N THE CIRCUIT COURT OF TUSCALOOSA COUNTY, ALABAMA
6TH JUDICIAL CIRCUIT
CIVIL DIVISION
SARAH GRIMES, )
)
Plaintiff, )
)
VS. )CASE NO.
)
KRISTEN SABAN, )
)
Defendant. )
COMPLAINT
1. The Plaintiff is over the age of nineteen (19) years; and she is
attending the University of Alabama.
2. The Defendant is over the age of nineteen (19) years; and she is
attending the University of Alabama.
3. In August 2010, Kristen Saban and Sarah Grimes were friends and
sorority sisters.
4. On Saturday, August 28, 2010, Kristen Saban, McKinnon
Moultrie, Hannah Muncher, and Meaghan Williams were playing "power hour"
which is a drinking game on YouTube, where you drink every time the song
changes.
5. Sarah Grimes arrived around 11:00 pm and began playing "power
hour."
6. Around 12:00 a.m., August 29, 2010, Kristen, McKinnon, Hannah,
Meaghan, and Sarah went to the bar called Rounders.
ELECTRONICALLY FILED
6/26/2012 10:39 AM
CV-2012-900538.00
CIRCUIT COURT OF
TUSCALOOSA COUNTY, ALABAMA
MAGARIA HAMNER BOBO, CLERK
2
7. At the bar, the drinking continued and Kristen's behavior became
more erratic.
8. Kristen had been dating "BV" who was also at Rounder's that
night.
9. Kristen became angry with "BV" because he was not paying
enough attention to her.
10. Kristen, Hannah, and Sarah stayed at the bar until last call when
the lights came on, and Kristen had to sign her tab.
11. The plan was to go back home to freshen up and then go over to a
pledge sister's house.
12. "BV" was also going, so Kristen wanted to go as well.
13. Kristen drove everyone back home where everyone gathered in the
kitchen and had a snack.
14. Kristen became upset with "BV" again, while talking over the
phone.
15. Kristen was lying on the floor next to McKinnon and Hannah
saying how everyone did not understand "how it was" for her and Kristen became
emotional.
16. After Kristen refused to get off the floor after several people had
tried to help her, Sarah looked over at Kristen and said, "Kristen, please just shut
up. We're all sick and tired of hearing it."
17. Kristen jumped up off the floor screaming "No one likes you, you
don't have any friends" and stormed to her room.
3
18. Sarah was laughing at this point because it was not unusual
behavior for Kristen and made the comment, "You really need therapy."
19. Kristen then screamed at Sarah, "Yeah, because that obviously
worked so well for you!" and then slammed her bedroom door.
20. Everyone in the kitchen was used to seeing Kristen behave this
way, and no one thought much of it.
21. About thirty minutes later, Hannah went to check on Kristen in her
room and closed the door.
22. For the next thirty or so minutes, Courtney, McKinnon and Sarah
were lying in Courtney's bed (across the hall from Kristen's) with the door open,
waiting to go to the Waffle House.
23. Sarah checked her Facebook via her phone and saw that Kristen
had posted a status saying "No one likes Sarah! Yayyyyy!"
24. Sarah showed Courtney her phone, and got up off the bed saying
"I'm done."
25. Courtney cautioned Sarah from confronting Kristen about the
status because of her known violent nature and previous assault on others.
26. Sarah stated to Courtney, "Well if she touches me, I'll kill her."
27. Sarah walked across the hall, with her phone in hand and knocked
on Kristen's door with the palm of her hand saying, "You've got five seconds to
take it off, or I'm going to tell everyone that you punched Daniel (Kristen's
former boyfriend) in the face last week. Try me."
4
28. Kristen did not respond but opened the door seconds later waving
her phone in Sarah's face, causing Sarah to move backwards towards Courtney's
bedroom door.
29. Kristen was yelling, "I took it off, I took it off!"
30. Sarah responded, "That's fine, but we're done, you're crazy."
31. Kristen immediately used both of her hands and shoved Sarah into
the corner of Courtney's open door, slamming Sarah's head.
32. Sarah defended herself by pushing Kristen into the opposite wall,
saying "Don't touch me."
32. Kristen proceeded to punch Sarah Grimes multiple times in her
head and nose, and to pull Sarah's hair, even though Kristen knew that Sarah had
really bad migraines from a prior head injury from an automobile accident.
33. By this time Meghan, who was outside in the parking lot, heard the
yelling and ran upstairs.
34. Sarah screamed "I'm calling the cops!"
35. Kristen's grip on Sarah's hair prevented Sarah from getting away
and they moved down the hall toward the kitchen as Sarah tried to get away.
36. After multiple blows to Sarah's face, Hannah intervened and tried
to pull Kristen away but was unable to do so due to Kristen's grip of Sarah's hair
and Kristen refused to stop hitting Sarah.
