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IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF TENNESSEE


AT NASHVILLE

DANTE R. SATTERFIELD, )
)
Plaintiff, )
)
vs. ) Case No. ________
)
) JURY DEMANDED
TAJAE SHARPE and )
SEBASTIAN TRETOLA, )
)
)
Defendants. )
)

COMPLAINT

COMES NOW the Plaintiff, Dante R. Satterfield, the victim, and for his Complaint in this

cause of action respectfully states as follows:

PARTIES

1. At all relevant times, Plaintiff, Dante R. Satterfield, was a resident of Nashville,

Davidson County, Tennessee. Plaintiff is 59 tall and weighs 180 pounds.

2. Upon information and belief, Defendant, Tajae Sharpe, (Defendant Sharpe), at all

relevant times, is a resident of Newark, New Jersey and a player for Tennessee Football, Inc. dba as

the Tennessee Titans of the National Football League in Nashville, Davidson County, Tennessee

(Tennessee Titans). Upon information and belief, Defendant Sharpe is 64 tall and weighs 201

pounds.

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3. Upon information and belief, Defendant, Sebastian Tretola, (Defendant Tretola), at

all relevant times, is a resident of San Bernardino, California and a player for the Tennessee Titans.

Upon information and belief, Defendant Tretola is 64 tall and weighs 314 pounds.

4. Plaintiff alleges herein that Defendants intentional and negligent actions proximately

caused his physical, mental, and emotional injuries.

5. Plaintiff brings this lawsuit to recover damages on account of his injuries and

continued distress caused by Defendants assaulting him around midnight on the evening of

Thursday, April 27, 2017 into the early morning hours of Friday, April 28, 2017.

JURISDICTION AND VENUE

6. Plaintiff incorporates paragraphs 1 through 5 as if restated here verbatim.

7. This Court has subject matter jurisdiction of this matter based on 28 U.S.C. 1332,

diversity of citizenship of the Plaintiff and the Defendants.

8. This is an action for damages in excess of $75,000.00, exclusive of interest and costs.

9. Venue in this Court is appropriate, pursuant to 28 U.S.C. 1391, because the attack

on the Plaintiff occurred in the Middle District of Tennessee.

JURY DEMAND

10. Plaintiff incorporates paragraphs 1 through 9 as if restated here verbatim.

11. Pursuant to Federal Rule of Civil Procedure 38(b), Plaintiff demands a trial by jury on

all issues.

. . . continued . . .

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FACTS

12. Plaintiff incorporates paragraphs 1 through 11 as if restated here verbatim.

13. The National Football League, Inc. (NFL) owns and operates a football league in

the United States and internationally. The NFL consists of 32 teams. Founded in 1920, in addition to

the United States, the NFL has operations in Canada, China, France, Japan, Mexico, and the United

Kingdom. Each year, the NFL season consists of four preseason games (NFL Preseason) and 16

regular season games (NFL Season).

14. One of the NFLs 32 teams is the Tennessee Titans (Titans). The Titans are based

and play their homes games in Nashville, Tennessee.

15. On Thursday, April 28, 2016, the NFL held its 81st annual meeting of NFL franchises

to select newly eligible football players in Chicago, Illinois (2016 NFL Draft).

16. In the 2016 NFL Draft, the Titans selected Defendant Tajae Sharpe, a wide receiver

from the University of Massachusetts, in the fifth round (140th overall).

17. In the 2016 NFL Draft, the Titans selected Sebastian Tretola, an offensive guard from

the University of Arkansas, in the sixth round (193th overall).

18. Defendants were named to the Titans roster and played for the Titans during the

2016 NFL season.

19. During the 2016 NFL Season, Defendant Sharpe played in all of the Titans 16

regular-season games.

20. For the 2016 NFL Season, Defendant Sharpe had 42 receptions for 522 yards and 2

touchdowns.

21. In the 2016 NFL Season, Defendant Tretola played in one regular-season game for

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the Titans.

22. On Thursday, April 27, 2017, the NFL held its 82nd annual meeting of NFL franchises

to select newly eligible football players in Philadelphia, Pennsylvania (2017 NFL Draft).

23. Upon information and belief, Titans Head Football Coach Mike Mularkey (Coach

Mularkey) considered Defendant Sharpes performance during the 2016 season to be subpar.

24. Before the 2017 NFL Draft, Coach Mularkey stated, in a Tennessean article dated

March 5, 2017, that Defendant Sharpe has to prove himself all over again after fading late in his

rookie season.

