STEPHEN LORENZO LAW OFFICES, P.A. W. StephenthLorenzo, Esq. (SBN 110869) 2630 SW 28 St.

, #14 Miami, FL 33133 Phone: (310) 210-0912 Fax: (305) 397-0960 Attorney for Plaintiff ULISES SOLIS

SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES CENTRAL DISTRICT
ULISES SOLIS, an individual ) ) Plaintiff, ) ) v. ) ) SAUL CANELO ALVAREZ, an individual; and ) DOES 1 through 100, Inclusive, ) ) Defendants. ) __________________________________________) Case. No. (Unlimited Civil Case) COMPLAINT FOR DAMAGES: 1. 2. 3. OF 4. ASSULT; BATTERY; INTENTIONAL INFLICTION EMOTIONAL DISTRESS; AND NEGLIGENCE

GENERAL ALLEGATIONS
1. At all times mentioned herein, Plaintiff ULISES SOLIS

(hereinafter the SOLIS and/or Plaintiff) was, and now is, an individual and a resident of Jalisco, Mexico. 2. At all times mentioned herein, Defendant SAUL CANELO

ALVAREZ (hereinafter ALVAREZ), was, and now is an individual and a resident of the County of Los Angeles, State of California, and within the jurisdiction of this Court. 3. The true name of capacities, whether individual, corporate,

associate, or otherwise, of the Defendants DOES 1 through 100 are unknown to Plaintiff at this time, who therefore sues such Defendants by such fictitious names, and will amend this Complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes, and thereon alleges, that each of said fictitiously named

Defendants is responsible for the occurrences herein alleged, and that Plaintiffs injuries, as herein alleged, were proximately caused by said Defendants. 4. Plaintiff is informed and believes and thereon alleges that

at all times herein mentioned each of the Defendants sued herein as DOE were the agents, servants, employees or employers of their Co-Defendant, and in doing the things hereinafter alleged, were acting in the course and scope of their authority as such agents, servants, employees or employers and with the permission and consent of their Co-Defendants.

FIRST CAUSE OF ACTION (FOR ASSAULT) (AGAINST DEFENDANT SAUL CANELO ALVAREZ, AND DOES 1 THROUGH 100, INCLUSIVE)
5. Plaintiff refers to the whole of the General Allegations,

and by reference incorporates the same herein as if set forth in full hereafter. 6. On or about October 25, 2011, on a street in Guadalajara

Mexico, Defendant, SAUL CANELO ALVAREZ, and DOES 1 through 100, intentionally, willfully, wantonly and maliciously threatened to strike Plaintiff and did raise his fist in such a manner so as to cause Plaintiff to reasonably believe he was about to be struck in a harmful and offensive manner. Due to Defendants threatening words violence

towards Plaintiff, including, but not limited to, the Plaintiff being 108 lbs and 53 tall and the Defendant being 59, 160 lbs, and a World Boxing Champion, a reasonable person in Plaintiffs situation would have been offended by the threatened, violent touching. 7. At no time during the events described in the preceding

paragraph, nor at any time prior thereto, did Plaintiff consent to any of Defendants, and DOES 1 through 100, threatened conduct. 8. As a direct and proximate result of Defendants, and DOES 1

through 100 threats, coupled with their present ability to carry them out, Plaintiff felt the imminent apprehension of such contact, and he

therefore suffered severe emotional distress and other injuries to his person, in an amount to be shown according to proof. 9. As a direct, legal and proximate result of the actions of

Defendants, and DOES 1 through 100, Plaintiff sustained serious and permanent injuries to his person, all to his damage in an amount to be shown according to proof and within the jurisdiction of the Superior Court. 10. As a direct, legal and proximate result of such acts of

