} do der BierDP ‘Beunty of San Francisco Troy King P.O BOX 47 Fop Antioch, cA oct 01 Telephone: GS *684- 2637 CLERK OF TE COURT IN PRO PER i A ch, em Oa SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCSICO UNLIMITED JURISDICTION Case No. EGC-20-587 138 TROY KING 1, NEGLIGENCE 2. NEGLIGENT INFLICTION OF y Plaintiffs, EMOTIONAL DISTRESS 3. INVASION OF PRIVACY SAN FRANCISCO PUBLIC LIBRARY; ) 3yRY TRIAL DEMAND CITY & COUNTY OF SAN FRANCISCO; URBAN ALCHEMY; STEVEN D. an individual Defendants, Plaintiff, Troy King, complains of Defendants San Francisco Public Library, City & County of San Francisco, Urban Alchemy, Steven D., an individual, pleading hypothetically and in the alternative, states as follows: GENERAL ALLEGATIONS 1. Atal times relevant times herein, Plaintiff Troy King was a resident of San Francisco Ca and is currently a resident of Antioch Ca. 2. Atall times relevant Defendant San Francisco Public Library (hereinafter “SFPL”) is an entity of the City and County of San Francisco, with its principal place of business at 100 Larkin St, San Francisco, CA 94102. + SEBLa7 18 as 20 aa 22 23 24 25 26 2 28 3. At all times relevant Defendant City and County of San Francisco (hereinafter “CCSF”) owned, operated, controlled, maintained, managed, supervised SFPL 4. At all times relevant Defendant Urban Alchemy (hereinafter “UA") is a California Corporation, with its principal place of business at 72 6th St., San Francisco CA 94103. 5. At all relevant times herein, Defendant Steven D. ("Steven") was an employee/agent of Urban Alchemy as a bathroom monitor. 6. At all times relevant herein, Defendants SFPL and UA were the agents and/or joint ventures of CCSF and each other, and at all times relevant herein were, as such, acting within the course, scope, and the authority of such said agency and/or venture, and that CCSF when acting as a principal, was negligent in the selection, hiring, training, and supervision of each and every other Defendant as an agent and/or venturer. re At all times relevant herein, Plaintiff Troy King is a member of the SFPL and used their computers and copiers to complete his school activities. As a result, Plaintiff used the restrooms on a regular basis with an expectation of privacy. 8. On November 9, 2019, Plaintiff was using the restroom at SFPL on the Ast floor, while undressed and bent over trying to get the toilet dispenser to work properly, Plaintiff felt someone watching him. As Plaintiff turns around, he sees the Defendant Steven watching him. Plaintiff asked the Defendant Steven " What are you doing." Defendant Steven replied "It is his job to look in on persons using SFPL restrooms. 9. Plaintiff, thereafter, washing his hands, asked Defendant Steven to speak with his supervisor. UA supervisor Charmain spoke with Plaintiff and Defendant, and she told the Defendant Steven he must 2 KING v. SEPL24 25 26 a 28 follow company policy by knocking on the door first, and if there is no response then look in. 10. The unknowing and unwelcome violation of Plaintiff's privacy while undressed using SFPL restrooms caused Plaintiff a great deal of emotional distress. COUNT 1 (NEGLIGENCE AS AGAINST SFPL, UA, CCSF, and Steven) 11. Plaintiff realleges as though fully set forth at length, and incorporated herein by reference, all of the allegations and statement in paragraphs -- to --of General Allegations above, inclusive. 12, Defendant Steven had a duty to exercise reasonable and ordinary care with respect to guests, and persons like Plaintiff Troy king. 13. Defendant Steven was negligent in his acts and/or omissions by, amongst other things, negligently engaging in acts as set forth above, that Defendant Steven knew, or should have known, would cause harm to Plaintiff. 