Case 1:14-cv-01999-APM Document 15 Filed 07/24/15 Page 1 of 7

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

LEANDER STOCKS,
2359 24th Street, S.E., #1801
Washington, DC 20020
Plaintiff,
v.

Civil Action No.: 1:14-cv-01999-APM

THE CORDISH COMPANIES, INC

Served: Registered Agent
RC VENTURES, INC.
601 East Pratt St. - 6th Floor
Baltimore, MD 21202
and
PPE CASINO RESORTS
MARYLAND, LLC
and
MARYLAND LIVE! CASINO #777
Serve: Registered Agent
CSC Lawyers Incorporating
Service Company
7 ST. Paul Street - Suite 820
Baltimore, MD 21202
Defendants.

SECOND AMENDED COMPLAINT

Leander Stocks (Plaintiff) brings this Complaint for negligence and battery
against Defendants, The Cordish Companies, Inc., PPE Casino Resorts Maryland. LLC,
and Maryland Live! Casino #777, (Defendant) and states the following:
JURISDICTION AND VENUE
1.

Jurisdiction of this Court is invoked under diversity of citizenship pursuant

to 28 U.S.C. 1332(a).

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2.

Jurisdiction is also present over Defendants pursuant to D.C. Code 13-

423, 13-423(a).
3.

Defendants purposefully direct activities toward the residents of the

District of Columbia through advertising on Washington, D.C. television stations with the
aim of attracting District of Columbia residents to Maryland Live! Casino #777.
4.

Defendants purposefully solicit patronage and derive revenue from

District of Columbia residents through a persistent course of conduct within the District
of Columbia and thereby avail themselves of the benefits, protections and obligations
imposed pursuant to the laws of the District of Columbia.
PARTIES
1.

Plaintiff, Leander Stocks is a resident of Washington, DC and has always

been a resident of Washington, DC at all times relevant to the cause of action herein.
2.

At all times relevant to the cause of action herein, Defendant, The Cordish

Companies, Inc., is a Maryland corporation with its corporate office and headquarters in
Baltimore, Maryland.
3.

At all times relevant to the cause of action herein, Defendant, PPE Casino

Resorts Maryland, LLC is a Maryland limited liability company registered in Baltimore,

Maryland.
4.

At all times relevant to the cause of action herein Defendant, Maryland

Live! Casino #777 is a gambling and entertainment venue located in Hanover, Maryland
that catered to, among others, the Washington, DC and Baltimore, MD metropolitan
communities.

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5.

At all times relevant to the cause of action herein Maryland Live! Casino

#777s registered (primary) owner is PPE Casino Resorts Maryland, LLC.

6.

At all times relevant to the cause of action herein, PPE Casino Resorts

Maryland, LLC is owned, operated or managed by The Cordish Companies, Inc., as its
affiliate or subsidiary.
7.

At all times relevant to the cause of action herein, The Cordish Companies

Inc., through its affiliate or subsidiary, PPE Casino Resorts Maryland, through Maryland
Live Casino #777 consistently and purposefully conducted business in Washington, DC
soliciting, attracting, enticing or otherwise drawing District residents to patronize
Defendant Maryland Live! Casino #777s gaming facility.
STATEMENT OF CLAIMS
COUNT I
1.

At or about 12:00 am on December 15, 2013, Plaintiff was a business

invitee of Defendant Maryland Live! Casino #777.

2.

Plaintiff was wagering at one of Defendant Maryland Live! Casino #777s

roulette wheels when the Defendants employee operating the device negligently caused
the wheels hard ball to become airborne and strike the Plaintiff just above the left eye at
high velocity.
3.

That initial impact caused a sharp and severe pain followed by general

disorientation in the Plaintiff and required one of Defendants security employees to

assist Plaintiff from the gaming area to a secure, private room of the casino for his
comfort, recovery and/or further assessment.

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4.

Once in the private room, Plaintiff was able to lie down on a bench to wait

for the pain above his eye to subside and for a cold compress to apply to the bruised area.
5.

While Plaintiff was so reclining, and without warning or consent, the

Defendants aforementioned security employee began to administer unidentified liquid

drops directly into Plaintiffs left eye despite the prominent contusion above that eye.
6.

