1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 TUSHAR SINGH, Plaintiff, v. VEGASSTARS LIMITED LIABILITY COMPANY dba DIRTY and TOP FLYTE SECURITY LLC, Defendants.

Plaintiff alleges: 1. Plaintiff, Tushar Singh, is a resident of Washington County, Oregon. 2. At all material times, defendant Vegasstars Limited Liability Company, dba Dirty (herinafter Dirty) was doing business in Multnomah County, Oregon 3. At all material times, Top Flyte Security LLC (hereinafter Top Flyte Security) offered security services to Dirty and was doing business in Multnomah County, Oregon.. 4. At all material times, Christopher Lenahan was the primary member/owner of Dirty. 5. At all material times, Top Flyte Security provided security service personnel to Dirty. 6. On August 14, 2011, Tushar Singh was a patron at Dirty, enjoying an evening of dancing with friends. Tushar Singh was wearing a turban on his head. No. COMPLAINT (Assault and Battery/Negligence) Amount of prayer: $530,000 Filing Fee: $ 879.00 (Not subject to mandatory arbitration) IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH

Page 1

COMPLAINT (Negligence/Assault and Battery)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 defendants.

7. Near closing time, Tushar Singh passed behind a person working for and on behalf of 8. Without justification, the security personnel made uninvited physical contact with Tushar Singh, charged Tushar Singh, and forced Tushar Singhs head onto a dancing platform, causing a cut deep into Tushar Singhs head. Upon information and belief, Tushar Singh was the only person wearing a turban who left Dirty with serious head wounds that night. 9. Defendants, jointly and severally, owed a duty to Tushar Singh to ensure that he was not hurt by defendants agents while a patron at Dirty. Defendants, jointly and severally breached that duty and were negligent in causing injury to Tushar Singh while he was at Dirty and/or in failing to properly train their security agents not to engage with patrons in a way that resulted in bodily injury. 10. As a result of defendants negligence, Tushar Singh suffered approximately 30 stitches to his face, permanent scarring, head trauma, and resulting anxiety. 11. As a direct and proximate result of defendants negligence, Tushar Singh has suffered and will suffer economic damages in terms of medical expenses in an amount to be proven at trial, but in an amount not more than $30,000. 12. As a direct and proximate result of defendants negligence, Tushar Singh has suffered and will suffer non-economic damages related to his pain and suffering in an amount to be proven at trial, but not more than $500,000. // //

Page 2

COMPLAINT (Negligence/Assault and Battery)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

WHEREFORE, plaintiff prays for judgment against defendants for $30,000 economic damages and $500,000 non-economic damages, plus his costs and disbursements for this litigation. Plaintiff notifies defendants of his intent to amend the complaint to add a claim for punitive damages. DATED: October 20, 2011. LAW WORKS LLC Lake James H. Perriguey OSB No. 983213 Plaintiffs attorney

Page 3

COMPLAINT (Negligence/Assault and Battery)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

Page 1

CERTIFICATE OF SERVICE

31616442.2 0099885-00002