4. On May 19, 1997, at approximately 11:30 a.m., the plaintiff was a lawful ticketed passenger with a boarding pass assigned to seat number 43-C on a plane owned by Air France, designated Flight #004 which had departed from Charles De Gaulle Airport in France and was destined for New York/Newark Airport in the United States.

5. That the plaintiff lawfully entered the said Air France plane for flight #004, and took his assigned seat for the plane's takeoff at 10:50 a.m.

6. That while plaintiff was lawfully on said Air France plane, at approximately 11:30 a.m. during the flight, the plaintiff was in one of the lavatories using the lavatory which was locked by him from the inside. The plaintiff was properly and lawfully using the lavatory, with his pants and underpants down and in the process of going to the bathroom, and while plaintiff was naked from the waist down, the defendant, Air France, its agents, servants, and employees, wrongfully, willfully, maliciously, unlawfully, and without any cause or justification or warning smashed open the door of the lavatory. Plaintiff, while still in the lavatory, was then viciously, willfully and maliciously assaulted, battered and physically struck by multiple crew members of the plane. The crew members then, while plaintiff was naked from the waist down, dragged plaintiff outside the lavatory, exposing his genitals and other body parts to many seated passengers, both female and male. Plaintiff pulled away from crew members and re-entered the lavatory and pulled up his underpants and pants.