37. The screaming woke up Beth Terry, who immediately jumped in to
help pull Kristen off from behind (Beth's shirt was ripped and stained with
Sarah's blood).
5
38. It took both Beth Terry and Hannah Muncher to pull Kristen off of
Sarah.
39. Once Kristen stopped hitting Sarah, Sarah saw a large amount on
blood on the wood floor.
40. Sarah looked down and noticed a great amount of blood was
running down her chest and into her bra.
41. Sarah felt her nose and realized that the blood was coming from it.
42. Kristen turned to go back to her room, picking Sarah's phone up
off the floor and throwing it into the wall, attempting to break it.
43. Sarah followed Kristen along with the other witnesses into her
bedroom to talk to her and found her lying on the floor to the left of her bed, with
her eyes closed and crying.
44. When Sarah caught a glimpse of her face in the mirror from her
bathroom, she saw that her temple had swollen to the size of a tennis ball, which
was extremely alarming to Sarah.
45. Sarah kneeled down on the floor next to Kristen and calmly said,
"Open your eyes and look at my face"
46. Kristen slightly sat up, opened her eyes, and Sarah said "I would
never do this to you."
47. Kristen responded, "You grabbed my throat!"
48. Sarah told Kristen that she did that in self-defense because Kristen
had thrown Sarah into the door frame and Sarah had to get Kristen off of her.
6
49. Kristen's eyes appeared to roll back into her head as if she had just
realized the severity of the situation, and Kristen fell back and started crying
again.
50. Sarah then told Kristen that she (Sarah) needed to go to the
hospital.
51. After Courtney agreed that Sarah needed to get checked out,
Kristen began hysterically crying louder and screaming "I'm going to jail!" over
and over.
52. Sarah went to DCH, the trauma hospital in Tuscaloosa.
53. Sarah was taken to the hospital by Courtney Reigel, Beth Terry,
and McKinnon Moultrie.
54. Sarah reported that she had been assaulted by her friend who had
hit Sarah's face repeatedly with her fists.
55. Sarah also reported that she had been bleeding some from her nose.
56. The emergency physician observed Sarah had a hematoma to the
left side of her face and abrasions were seen on the bridge of Sarah's nose and left
elbow.
57. The physician diagnosed Sarah with an elbow contusion, a
concussion, cervical strain, and headache. Later, Sarah would be diagnosed with
a deviated septum.
58. The emergency physician informed Sarah that her injuries were
very serious and could have been life threatening.
7
59. The concussion was so bad that it affected Sarah's ability to
concentrate and do her schoolwork.
60. University of Alabama police officers, Tuscaloosa police officers,
and the University of Alabama Dean of Students responded to an assault call at
the DCH emergency room.
61. The officers spoke with Sarah Grimes, Courtney Reigel and Beth
Terry; McKinnon had left the hospital before the police arrived.
62. The officers were told what had happened.
63. The officers observed bruises to Sarah's left eye and took
photographs of Sarah's injuries.
64. Sarah stated that she did not want to have Kristen criminally
prosecuted.
65. The beating was submitted to Judicial Affairs at the University and
Kristen pled guilty.
66. Kristen was ordered to take psychological testing, an anger
management class, and a no contact order was issued between Kristen and Sarah.
67. As a result of the beating and the head injuries Sarah Grimes
sustained by Kristen Saban, Sarah has had repeated night terrors, anxiety, physical
trembling, fears of dying from brain injuries, trouble sleeping, and intrusive
recollections of the event.
68. Sarah also had an increase in her migraine headaches since the
beating.
8
69. Based on the psychological problems that Sarah incurred from the
beating, she began to see a psychologist for the severe emotional trauma that she
sustained from the beating.
70. On December 27, 2011, Sarah Grimes underwent nasal surgery
with osteotomies and reconstruction.
71. When the doctor performed the surgery, he could see the petition
in the middle of Sarah's nose was deformed, was shifted, and it was a direct result
of the beating that Sarah received from Kristen.
COUNT (ASSAULT AND BATTERY)
72. Plaintiff adopts and realleges paragraphs 1-71, above, as if set out
in full herein.
73. The Defendant Kristen Saban did negligently, recklessly,
maliciously, willfully and/or wantonly assault and batter the Plaintiff.
74. As a result of the beating, the Plaintiff felt physically threatened
and suffered physical injuries, mental anguish, emotional distress, humiliation,
permanent emotional and psychological injury, and other damages for which she
claims compensatory and punitive damages.
WHEREFORE, PREMISES CONSIDERED, Your Plaintiff demands
judgment against the Defendant Kristen Saban for compensatory and punitive
damages in an amount which the Jury finds reasonable and justifiable under the
circumstances, plus costs and interest, but avers that the Plaintiff's claim is for more
than $10,000.00.
