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Case 2:11-cv-01065-TFM Document 1-1 Filed 08/16/11 Page 1 of 2
Case 2:11-cv-01065-TFM Document 1-1 Filed 08/16/11 Page 2 of 2
Violet Elizabeth Grayson (VEG-2792)<br />
Attorney at Law<br />
SB#: CA 122611<br />
548 West 148 th Street<br />
New York, New York 10031<br />
(646) 406-1512<br />
vegrayson@gmail.com<br />
Attorney for Plaintiff<br />
UNITED STATES DISTRICT COURT<br />
WESTERN DISTRICT OF PENNSYLVANIA<br />
--------------------------------------------------------------X<br />
SUSAN PATROSKI, :<br />
:<br />
Plaintiff, :<br />
: COMPLAINT<br />
-against- :<br />
: JURY TRIAL DEMANDED<br />
PRESSLEY RIDGE, PRESSLEY RIDGE :<br />
FOUNDATION, AND B. SCOTT FINNELL, : ECF Filing<br />
:<br />
Defendants. :<br />
--------------------------------------------------------------X<br />
Introduction<br />
1. Plaintiff, Susan Patroski, seeks damages for sexual harassment, retaliatory dismissal,<br />
sexual battery, and related causes of action, arising out of her employment with Defendant<br />
Pressley Ridge, and her interaction with former Pressley Ridge Chief Executive Officer, B. Scott<br />
Finnell.<br />
1
Parties, Jurisdiction and Venue<br />
2. Plaintiff Susan Patroski (“Patroski”) is a natural person.<br />
3. Defendant Pressley Ridge is a not-for-profit corporation with its principal place of<br />
business at 5500 Corporate Drive, Suite 400, Pittsburgh, Pennsylvania 15237.<br />
4. Defendant Pressley Ridge Foundation (the “Foundation”) is, upon information and<br />
belief, a foundation or not-for-profit corporation, with its principal place of business at 5500<br />
Corporate Drive, Suite 400, Pittsburgh, Pennsylvania 15237.<br />
5. Defendant B. Scott Finnell (“Finnell”) is a natural person, and the former Chief<br />
Executive Officer of Defendant Pressley Ridge.<br />
6. Plaintiff invokes this Court’s federal question jurisdiction pursuant to 28 U.S.C.<br />
section 1331, because the action states claims under Title VII of the Civil Rights Act of 1964, as<br />
amended, 42 U.S.C. sections 2000(e) et seq. Plaintiff further invokes this court’s supplemental<br />
jurisdiction pursuant to 28 U.S.C. section 1367.<br />
7. Venue is properly laid in the Western District of Pennsylvania, as all events giving rise<br />
to this action occurred in this District, and two defendants maintain principal places of business<br />
within this District.<br />
Facts<br />
8. Beginning in 2008, Patroski was employed in the Human Resources Department of<br />
Pressley Ridge. On June 1, 2009, she was promoted to the position of Human Resources<br />
Coordinator. Throughout her employment with Pressley Ridge, one of Patroski’s supervisors was<br />
Chief Executive Officer, B. Scott Finnell.<br />
2
9. Commencing on December 24, 2008, Finnell purported to treat Patroski for “stress”<br />
with a “relaxation technique,” which was in fact hypnosis. Finnell told Patroski that the<br />
“relaxation sessions” were necessary not merely for her own benefit, but also because he was<br />
making a relaxation compact disk for the Pressley Ridge Wellness Program. Thus, the sessions<br />
were appropriately part of her duties as a member of the Pressley Ridge Human Resources<br />
Department. Nonetheless, Finnell also instructed Patroski not to tell anyone about the “relaxation<br />
sessions.”<br />
10. The hypnosis sessions occurred on a frequent basis over the course of approximately<br />
a year, always behind closed doors in Finnell’s office, on what Finnell referred to as his “magic<br />
couch.” During the hypnosis sessions, while Patroski was hypnotized, Finnell stroked Patroski’s<br />
breasts, and repeatedly brought her to orgasm, utilizing the hypnotic suggestion that he would<br />
slowly count to five, and when he reached five, she would experience a rush of pleasure.<br />
11. During the period when Finnell was hypnotizing Patroski, he also repeatedly told her<br />
that she was very attractive, and requested that she accompany him to his house during the lunch<br />
hour when his wife was out. Patroski declined the invitation.<br />
12. Immediately after each hypnosis session, Patroski could not recall what transpired.<br />
But she often noticed that the cardigan she had been wearing when she entered Finnell’s office<br />
was now on her arm, or that the fashion in which the cardigan was buttoned had changed. She<br />
also noticed that her underpants were very damp. On one occasion, she was involved in an<br />
automobile collision while still foggy from a hypnosis session.<br />
13. Beginning in December of 2009, Patroski began recalling what transpired during the<br />
