CAUSE NO. _redacted, 50_


SASCHA BARROS
Plaintiff


v.


DONALD J. TRUMP
Defendant


IN THE DISTRICT COURT
TARRANT COUNTY, TEXAS
_redacted, 100_ JUDICIAL DISTRICT


PLAINTIFF’S ORIGINAL PETITION


TO THE HONORABLE JUDGE:


Plaintiff Sascha Barros (also known as William Sasha Riley) complains of Defendant Donald J. Trump 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 11–13 years old) at all times relevant to this action.
2. Defendant Donald J. Trump is an individual who, during 1984–1987, maintained business and political connections in Texas, including documented campaign contributions to the 1984 presidential election cycle. He is subject to personal jurisdiction in Texas because the tortious acts alleged below occurred at Southfork Ranch 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 giving rise to this claim occurred at Southfork Ranch, Texas (a location Defendant visited in connection with his Texas business and political activities in 1984–1987). Texas Civil Practice & Remedies Code § 15.002.


III. FACTS
5. Between 1984 and 1987, at Southfork Ranch in Texas, Defendant Donald J. Trump subjected Plaintiff, then a minor, to repeated sexual assaults and physical torture.
6. On the occasion giving rise to the most severe injuries, Defendant and several other adults forced Plaintiff and another minor female victim, Patricia, into a private room at Southfork Ranch. Defendant and the group sexually assaulted and tortured Patricia in Plaintiff’s presence while holding Plaintiff at gunpoint.
7. After the assault on Patricia, Defendant and the group murdered Patricia by shooting her in the head in front of Plaintiff. Defendant and/or members of the group then explicitly told Plaintiff that the same fate awaited him if he did not comply with every demand made by the next person who entered the room.
8. Immediately thereafter, Defendant entered the room alone with Plaintiff. Defendant demanded that Plaintiff engage in anal sex with him and subjected Plaintiff to further sexual assault and physical degradation.
9. Plaintiff, believing he would be killed regardless of compliance—having just witnessed Patricia’s murder and having been threatened with the same outcome—seized a wooden tent peg that was present in the room, placed a condom over it as a makeshift barrier, forcefully inserted it into Defendant’s anus, and then kicked it as hard as possible. This action caused Defendant to sustain a severe internal injury, resulting in immediate, extreme pain, screaming, and the need for emergency medical evacuation (life-flight).
10. Plaintiff’s actions were a direct, instinctive response to the ongoing sexual assault and torture being inflicted upon him by Defendant, compounded by the fresh trauma of having just witnessed Patricia’s murder and received an explicit death threat tied to non-compliance. Plaintiff had been conditioned over years to believe that both compliance and resistance could lead to death; the counter-attack was Plaintiff’s desperate attempt to stop the assault and survive.
11. As a direct and proximate result of Defendant’s sexual assaults, physical torture, and the murder of Patricia carried out in Plaintiff’s presence under Defendant’s direction or participation, Plaintiff suffered severe physical injuries, lifelong psychological trauma (including complex PTSD), profound emotional distress, and other damages.
12. Defendant’s conduct was intentional, malicious, and committed with conscious indifference to Plaintiff’s rights and safety.


IV. CAUSES OF ACTION

Count 1 – Sexual Assault (Texas Civil Practice & Remedies Code § 16.0045 & common-law assault)
Defendant intentionally and knowingly subjected Plaintiff, a child, to sexual contact and penetration without consent on multiple occasions, including the final assault that immediately followed Patricia’s murder.

Count 2 – Battery
Defendant’s unwanted sexual touching and physical torture constituted harmful and offensive contact.

Count 3 – Intentional Infliction of Emotional Distress
Defendant’s extreme and outrageous conduct—repeated sexual assaults and torture of a child, combined with forcing Plaintiff to witness the murder of another child victim (Patricia) and then threatening Plaintiff with the same fate—caused Plaintiff severe emotional distress that no reasonable person could be expected to endure.

Count 4 – Negligent Infliction of Emotional Distress (in the alternative)
To the extent any aspect of Defendant’s conduct is deemed negligent rather than intentional, it still caused foreseeable severe emotional harm.


V. DAMAGES
Plaintiff seeks:
• Actual damages (past and future physical pain, mental anguish, medical and psychological treatment expenses, loss of earning capacity);
• Exemplary/punitive damages (Defendant’s conduct was malicious and consciously indifferent);
• Pre- and post-judgment interest;
• Costs of court; and
• All other relief to which Plaintiff is entitled.


VI. STATUTE OF LIMITATIONS
Plaintiff’s claims are timely under Texas law governing childhood sexual abuse. Texas Civil Practice & Remedies Code § 16.0045 and subsequent amendments extending limitations periods for victims of childhood sexual assault allow this action. The profound trauma, Defendant’s position of power, and threats of death prevented earlier filing.


PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiff Sascha Barros prays that Defendant Donald J. Trump be cited to appear and answer herein, and that upon final trial Plaintiff have and recover judgment against Defendant for actual damages, exemplary damages, interest, costs, and such other and further relief to which Plaintiff may be justly entitled.


Respectfully submitted,

redacted


ATTORNEY FOR PLAINTIFF