1 Lisa Bloom, Esq.

(SBN 158458)
A. Douglas Mastroianni, Esq. (SBN 150438)
2 Anna Levine-Gronningsater, Esq. (SBN 286341)
3 THE BLOOM FIRM
20700 Ventura Blvd., Suite 301
4 Woodland Hills, CA 91364
Telephone: (818) 914-7397
5 Facsimile: (818) 884-8079
6 Lisa@TheBloomFirm.com
Doug@TheBloomFirm.com
7 Anna@TheBloomFirm.com
8 Attorneys for Plaintiffs
9 JERMAINE EDMONDSON and BIANCA WILLIAMS

10
11
12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
COUNTY OF ALAMEDA
14
15
16
JERMAINE EDMONDSON, an individual; CASE NO.:
17 BIANCA WILLIAMS, an individual,
COMPLAINT FOR DAMAGES
18 Plaintiffs,
19 1. ASSAULT
v. 2. BATTERY
20 3. INTENTIONAL INFLICTION OF
DRAYMOND GREEN, an individual; and EMOTIONAL DISTRESS
21 DOES 1 through 25, inclusive. 1.
22 JURY TRIAL DEMANDED
Defendants.
23
24
______________________________________
25
26 Draymond Green is a bully. On the basketball court, he is famous for hitting players in
27 the groin, kicking violently, and feigning shock every time a foul is called against him. Off the
28

1
 1 court, he drinks excessively, lashes out at reporters and other athletes on social media, and
2 continues to complain about being overlooked in the first round of the 2012 NBA draft. His
3 anger management problem recently victimized two innocent people, a young man and woman,
4 who were demeaned, assaulted, and choked. When the man told Mr. Green that violence
5 against a woman took things too far, Mr. Green responded by hitting him in the face. Mr. Green
6 has never apologized for these incidents, which caused his victims to be shunned and ostracized
7 as targets of a celebrity athlete. Their lives have been forever changed. This lawsuit seeks
8 accountability for Mr. Greens vicious bullying, physical assault, and violence against a woman.
9 Plaintiffs JERMAINE EDMONDSON and BIANCA WILLAMS allege as follows:
10 PARTIES
11 1. Plaintiff JERMAINE EDMONDSON is an individual residing in Washtenaw County in
12 the State of Michigan.
13 2. Plaintiff BIANCA WILLIAMS is an individual residing in Washtenaw County in the
14 State of Michigan.
15 3. Defendant DRAYMOND GREEN is an individual who is and at all times herein was a
16 professional basketball player, employed by the Golden State Warriors which has its principal
17 place of business in Oakland, California. Mr. Green owns a home in Berkeley, California
18 where he resides with his family.
19 4. At all times alleged in the complaint, Defendant Green was the agent, employer,
20 principal, partner, and co-conspirator of third parties acting as his entourage and
21 bodyguards who committed some of the assaults against Plaintiffs as alleged below. These
22 parties were at all times acting within the course and scope of said relationship, and Green was
23 fully aware of the conduct of the third parties, and authorized, ratified, and approved their acts
24 and is, therefore, vicariously liable for the damages caused by their conduct.
25 5. The true names and capacities, whether individual, corporate, associate or otherwise, of
26 Defendants Does 1 through 25, inclusive, are unknown to Plaintiff at this time, who therefore
27 sue said defendants by such fictitious names. When the true names and capacities of said
28 defendants are ascertained, Plaintiff will seek leave of the Court to amend this Complaint to