6TH JUDICIAL CIRCUIT
CIVIL DIVISION
SARAH GRIMES, )
)
Plaintiff, )
)
VS. )CASE NO.
)
KRISTEN SABAN, )
)
Defendant. )
COMPLAINT
1. The Plaintiff is over the age of nineteen (19) years; and she is
attending the University of Alabama.
2. The Defendant is over the age of nineteen (19) years; and she is
attending the University of Alabama.
3. In August 2010, Kristen Saban and Sarah Grimes were friends and
sorority sisters.
4. On Saturday, August 28, 2010, Kristen Saban, McKinnon
Moultrie, Hannah Muncher, and Meaghan Williams were playing "power hour"
which is a drinking game on YouTube, where you drink every time the song
changes.
5. Sarah Grimes arrived around 11:00 pm and began playing "power
hour."
6. Around 12:00 a.m., August 29, 2010, Kristen, McKinnon, Hannah,
Meaghan, and Sarah went to the bar called Rounders.
ELECTRONICALLY FILED
6/26/2012 10:39 AM
CV-2012-900538.00
CIRCUIT COURT OF
TUSCALOOSA COUNTY, ALABAMA
MAGARIA HAMNER BOBO, CLERK
2
7. At the bar, the drinking continued and Kristen's behavior became
more erratic.
8. Kristen had been dating "BV" who was also at Rounder's that
night.
9. Kristen became angry with "BV" because he was not paying
enough attention to her.
10. Kristen, Hannah, and Sarah stayed at the bar until last call when
the lights came on, and Kristen had to sign her tab.
11. The plan was to go back home to freshen up and then go over to a
pledge sister's house.
12. "BV" was also going, so Kristen wanted to go as well.
13. Kristen drove everyone back home where everyone gathered in the
kitchen and had a snack.
14. Kristen became upset with "BV" again, while talking over the
phone.
15. Kristen was lying on the floor next to McKinnon and Hannah
saying how everyone did not understand "how it was" for her and Kristen became
emotional.
16. After Kristen refused to get off the floor after several people had
tried to help her, Sarah looked over at Kristen and said, "Kristen, please just shut
up. We're all sick and tired of hearing it."
17. Kristen jumped up off the floor screaming "No one likes you, you
don't have any friends" and stormed to her room.
3
18. Sarah was laughing at this point because it was not unusual
behavior for Kristen and made the comment, "You really need therapy."
19. Kristen then screamed at Sarah, "Yeah, because that obviously
worked so well for you!" and then slammed her bedroom door.
20. Everyone in the kitchen was used to seeing Kristen behave this
way, and no one thought much of it.
21. About thirty minutes later, Hannah went to check on Kristen in her
room and closed the door.
22. For the next thirty or so minutes, Courtney, McKinnon and Sarah
were lying in Courtney's bed (across the hall from Kristen's) with the door open,
waiting to go to the Waffle House.
23. Sarah checked her Facebook via her phone and saw that Kristen
had posted a status saying "No one likes Sarah! Yayyyyy!"
24. Sarah showed Courtney her phone, and got up off the bed saying
"I'm done."
25. Courtney cautioned Sarah from confronting Kristen about the
status because of her known violent nature and previous assault on others.
26. Sarah stated to Courtney, "Well if she touches me, I'll kill her."
27. Sarah walked across the hall, with her phone in hand and knocked
on Kristen's door with the palm of her hand saying, "You've got five seconds to
take it off, or I'm going to tell everyone that you punched Daniel (Kristen's
former boyfriend) in the face last week. Try me."
4
28. Kristen did not respond but opened the door seconds later waving
her phone in Sarah's face, causing Sarah to move backwards towards Courtney's
bedroom door.
29. Kristen was yelling, "I took it off, I took it off!"
30. Sarah responded, "That's fine, but we're done, you're crazy."
31. Kristen immediately used both of her hands and shoved Sarah into
the corner of Courtney's open door, slamming Sarah's head.
32. Sarah defended herself by pushing Kristen into the opposite wall,
saying "Don't touch me."
32. Kristen proceeded to punch Sarah Grimes multiple times in her
head and nose, and to pull Sarah's hair, even though Kristen knew that Sarah had
really bad migraines from a prior head injury from an automobile accident.
33. By this time Meghan, who was outside in the parking lot, heard the
yelling and ran upstairs.
34. Sarah screamed "I'm calling the cops!"
35. Kristen's grip on Sarah's hair prevented Sarah from getting away
and they moved down the hall toward the kitchen as Sarah tried to get away.
36. After multiple blows to Sarah's face, Hannah intervened and tried
to pull Kristen away but was unable to do so due to Kristen's grip of Sarah's hair
and Kristen refused to stop hitting Sarah.
