complaint, and incorporates them herein by reference as 

though set forth at length, 

63, 

The act pushing down Meacham and Conrad putting her hands on Meacham 

and pushing him were without his consent and against his will. 

64. 

Said acts were physically injurious, painful, degrading and offensive. 

65. 

Said acts constituted acts of battery committed against Meacham. 

66. 

Spirit and Conrad are jointly and severally liable for the damages resulting from 

the battery to Meacham. 

61. 

As a result of the above-described battery, Meacham suffered great fear and 

humiliation, a sense of helplessness, loss of control, and personal violation, and has 

suffered, continues to suffer, and may permanently suffer from back and neck pain, 

feelings of fear, humiliation, disgust, and feelings of vulnerability, all to his 

noneconomic damage in the amount of $900,000. 

I 

Complaint 

- 16 

ATTORNEY WILLIAM BALL, LLC 

'l20 SW WASHlllGTOfl, sum 400 

PORTLAND, OREGON 9720q 

TEL {503) 477~8194 /FAY. {877}47~0429 

e.o.u W!i l@.jHA!L(QM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 19 of 21
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2 As a further result of defendants' conduct, Meacham is entitled to noneconomic 

3 damages in an amount to be proven at trial. 

4 69. 

s As a result of defendants' conduct, Meacham suffered severe emotional distress, 

6 in an amount to be determined at trial. 

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PRAYER FOR RELIEF 

WHEREFORE, Plaintiff prays for the following relief: 

a) On all Causes of Action, judgment in his favor for past and future pain and 

suffering against defendants in the amount of $900,000 in noneconomic 

damages. 

b) On all Causes of Action, judgment in his favor and against defendants in the 

amount of $73,415 in economic damages. 

c) On all Causes of Action, judgment in his favor and against defendants in the 

amount to be determined at trial for future medical costs and treatment for the 

plaintiff. 

d) On all Causes of Action, costs, expenses, including attorney fees against 

defendants. 

e) On all Causes of Action, such other and further relief as the Court may deem just 

and proper. 

f) Plaintiff reserves the right to plead punitive damages at a later time. 

Complaint 

- 17 

ATTORNEY WILLIAM SALL, llC 

420 SWWASH!NGTON, SUITT 400 

PORTi.AfiD, OREGON 97204 

TEL (503) 477·8194 /FAX (S77fU9·0429 

BA! I Wt! 1 /l.i}(;MA\\ C()f:', 

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g) Plaintiff reserves the right to plead additional claims of defenses as they become 

discovered by Plaintiff. 

Complaint 

- 18 

Dated this January 29, 2014 

isl William Ball 

William Ball OSB 011558 

Attorney for Plaintiff 

Trial Attorney 

ATIORNEY WlLUAN BAU, LLC 

'120 '!NI WASKlflGTOfl, sum 400 

PORTLAND, OREGON 11204 

TEL ($03) 477·8194 /FAX (871)479'-0429 

fJA! ! Wttt®GJ:ltll ffiM 

Case 3:15-cv-00338-SI Document 1-1 Filed 02/25/15 Page 21 of 21