SECOND CAUSE OF ACTION
(ASSAULT AND BATTERY)

10. Plaintiff incorporates Paragraphs 1 through 9 of the First Cause
of Action as if set forth in full herein.

11. That because of intentional misrepresentations made to plaintiff
by defendants, and each of them, to the effect that eye "floaters"
could not be produced or increased as the result of the defendants'
recommended surgical procedure, plaintiff submitted to the so-called
"advanced" type of surgery, which, in fact, did cause and increase
floaters in both of plaintiff's eyes, so as to seriously interfere
with her vision, and the details of which has been described in
paragraphs 4, 5, and 6, above; that had the defendants advised
plaintiff that the contemplated surgery was known to have caused, and/
or increased eye "floaters" in other patients, plaintiff would never
have submitted to surgery.

12. That as a legal result of defendants' aforedescribed conduct,
defendants and each of them they failed to obtain a legal and informed
consent from plaintiff to carry out the the recommended surgery. The
so-called "advanced" laser surgery and its subsequent required follow-
up treatment administered to plaintiff amounted to a legal battery on
plaintiff's person.

13. Further, the battery was carried out by the defendants and each of
them with a conscious disregard of plaintiff's legal rights, her
health and future welfare. Each of defendant's conduct was malicious.
Defendants are liable for punitive damages in an amount to be alleged
at a later date.

W H E R E F O R E, plaintiff prays for judgment against defendants,
and each of them, as follows:
FIRST CAUSE OF ACTION
(PROFESSIONAL NEGLIGENCE)

1. General damages according to proof, in excess of this Court's
minimum jurisdictional amount;
2. All medical and incidental expenses according to proof;
3. Loss of earnings according to proof;
4. For prejudgment interest according to proof;
5. For costs of suit incurred herein; and
6. For such other and further relief as this Court may deem just and
proper.

SECOND CAUSE OF ACTION
(ASSAULT AND BATTERY)

1. General damages according to proof, in excess of this Court's
minimum
jurisdictional amount;
2. All medical and incidental expenses according to proof:
3. Loss of earnings according to proof;
4. For prejudgment interest according to proof
5. For costs of suit incurred herein;
6. For punitive damages according to proof; and
7. For such other and further relief as this Court may deem just and
proper.

Dated: April 10, 2000. LAW OFFICES OF MARK P. ROBINSON
BY:
MARK P. ROBINSON
Attorneys for Plaintiff
DEMAND FOR JURY TRIAL

Comes now, plaintiff, YVETTE BOLESLAV, and demands a Jury Trial on all
causes of action.

Dated: April 10, 2000. LAW OFFICES OF MARK P. ROBINSON
BY:
MARK P. ROBINSON
Attorneys for Plaintiff