14. Defendant CCSF, individually, and by and through its agents and/or joint ventures, Defendant SFPL and/or UA, had a duty to exercise reasonable and ordinary care and caution in and about the management, maintenance, supervision, control, and operation of SFPL and each of its employees, agents, servants, and independent contractors, all to the benefit of guests, patrons, and persons like Plaintiff Troy King. 15. Defendants SFPL, and CCSF by and through their agents, employees, servants, and/or independent contractors, were negligent in their acts and/or omissions by, failing to discover that Defendant Steven would peep in on Plaintiff while he was undressed, possible allowing Defendant possible videotape or take pictures of them.2 16. As a direct and proximate result of the above-said conduct of 2 || Defendants SFPL, CCSF, and/or UA, Plaintiff has suffered and continues to suffer from, including but not limited to severe and permanent emotional 4 || distress, and embarrassment relating from the unauthorized viewing of ® || Plaintiff personal parts. 6 Count 2 7 || NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AS AGAINST SFPL, 8 CCSF, AND UA) a 17. Plaintiff realleges as though fully set forth at length, and 1° || incorporated herein by reference, all of the allegations and statement in + || paragraphs 1 to 16 of this complaint, inclusive. 2 18. Defendant CCSF, individually, and by and through its agents +? || and/or joint ventures, Defendant SFPL and/or UA, had a duty to exercise +4 |! reasonable and ordinary care and caution in and about the management, 15 |/ maintenance, supervision, control, and operation of SFPL and each of its *6 || employees, agents, servants, and independent contractors, all to the benefit +" || of guests, patrons, and persons like Plaintiff Troy King. re 19. Defendants SFPL, and CCSF by and through their agents, employees, servants, and/or independent contractors, were negligent in °° |! their acts and/or omissions by, failing to discover that Defendant Steven 71 || would peep in on Plaintiff while he was undressed, possible allowing * |! Defendant possible videotape or take pictures of them. a 20. Asa direct and proximate result of the above-said conduct of ** || Defendants SFPL, CCSF, and/or UA, Plaintiff has suffered and continues to * |! suffer from, including but not limited to severe and permanent emotional 26 distress, and embarrassment relating from the unauthorized viewing of Plaintiff personal parts. 28 4 KING v.20 an 22 23 24 26 2 28 COUNT 3 INVASION OF PRIVACY-INTRUSION OF SECLUSION AS AGAINST STEVEN 21. Plaintiff realleges as though fully set at length, and incorporates herein by reference, all of the allegation and statements contained in 1 through 20 of this complaint, inclusive. 22. The acts of the Defendant, set forth above, including but not limited to peeping into Plaintiff bathroom stall possibly taking unauthorized video recordings and/or taking pictures, were unauthorized intrusion into Plaintiff's seclusion. 23. The intrusion by Defendant Steven were and are objectionable and offensive to a reasonable person, including Plaintiff. 24. As set forth above, the intrusion by Steven, were at the SFPL restroom, while Plaintiff was undressed, and when he had the greatest expectation of privacy. 25. Asa direct and proximate result of the intrusion of seclusion and invasion of privacy by Steven, Plaintiff Troy King has suffered and continues to suffer from, including but not limited to severe and permanent emotional distress and embarrassment relating to the unauthorized viewing of Plaintiff personal parts. Under California Code, Code of Civil Procedure section 631, Plaintiff demands trial by jury in this action of all issues KING v10 az aa 4 15 16 a 18 a9 24 25 26 2 28 PRAYER FOR DAMAGES. WHEREFORE, Plaintiff Troy King prays for judgement in his favor and against all the defendants, jointly and severally, in the sum of 10 MILLION AND NO/100, and any other damages this Court deems fair. Date: October 1, 2020 Troy‘ King In Pro Per|Troy King “— Ip. Box-777 Anoch, CA. O46 ‘ArToRNEYFOR ene! IN PRO PER Sepeity Sf Ban Foncsce [SUPERIOR COURT OF CALIFORNIA, COUNTY OF ‘SAN FRANCISCO omer soone88. 