Electronically Filed

10/12/2021 4:11 PM
Steven D. Grierson
ACOM CLERK OF THE COURT
Bruce D. Tingey, Esq.
Nevada Bar No. 5151
Tingey Injury Law Firm
817 S. Main Street
Las Vegas, Nevada 89101
Telephone: (702) 333∙0000
Facsimile: (702) 333∙0001
bruce@tingeylawfirm.com
Attorney for Plaintiff

DISTRICT COURT
CLARK COUNTY, NEVADA

YANETH COROMOTO CASIQUE, Case No: A-21-842188-C

Dept No: IV
Plaintiff,
vs.
LAS VEGAS RAIDERS FOOTBALL L.L.C., DAMON
ARNETTE and DOES II through X, inclusive,
Defendants.

AMENDED COMPLAINT
(Arbitration Exemption Claimed: Value in Excess of $50,000.00)
COMES NOW plaintiff Yaneth Coromoto Casique, by and through the attorney, Bruce D.
Tingey, Esq. of the Tingey Injury Law Firm, and for a cause of action against the defendants, and each
of them, for damages and injuries sustained on or about October 14, 2020, alleges, on information
and belief, as follows:
THE PARTIES
1. Plaintiff Yaneth Coromoto Casique is a resident of Clark County, Nevada.
2. Defendant Damon Arnette is a resident of Clark County, Nevada.
3. Defendant Las Vegas Raiders Football L.L.C. (hereinafter “Las Vegas Raiders”) is a
corporation or other business entity doing business in Clark County, Nevada.
4. The true names and capacities of defendants doe II through X, inclusive, are unknown
at this time. The plaintiff alleges that each of the defendants designated herein as doe defendant is
responsible in some manner for the damages as herein alleged, and is operating within the course and
scope of their duties or a relationship that will support a finding of joint and several liability.

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Case Number: A-21-842188-C
 5. More specifically, one or more fictitiously named doe defendants is the employer of
defendant Damon Arnette, identified herein as defendant Las Vegas Raiders Football L.L.C. and
referred to as defendant Las Vegas Raiders. If defendant Las Vegas Raiders Football L.L.C. is not the
correct identification of the employer of defendant Damon Arnette, then one or more fictitiously named
doe defendants will be identified once known.
THE FACTS
6. On or about October 14, 2020, in Clark County, Nevada, defendant Damon Arnette
operated a vehicle that collided with a vehicle operated by plaintiff Yaneth Coromoto Casique.
7. At all times relevant, defendant Damon Arnette was acting within the course and scope
of his employment with defendant Las Vegas Raiders.
8. More specifically, the collision--identified as an accident with a “hit and run”--occurred
at or about 7:29 a.m. on Wednesday, October 14, 2020 on eastbound St. Rose Parkway at or near the
intersection with northbound Bermuda Road in Henderson, Nevada.
9. At or about this time and location, plaintiff Yaneth Coromoto Casique was operating a
vehicle traveling northbound on Bermuda Road but was stopped or stopping her vehicle at the
intersection with St. Rose Parkway.
10. At or about this same time and location, defendant Damon Arnette was operating a
vehicle traveling eastbound on St. Rose Parkway in the #3 of 4 travel lanes approaching the
intersection with Bermuda Road. His friend, Jonathan Washington, was a passenger in his vehicle.
11. The collision occurred when defendant Damon Arnette failed to operate a vehicle with
due care. He was traveling eastbound on St. Rose Parkway at a high rate of speed to avoid being late
for a meeting he was to attend at Raiders Headquarters located on Raiders Drive, which is the next
intersection on eastbound St. Rose Parkway, after Bermuda Road. But defendant Damon Arnette
mistakenly believed Bermuda Road was Raiders Drive, so he executed a right turn from the #3 travel
lane, across the #4 or right travel lane to attempt a last second right turn. While traveling at a speed
of no less that 65 miles per hour, the wheels on his vehicle skidded and he lost control of his vehicle
when defendant Damon Arnette caused his vehicle to violently crash into the vehicle operated by
plaintiff Yaneth Coromoto Casique and causing damage to the vehicles involved, including as depicted:

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 Yaneth Coromoto Casique vehicle Damon Arnette vehicle
12. After the collision, defendant Damon Arnette illegally left the scene of the crash.
Jonathan Washington attempted to falsely claim he was the operator of the Damon Arnette vehicle.
Later defendant Damon Arnette was located and confronted at Raiders Headquarters when he
admitted he was the operator of the vehicle that was traveling at a high rate of speed when he lost
control of the vehicle and crashed into the vehicle operated by plaintiff Yaneth Coromoto Casique.
13. As a result of the collision, plaintiff Yaneth Coromoto Casique was injured and suffered
damages including special damages currently known to total $92,091.23 in medical bills or according
to proof, along with general damages of pain and suffering.
14. Plaintiff Yaneth Coromoto Casique was transported to the emergency room of Sunrise
Hospital where she was provided with emergency medical treatment. After being released, she has
continued with treatment with multiple medical providers (including orthopedic, pain management
and neurologist) for injuries she sustained in the crash. When the crash occurred, she struck her
head on the side window and experienced a loss of consciousness, which developed into headaches,
balance impairment, memory loss, loss of concentration and related symptoms.. She had an injury to
her left shoulder, neck and back (middle and lower back) with debilitating arm pain. She developed
anxiety with depression and panic attacks that required treatment, medication and another emergency
room evaluation at a hospital. MRI findings were consistent with traumatic brain injury. She has had
multiple injections in an effort to alleviate pain she sustained in this crash. As a result of the crash,
such experienced pain and suffering.

