CAUSE NO. __

SASCHA BARROS
Plaintiff

v.

ANDY BIGGS
Defendant

IN THE DISTRICT COURT
BERNALILLO COUNTY, NEW MEXICO
__ JUDICIAL DISTRICT

PLAINTIFF’S ORIGINAL COMPLAINT

TO THE HONORABLE JUDGE:

Plaintiff Sascha Barros (also known as William Sasha Riley) complains of Defendant Andy Biggs and respectfully shows the Court as follows:

I. PARTIES
1. Plaintiff Sascha Barros is an adult resident of the United States who was a minor child (approximately 11–12 years old) at the time of the events giving rise to this action.
2. Defendant Andy Biggs, in 1984, was a mid-20s final-year law student at the University of Arizona who was transitioning to New Mexico and becoming a newly licensed attorney. He is subject to personal jurisdiction in New Mexico because the intentional torts alleged below occurred in New Mexico.

II. JURISDICTION AND VENUE
3. This Court has subject-matter jurisdiction because the amount in controversy exceeds the minimum jurisdictional limit of the district court.
4. Venue is proper in Bernalillo County, New Mexico, because a substantial part of the events giving rise to the claim occurred in New Mexico. NMSA 1978 § 38-3-1.

III. FACTS
5. In 1984, in New Mexico, Defendant Andy Biggs subjected Plaintiff, then an 11- or 12-year-old child, to a brutal, retaliatory physical and sexual assault. This was a single, standalone incident that occurred approximately one to two weeks (or up to a month) after an earlier event at “the farm.”
6. Defendant personally beat Plaintiff without mercy until multiple ribs were broken. Plaintiff turned blue, began convulsing, and his chest produced a continuous “clicking” sound with every attempted breath — a sound Plaintiff and others have described as a death rattle. Defendant continued the beating even after Plaintiff could no longer breathe normally.
7. Plaintiff’s adoptive father was present and argued with Defendant, stating in substance: “You said I could do whatever I wanted” versus “I didn’t say you could kill him.” The beating was so severe that Defendant’s own actions prompted this direct confrontation.
8. After the assault, Plaintiff’s father later told him that “the debt” owed because Plaintiff had earlier fought back against another perpetrator was now considered paid. No further parties or assaults of this nature occurred afterward.
9. A child of 11 or 12 years old should never have been placed in any such position; the entire situation was inherently unfair, exploitative, and illegal.
10. As a direct and proximate result of Defendant’s assault, Plaintiff suffered:
- severe physical injuries (multiple broken ribs, extensive bruising, respiratory trauma, and permanent rib-cage deformity);
- profound and lifelong psychological injuries (complex post-traumatic stress disorder, dissociative symptoms, chronic hypervigilance, and major depressive episodes directly traceable to this beating);
- permanent emotional distress and loss of capacity to form trusting intimate relationships;
- past and future medical and psychological treatment expenses.
11. Defendant’s conduct was intentional, malicious, and carried out with conscious indifference to the rights, safety, and severe suffering of a child victim.

IV. CAUSES OF ACTION

Count 1 – Battery
Defendant intentionally caused harmful and offensive physical contact to Plaintiff through repeated, rib-breaking blows that continued after Plaintiff was convulsing and unable to breathe normally.

Count 2 – Assault
Defendant placed Plaintiff in reasonable apprehension of imminent harmful or offensive contact and then carried out that contact.

Count 3 – Intentional Infliction of Emotional Distress
Defendant’s extreme and outrageous conduct — the savage, near-fatal beating of an 11- or 12-year-old child — was calculated to humiliate, terrorize, and destroy Plaintiff and caused severe emotional distress that no reasonable person in civilized society should be expected to endure.

Count 4 – Childhood Sexual Abuse / Assault (NMSA 1978 § 37-1-30)
The assault occurred in the context of a pattern of child sexual exploitation; the physical torture was inflicted as punishment and retaliation within that exploitative framework.

V. DAMAGES
Plaintiff seeks:
• Actual (compensatory) damages for past and future physical pain and suffering, mental anguish, medical and psychological treatment expenses, loss of earning capacity, and physical impairment;
• Exemplary (punitive) damages because Defendant’s conduct was intentional, malicious, and demonstrated conscious indifference to the rights and welfare of a child;
• Prejudgment and post-judgment interest at the maximum rate allowed by law;
• Costs of court; and
• Such other and further relief to which Plaintiff may show himself entitled.

VI. STATUTE OF LIMITATIONS
Plaintiff’s claims are timely pursuant to NMSA 1978 § 37-1-30 and subsequent amendments and judicial interpretations that extend or revive the limitations period for civil actions arising from childhood sexual abuse and related physical torture. The profound trauma and Defendant’s position of adult authority rendered timely filing impracticable until recent years.

PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff Sascha Barros prays that Defendant Andy Biggs be cited to appear and answer herein, and that upon final trial or other disposition Plaintiff recover judgment against Defendant for actual damages, exemplary damages, interest, court costs, and all other relief, both general and special, at law or in equity, to which Plaintiff may be justly entitled.

Respectfully submitted,

ATTORNEY FOR PLAINTIFF