400 MeAliser Street oct 0 1Raa to ones |crry ano zie cone: San Francisco 94102 | CLERK OF YAE COURT vorune. San Francisco Superior es CASE NAME: OS ‘ANGE ‘Deputy Clerk Troy king v. SFPL, CCSF, Urban Alchemy, Steven D. an individual CIVIL CASE COVER SHEET ‘Complex Case Designation “eee 20-587 138 [32] Unlimited (5 Limitea [J counter J soinder Goan noun Filed with first appearance by defendant Somented Semandedis | “™'(Cal. Rules of Court, rule 3402) | pery exceeds $25,000) $25,000) " tate toms 1~6 below must Be Completed (see instructions on page 2) ‘case type that best describes this case: ‘Auto Tort Contract Provisionally Complex Givi Litigation Ato cay [Bese otcomacwarany 26) (Ea Res of Court res 3400-340) dninsured motorist 46) (Rue 3740 cotectins (09) TE Antrstrrate regeation ‘Other PUROID (Personal injury/Property F] Gther collections (09) (Construction aetect (10) aranetrongt Bea ot [instance coverage (18) Mass ton 40) EE] Pearkoan T,comrcounar on cement 0) ‘Reel Property -nvronmentaToxc (Metical mapracice (45) [eo] erhnart donsinwere | Instance coverage cas ring om he I onerPuP oD 23) Soneressn tt) i 'Non-PUPDIWD (Other) Tort 2 Wrongful eviction (33) Enoreeaint ot dudeinert Business truntar business practice (07) [—] Other real property (26) [J Envorcement of judgment (20) I on as) nwt Detain Miscalaneoue Ci Compan TS Detamaton (13) 2 Commerciat rice Frawa 16) (F) Reseencat 32 (Other complaint (not speciiod above) (42) intetiectual property (18) TJ Orgs (38) Miscolaneous Civil Petition TE Protessionai negigence (25) suse en) [1 Parmetship and corporate governance (21) [2] other non-PUPDIWD tort (35) (2) Asset forfeiture (05) ee eee Eaopaee [J Peition re: rbration award (11) —] Other petition not specied above) 43) J Wrong! termination (36) (5) wit ot mandate (02) otter employment (15) J otter jit review (30) 2 This case [—] is [=] isnot _ complex under rule 5 400 of the California Rules of Court Ifthe case is complex, mark the factors requiring exceptional judicial management: a. [] Large number of separately represented parties d. [—] Large number of witnesses b. [=] Extensive motion practice raising difficult or novel e. [—] Coordination with related actions pending in one or more issues that wil be tme-consuming to resolve courts in other counties, states, of counties, orn a federal e ‘Substantial amount of documentary evidence ‘court 7 {,_[) Substantial postjudgment judicial supervision 3. Remedies sought (check al hat apply. [3] monetary . [—-T nonmanetary; declaratory or injunctive relief c. [—] punitive 4. Number of cquses of action (specify): Negligence, Negigent infiion of Emotional Distress, invasion of Privacy 5. Thiscase [XJ is [J isnot a class action su 6. If there are dny known related cases, fle and serva a notice of related case, (You Date: October 1, 2020 Troy King NOTICE + Plaintif must file this cover sheet with the frst paper fied inthe action or proceeding (except small or cases fled Under the Probate Code, Family Code, or Welfare and institutions Cade) (Cal, Rules of Cour, rulé 3.220, Failure to file may result in sanctions + File this cover sheet in addition to any cover shest required by local court rule. J I this case is complex under rule 2.400 et seq. ofthe California Rules of Court, you must serve a copy of this cover sheet on al other partis tothe action or proceeding |+ Unless this is a colections cave under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes ‘heal Ganoter Caton CIVIL CASE COVER SHEET ene Sara out aren i290 ly