so-called “relaxation sessions.” The recollections which surfaced included not only the “count-<br />
down to orgasm” sequence described above, but also:<br />
3
a) being on the floor in front of Finnell, and having her head between his legs;<br />
b) Finnell saying: “I’m touching you, but you’re so relaxed, you’re so deeply asleep, you<br />
don’t even feel it”;<br />
c) a clicking sound, which may have been a camera, leading Patroski to now fear that she<br />
was photographed in a state of dishabille.<br />
14. When the above memories surfaced, Patroski sent an e-mail to Finnell, expressing her<br />
concerns. She also confided in co-worker, Linda Kady. Ms. Kady informed Patroski that Finnell<br />
was trained as a hypnotist, and had attempted to hypnotize her to stop smoking. Patroski<br />
subsequently learned that a number of other female employees had been hypnotized.<br />
15. After Finnell discovered that Patroski was remembering details of the hypnosis<br />
sessions and discussing the subject of hypnosis with other personnel, he moved to push her out<br />
of the organization. On February 22, 2010, Patroski was asked to resign and execute a release,<br />
because she allegedly implied to co-workers that she had a sexual relationship with Finnell.<br />
When Patroski declined to resign, she was barred from executive committee meetings, prohibited<br />
from speaking to anyone in upper management, stripped of her duties as Human Resources<br />
Coordinator, and demoted to the lesser position of Benefits Coordinator.<br />
16. The foregoing actions constituted a material deterioration in the conditions of<br />
Patroski’s employment, particularly because previously, Finnell had lead Patroski to expect that<br />
she would be promoted to Assistant Director of Human Resources after she finished her PHR<br />
certification in June 2010, and to Director of Human Resources after she finished her Master’s<br />
Degree in 2011.<br />
17. In April of 2010, Patroski brought the foregoing circumstances to the attention of the<br />
Board of Directors of Pressley Ridge, and requested redress. None was forthcoming.<br />
4
Pittsburgh.<br />
18. On June 2, 2010, Patroski filed a Charge of Discrimination with the EEOC office in<br />
19. On June 4, 2010, Pressley Ridge terminated Patroski’s employment, in further<br />
retaliation for complaining of sexual harassment and reporting said sexual harassment to both the<br />
Board of Directors and the EEOC. Adding insult to injury, Pressley Ridge objected to Patroski’s<br />
unemployment claim.<br />
20. On June 8, 2010, the EEOC issued Patroski a Right to Sue Letter. On July 22, 2010,<br />
Patroski filed suit against Pressley Ridge, the Foundation, and Finnell, in the Federal District<br />
Court for the Western District of Pennsylvania. On December 7, 2010, the District Court<br />
dismissed the action without prejudice, opining that the EEOC issued its Right to Sue Letter<br />
prematurely. On December 21, 2010, the EEOC withdrew its Right to Sue Letter in light of the<br />
Court’s opinion, and commenced investigation and conciliation. These efforts did not result in<br />
resolution of the matter, and on July 13, 2011, the EEOC issued a new Right to Sue Letter.<br />
21. During the period described in the foregoing paragraph, the Board of Directors of<br />
Pressley Ridge learned that Finnell had indeed hypnotized numerous female employees and<br />
engaged in other misconduct warranting his dismissal. Finnell was dismissed from his post, but<br />
Pressley Ridge did not apologize to Patroski, much less offer suitable reparation.<br />
First Cause of Action Against Pressley Ridge - Quid Pro Quo Sexual Harassment In Violation of<br />
Title VII of the Civil Rights Act of 1964<br />
herein.<br />
22. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-21<br />
23. The facts and circumstances described above violate the Civil Rights Act of 1964,<br />
insofar as Patroski was required to participate in the “relaxation sessions” during which she was<br />
5
hypnotized and sexually molested by her supervisor, and also to remain silent about the hypnosis<br />
and sexual molestation, as a quid pro quo for her continued employment. When Patroski ceased<br />
to silently acquiesce, the conditions of her employment materially deteriorated, and shortly<br />
thereafter she was fired.<br />
24. Finnell’s actions in hypnotizing and sexually molesting Patroski, and then having her<br />
fired, were so outrageous in character, and so extreme in degree, as to go beyond all possible<br />
bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized<br />
