Romana, Ray, Orochi, LLP
100 Plaza of the Toad, Ste. 300
Divinity’s Reach, Kryta
State Bar No: 47358
Attorney for JANE ROE (a minor)
SUPERIOR COURT OF DIVINITY’S REACH
COUNTY OF QUEENSDALE
JANE ROE (a minor), et. al.
CASE NO: 475-DR-8913
COMPLAINT FOR DAMAGES AND STRICT PRODUCTS LIABILITY
Plaintiff complains and for causes of action alleges as follows:
First Cause of Action—Negligence
1. Plaintiff, Jane Roe (a minor), is an individual and is
now, and at all times mentioned in this complaint was, a
resident of Divinity’s Reach.
2. Defendant TIXX INFINIRARIUM is now, and at
all times mentioned in this complaint was, in the business of
inspecting, maintaining, installing, and selling at retail to
members of the public various types toys, dolls, homicidal action figures, and
assorted trinkets manufactured by defendant, TIXX INFINIRARIUM, in-house in its
own proprietary facility.
3. On Day 74 – Season of Colossus, plaintiff attempted to play with said Princess Doll
®, purchased from TIXX INFINIRARIUM, whereupon said Princess Doll®
spontaneously began a program wherein a “tantrum” was thrown, to the best of
knowledge of the Plaintiff, in the general direction of the Plaintiff. Shortly thereafter,
said Princess Doll® began firing lethal projectiles in, to the best of the Plaintiff’s
knowledge, the general direction of the plaintiff. Such firing did continue until
aforementioned Princess Doll® did run out of batteries and cease all homicidal
4. As a direct and proximate result of the negligence and
carelessness of defendant as described above, plaintiff sustained injury as a direct
and proximate cause of this unreasonably dangerous activity. Princess Doll®
purchased by plaintiff was destroyed by fire and plaintiff’s home, personal
belongings, furnishings, clothing, pets, and parents were damaged by smoke,
missiles, fire, and psychological impression caused by sudden homicidal behavior
exhibited by Defendant TIXX INFINIRARIUM’s Princess Doll®.
5. As a further direct and proximate result of the
negligence and carelessness of defendants as described above,
plaintiff sustained the following serious injuries and damages:
– Permanent Disability caused by 3 projectiles embedded in Plaintiff’s right leg and
– Psychological harm caused by severely traumatic tantrum program preceding
aforementioned homicidal missile assault
– Deceased Pet (Trixie, bunny)
– Psychological harm caused by deceased pet (Trixie, bunny)
WHEREFORE, plaintiff demands judgment as set forth below.
Second Cause of Action—Strict Products Liability
6. Plaintiff incorporates by this reference all
allegations contained in Paragraphs 1 through 5 of the First
Cause of Action of this complaint, as though fully set forth
7. At all times mentioned in this complaint, the Princess Doll® and
its component parts were defective as to design, manufacture,
and warnings, causing the Princess Doll® and its component parts to be in
a dangerous and defective condition that made them unsafe for
their intended use.
WHEREFORE, plaintiff demands judgment against defendants,
and each of them, as follows:
1. FIVE MILLION COPPER PIECES (500 gold, 0 silver, 0 copper), plus interest, costs
and any other relief this court deems appropriate.
2. General damages according to proof;
3. Special damages according to proof;
4. Prejudgment interest according to law;
5. Costs of this action; and
6. Any other and further relief that the court considers
I, Vitellio Romana, am an Attorney, in the above-entitled action. I have read the foregoing and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed at Divinity’s Reach, Kryta.
attorney for Jane Roe (a minor)