Defendants, and DOES 1 through 100, Plaintiff compelled to and did employ the services of hospitals, physicians and surgeons, nurses, and the like, to care for and treat him, and did incur hospital, medical, professional and incidental expenses, and Plaintiff is informed and believes, and upon such information and belief alleges, that he will necessarily by reason, of his injuries, incur additional like expenses for an indefinite period of time in the future, all to Plaintiffs damage in a sum to be shown according to proof. 11. Plaintiff is informed and believes and alleges thereon that

such acts directed towards the Plaintiff were malicious and belligerent, and the acts were done with a conscious disregard of Plaintiffs right to be free from such tortious and criminal behavior, such as to constitute oppression, fraud or malice pursuant to California Civil Code 3294, entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of said Defendants and DOES 1 through 100. 12. Plaintiff, at the time of the incident, was the IBF World

Boxing Champion. He was stripped of his title because he could not defend it, because of his broken jaw denying him the medical clearance and ability to defend his championship title. In addition to Plaintiff being stripped of his title, he has been denied the physical ability to box in the future; despite one attempt to do so.

SECOND CAUSE OF ACTION (FOR BATTERY) (AGAINST DEFENDANT SAUL CANELO ALVAREZ,

AND DOES 1 THROUGH 100, INCLUSIVE)

13. Plaintiff refers to the whole of the General Allegations, as

well as the whole of the First Cause of Action, and by reference incorporates the same herein as if set forth in full hereat. 14. On or about October 25, 2011, Defendants, and DOES 1 through

100, intentionally and recklessly did acts which resulted in offensive contact with the Plaintiffs person, including but not limited to: punching and hitting Plaintiff in the face, knocking out a tooth, and fracturing his jaw. 15. Defendants, and DOES 1 through 100, did such acts with the

intent to cause a harmful or offensive contact with the body of Plaintiff. 16. As a direct, legal and proximate result of such acts of

Defendants, and DOES 1 through 100, Plaintiff sustained serious and permanent injuries to his person, all to him damage in an amount to be shown according to proof and within the jurisdiction of the Superior Court. 17. As a direct, legal and proximate result of such acts of

Defendants, and DOES 1 through 100, Plaintiff was compelled to and did employ the services of hospitals, physicians and surgeons, nurses, and the like, to care for and treat him, and did incur hospital, medical, professional and incidental expenses, and Plaintiff is informed and believes, and upon such information and belief alleges, that he will necessarily by reason of his injuries, incur additional like expenses for an indefinite period of time in the future, all to Plaintiffs damage in a sum to be shown according to proof. 18. Plaintiff is informed and believes that such acts directed

towards Plaintiff were malicious, and belligerent, and the acts were done with a conscious disregard of Plaintiffs right to be free from such tortious and criminal behavior, such as to constitute oppression, fraud or malice pursuant to California Civil Code 3294, entitling

Plaintiff to punitive damages in an amount appropriate to punish and set an example of said Defendants and DOES 1 through 100.

THIRD CAUSE OF ACTION (FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS) (AGAINST DEFENDANT SAUL CANELO ALVAREZ, AND DOES 1 THROUGH 100, INCLUSIVE)
19. Plaintiff refers to the whole of the General Allegations, as

well as the whole of the First and Second Causes of Action, and by reference incorporates the same herein as if set forth in full hereat. 20. Plaintiff is informed and believes, and thereon alleges,

that such acts of Defendants, and DOES 1 through 100, were intentional, extreme, and outrageous. Plaintiff is further informed and believes, and thereon alleges, that such actions were done with the intent to cause serious emotional distress or with reckless disregard of the probability of causing Plaintiff serious emotional distress. 21. As a direct, legal and proximate result of such acts of

Defendants, and DOES 1 through 100, Plaintiff suffered severe emotional distress which has caused Plaintiff to sustain severe, serious and permanent injuries to his person, all to his damage in a sum to be shown according to proof and within the jurisdiction of the Superior Court. 22. As a direct, legal, and proximate result of such acts of

Defendants, and DOES 1 through 100, Plaintiff was compelled to and did employ the services of hospitals, physicians and surgeons, nurses, and the like, to care for the treat him, and did incur hospital, medical, professional and incidental expenses. 23. Plaintiff is informed and believes, and upon such

information and belief alleges, that he will necessarily by reason of his injuries, incur additional like expenses for an indefinite period of time in the future, all to Plaintiffs damage in a sum to be shown according to proof. 24. Plaintiff is informed and believes that such acts directed

towards Plaintiff were carried out with a conscious disregard of

Plaintiffs right to be free from such tortious and criminal behavior, such as to constitute oppression, fraud or malice pursuant to California Civil Code 3294, entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of said Defendants and DOES 1 through 100.

