CAUSE NO. __

SASCHA BARROS
Plaintiff

v.

JAMES DANIEL JORDAN
Defendant

IN THE DISTRICT COURT
TARRANT COUNTY, TEXAS
__ JUDICIAL DISTRICT

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE:

Plaintiff Sascha Barros (also known as William Sasha Riley) complains of Defendant James Daniel Jordan 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 (approximately 11–12 years old) at the time of the events giving rise to this action.
2. Defendant James Daniel Jordan is an individual who, in 1986, was a championship wrestler from Ohio actively traveling the country for wrestling competitions, exhibitions, and related events. His travels brought him to Texas, where he participated in the tortious acts described below at Southfork Ranch. He is subject to personal jurisdiction in Texas because the intentional torts alleged occurred in Texas.

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 Tarrant County, Texas, because a substantial part of the events or omissions giving rise to the claim occurred at Southfork Ranch, Texas. Texas Civil Practice & Remedies Code § 15.002.

III. FACTS
5. In 1986, at Southfork Ranch in Texas (referred to in Plaintiff’s childhood memory as “The Farm”), Defendant James Daniel Jordan subjected Plaintiff, then a minor child, to violent sexual assault and severe physical battery.
6. Defendant, a championship wrestler from Ohio who was traveling the country for wrestling competitions and exhibitions (including events that took him to the Dallas-Fort Worth area in 1986), used his superior wrestling skills and techniques to overpower Plaintiff in front of a crowd of approximately 25–50 adults. The event was structured by adults such that any adult who could pin Plaintiff could then do whatever he wanted to him. 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.
7. Defendant rushed Plaintiff, executed a wrestling tackle, and pinned him using championship-level wrestling moves. Plaintiff, a small child with no realistic ability to defend himself against an adult champion wrestler, was completely overpowered and immobilized. Defendant then subjected Plaintiff to anal rape without consent while continuing to apply wrestling holds and restraints.
8. Defendant performed these acts in a deliberate, show-off manner before the assembled crowd, visibly demonstrating his athletic dominance and wrestling prowess. The sexual assault was accompanied by repeated, brutal physical blows to Plaintiff’s head and body during and immediately after the rape.
9. At the conclusion of the assaults by Defendant and others in the group, Plaintiff was hosed down with a garden hose in full view of the crowd and Defendant. One assailant threw a bar of soap at Plaintiff’s head, striking him, while the group—including Defendant—laughed. Defendant was present for, participated in, or acquiesced to this additional humiliating and degrading treatment.
10. As a direct and proximate result of Defendant’s sexual assault, battery, and participation in the degrading post-assault treatment, Plaintiff suffered:
- severe physical injuries (including head trauma, extensive bruising, temporary impairment of motor coordination, and lasting rib-cage deformity);
- profound and lifelong psychological injuries (complex post-traumatic stress disorder, dissociative symptoms, chronic hypervigilance, and major depressive episodes directly traceable to the event);
- permanent emotional distress and loss of capacity to form trusting intimate relationships;
- medical and psychological treatment expenses (past and future).
11. Defendant’s conduct was intentional, malicious, and carried out with conscious indifference to the rights, safety, and severe suffering of a child victim. The entire encounter was fundamentally unfair and illegal; no 11- or 12-year-old child should ever have been forced into such a situation.

IV. CAUSES OF ACTION

Count 1 – Sexual Assault of a Child (Texas Civil Practice & Remedies Code § 16.0045 & common-law sexual assault)
Defendant intentionally and knowingly caused sexual penetration of Plaintiff, a child, without consent, using wrestling holds and restraints to overpower and immobilize him.

Count 2 – Battery
Defendant intentionally caused harmful and offensive physical contact to Plaintiff through wrestling tackles, pins, repeated beatings, blows to the head and body, and participation in the garden-hose humiliation.

Count 3 – Intentional Infliction of Emotional Distress
Defendant’s extreme and outrageous conduct—using championship wrestling moves to publicly overpower, rape, and beat a child in front of a crowd, followed by public degradation—was calculated to humiliate and destroy Plaintiff and caused severe emotional distress that no reasonable person in civilized society should be expected to endure.

Count 4 – Negligent Infliction of Emotional Distress (in the alternative)
To the extent any portion of Defendant’s conduct is characterized as negligent rather than intentional, it foreseeably caused severe emotional harm to Plaintiff.

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 Texas Civil Practice & Remedies Code § 16.0045 and subsequent amendments that extend the limitations period for civil actions arising from sexual assault of a child. The nature and severity of the trauma, combined with Defendant’s position of adult authority and athletic dominance over a minor, rendered timely filing impracticable until recent years.

PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiff Sascha Barros prays that Defendant James Daniel Jordan 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