2
 1 allege their true names and capacities. Plaintiff is informed and believes and thereon alleges
2 that each Defendant designated herein as a Doe is responsible in some manner for each other
3 Defendants acts, omissions, and for the resulting injuries and damages to Plaintiff, as alleged
4 herein.
5 VENUE
6 6. Venue is proper because Defendant Green is employed in Oakland and resides with his
7 family in Berkeley, in the County of Alameda.
8
FACTUAL ALLEGATIONS
9
Background
10
7. Getting a college degree has always been important to Plaintiff Jermaine Edmondson
11
(Mr. Edmondson), so when he was heavily recruited by colleges for a football scholarship, he
12
wanted to choose a school that was a good fit on and off the football field. As soon as he first
13
stepped on campus at Michigan State University (MSU), he knew it was the right school for
14
him.
15
8. Mr. Edmondson enrolled at MSU in the fall of 2012, with a full scholarship. He was
16
excited to join a brotherhood of student athletes who would be forever friends groomsmen at
17
each others weddings and who would carry MSUs school spirit with them throughout their
18
lives.
19
9. Bianca Williams (Ms. Williams) is a talented singer and scholar who enrolled at MSU
20
in the fall of 2013.
21
10. Mr. Green is also an MSU alumnus, and is a professional basketball player for the NBA
22
team Golden State Warriors (the Warriors).
23
11. Mr. Green has garnered a nasty reputation for striking and kicking opposing players,
24
with one media outlet calling him a dangerous player and his maneuvers much more violent
25
in nature than other players. He has been fined, ejected, and suspended from games for
26
violent outbursts.
27
28

3
 1 12. Off the court, Mr. Green has partnered with the NBA and his alma mater to spin a better
2 image of himself. As a former MSU scholarship recipient, he gave $3.1 million to MSU in
3 2015 for the Draymond Green Strength and Conditioning Center and a scholarship endowment.
4 13. In 2016, he shot a video for the NBAs Lean In Together campaign, talking about how
5 important it is for men to lean in to support the women in their lives.
6 14. During the spring of 2016, Mr. Green played for the Warriors in the NBA playoffs. In
7 May of 2016, the NBA fined him $25,000.00 after he kicked an opposing player in the groin
8 twice. In June of 2016, the NBA assessed a whopping $129,644.00 fine against him after he hit
9 another opposing player in the groin. With the Warriors leading the Cleveland Cavaliers three
10 games to one in the best-of-seven championship round, Mr. Green was suspended for Game
11 Five for the June hit. It was reported that Mr. Greens win-at-all-costs mentality has suddenly
12 opened the door for LeBron James and the Cleveland Cavaliers to get back into the NBA
13 Finals. That is exactly what happened, as the Cleveland Cavaliers became the first team to
14 overcome a three-one deficit to win the championship.
15 15. Less than one month after the Warriors frustrating defeat in the 2016 playoffs, Mr.
16 Edmondson and Ms. Williams encountered the hostile and vicious version of Mr. Green, not the
17 phony version he has been trying to project off the court.
18 The July 8, 2016 Attack
19 16. Shortly after the Warriors June 19, 2016 loss in Game Seven, Mr. Green traveled to
20 East Lansing to attend the wedding of former MSU classmate Denzel Drone. Mr. Green was a
21 groomsman.
22 17. On Friday, July 8, 2016, the night before the wedding, Mr. Green went to Ricks
23 American Caf in East Lansing, along with two men who were also groomsmen. The two men,
24 who were both tall and large with black beards, followed him around all night like bodyguards.
25 18. Mr. Green was in a foul mood, and at one point grabbed another patrons phone and
26 threw it on the ground when he tried to take a picture.
27
28

4
 1 19. Mr. Edmondson and Ms. Williams were celebrating Mr. Edmondsons birthday the same
2 weekend, and they were also at Ricks on Friday night. At the end of the night, Ms. Williams
3 walked toward the exit while Mr. Edmondson stopped to chat with a former MSU teammate.
4 20. Mr. Green walked by, along with his bodyguards, and bumped into Mr. Edmondson in
5 the process. Mr. Edmondson turned to Mr. Green and said, you can at least say excuse me.
6 Mr. Green looked at Mr. Edmondsons teammate and asked, in reference to Mr. Edmondson,
7 who the fuck is this nigga? As Mr. Edmondson replied, Mr. Green said, I know niggas like
8 you. I pay for niggas like you scholarships.
9 21. Mr. Green turned around and said something to the two men behind him, his
10 bodyguards. On information and belief, Mr. Green instructed them, either implicitly or
11 explicitly, to attack Mr. Edmondson.
12 22. All of a sudden, the two men grabbed Mr. Edmondson, and pushed him up against a
13 wall. They were both bigger than Mr. Edmondson, and together they held him against the wall
14 and choked him so that he could not move. Mr. Green did nothing to stop the attack.
15 23. Ms. Williams, who was by the exit, heard the commotion and saw the two men choking
16 Mr. Edmondson. She tried to get to him, and screamed, please stop! Thats my boyfriend!
17 One of the men turned around and said, I dont give a fuck who he is, and grabbed her by the
18 neck. He pushed her, by her neck, into a wall. Mr. Green did not do anything to stop this
19 vicious attack on a 21-year-old woman conducted on his behalf right in front of him.
20 24. Mr. Edmondson heard Ms. Williams crying and calling for him. He got loose and ran
21 over to her.
22 25. Ms. Williams was hurt and stunned. Instead of retaliating or escalating the situation,
23 Mr. Edmondson stayed by her side and tried to soothe her. She was terrified that Mr. Green and
24 the other men would come back. Mr. Edmondson and Ms. Williams left Ricks together.
25 26. Outside Ricks, Mr. Edmondson and Ms. Williams saw Mr. Green running away. He
26 was laughing.
27 27. The choking attack at Ricks was shocking, disturbing and offensive. Mr. Edmondson
28 felt humiliated that he was attacked in front of his girlfriend and former teammate, and belittled