community. The actions of Pressley Ridge, in initially protecting Finnell and firing Patroski,<br />
after Finnell’s hypnosis and molestation of Patroski came to light, were likewise so outrageous in<br />
character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be<br />
regarded as atrocious, and utterly intolerable in a civilized community. Also, outrageous,<br />
indecent, and intolerable, was the failure of Pressley Ridge to offer any apology or meaningful<br />
reparation to Patroski after the full extent of Finnell’s misconduct became known.<br />
25. Patroski has suffered serious damage as a consequence of the quid pro quo sexual<br />
harassment described above. In addition to extraordinary mental anguish so severe as to be<br />
disabling, cause her to feel physically ill, and amount to a physical injury, Patroski has suffered<br />
from loss of salary, damage to reputation, and loss of opportunity for future career advancement.<br />
Second Cause of Action Against Pressley Ridge – Hostile Workplace Sexual Harassment In<br />
Violation of Title VII of the Civil Rights Act of 1964<br />
herein.<br />
26. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-25<br />
27. The occurrences described above subjected Patroski to a Hostile Workplace, in<br />
violation of Title VII of the Civil Rights Act of 1964. After Patroski realized that she had been<br />
6
hypnotized and sexually assaulted by Finnell, and raised the subject with Kady and Finnell<br />
himself, Pressley Ridge did everything possible to force Patroski from her job, and make her<br />
continued employment as unpleasant, uncomfortable, and unrewarding as possible, pending her<br />
ultimate termination. Indeed, the conditions under which Patroski worked between February 22,<br />
2010 and June 4, 2010 were so severely and pervasively hostile as to be intolerable.<br />
28. The actions of Finnell and Pressley Ridge in deliberately creating a Hostile<br />
Workplace for Patroski after she discovered Finnell’s misconduct, were malicious, vile, wanton,<br />
and lawless. Indeed, they were so outrageous in character, and so extreme in degree, as to go<br />
beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in<br />
a civilized community.<br />
29. Patroski has suffered serious damages as a consequence of the Hostile Workplace<br />
sexual harassment described above. In addition to severe and disabling mental anguish<br />
amounting to physical injury, she has suffered from loss of salary, damage to reputation, and loss<br />
of opportunity for future career advancement.<br />
Third Cause of Action Against Pressley Ridge – Retaliation In Violation of Title VII of the Civil<br />
Rights Act of 1964<br />
herein.<br />
30. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-29<br />
31. Defendant Pressley Ridge retaliated against Patroski for her objection to and protest<br />
of the conduct in violation of Title VII of the Civil Rights Act of 1964, by first rendering the<br />
conditions of her employment so intolerable as to amount to constructive termination, and then<br />
formally terminating her employment and protesting her unemployment application. This<br />
retaliatory conduct itself constitutes a violation of Title VII.<br />
7
32. The actions of Finnell and Pressley Ridge in retaliating against Patroski for<br />
exercising her rights under Title VII of the Civil Rights Act of 1964 were willful, malicious, vile,<br />
wanton and lawless. They were so outrageous in character, and so extreme in degree, as to go<br />
beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in<br />
a civilized community<br />
33. Patroski has suffered serious damages as a consequence of the retaliatory conduct<br />
described above. In addition to severe and disabling mental anguish amounting to physical<br />
injury, she has suffered from loss of salary, damage to reputation, and loss of opportunity for<br />
future career advancement.<br />
herein.<br />
Fourth Cause of Action Against Finnell For Sexual Assault<br />
34. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-33<br />
35. Finnell hypnotized Patroski, and then, while she was under the influence of hypnosis<br />
and unable to resist, touched her sexually and caused her to engage in involuntary sexual<br />
activities with him. This constituted sexual assault.<br />
36. Finnell’s conduct in first claiming that he was only going to “relax” Patroski, and<br />
then hypnotizing her and taking advantage of her sexually, was so outrageous in character, and<br />
so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as<br />