FORTH CAUSE OF ACTION (FOR NEGLIGENCE) (AGAINST DEFENDANT SAUL CANELO ALVAREZ, AND DOES 1 THROUGH 100, INCLUSIVE)
25. Plaintiff refers to the whole of the General Allegations, as

well as the whole of the First and Second Causes of Action, and by reference incorporates the same herein as if set forth in full hereat. 26. On or about October 25, 2011, Defendant negligently,

carelessly, recklessly, and wantonly caused injury to Plaintiff in that among other things: Defendant conducted himself in such a manner that SAUL CANELO ALVAREZs body contacted Plaintiffs person in a forceful and harmful manner. 27. As a direct and proximate result of the negligence,

carelessness, recklessness, wantonness and unlawfulness of Defendants, and each of them, Plaintiff sustained severe and serious injury to his person, all to Plaintiffs damage in a sum within the jurisdiction of this Court and to be shown according to proof. 28. By reason of the foregoing, Plaintiff has been required to

employ the services of hospitals, physicians, surgeons, nurses and other professional services, and Plaintiff has been compelled to incur expenses for machines, x-rays, and other medical supplies and services.

Plaintiff is informed and believes, and thereon alleges, that further services of said nature will be required by Plaintiff in an amount to be shown according to proof.

WHEREFORE, Plaintiff prays judgment against Defendants as follows:

ON THE FIRST CAUSE OF ACTION

(1) (2) For General damages in an amount subject to proof at trial; For sums incurred and to be incurred for services to hospitals, physicians, surgeons, nurses and other professional services, x-rays and other medical supplies and services; (3) For punitive and exemplary damages as the Court may determine; (4) For interest provided by law including, but not limited to, California Civil Code 3291; (5) For economic damages for loss of income and future economic loss;

ON THE SECOND CAUSE OF ACTION

(6) (7) For General damages in an amount subject to proof at trial; For sums incurred and to be incurred for services to hospitals, physicians, surgeons, nurses and other professional services, x-rays and other medical supplies and services; (8) For punitive and exemplary damages as the Court may determine; (9) For interest provided by law including, but not limited to, California Civil Code 3291;

(10)

For economic damages for loss of income and future economic loss;

ON THE THIRD CAUSE OF ACTION

(11) (12) For General damages in an amount subject to proof at trial; For sums incurred and to be incurred for services to hospitals, physicians, surgeons, nurses and other professional services, x-rays and other medical supplies and services; (13) For punitive and exemplary damages as the Court may determine; (14) For interest provided by law including, but not limited to, California Civil Code 3291; (15) For economic damages for loss of income and future economic loss;

ON THE FOURTH CAUSE OF ACTION

(16) (17) For General damages in an amount subject to proof at trial; For sums incurred and to be incurred for services to hospitals, physicians, surgeons, nurses and other professional services, x-rays and other medical supplies and services; (18) For punitive and exemplary damages as the Court may determine; (19) For interest provided by law including, but not limited to, California Civil Code 3291; (20) For economic damages for loss of income and future economic loss;

ON ALL CAUSES OF ACTION

(21) (22) (23) For costs of suit herein incurred; For attorneys fees; and For such other and further relief as the Court may deem just and proper.

Date: Respectfully Submitted, Attorney for Plaintiffs Stephen Lorenzo Law Offices, P.A. 2630 SW 28th ST. Suite 14 Miami, FL 33133 Phone: (310) 210-0912 Fax: (305) 397-0960

by:________________________________ W. STEPHEN LORENZO, ESQ. CA Bar No.: 110869