5
 1 by Mr. Greens reference to his scholarship. Mr. Edmondson believed that Mr. Greens
2 donation did not give him the right to degrade students on scholarship at MSU. But more than
3 anything, he wanted to support Ms. Williams, who was hurt and scared.
4 28. Ms. Williams cried on and off all night. Starting at a young age, she had witnessed
5 years of her mother being abused by a man. Feeling a mans hands around her neck brought
6 back horrifying memories, in which she used to hide under the bed listening to the attacks,
7 imagining what her mother was going through.
8 The July 10, 2016 Attack
9 29. Mr. Edmondson and Ms. Williams talked to their friends about the attack. With the
10 support of their friends, they decided not to cancel Mr. Edmondsons birthday plans the next
11 night because they knew Mr. Green would be at the wedding. The next night, July 9, 2016, they
12 went out with friends.
13 30. In the early morning hours of July 10, 2016 Mr. Edmondson, Ms. Williams, and some
14 friends went to Conrads Grill (Conrads), a restaurant that serves late-night food. After they
15 ordered their food, Mr. Green entered the restaurant and got in line at the food counter. He was
16 alone. When he saw Ms. Williams, he got out of line and walked towards her. He stopped a
17 few feet in front of her, making sure she saw him as he looked her up and down, leering at her.
18 He smirked.
19 31. Ms. Williams was scared and nervous about what Mr. Green would do, given that the
20 night before, Mr. Greens entourage had physically attacked her at his behest. She froze. Mr.
21 Edmondson, who had walked outside before he saw Mr. Green enter Conrads, went to the door
22 and called out to Ms. Williams. He and Ms. Williams walked outside. Shortly thereafter, Mr.
23 Green walked outside too.
24 32. Seeing that the mood was calm, Mr. Edmondson and Ms. Williams approached Mr.
25 Green to make peace. Mr. Edmondson knew that Ms. Williams was still very upset about what
26 had happened, and he wanted her to feel safe again. Mr. Edmondson said, last night did not
27 have to happen. My girl got choked that wasnt cool.
28

6
 1 33. Mr. Green started poking Mr. Edmondson in the shoulder goadingly. Mr. Edmondson
2 told him that there were was no need to get physical. In response, Mr. Green hit Mr.
3 Edmondson in the face.
4 34. Mr. Edmondson grabbed his face and reeled backwards, stunned and in pain. He spat
5 out blood. Ms. Williams, who was standing right next to Mr. Edmondson, was stunned,
6 shocked, and yet again terrified of Mr. Green.
7 35. The hit emitted a loud slap or smack sound. It would be expected for any MSU
8 football players at the scene to run to their teammates defense, but because Mr. Edmondson
9 had been hit by Draymond Green, no one did anything. This was humiliating for Mr.
10 Edmondson.
11 36. Just like the previous night, Mr. Green ran away. Police who were patrolling the area
12 and heard the slap sound approached, and found him trying to sneak out of the side exit from
13 Conrads. They arrested Mr. Green.
14 37. One of Mr. Greens friends showed up on the scene to help Mr. Green and try to talk to
15 Mr. Edmondson and Ms. Williams. Mr. Edmondson and Ms. Williams did not want to hear
16 anything he had to say in Mr. Greens defense, and went home.
17 Mr. Greens Attempts to Silence Mr. Edmondson
18 38. Mr. Green was arrested and charged with assault and battery. At the jail, Mr. Green was
19 smiling and looked happy. He displayed an arrogant grin in his mugshot. The police
20 administered a preliminary breath test on him which revealed a .10 blood alcohol content, above
21 the legal limit. They held him in jail until he sobered up.
22 39. Not understanding how seriously Mr. Edmondson takes violence against women, Mr.
23 Green embarked on a campaign to try to bribe, influence, intimidate, or threaten witnesses,
24 including Mr. Edmondson.
25 40. Upon information and belief, Mr. Green instructed his friends to buy Mr. Edmondsons
26 silence. One of Mr. Greens close friends texted Mr. Edmondson on July 10, 2016, writing:
27
Hey bro dont press charges
28 Please talk to day