atrocious, and utterly intolerable in a civilized community.<br />
37. When memories of Finnell’s sexual assault surfaced in Patroski’s mind, they caused<br />
Patroski extraordinary mental anguish so severe as to constitute a debilitating injury which<br />
rendered Patroski physically ill.<br />
8
Fifth Cause of Action Against Finnell and Pressley Ridge for Fraudulent Misrepresentation<br />
37 herein.<br />
38. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1 through<br />
39. On December 28, 2008, in his Pressley Ridge Office, located at 5500 Corporate<br />
Drive, Suite 400, Pittsburgh, Pennsylvania, Finnell represented to Patroski that if she reposed her<br />
trust in him during the “relaxation sessions,” and followed his suggestions, she would experience<br />
benefit in the form of stress relief. He further represented that the relaxation sessions were<br />
necessary for the preparation of the relaxation compact disc which was part of the Pressley Ridge<br />
Wellness Program, and that her participation as an employee of Pressley Ridge in the Human<br />
Resources Department was therefore appropriate.<br />
40. Finnell made the foregoing representations in his capacity as CEO of Pressley Ridge<br />
and as Patroski’s supervisor. In subsequently employing the “relaxation technique,” which was<br />
in fact hypnosis, Finnell acted with apparent authority as an officer and agent of Pressley Ridge.<br />
41. When Finnell made the foregoing representations, he knew that they were false,<br />
because he would hypnotize and sexually molest Patroski, rather than simply relaxing her, and<br />
this would ultimately cause Patroski grave injury rather than stress relief.<br />
42. Patroski relied upon Finnell’s false representations set forth above by participating in<br />
the so-called relaxation sessions, which were in fact hypnosis sessions during which she was<br />
sexually assaulted.<br />
43. Patroski’s reliance upon the false representations was reasonable and foreseeable in<br />
light of her employment relationship with Pressley Ridge, Finnell’s position as Chief Executive<br />
Officer of Pressley Ridge, and all of the other circumstances set forth above.<br />
9
44. As previously set forth herein, Patroski was greatly injured by the fraudulent<br />
misrepresentation. She is entitled to compensation for her injuries.<br />
45. The actions of Finnell and Pressley Ridge, as set forth in this Cause of Action for<br />
Fraudulent Misrepresentation, were so outrageous in character, and so extreme in degree, as to<br />
go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable<br />
in a civilized community, thus entitling Patroski to punitive as well as compensatory damages.<br />
herein.<br />
Sixth Cause of Action Against Finnell for Fraud<br />
46. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-45<br />
47. On December 24, 2008, in his Pressley Ridge office, located at 5500 Corporate Drive,<br />
Suite 400, Pittsburgh, Pennsylvania, Finnell promised Patroski that if she repeatedly came to his<br />
office, sat on his couch, and followed the procedures he suggested, he would engage her in safe<br />
and beneficial “relaxation sessions” teaching her a technique to relieve stress.<br />
48. Finnell knew this promise to be false at the time when he made it because his<br />
intention was to hypnotize Patroski and engage in sexual activity with her while she was<br />
hypnotized, thereby benefitting himself while harming Patroski.<br />
49. Patroski foreseeably and actually relied upon Finnell’s false promise by repeatedly<br />
coming to his office, sitting on his couch, and participating in good-faith in the so-called<br />
“relaxation sessions” where she was in fact hypnotized and sexually abused.<br />
50. Finnell thereby benefitted from his false and fraudulent promise while Patroski, as<br />
previously set forth herein, suffered harm.<br />
10
51. Finnell’s actions described in this Fraud Cause of Action were so outrageous in<br />
character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be<br />
regarded as atrocious, and utterly intolerable in a civilized community.<br />
herein.<br />
Seventh Cause of Action Against Finnell For Intentional Infliction of Emotional Distress<br />
52. Plaintiff repeats and incorporates by reference, the allegations of paragraphs 1-51<br />
53. By taking the actions previously set forth herein, including tricking Patroski into<br />
participating in the “relaxation sessions,” hypnotizing her, sexually assaulting her, and then<br />
causing Pressley Ridge to first render her conditions of employment intolerable and then fire her,<br />
