suchthatSilverado such that Silverado should beassessed shouldbe exemplary assessed exemplary punitive orpunitive or damages. damages.
B B ASSAULT ASSAULT AND BATTERY AND BATTERY
36 Plaintiffs a Plaintiffs llegeand allege andwould would prove thatSilverado provethat hascommitted Silverado has assaultand committed assault and battery of Ruby battery of Rubywith respectto with respect psychotropic topsychotropic drugsforced drugs heragainst uponher forced upon her against her
willinfoodandotherwise. Plaintiffs will in food and otherwise. Plaintiffs allegeand allege andwould thatSilverado provethat would prove knew Silverado knew
or or should haveknown shouldhave thatRubyrefused known that Ruby refused to takemedications totake thatshecomplained medications that she complained
made hersick. made her sick. 37 Plaintiffsallege Plaintiffs allegeandwould thatSilverado provethat and would prove placedRuby Silverado placed Rubyinreasonable in reasonable
fearof harmfulor fear of aa harmful offensive oroffensive and/orforcing contactand/or contact forcingor herintotaking or tricking her into taking
whichshe drugs,which drugs, sherefused takevoluntarily totake refused to becausethey voluntarily because made herfeelsick. theymade her feel sick.
38 Plaintiffsallege Plaintiffs allegeand andwould thatRubysustained provethat would prove substantial Ruby sustained substantial damages damages
proximate asaa proximate resultof wrongful ofSilverado's and/orbattery. assaultand/or battery. as result Silverado's wrongful assault . 39 Plaintiffs ffurther Plaintiffs andwould urtherallege and thatSilverado's provethat would prove wrongful Silverado's wrongful assault assault
andbattery and intentional wasintentional battery was andmalicious, and suchthat malicious, such Silverado that Silverado shouldbe should beassessed assessed
exemplary exemplary orpunitive or damages.14 punitive damages.
Silverado Appx. 0428 No. 1-15-567-CV 1550 OF TRUST CBREACH FIDUCIARY OF BREACH and DUTY C BREACH OF TRUST and BREACH OF FIDUCIARY DUTY
40Plaintiffs Carol 40 Carol andTonya and Peterson Tonya Peterson allege allege andwould and prove would prove thatRuby that Ruby
revoked the1993 the 1993 Power Power o offAttorney Attorney o on November 15,2013.Silverado nNovember hadaa duty 15, 2013. Silverado had duty acknowledge toacknowledge to thefactthatRuby the revoked fact that Ruby revoked the1993 the ofattorney. powerof 1993 power attorney. 41 Plaintiffs C Plaintiffs aroland Carol andTonya Peterson a Tonya Peterson llegeandwould allege and would prove thatRubyand prove that Ruby and
theyhavesustained substantialdamages they have sustained substantial proximate damages as aa proximate resultof result Silverado's of Silverado's
breachof breach and/orbreachof trustand/or of trust dutyregarding breach of fiduciary duty regarding its actions,which itsactions, which interfered,infringed interfered, infringed or deniedRuby's or denied andthe Ruby's rights and Plaintiffs' thePlaintiffs' rights,when rights, when
Silverado Silverado rrepeatedly epeatedly eniedRuby's ddenied Ruby's rrequests to thechurch go to equeststtoo go ofherchoice, the church of go her choice, go
outtoeat andgo out to eat and visitPlaintiffs tovisit goto Plaintiffs at theirhomes, attheir despiteexpress homes, despite expressnotice ofRuby's noticeof Ruby's
revocation ofthe1993 revocation of the 1993 power ofattorney power of attorneyoonnNovember 15,2013. November 15, 2013.
42 Plaintiffs Plaintiffs Carol andTonya Carol and TonyaPeterson allege Peterson allege and would andwould prove prove that that Silverado Silverado
intentionally intentionally and maliciously failed andmaliciously failed or refusedto or refused to honor andrecognize honorand Ruby's recognize Ruby's
revocation revocation ofherprevious ofattorney, powerof of her previous power attomey, andinstead, and continued instead, continued tohonor to and honorand N recognize of attorney, the1993power suchthat hadbeenrevoked, which recognize the 1993 power of attorney,