CIVIL COVER SHEET
Clark County, Nevada
1. Party Information
Plaintif{s) (name/adress/phone): STEPHEN PADDOCK,
RESORTS, INC.
Attomey (name/addressphone):
A- 12-668412-C
XXVI
Defendants) (name/address/phone): COSMOPOLITAN HOTELS &
RICHARDS & ASSOCIATES, LLC, 1489 W. Warm Springs | Atorey (nameadaress/phon}
Road, Ste. 110, Henderson, NV 89014
702-518-5180
IL. Nature of Controversy (Please check applicable bold category and
applicable subcategory, if appropriate)
Civil Cases
Real Property
Ci Arbitration Requested
Torts
Negligence
Negligence — Auto
Ci Negligence ~ Medical/Dental
‘DLandtoravTenant
D7 Unlawful Detainer
D1 Title to Property
1 Foreclosure Bi Negligence ~ Premises Liability
Liens (SipFal)
Quiet Tite (Negligence — Other
D1 Specific Performance
Ci Condemnation/Eminent Domain
other Real Property
O Partition
C1 Planning/Zoning
Coradecttiabitty
1 Product Lisiiyotor Veni
1 Othe TortProduct ible
C1 Intentional Misconduct
O Torts/Defamation (Libel/Slander)
Ly Interfere with Contract Rights
C1 Employment Torts (Wrongful termination)
Other Torts
Ey ania
[Dy FraMisepesenttion
i inmrance
Cy Lega Tor
Unfair Competition
Other Civil Filing Types
Probate
stated Este Value Ti Construction Defect
pier
Summary Administration Bi Shaptr40
(General Administration C1 Breach of Contract
" Bilcing de Consoton
special Administration Pallas Ona
Ciset Asie estates Commer strane
Other Contracts/AcctJudgment
ag
q
q
TrustConservatoes
a _ ) Coesion of Actions
g
g
q
oa
1 tnavidual Trustee
i comerste Trustee
Clother Probate
‘Employment Contract
Guarantee
Sale Contract
Uniform Commercial Code
Ci Civil Petition for Judicial Review
G Foreclosure Mediation
Oy other Administrative Law
(] Department of Motor Vehicles
Fy Worker’s Compensation Appeal
C1 Appeal from Lower Court flea check
applicable cin case bas)
(Ly Transfer from Justice Court
D7 Justice Court Civil Appeal
Chewvitwrit
C1 Other Special Proceeding
C. Otter Civit Fiting
(Compromise of Minor’s Claim
[5 Conversion of Property
Ey Damage to Property
Employment Security
Enforcement of Judgment
Foreign Judgment ~ Civil
1 other Personal Property
D Recovery of Property
Stockholder Suit
0 Other Civil Matters:
III. Business Court Requested (ease check applicable category for Clare Washoe Counties onl)
CI NRS Chapters 78-88
Fy Commodities (NRS 90)
G7 Investments (NRS 104 Art. 8)
5 Deceptive Trade Practices (NRS 598)
Enhanced Case Memt/Business
C7 Other Business Court Matters
i Securities (NRS 90) Cy Trademarks (NRS 6004)
‘September 17, 2012 ] a 7
Date
‘See other side fr famiy-rlated ease fing
ating party or representativeeo)
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Richards & Associates
Electronically Filed
09/17/2012 09:01:36 AM
COMP :
Jared R. Richards, Esq. hen
Nevada Bar No. 11254 bin b
RICHARDS & ASSOCIATES, LLC CLERK OF THE COURT
1489 W. Warm Springs Rd., Ste. 110,
Henderson, NV 89014
Telephone (702) 518-5180
Facsimile (702) 508-9393
Email jared@jazedrichardslaw.com
Attomeys for Plaintiff
DISTRICT COURT
CLARK COUNTY, NEVADA
Stephen Paddock, an individual | caseno, A- 12-668412-C
ve Plaintiff, DEPT. NO. XXVI
COMPLAINT
Cosmopolitan Hotels & Resorts Inc., a i
‘Nevada corporation, DOES I-X, and ROES |
LX
Defendants. |
THE PARTIES, JURISDICTION, AND VENUE
1, Plaintiff STEPHEN PADDOCK is an individual.
