COMPLAINT

February 3, 2023

OMAR ANAS 

1822 East Route 66 St. A458 

Glendora, CA 91740

Plaintiff In Pro Per

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

FOR THE COUNTY OF LOS ANGELES

 

OMAR ANAS,

                                  Plaintiff

                   v.

HENRICK MKRTCHYAN, and  ALICIA O’CONNOR

                                      Defendants

Case No.: 

 

 

    COMPLAINT

Plaintiff, OMAR ANAS, pro se, alleges the following on information and belief:

INTRODUCTION

  1. This case involves harassment that was occasioned against Plaintiff by the Defendants. The said harassment has caused Plaintiff significant harm and emotional distress, which necessitates Plaintiff’s need for relief. 

 

PARTIES

  1. Plaintiff OMAR ANAS is a California resident of address 1822 East Route 66 St. A458 Glendora, CA 91740. Plaintiff was a student of the West Coast University. 
  2. Defendant HENRICK MKRTCHYAN (hereinafter “Henrick”), of address [ENTER ADDRESS] was a student of the West Coast University.

. 4. Defendant ALICIA O’CONNOR (hereinafter “Alicia”), of address [ENTER ADDRESS] was a student of the West Coast University.

JURISDICTION AND VENUE

  1. This Court has personal jurisdiction over each of the Defendants pursuant to California Constitution, Article VI, section 10, and California Code of Civil Procedure section 410.10, in that upon Plaintiff’s information and belief, each Defendant resides in this State; and the Defendants’ violations of law alleged herein occurred, in whole or in part, in this state.
  2. The claims herein alleged in this Complaint occurred in Los Angeles City. Venue for this matter properly lies within Los Angeles County because the claims herein alleged in this Complaint occurred, in whole or in part, in Los Angeles County.

FACTS COMMON TO ALL CAUSES OF ACTION 

  1. Plaintiff was subjected to several incidences of harassment from the Defendants. 
  2. The first incidence happened when Plaintiff was in a classroom working on a group project with some of her classmates. Henrick bulged into the room upon which Plaintiff made a joke to wit “Say hi you your wife for me”. Upon this joke, Henrick angrily yelled at Plaintiff, forcing Plaintiff to run out of the classroom for her safety. At the hallway, Henrick kept hurling curses at Plaintiff but Plaintiff was silent. Henrick then caught up with Plaintiff on the hallway and placed his hands on Plaintiff’s shoulder, which hands Plaintiff quickly shrugged off in reflex. Henrick then clenched his fists and threatened Plaintiff by telling her “I am warning you.” Plaintiff reported the matter to the administration but no further action was taken.
  3. On another day, Plaintiff was having lunch at the lunch room. Henrick was also in the lunch room at that time. Henrick kept staring at Plaintiff and asked Plaintiff “you have something to say?”, to which Plaintiff responded in fear that she had nothing to say. Plaintiff then reported the matter at the administration and Henrick was given a warning. 
  4. On the third incidence of harassment, Plaintiff had entered class and was about to sit on her chair. Henrick kept staring at Plaintiff, and went to sit behind her. As Plaintiff was about to sit, Henrick pushed his laptop screen further such that Plaintiff’s backpack accidentally hit the said screen. Henrick then exploded in anger, about to get into an altercation with Plaintiff. It took the intervention of the classmates to prevent the fight that would have ensued. 
  5. On another occasion, Plaintiff was in class when Henrick got in and went straight to Plaintiff. He proceeded to whisper the following words in Plaintiff’s ears “Not to say stupid things.” Henrick did that to provoke Plaintiff. However, Plaintiff reported the matter at the student affairs and Henrick was given a warning. 
  6. Still on another occasion, Plaintiff and Henrick were in a class session. As Plaintiff was answering a question from the professor, Henrick whispered that the answer was offensive. Plaintiff reported the matter to the student affairs and Henrick was issued a warning. 

` 13. Plaintiff’s allegations against Alicia happened when Alicia and Plaintiff were working on a group project. Alicia became bossy and made demands without involving the group members. Notably, Alicia demanded that the group members report to school early in the morning, to which Plaintiff objected on the grounds that she would be attending to her sick and disabled father. Alicia refused to consider Plaintiff’s request and ended up removing Plaintiff from the group project. She also edited the power point presentation to remove Plaintiff’s work without Plaintiff’s knowledge.

