E-FILED IN COUNTY CLERK'S OFFICE PIERCE COUNTY, WASHINGTON August 01 2012 8:30 AM

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KEVIN STOCK COUNTY CLERK

NO: 12-2-11437-0

SUPERIOR COURT OF THE STATE OF WASHINGTON FOR PIERCE COUNTY K.C., Plaintiff, v. HERBERT CY SUN, Defendant. Plaintiff K.C., by and through her attorneys Darrell L. Cochran and Jason P. Amala of NO. COMPLAINT FOR DAMAGES

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Pfau Cochran Vertetis Amala PLLC, hereby states and alleges as follows:
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PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 http://www.pcvalaw.com

I. 1.1

INTRODUCTION

This complaint is based on the sexual abuse and exploitation that plaintiff K.C.

suffered as a child at the hands of defendant Herbert Cy Sun. II. 2.1 PARTIES

As a young child, plaintiff K.C. was sexually abused and exploited by

defendant Herbert Cy Sun. Given the nature of these allegations, this complaint identifies K.C. by her initials, only. 2.2 Defendant Herbert Cy Sun (Cy Sun) is a man who resides in Pacific,

Pierce County, Washington.

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III. 3.1

JURISDICTION AND VENUE

As discussed in more detail below, the majority of the acts that give rise to this

complaint, including defendant Cy Suns sexual abuse and exploitation of K.C., took place in Pierce County, Washington. 3.2 As such, jurisdiction and venue are proper in this Court under RCW 4.12.020. IV. 4.1 4.2 STATEMENT OF FACTS

Plaintiff K.C. re-alleges the paragraphs above and below. Plaintiff K.C. was first sexually abused and molested by defendant Cy Sun in

approximately the summer of 1968, when she was about fourteen-years old. 4.3 Defendant Cy Sun continued to sexually abuse and molest plaintiff K.C. until

just before her sixteenth birthday. 4.4 Defendant Cy Sun was an adult male at all times he sexually abused and

molested plaintiff K.C. 4.5 At the time defendant Cy Sun sexually abused and exploited her, plaintiff K.C.

and defendant Cy Sun were neighbors living in or around Tacoma, Washington. 4.6 The majority of the sexual abuse and molestation took place inside Cy Suns

house and on his property, which was in or around Tacoma, Washington. 4.7 As a result of the unlawful acts described above, plaintiff K.C. has suffered,

and continues to suffer, general and special damages. These damages include, but are not limited to, emotional distress, humiliation, mental anguish, physical and mental pain and suffering, a decrease in her ability to enjoy life, past and future medical expenses, attorneys fees and costs, and other general and special damages, all in an amount to be determined at trial. 4.8 In approximately December 2011, plaintiff K.C. learned that defendant Cy Sun

had become the mayor of Pacific, Washington, which caused plaintiff K.C. to suffer extreme

PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 http://www.pcvalaw.com

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emotional distress. It also led her to begin to address some of the serious ways that the abuse and exploitation damaged her. V. CAUSES OF ACTION

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A.

Sexual Assault and Battery 5.1 5.2 Plaintiff K.C. re-alleges the paragraphs set forth above and below. Defendant Cy Sun intentionally engaged in harmful and offensive contact with

plaintiff K.C. while K.C. was a minor. This contact included sexual assault and molestation. 5.3 As a direct and proximate result of that intentional harmful and offensive

contact, plaintiff K.C. suffered general and special damages. B. Outrage and Intentional Infliction of Emotional Distress 5.4 5.5 Plaintiff K.C. re-alleges the paragraphs set forth above and below. Defendant Cy Sun engaged in extreme and outrageous conduct by sexually

abusing and exploiting K.C. 5.6 Defendant Cy Sun knew that his extreme and outrageous conduct would

irreparably and severely harm K.C., or he recklessly disregarded the same. 5.7 As a direct and proximate result of defendant Cy Suns extreme and

outrageous conduct, K.C. suffered and continues to suffer severe emotional distress and other general and special damages. VI. PRAYER FOR RELIEF

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6.1
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Plaintiff K.C. prays for judgment against defendant Cy Sun for the general and

special damages she has incurred, and she continues to incur, as described more fully herein, including her reasonable attorneys fees and costs. She also prays for any other damages and equitable relief the Court or jury deems appropriate under the circumstances.

COMPLAINT - 3 of 4

PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 http://www.pcvalaw.com

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6.2

K.C. reserves the right to pursue additional causes of action, other than those

specifically outlined above, that are supported by the facts pleaded herein or that may be
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supported by other facts that are developed during discovery.

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PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 http://www.pcvalaw.com

Dated this 1st day of August 2012. PFAU COCHRAN VERTETIS AMALA PLLC

By _________________________________________ Darrell L. Cochran, WSBA No. 22851 darrell@pcvkaw.com Jason P. Amala, WSBA No. 37054 jason@pcvklaw.com Attorneys for Plaintiff