Finnell caused Patroski grave and debilitating emotional distress amounting to a physical injury.<br />
Patroski has become emotionally withdrawn from her family and friends. Physical effects of the<br />
emotional distress suffered by Patroski include severe gastrointestinal upset, gynecological<br />
disturbance, shaking, nightmares, and talking and crying in her sleep.<br />
54. Finnell’s actions causing Patroski debilitating emotional distress and injury were so<br />
outrageous in character, and so extreme in degree, as to go beyond all possible bounds of<br />
decency, and to be regarded as atrocious, and utterly intolerable in a civilized community.<br />
Eighth Cause of Action Against Pressley Ridge For Intentional Infliction of Emotional Distress<br />
herein.<br />
55. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-54<br />
56. After Pressley Ridge learned that Finnell fraudulently hypnotized and sexually<br />
molested Patroski, it deliberately protected Finnell and punished Patroski, first by creating a<br />
11
Hostile Workplace where conditions of employment were unbearable, and then by terminating<br />
Patroski’s employment and attempting to deny her unemployment. Then, after Pressley Ridge<br />
learned the full extent of Finnell’s misconduct and terminated him, it still failed to apologize to<br />
Patroski or offer her meaningful reparation.<br />
57. This conduct caused Patroski grave and debilitating emotional distress amounting to<br />
physical injury. Patroski has become emotionally withdrawn from her family and friends.<br />
Physical effects of the emotional distress suffered by Patroski include severe gastrointestinal<br />
upset, gynecological disturbance, shaking, nightmares, and talking and crying in her sleep.<br />
58. The actions of Pressley Ridge, intentionally inflicting emotional distress upon<br />
Patroski as set forth in this cause of action were so outrageous in character, and so extreme in<br />
degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and<br />
utterly intolerable in a civilized community.<br />
Ninth Cause of Action Against Pressley Ridge for Negligence in Hiring And Supervising Finnell<br />
herein.<br />
59. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-58<br />
60. As previously set forth herein, Patroski is not the first female employee of Pressley<br />
Ridge to be hypnotized by Finnell, and, upon information and belief, not the first female<br />
employee to be sexually assaulted by Finnell while hypnotized. Pressley Ridge, through its<br />
Directors, Officers, and management level employees, including Chief Financial Officer Scott<br />
W. Erickson, was aware that Finnell was hypnotizing female employees, before he ever<br />
hypnotized Patroski. Pressley Ridge also knew or should have known, that Finnell was sexually<br />
assaulting the employees he hypnotized, all of whom were both female and attractive. Even if<br />
12
Pressley Ridge did not know, or have reason to know, that Finnell was sexually assaulting the<br />
female employees he hypnotized, it knew, or should have known, that Finnell’s hypnosis of<br />
female employees was improper, dangerous, and harmful in and of itself.<br />
61. Pressley Ridge owed Patroski and every female employee a duty of care, to keep<br />
them reasonably safe in the workplace.<br />
62. Pressley Ridge breached this duty of care by failing to take action to prevent and stop<br />
Finnell’s hypnosis of female employees.<br />
63. Plaintiff is further informed and believes that Finnell engaged in misconduct similar<br />
to the misconduct here, prior to joining Pressley Ridge as its Chief Executive Officer. Pressley<br />
Ridge was negligent in failing to properly investigate Finnell before hiring him. A proper<br />
investigation would have brought to light Finnell’s prior misconduct.<br />
64. Plaintiff was injured as a consequence of Defendant Pressley Ridge’s negligence; if<br />
Pressley Ridge had properly investigated Finnell’s past before hiring him, or taken appropriate<br />
action when Finnell first began hypnotizing other female employees, Patroski would never have<br />
been hypnotized and sexually assaulted.<br />
65. As previously set forth herein, Patroski’s emotional, physical, and economic injury,<br />
of which Pressley Ridge’s acts and omissions is the cause-in-fact, is severe and on-going.<br />
Tenth Cause of Action Against Pressley Ridge for Breach of Covenant of Good Faith and Fair<br />
Dealing<br />
herein.<br />
66. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-65<br />
13
67. The contract of employment between Patroski and Pressley Ridge contained a<br />
