GARY ROBINSON

C/o

El Castillo

12000 Washington Blvd.

Culver City, CA 90232

310-398-0000

Plaintiff in Pro Per

SUPERIOR COURT OF CALIFORNIA

Limited Jurisdiction Court

COUNTY OF LOS ANGELES

West Los Angeles

1633 Purdue Avenue,

Los Angeles, CA 90025

Plaintiff, Gary Robinson, alleges:

FIRST CAUSE OF ACTION

(Battery)

1. Plaintiff is and at all times mentioned in this complaint was, a resident of Los Angeles County, California.
2. Defendant is and at all times mentioned in this complaint was, a resident of Los Angeles County, California.
3. Plaintiff was working for the U.S. Department of Commerce Bureau of the Census on May 19, 2000.
4. On or about May 19, 2000, at approximately 7:23 PM went to 12611 Pacific Avenue, Los Angeles California 90066, to enumerate several non-responders at that address.
5. One of the non-respondents at the above address was the Defendant Daniel Luchansky.
6. Defendant Daniel Luchansky, was believed to be in unit 204 of 12611 Pacific Avenue, Los Angeles California 90066.
7. The apartment building at 12611 Pacific Avenue is a secured building with an intercom at the front of the building.
8. Manuel Castillo, who was working for Pizza Hut, came to the above address to deliver a pizza to the Defendant, Daniel Luchansky in unit 204.
9. Both Manuel Castillo and the Plaintiff arrived at the building at approximately the same time.
10. Manuel Castillo buzzed unit 204 from the intercom at the front of the building. The voice at the other end of the intercom answered. Manuel Castillo asked if he was Daniel Luchansky and he said that he was.
11. The Defendant came down to pick up his pizza.
12. After Defendant paid for and took his pizza, Plaintiff identified himself and showed the Defendant his Census Enumerator badge.
13. Plaintiff told that Defendant that he needed to ask to Defendant questions for the Census.
14. The Defendant said that he would not answer any questions.
15. When the Plaintiff attempted to enter the building to contact other non-respondents, the Defendant pushed him into Manuel Castillo.
16. The push knocked both the Plaintiff and Manuel Castillo down the stairs in front of the building.
17. Defendant intended to cause and did cause a harmful contact with defendant's person.
18. Plaintiff did not consent to defendant's act.
19. As a direct and proximate result of defendant's conduct plaintiff suffered a sore ankle. Plaintiff has suffered mental anguish and physical pain.
20. Defendant's act was done knowingly, willfully, and with malicious intent and plaintiff is entitled to punitive damages in an amount to be determined at trial.

WHEREFORE, plaintiff demands judgment against defendant, as follows:

1. General damages in the amount of $3000.
2. Punitive damages.
3. Any other and further relief that the court considers proper.

Dated 4-23-2002.

_________________________________

Gary Robinson