7
 He will give you bread
1
Lets meet bro
2 Mr. Edmondson did not respond.
3 41. Later in the day on July 10, 2016 Mr. Edmondsons birthday another one of Mr.
4 Greens friends told Mr. Edmondson that Mr. Green said he would pay Mr. Edmondson if he
5 did not press charges. Mr. Edmondson received a text message saying, [d]ont press no
6 charges that nigga said he ah cut you a check.
7 42. On or around July 11, 2016, James Heos, Mr. Greens attorney, told Mr. Edmondsons
8 friend over the phone to keep your mouth shut, and instructed him to tell Mr. Edmondson to
9 keep his mouth shut.
10 43. My legal team is handling it. It will be resolved really quickly, Mr. Green told the
11 press on July 12, 2016. When things happen, you meet them head on.
12 44. On information and belief, no one other than Mr. Green, Mr. Edmondson, and Ms.
13 Williams made a statement to the police.
14 45. On or around July 28, 2016, Mr. Green accepted a deal and was issued a citation on a
15 lesser charge.
16 The Aftermath
17 46. News spread quickly around campus that Mr. Green had been arrested at Conrads, and
18 that Mr. Edmondson was the complaining party. Mr. Edmondson and Ms. Williams were
19 harassed on a daily basis. Both of the social media posts they shared about Mr. Edmondsons
20 birthday were bombarded with insults from students who had heard about the attack, making
21 fun of Mr. Edmondson for getting bitch slapped by Mr. Green, and telling Ms. Williams
22 your boyfriend is a pussy.
23 47. Mr. Edmondsons name was released by the press on July 11, 2016. Once Mr.
24 Edmondsons name was released by the press, he and Ms. Williams were heckled by strangers
25 about the assault, online and in person, and did not feel safe on campus.
26 48. The Warriors released a statement saying that they were collecting information and will
27 have no further comment until we have a better understanding of the situation. On information
28

8
 1 and belief, they released no further statement, even after the press reported that Mr. Greens
2 associates had choked a woman. The Warriors now have two players on their team who are
3 accused of participating in late-night bar fights and choking female patrons.
4 49. Mr. Greens arrest garnered so much attention that other celebrity athletes made public
5 statements about the assault, including some who spoke to Mr. Green about the incident. Mr.
6 Heos announced publicly that [a]ll of the witnesses say Draymond didnt do anything.
7 50. Due to concerns for his safety on campus, Mr. Edmondson and his family decided that it
8 would be safest for him to leave MSU. He transferred schools, torn about leaving the school he
9 had loved so much.
10 51. As she ended the summer and started her senior year at MSU without her boyfriend, Ms.
11 Williams continued to endure harassment and ridicule on campus about Mr. Greens assault.
12 Some of the MSU athletes she considered friends refused to talk to her. Others made fun of Mr.
13 Edmondson to her, ignoring the trauma she endured. She also had to watch her boyfriend suffer
14 national ridicule, all for defending her.
15 52. Mr. Edmondson and Ms. Williams talked every day, often by video chat. They often
16 cried, feeling abandoned and isolated by others and sad to be separated from each other.
17 Neither of them had an appetite or slept soundly.
18 53. Once the school year started, Mr. Edmondson learned that the NCAA was denying his
19 eligibility to play football. Mr. Edmondson wanted to earn his Sociology degree from MSU and
20 graduate. He made the brave decision to return to MSU, even though he could not play football
21 and was a constant victim of harassment and ridicule on campus. Because it was too late to
22 enroll for fall semester, he got a job. He enrolled in school spring semester, and graduated on
23 May 6, 2017.
24 54. Mr. Edmondsons reputation at MSU and in the football community was tarnished by
25 Mr. Greens assault. He attended Pro Day at MSU, but his NFLdraftscout.com notes read,
26 Edmondson, center of the Draymond Green assault arrest
27 55. Even after he entered into a plea agreement in his criminal case, Mr. Green refused to
28 take responsibility for hitting Mr. Edmondson and failed to speak out against the violence