2. Defendant COSMOPOLITAN HOTELS & RESORTS INC. is a corporation!
domiciled in Nevada and doing business in Nevada.
3. This Court has jurisdiction over the parties and venue is proper because Defendant|
is a resident of Nevada and the injury at issue in this case occurred on real property owned by
Defendant in Clark County, Nevada.
4, The true names and capacities of Defendants named as DOES I through X and|
ROES I-X are unknown to Plaintiff at this time; therefore, Plaintiff sues these Defendants by
fictitious names. Plaintiff will advise this Court and seek leave to amend this Complaint when the
name and capacity of each DOE Defendant has been ascertained. Plaintiff alleges that each|wn
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Richards & Associates
Defendant named under such a fictitious name is responsible in some manner for the events and
happenings alleged
GENERAL ALLEGATIONS
5. Defendant is the owner of real property located in Clark County, Nevada|
commonly known as the Cosmopolitan, 3708 Las Vegas Boulevard South, Las Vegas, Nevada
89109 (the “Property”),
6 Onor around October 30, 2011, Plaintiff was on Defendant's commercial Property
as an invited guest and customer.
7. While on the Property, Plaintiff slipped and fell on an obstruction on the floor in|
an area intended for foot traffic. The obstruction is herein referred to as the “dangerous
condition”,
8. Defendant knew or should have known about the dangerous condition, but did not|
take the appropriate steps to remedy the dangerous condition.
9. AS a proximate result of Plaintiff's slip and fall on the dangerous condition,
Plaintiff sustained substantial injuries.
FIRST CAUSE OF ACTIO}
NEGLIGENCE
10. Plaintiff incorporates the allegations in the preceding and ensuing paragraphs o
this Complaint as if fully set forth herein,
11. Defendant had a duty to properly maintain, inspect and care for the area of the
dangerous condition.
12, Atal relevant times, Defendant failed to fulfill that duty.
13, At all relevant times, Defendant was aware or should have been aware of the
dangerous condition.
14, At all relevant times, Defendant failed to wam Plaintiff of the dangerous
condition.Dog Om &
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15. Plaintiff had no actual or constructive knowledge of the dangerous nature of the
dangerous condition.
16. The dangerous condition created a risk foreseeable to Defendant as to anyone|
Defendant or it lesees, agents or assigns invited onto the Property.
17. It was reckless of Defendant to allow the dangerous condition to exist.
18. Asa direct and proximate result of Defendant’s negligence, Plaintiff slipped and
fell on the dangerous condition and sustained personal injuries.
19. As a direct and proximate result of Defendant's negligence, carelessness and|
recklessness, Plaintiff was injured in his health, strength and activity, sustaining shock and injury
to his body, nervous system and person, all of which caused and will continue to cause physical,
mental and nervous pain and suffering,
20. As a direct and proximate result of Defendant's negligence, carelessness and
recklessness, Plaintiff has incurred medical expenses, loss of income, possible future loss o
income and medical expenses, and loss of enjoyment of life, In all, Plaintiff has been damaged in
‘an amount in excess of $10,000.00.
21. Asa result of Defendant's negligence and recklessness, Plaintiff has been required|
to retain the law firm of Richards & Associates, LLC to prosecute this action, and Plaintiff is
entitled to recover reasonable attomey’s fees and costs.
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PRAYER
WHEREFORE, Plaintiff prays for Judgment against Defendant as follows:
1, For damages in excess of $10,000 for pecuniary and non-pecuniary damages.
2. Forattomney’s fees and costs.
3. For such other and further rel
Dated: September 12, 2012
lief as the Court may deem just and proper.
RICHARDS & ASSOCIATES, LLC
Wada Bar No. 11254
Springs Rd., Ste. 110,
NEVADA 89014
: (702) 518-5180
Attorneys for Plaintiff