25. In the 2017 NFL Draft, with its first pick (pick number five overall), the Titans

selected Corey Davis (Mr. Davis), a wide receiver from Western Michigan University.

26. Upon information and belief, because the Titans drafted Mr. Davis with its first pick

in the 2017 NFL Draft, Defendant Sharpe is likely to receive less playing time in the 2017 NFL

Season and his job may be in jeopardy.

27. Upon information and belief, Defendant Sharpe was very upset by the Titans

selection of Mr. Davis.

28. At or about 11:30 p.m. on April 27, 2017, Plaintiff was with Defendants at Tin Roof

Nashville, which is a restaurant and bar located at 1516 Demonbreun Street, Nashville, Tennessee

37203 (Tin Roof).

29. Plaintiff and Defendants had a conversation about the 2017 NFL Draft and the Titans

selection of Mr. Davis in the First Round.

30. Around 11:45 p.m., this conversation between Plaintiff and Defendants became

heated.

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31. At the air, Plaintiff made remarks about the 2017 NFL Draft and the effect of the

Titans selection of Mr. Davis would have on Defendant Sharpe.

32. Defendant Sharpe took exception to the comments made by Plaintiff.

33. Around 11:55 p.m. or shortly after midnight on April 28, 2017, Defendants told

Plaintiff to follow them outside. Plaintiff believed the group was headed outside for lawful purposes.

34. As a result, Plaintiff followed the Defendants out the back door of Tin Roof to an

alley.

35. In that alley, Defendants brutally assaulted Plaintiff.

36. Defendant Sharpe repeatedly hit Plaintiff in the face causing severe injuries.

37. Upon information and belief, Defendant Tretola served as a lookout who provided

protection to Defendant Sharpe while Defendant Sharpe beat Plaintiff with his fists.

38. Upon information and belief, Defendants continued their assault even after Plaintiff

lay helpless on the ground, unconscious, striking and bruising his face.

39. Plaintiff was beaten unconscious in the attack.

40. After the brutal assault, Defendants left Plaintiff unconscious in the alley alongside

Tin Roof.

41. A bystander found Plaintiff and called 911.

42. Unconscious and unresponsive, Plaintiff was transported by ambulance to a local

Nashville hospital.

43. Plaintiff did not regain consciousness for more than twelve (12) hours.

44. As a result of the assault, Plaintiff suffered a concussion, broken bones in the face,

massive facial bruising, a perforated eardrum, among other injuries.

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45. Photographs of some of the injuries, taken the next day, are depicted in Exhibit 1 to

this Complaint.

46. Plaintiff never consented to a physical altercation of any kind with Defendants.

Through this brutal assault, Defendants caused Plaintiff to suffer physical trauma, emotional distress,

humiliation, and further caused him to incur expenses in the form of time and money to treat his

physical, mental, and emotional injuries.

CAUSES OF ACTION

COUNT I
ASSAULT AND BATTERY

47. Plaintiff incorporates paragraphs 1 through 46 as if restated here verbatim.

48. Defendant Sharpe intentionally, willfully, unlawfully and without justification

threatened and then struck Plaintiff causing severe injuries to the person of Plaintiff. This

Defendant, much bigger, taller, and stronger than Plaintiff, beat Plaintiff with his fists, and

continued his assault even after Plaintiff was helpless and on the ground, striking and bruising him.

49. Defendant Tretola intentionally, willfully, unlawfully and without justification

assisted Defendant Sharpe in his efforts to threaten and strike Plaintiff causing severe injuries to the

person of Plaintiff. This Defendant, much bigger, taller, and stronger than Plaintiff, functionally

served as a lookout while Defendant Sharpe beat Plaintiff with his fists, and encouraged the assault

even after Plaintiff was helpless and on the ground, striking and bruising him.

50. Plaintiff did not, expressly or impliedly, give consent to the actions of Defendants.

51. Defendants are guilty of assault and battery upon the person of Plaintiff.

52. The assault and battery of Plaintiff by these Defendants was a direct and proximate

cause of injuries and damage to the Plaintiff.


6

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COUNT II
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

53. Plaintiff incorporates paragraphs 1 through 52 as if restated here verbatim.

54. Defendants committed the acts described in paragraphs 1 through 52, causing severe

injuries to the person of Plaintiff.

55. Defendants intentional conduct was so outrageous that is not tolerated in civil

society and is in fact the basis for several crimes, including Aggravated Assault.

56. Defendants intentional conduct has caused Plaintiff to suffer serious mental and

emotional injuries that impair his enjoyment of daily life.