9
 1 perpetrated against Ms. Williams. In fact, he told a reporter in or around October of 2016 that
2 he wouldnt change anything that happened this summer. Mr. Greens refusal to
3 acknowledge the true facts and apologize compounded the ostracism and public humiliation of
4 Mr. Edmondson and Ms. Williams that continues to date.
5 56. Mr. Green is a hypocrite. The Lean In Together campaign is part of the Sheryl
6 Sandberg & Dave Goldberg Family Foundations Lean In initiative, which seeks to empower
7 women. Through the Lean In Together partnership with the NBA, the NBA highlights and
8 creates videos featuring particular players they believe epitomize what it means to lean in to
9 support the women in their lives. Mr. Edmondson was doing exactly that when he stood up to
10 Mr. Green without violence to tell him it was wrong that he and his friends choked Ms.
11 Williams. Mr. Greens response to Mr. Edmondsons real-life, off-screen attempt to lean in
12 was to hit him in the face.
13 FIRST CAUSE OF ACTION
14 ASSAULT
15 (BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS)
16 57. Plaintiffs restate and incorporates by reference, as though fully set forth herein, the
17 allegations contained in each of the paragraphs above.
18 58. Defendants acted with the intent to cause harmful or offensive contact of Plaintiffs, and
19 to assault Plaintiffs.
20 59. Plaintiffs reasonably believed that they were about to be touched in a harmful or
21 offensive manner.
22 60. Plaintiffs did not consent to Defendants contact.
23 61. On information and belief, On July 8, 2016, Mr. Green gave authority to his entourage
24 to act on his behalf in transactions with third parties, including physical interactions with other
25 patrons at Ricks.
26 62. On information and belief, Mr. Green and members of his entourage agreed to assault
27 Mr. Edmondson and Ms. Williams at Ricks. On information and belief, Mr. Green was aware
28

10
 1 that his entourage planned to assault Mr. Edmondson and Ms. Williams at Ricks, and Mr.
2 Green agreed with his entourage and intended that the assault be committed.
3 63. Mr. Edmondson and Ms. Williams reasonably believed that they were about to be
4 touched in a harmful or offensive manner, and it reasonably appeared to them that Defendants
5 were threatening to touch them in a harmful or offensive manner, and that Defendants about to
6 carry out the threat.
7 64. Plaintiffs did not consent to any touching by Mr. Green, or other agents and/or co-
8 conspirators, or Does 1-20.
9 65. As a direct and proximate result of the Defendants actions as herein alleged, Plaintiffs
10 have suffered and continue to suffer harm, entitling them to damages in an amount to be proven
11 at trial. Harm includes the shock and emotional distress of being publicly threatened and
12 attacked by a celebrated sports star, financial hardship, wage losses, humiliation, mental and
13 physical pain, harm to reputation, nervousness, grief, anxiety, worry, mortification, indignity,
14 embarrassment, apprehension, and other damages in an amount to be proven at trial.
15 66. Defendants conduct was willful, malicious, oppressive, and wanton. Defendants acted
16 in knowing disregard of Plaintiffs rights and safety, with awareness of the probable
17 consequences of his conduct. Plaintiffs suffered humiliation, outrage, and indignity therefrom.
18 Defendants acts constitute oppression, fraud, or malice under California Civil Code section
19 3294, entitling Plaintiffs to punitive damages.
20 SECOND CAUSE OF ACTION
21 BATTERY
22 (BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS)
23 67. Plaintiffs restate and incorporate by reference, as though fully set forth herein, the
24 allegations contained in each of the paragraphs above.
25 68. On information and belief, Mr. Green and members of his entourage agreed to batter Mr.
26 Edmondson and Ms. Williams at Ricks. On information and belief, Mr. Green was aware that
27 his entourage planned to batter Mr. Edmondson and Ms. Williams at Ricks, and Mr. Green
28 agreed with his entourage and intended that the battery be committed.