  1. On the presentation day, Plaintiff was still oblivious of the fact that her work was removed from the presentation. The Professor pointed out notable flaws with the presentation, which flaws were covered by Plaintiff’s work (that were deleted).  The group ended up getting bad grades. Plaintiff reported the matter to the Professor who promised to look at it. 

` 15. On another incident, Plaintiff had taken off her sandals to make her feet comfortable. Alicia saw that and confronted Plaintiff to put on her sandals. It was Alicia’s contention that Plaintiff had violated the school rules by removing her sandals. Plaintiff had to confirm with the authorities whether she was violating any law, and she was informed that there was no such law. 

  1. On another incident, Plaintiff was in a group discussion. When Plaintiff made a suggestion, Alicia shouted that Plaintiff was not making sense and that she should be careful. Plaintiff reported the matter to the authorities. Plaintiff reported the matter to the student affairs but no further action was taken. In retaliation, Alicia falsely alleged that Plaintiff threatened her. Plaintiff was therefore subjected to the Conduct Committee and was sanctioned for a wrong she did not commit. 
  2. The said incidences of harassment dealt a heavy blow on Plaintiff’s life. Notably, Plaintiff was so distressed that she began failing her exams. She was an “A”s student but began getting “B”s and “C”s. Besides, they also affected Plaintiff’s Clinical rotation. Plaintiff did many mistakes in the clinical rotation. Plaintiff had nightmares and could not focus well without thoughts of Henrick’s conduct distressing her. See Plaintiff’s letter to Dr. Kyle Sousa. 
  3. Plaintiff has suffered severe mental and/or psychological distress that saw her being handed over to the County Mental Health Care providers. See Letter from Emmanuel Kuenzig. Clearly Plaintiff’s dream of being an outstanding pharmacist is at stake. 

FIRST CAUSE OF ACTION

Intentional Infliction of Emotional Distress

  1. The allegations set forth in paragraphs 1 through 18 are re-alleged and incorporated herein by reference. 
  2. The conducts of the Defendants as set forth above were extreme, and outrageous.
  3. Defendants ought to have reasonably known that their actions and/or inactions would cause severe harm on Plaintiff. 
  4. The Defendants filed to consider the adverse effects of their actions and/or inactions on Plaintiff. 
  5. As a result of the Defendants’ acts as alleged above, Plaintiff has gone through emotional distress. 

SECOND CAUSE OF ACTION

Civil Harassment

  1. The allegations set forth in paragraphs 1 through 23 are re-alleged and incorporated herein by reference.
  2. The foregoing shows how the Defendants committed unlawful violence on Plaintiff.
  3. The said Defendants’ actions amounted to a credible threat of violence. 
  4. The said violence was calculated to threaten, annoy, scare, and/or harass Plaintiff. Besides, there was no legitimate reason for the violence. 
  5. As a result of the Defendants’ acts as alleged above, Plaintiff has gone through emotional distress.

THIRD  CAUSE OF ACTION

Declaratory Relief

  1. Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
  2. There now exists, between the parties hereto, a dispute and controversy to which the Plaintiff and the Defendants are entitled to have a declaration of their rights and further relief relating to the facts and circumstances as set forth in this action.
  3. Plaintiff respectfully request this Honorable Court issue a declaratory judgment declaring that the actions and/or inactions of the Defendants violate the rights of Plaintiff, and issue appropriate remedies thereof.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant:

  1. An order and judgment for compensatory damages against all Defendants on all counts herein, in an amount to be determined by this Honorable Court,
  2. That the Court grants Declaratory Order against Defendants for their actions and/or inactions alleged herein. 
  3. Any such other relief, as this Court deems just and equitable.

 

DECLARATION

Executed this _____ day of May 2021 at ______, California, I declare under penalty of perjury that the foregoing is true and correct.  For all the foregoing reasons, Plaintiff respectfully requests that the Court grant all requested relief in Plaintiff’s prayers above. 

DATED: 

 

                                                           

 

CERTIFICATE OF SERVICE

I hereby certify that on [ENTER DATE], copies of the foregoing document have been sent to the Defendants in the following addresses:

 

DATED:     

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