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 CLAIMS FOR RELIEF
FIRST CAUSE OF ACTION: NEGLIGENCE
(Against defendant Damon Arnette)
15. The plaintiff incorporates herein by reference all allegations within this amended
complaint and further alleges as follows:
16. At all times relevant, defendant Damon Arnette owed a duty to the plaintiff, including a
duty of due care, but breached that duty when the defendant operated a vehicle in such a negligent,
reckless and careless manner so as to cause the collision described above.
17. Further, at all times relevant, defendant Damon Arnette violated the laws, statutes and
ordinances that govern within the state of Nevada, including traffic laws, such as:
NRS 484B.413(1): A driver shall not turn a vehicle from a direct course upon a highway unless
and until such movement can be made with reasonable safety….
NRS 484B.223(1): If a highway has two or more clearly marked lanes for traffic traveling in one
direction, vehicles must: (a) Be driven as nearly as practicable entirely within a single lane; and
(b) Not be moved from that lane until the driver has given the appropriate turn signal and
ascertained that such movement can be made with safety.
NRS 484B.603(1): [The driver of a vehicle on a highway has a] duty to decrease speed [of a
vehicle] as may be necessary to avoid colliding with any person [or] vehicle...on or entering a
highway in compliance with legal requirements and the duty of all persons to use due care.
NRS 484E.010(1): The driver of any vehicle involved in a crash on a highway...resulting in
bodily injury to...a person shall immediately stop his or her vehicle at the scene of the
crash...and shall forthwith return to and in every event shall remain at the scene of the crash
until the driver has fulfilled [all legal] requirements….
The plaintiff belonged to the class of persons the laws, statutes and ordinances were designed to
protect. The defendant's violations of the laws, statutes and ordinances constitute negligence per se.
18. As a proximate cause of the negligence of defendant Damon Arnette, the plaintiff was
injured and damaged in a manner as alleged herein.
SECOND CAUSE OF ACTION: NEGLIGENCE (RESPONDEAT SUPERIOR)
(Against defendant Las Vegas Raiders)
19. The plaintiff incorporates herein by reference all allegations within this amended
complaint and further alleges as follows:
20. At all times relevant, defendant Damon Arnette was acting within the course and scope
of employment with defendant Las Vegas Raiders.

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 21. As such, defendant Las Vegas Raiders is legally responsible (vicariously liable) for the
negligent conduct of defendant Damon Arnette as alleged herein.
22. As alleged herein, defendant Damon Arnette operated a vehicle in such a negligent,
reckless and careless manner so as to cause it to collide into a vehicle operated by the plaintiff.
23. As a proximate cause of the negligence of defendant Damon Arnette, which is imputed
to defendant Las Vegas Raiders, the plaintiff was injured and damaged in a manner as alleged herein.

CAUSATION AND DAMAGES

24. The plaintiff incorporates herein by reference all allegations within this complaint and
further alleges as follows:
25. As a direct and proximate result of all the foregoing, the plaintiff was injured in and
about the spine, body, limbs, organs and systems, and otherwise injured and caused to suffer great
pain of body and mind, and some or all of the same are permanent and disabling conditions, all for the
plaintiff's past and future general damages in excess of $15,000.00.
26. As a further direct and proximate result of all the foregoing, the plaintiff was caused
and will be caused to expend monies for medical care and expenses incidental thereto, in an amount
according to proof.
27. As a further direct and proximate result of all the foregoing, the plaintiff was caused
and will be caused to suffer a loss of income and an impairment of earning capacity, in an amount
according to proof.
28. As a further direct and proximate result of all the foregoing, the plaintiff has suffered
damages related to the property damage of a vehicle, including repairs, towing expenses, storage
expenses, loss of use, a property damage deductible, rental costs, loss of value and other incidental
damages, in an amount according to proof.
29. The plaintiff has been required to hire an attorney to prosecute this action and thus
entitled to reasonable attorney fees and cost of suit.

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 PRAYER FOR RELIEF
WHEREFORE, the plaintiff prays judgment against the defendants, and each of them, jointly
and severally, as follows:
1. General damages in excess of $15,000.00;
2. Damages for medical expenses in an amount according to proof;
3. Damages for loss of income in an amount according to proof;
4. Damages for property damage-related claims in an amount according to proof;
5. Reasonable attorney's fees and cost of suit; and
6. Any further relief which the court may deem just and proper in the premises.
Dated this 12th day of October 2021.
Tingey Injury Law Firm

_________________________
Bruce D. Tingey, Esq.
817 S. Main Street
Las Vegas, Nevada 89101
Attorney for Plaintiff