11
 1 69. Mr. Green knew that assault and battery was being committed or was going to be
2 committed by his entourage against Mr. Edmondson and Ms. Williams at Ricks. Mr. Green
3 gave encouragement to his entourage to batter Mr. Edmondson and Ms. Williams.
4 70. On information and belief, Mr. Green and members of his entourage agreed to batter Mr.
5 Edmondson and Ms. Williams at Ricks. Mr. Green was aware that his entourage planned to
6 assault Mr. Edmondson and Ms. Williams, and gave them encouragement.
7 71. On information and belief, Mr. Green and members of his entourage agreed to commit
8 battery against Mr. Edmondson. Mr. Green was aware that his entourage planned to attack Mr.
9 Edmondson, and he tacitly instructed and intended for the attack to occur.
10 72. Defendants touched Mr. Edmondson with the intent to cause harmful or offensive
11 contact, including by pushing and choking him.
12 73. Defendants touched Ms. Williams with the intent to cause harmful to offensive contact,
13 including by pushing and choking her.
14 74. Mr. Green touched Mr. Edmondson with the intent to harm him, including by striking
15 him in the face with his hand.
16 75. Plaintiffs did not consent to any touching by Defendants. A reasonable person in
17 Plaintiffs situation would be offended by the touching.
18 76. As a direct and proximate result of the acts alleged herein, Plaintiffs suffered harm,
19 entitling them to damages in an amount to be proven at trial. Plaintiffs suffered and continue to
20 suffer extreme physical and emotional distress, financial hardship, wage losses, humiliation,
21 mental and physical pain, and other damages in an amount to be proven at trial.
22 77. Defendants conduct was willful, malicious, oppressive, and wanton. Defendants acted
23 in knowing disregard of Plaintiffs rights and safety, with awareness of the probable
24 consequences of their conduct. Plaintiffs suffered humiliation, outrage, and indignity
25 therefrom. Defendants acts constitute oppression, fraud, or malice under California Civil Code
26 section 3294, entitling Plaintiffs to punitive damages.
27
28

12
 1 THIRD CAUSE OF ACTION
2 INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
3 (BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS)
4 78. Plaintiffs restate and incorporate by reference, as though fully set forth herein, the
5 allegations contained in each of the paragraphs above.
6 79. As alleged herein, Defendants engaged in outrageous conduct towards Mr. Edmondson
7 and Ms. Williams, with intention to cause, or with reckless disregard of the probability of
8 causing, them to suffer severe physical, emotional and psychological distress.
9 80. As a direct and proximate result of Mr. Greens actions, Plaintiffs have suffered and will
10 continue to suffer pain and suffering, extreme and severe mental anguish, and emotional
11 distress, including harm to reputation. Mr. Edmondson has suffered and will continue to suffer
12 a loss of earnings and other employment benefits and job opportunities.
13 81. Defendants conduct was malicious and oppressive, and Plaintiffs are entitled to punitive
14 damages in an amount to be determined at trial. As a famous athlete who is both revered and
15 reviled for his violent antics on the court, Mr. Greens off-court antics are likewise subject to
16 intense public scrutiny. Mr. Edmondsons name was dragged through the mud because Mr.
17 Green intentionally tried to engage him in a brawl, even though Mr. Edmondsons response was
18 beyond reproach. Mr. Greens conduct towards Mr. Edmondson and Ms. Williams exposed
19 Plaintiffs to intense suffering, anguish, nervousness, grief, anxiety, worry, shock, humiliation,
20 and shame. Mr. Edmondson has been exposed to intense public scorn, with harassers ridiculing
21 him for getting slapped and berating him for having Mr. Green arrested. Almost one year
22 after the attack, he still plays the assault back in his head over and over again, wondering how it
23 happened so fast but changed his life so drastically. It is still hard for him to sleep, and when he
24 does, sometimes he wakes up crying.
25
PRAYER FOR RELIEF
26
WHEREFORE, Plaintiff prays for judgment and damages against each of the
27
Defendants as follows:
28

13