COUNT III
CIVIL CONSPIRACY

57. Plaintiff incorporates paragraphs 1 through 56 as if restated here verbatim.

58. Defendants participated in a common design to accomplish the assault and battery of

Plaintiff. More specifically, but without limitation, these individuals conspired to isolate Plaintiff

while simultaneously and in concert inflicting serious physical hard to Plaintiffs person.

DAMAGES

59. Plaintiff incorporates paragraphs 1 through 58 as if restated here verbatim.

60. Defendants have inflicted physical and emotional injury upon Plaintiff and serious

emotional trauma and injury upon him.

61. Plaintiff has incurred, and continues to incur, damages for which he is justly entitled

to compensation, including medical expenses, and physical and emotional pain and suffering as well

as lost wages and future wage-earning capacity.

PUNITIVE DAMAGES

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62. Plaintiff incorporates paragraphs 1 through 61 as if restated here verbatim.

63. Plaintiff is further entitled, by virtue of the willful, wanton, reckless and intentional

nature of the wrongs of Defendants, to an award of exemplary and punitive damages in an amount

sufficient to punish the Defendants for their wrongdoing and to deter them and others like them from

committing such acts again in the future.

64. Because of the physical, mental, and emotional injuries proximately caused by

Defendants intentional conduct, Plaintiff is entitled to reasonable and proper compensation for the

following legal damages:

(a) Past and future physical pain;

(b) Past and future mental and emotional anguish;

(c) Past and future medical expenses;

(d) Past and future counseling expenses;

(e) Past lost wages and future lost wage-earning capacity; and

(f) Punitive damages.

WHEREFORE, Plaintiff demands a trial of this cause by a jury and prays for a determination

of the following:

(a) that Defendants committed the intentional assault and battery against Plaintiff;

(b) that Defendants intentionally inflicted emotional distress upon Plaintiff;

(c) that Plaintiff is entitled to all damages listed above in an amount not less than five

hundred thousand dollars ($500,000.00);

(d) that Plaintiff be awarded Court costs, including discretionary costs; and

(e) that Plaintiff be awarded such other and further relief as this Court deems necessary

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to effectuate justice between the parties.

Dated this 10th day of May, 2017.

RESPECTFULLY SUBMITTED,

BONE MCALLESTER NORTON PLLC

s/ J. Alex Little
By: ___________________________________
J. Alex Little (TN BPR No. 29858)
James A. Crumlin, Jr. (TN BPR No. 19760)
511 Union Street, Suite 1600
Nashville, TN 37219
(615) 238-6300
(615) 238-6301 facsimile
alex.little@bonelaw.com
jcrumlin@bonelaw.com

Attorneys for the Plaintiff

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AO 440 (Rev. 12/09) Summons in a Civil Action

UNITED STATES DISTRICT COURT


for the
Middle District
__________ District of
of Tennessee
__________

Dante R. Satterfield
)
)
Plaintiff
)
v. ) Civil Action No.
Tajae Sharpe and Sebastian Tretola )
)
Defendant
)

SUMMONS IN A CIVIL ACTION

To: (Defendants name and address) Sebastian Tretola


c/o Blaine Roche, Esq.
Athletes First
23091 Mill Creek Drive
Laguna Hills, CA 92653

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
whose name and address are: J. Alex Little
James A. Crumlin, Jr.
Bone McAllester Norton, PLLC
511 Union Street, Suite 1600
Nashville, TN 37219

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

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AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)


was received by me on (date) .

u I personally served the summons on the individual at (place)


on (date) ; or

u I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individuals last known address; or

u I served the summons on (name of individual) , who is


designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

u I returned the summons unexecuted because ; or

u Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc:

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AO 440 (Rev. 12/09) Summons in a Civil Action

UNITED STATES DISTRICT COURT


for the
Middle District
__________ District of
of Tennessee
__________

Dante R. Satterfield
)
)
Plaintiff
)
v. ) Civil Action No.
Tajae Sharpe and Sebastian Tretola )
)
Defendant
)

SUMMONS IN A CIVIL ACTION

To: (Defendants name and address) Tajae Sharpe


c/o Blaine Roche, Esq.
Athletes First
23091 Mill Creek Drive
Laguna Hills, CA 92653

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
whose name and address are: J. Alex Little
James A. Crumlin, Jr.
Bone McAllester Norton, PLLC
511 Union Street, Suite 1600
Nashville, TN 37219

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

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AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)


was received by me on (date) .

u I personally served the summons on the individual at (place)


on (date) ; or

u I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individuals last known address; or

u I served the summons on (name of individual) , who is


designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

u I returned the summons unexecuted because ; or

u Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc:

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