37. The screaming woke up Beth Terry, who immediately jumped in to
help pull Kristen off from behind (Beth's shirt was ripped and stained with
Sarah's blood).
5
38. It took both Beth Terry and Hannah Muncher to pull Kristen off of
Sarah.
39. Once Kristen stopped hitting Sarah, Sarah saw a large amount on
blood on the wood floor.
40. Sarah looked down and noticed a great amount of blood was
running down her chest and into her bra.
41. Sarah felt her nose and realized that the blood was coming from it.
42. Kristen turned to go back to her room, picking Sarah's phone up
off the floor and throwing it into the wall, attempting to break it.
43. Sarah followed Kristen along with the other witnesses into her
bedroom to talk to her and found her lying on the floor to the left of her bed, with
her eyes closed and crying.
44. When Sarah caught a glimpse of her face in the mirror from her
bathroom, she saw that her temple had swollen to the size of a tennis ball, which
was extremely alarming to Sarah.
45. Sarah kneeled down on the floor next to Kristen and calmly said,
"Open your eyes and look at my face"
46. Kristen slightly sat up, opened her eyes, and Sarah said "I would
never do this to you."
47. Kristen responded, "You grabbed my throat!"
48. Sarah told Kristen that she did that in self-defense because Kristen
had thrown Sarah into the door frame and Sarah had to get Kristen off of her.
6
49. Kristen's eyes appeared to roll back into her head as if she had just
realized the severity of the situation, and Kristen fell back and started crying
again.
50. Sarah then told Kristen that she (Sarah) needed to go to the
hospital.
51. After Courtney agreed that Sarah needed to get checked out,
Kristen began hysterically crying louder and screaming "I'm going to jail!" over
and over.
52. Sarah went to DCH, the trauma hospital in Tuscaloosa.
53. Sarah was taken to the hospital by Courtney Reigel, Beth Terry,
and McKinnon Moultrie.
54. Sarah reported that she had been assaulted by her friend who had
hit Sarah's face repeatedly with her fists.
55. Sarah also reported that she had been bleeding some from her nose.
56. The emergency physician observed Sarah had a hematoma to the
left side of her face and abrasions were seen on the bridge of Sarah's nose and left
elbow.
57. The physician diagnosed Sarah with an elbow contusion, a
concussion, cervical strain, and headache. Later, Sarah would be diagnosed with
a deviated septum.
58. The emergency physician informed Sarah that her injuries were
very serious and could have been life threatening.
7
59. The concussion was so bad that it affected Sarah's ability to
concentrate and do her schoolwork.
60. University of Alabama police officers, Tuscaloosa police officers,
and the University of Alabama Dean of Students responded to an assault call at
the DCH emergency room.
61. The officers spoke with Sarah Grimes, Courtney Reigel and Beth
Terry; McKinnon had left the hospital before the police arrived.
62. The officers were told what had happened.
63. The officers observed bruises to Sarah's left eye and took
photographs of Sarah's injuries.
64. Sarah stated that she did not want to have Kristen criminally
prosecuted.
65. The beating was submitted to Judicial Affairs at the University and
Kristen pled guilty.
66. Kristen was ordered to take psychological testing, an anger
management class, and a no contact order was issued between Kristen and Sarah.
67. As a result of the beating and the head injuries Sarah Grimes
sustained by Kristen Saban, Sarah has had repeated night terrors, anxiety, physical
trembling, fears of dying from brain injuries, trouble sleeping, and intrusive
recollections of the event.
68. Sarah also had an increase in her migraine headaches since the
beating.
8
69. Based on the psychological problems that Sarah incurred from the
beating, she began to see a psychologist for the severe emotional trauma that she
sustained from the beating.
70. On December 27, 2011, Sarah Grimes underwent nasal surgery
with osteotomies and reconstruction.
71. When the doctor performed the surgery, he could see the petition
in the middle of Sarah's nose was deformed, was shifted, and it was a direct result
of the beating that Sarah received from Kristen.
COUNT (ASSAULT AND BATTERY)
72. Plaintiff adopts and realleges paragraphs 1-71, above, as if set out
in full herein.
73. The Defendant Kristen Saban did negligently, recklessly,
maliciously, willfully and/or wantonly assault and batter the Plaintiff.
74. As a result of the beating, the Plaintiff felt physically threatened
and suffered physical injuries, mental anguish, emotional distress, humiliation,
permanent emotional and psychological injury, and other damages for which she
claims compensatory and punitive damages.
WHEREFORE, PREMISES CONSIDERED, Your Plaintiff demands
judgment against the Defendant Kristen Saban for compensatory and punitive
damages in an amount which the Jury finds reasonable and justifiable under the
circumstances, plus costs and interest, but avers that the Plaintiff's claim is for more
than $10,000.00.