Plaintiffs reaction to this unwanted touching and unauthorized medical

procedure was immediate blurred vision, increased pain and discomfort in the affected
area, overwhelming disorientation and pronounced loss of physical coordination.
7.

Attempting to rise from the bench in this distressed physical and mental

state, the Plaintiff experienced severe disorientation that caused him to fall forward,
violently hit the front and top of his head against the hardwood door to the room, and lose
consciousness.
8.

The injuries sustained in the fall required that the Plaintiff be taken to a

local hospital emergency room where he was evaluated and treated for the concussion
sustained in the fall and the contusion resulting from being struck by the roulette wheel
ball.
9.

From that initial medical treatment in the early morning hours of

December 15, 2013, Plaintiff has continued to suffer bouts of blurred vision, occasional
loss of coordination and regular episodes of post-traumatic headaches to the present, this
despite repeated medical evaluations and treatment.
10.

Plaintiff avers that these episodic incidents of debilitating headaches,

blurred vision and loss of coordination are the result of both negligent and willful
misconduct by the Defendant Maryland Live! Casino #777s employees, to wit:

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Defendants negligent operation of its roulette wheel that caused Plaintiff to sustain the
contusion above his eye; and, Defendants willfully aggressive and unwelcomed
administration of an unknown liquid directly into Plaintiffs eye, which caused him to
suffer, among other things, a syncopal episode leading to his fall and ensuing concussion.
11.

The physical and emotional damage done to the Plaintiff by the

Defendants negligent and willful misconduct has demonstrably diminished the

Plaintiffs quality of life and the enjoyment thereof since sustaining his injuries and will
continue to do so into the foreseeable future.

COUNT II
1.

Plaintiff reiterates herein all of the allegations set forth in Count I above

and incorporates the same as if set forth at length.

2.

Plaintiff avers that the Defendant Maryland Live! Casino #777s

unwelcomed, unwanted and willful act of placing unidentified liquid directly into
Plaintiffs eye amounted to a battery to his person done in wanton and reckless disregard
for plaintiff's rights to be free of unsolicited medical treatment and/or other batteries to
his person and rise therefore to the level of malice.
3.

That act of unwanted touching proximately caused Plaintiff to suffer a

concussion and its continuing consequences manifesting in episodic incidents of

debilitating headaches, blurred vision and loss of coordination and general diminishment
in Plaintiffs quality of life and the peaceful enjoyment thereof. 

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PRAYER FOR RELIEF



COUNT I
WHEREFORE, Plaintiff Leander Stocks demands judgment against Defendants
for Count I as follows:
1.

Prays for judgment against the Defendants in the amount of One Hundred

Fifty Thousand ($150,000.00) Dollars, plus pre-judgment and post-judgment interest;

2.

Plaintiff prays for interest at a rate determined by the jury on the principal

amount or a portion thereof, as set by the jury, for a term commencing December 15,
2013;
3.

Plaintiff prays for reimbursement for Court costs expended herein;

4.

Plaintiff reserves his right to amend his Complaint up to and including the

date of the trial of this matter; and

5.

Such other and further relief as the Court deems just and proper.
COUNT II

WHEREFORE, Plaintiff Leander Stocks demands judgment against Defendants

for Count II as follows:
1.

Plaintiff prays for judgment against Defendants for Punitive Damages in

the amount of One Hundred Fifty Thousand ($150,000.00) Dollars plus pre-judgment and
post-judgment interest;
2.

Plaintiff prays for interest at a rate determined by the jury on the principal

amount or a portion thereof, as set by the jury, for a term commencing December 15,
2013;
3.

Plaintiff prays for reimbursement for Court costs expended herein;

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4.

Plaintiff reserves his right to amend his Complaint up to and including the

date of the trial of this matter; and

5.

Such other and further relief as the Court deems just and proper.
JURY TRIAL DEMAND

Plaintiff demands a trial by jury of all issues so triable.

Respectfully submitted,

/s/
Deborah D. Wright 429549
Law Office of Deborah D Wright
P.O. Box 34314
Washington, DC 20043
202.251.0677 (o)
202.688.1841 (f)
ddwright165@gmail.com
Dated: February 25, 2015

Counsel for Plaintiff

Leander Stocks