covenant of good faith and fair dealing implied by law. The conduct of Pressley Ridge<br />
previously set forth herein breached the covenant of good faith and fair dealing.<br />
68. Said breach of contract caused Patroski severe economic damage in the form of loss<br />
of wages, loss of experience, and loss of opportunity for advancement at Pressley Ridge.<br />
Eleventh Cause of Action To Pierce Corporate Veil of Pressley Ridge to Reach the Foundation<br />
herein.<br />
69. Plaintiff repeats and incorporates by reference the allegations of paragraphs 1-68<br />
70. The business of Pressley Ridge and the Foundation is in fact one business, operating<br />
out of a single office, with unity of ownership and administrative control, each entity being the<br />
alter ego of the other. The unitary business is organized – solely on paper – into two legal entities<br />
so as to sequester all assets in the Foundation, while encapsulating all liabilities, actual and<br />
potential, in the thinly-capitalized operating company known as Pressley Ridge, thereby<br />
defrauding creditors. Plaintiff is further informed and believed that the corporate formalities of<br />
two distinct entities are not observed.<br />
71. The arrangement described in the preceding paragraph has the purpose and effect of<br />
rendering the operating company, Pressley Ridge, judgment-proof as against persons such a<br />
Plaintiff, with legitimate claims against it. The Foundation has no purpose other than to hold<br />
assets for use by Pressley Ridge, in an entity where they cannot be reached by creditors. This<br />
constitutes an abuse of the corporate form, such that the corporate veil of Pressley Ridge should<br />
be pierced to reach the assets of the Foundation.<br />
14
PRAYER FOR RELIEF<br />
WHEREFORE, PLAINTIFF PRAYS FOR JUDGMENT AS FOLLOWS:<br />
On The First through Third Causes of Action (Title VII)<br />
Entering judgment against Pressley Ridge and in favor of Patroski, for front-pay, back-<br />
pay, compensatory damages, punitive damages, and attorney’s fees, all according to proof, and<br />
all as authorized by Title VII of the Civil Rights Act of 1964 as amended.<br />
On the Fourth Cause of Action (Sexual Assault)<br />
Entering judgment against Finnell and in favor of Patroski, for compensatory and<br />
punitive damages according to proof.<br />
On the Fifth Cause of Action (Fraudulent Misrepresentation)<br />
Entering judgment in favor of Patroski, jointly and severally against Pressley Ridge and<br />
Finnell, for both compensatory and punitive damages according to proof.<br />
On the Sixth Cause of Action (Fraud)<br />
Entering judgment against Finnell and in favor of Patroski for compensatory and punitive<br />
damages according to proof.<br />
15
On the Seventh Cause of Action (Intentional Infliction of Emotional Distress By Finnell)<br />
Entering judgment against Finnell and in favor of Patroski for compensatory and punitive<br />
damages according to proof.<br />
On the Eighth Cause of Action (Intentional Infliction of Emotional Distress By Pressley Ridge)<br />
Entering judgment against Pressley Ridge and in favor of Patroski for compensatory and<br />
punitive damages according to proof.<br />
On the Ninth Cause of Action (Negligent Hiring and Supervision)<br />
Entering judgment against Pressley Ridge and in favor of Patroski for compensatory<br />
damages according to proof.<br />
On the Tenth Cause of Action (Breach of Covenant of Good Faith and Fair Dealing)<br />
Entering judgment against Pressley Ridge and in favor of Patroski for compensatory<br />
damages according to proof.<br />
On the Eleventh Cause of Action (Veil Piercing Claim Against the Foundation)<br />
Declaring the corporate veil of Pressley Ridge pierced to reach the Foundation, and<br />
declaring the Foundation jointly and severally liable for any judgment entered in favor of<br />
Patroski and against Pressley Ridge in this action.<br />
16
On All Causes of Action<br />
1) Awarding compensatory and punitive damages, in a total amount of not less than<br />
$5,000,000, in favor of Patroski, jointly and severally against Finnell, Pressley Ridge, and<br />
Pressley Ridge Foundation.<br />
2) Awarding to Patroski, costs and attorneys fees if and as allowed by law;<br />
3) Awarding such other and further relief as this Court may deem just and proper.<br />
Respectfully submitted,<br />
s/ Violet Elizabeth Grayson (VG-2792)<br />
SB#: CA 122611<br />
Attorney at Law<br />
548 West 148 th Street<br />
New York, N.Y. 10013<br />
(646) 406-1512<br />
vegrayson@gmail.com<br />
Attorney for Plaintiff<br />
17