MEMORANDUM

To: Supervising Partner, Uzair Kayani

From: Associate [redacted]
Date: [redacted]
Re: Claims and Defenses Arising from the Mr. Page Moshroff Case
Issues
1. Can Mr. Marankan and Mr. Cordrey be held liable for public
nuisance? Can Mr. Moshroff bring a private action against them?
2. Was Moshroff negligent in driving over Gluebutton?
3. Was Gluebutton contributorily negligent?
4. Can Moshroff be held liable for his failure to assist Gluebutton
after the accident?
5. Can Moshroff be held liable for his refusal to take Pollybutton to
the hospital?
6. Can Moshroff be held liable for taking 10,000 rupees from
Pollybuttons wallet for the damage done to his windshield?
7. Was Moshroff negligent in swinging the chair for his self-defense
at the protest after the lights went out?
8. Were the Organizers negligent for the madness that resulted
after the lights went out?
9. Can Moshroff and the Organizers be held jointly liable for the
harm caused to twenty people?
10.
Is Ms. Zeemy liable for the injuries sustained by Moshroff
because of her dog?

11.

Can Moshroff be held liable to pay medical bills to Mosnieur

Phillipe?
12.
Can Moshroff be held liable for causing the death of
Multibutton?
Brief Answers
1. Yes and Yes, Marankan and Cordrey can be held liable for public
nuisance due to their protestors interference with public rights
and special damage caused to Moshroff.
2. Yes, Moshroff was negligent under the reasonable man standard.
3. Yes, Gluebutton was contributory negligent for the harm he
suffered.
4. Yes, he can be held liable for his failure to assist Gluebutton.
5. No, Moshroff cannot be held liable for his refusal as there is no
duty to rescue others.
6. Yes, Moshroff can be held liable for taking 10,000 rupees under
conversion.
7. Yes, Moshroff was negligent as he created unreasonable risk of
harm for others.
8. Yes, the Organizers were negligent because of their failure to
take necessary precautions.
9. Yes, they can be held jointly liable as the cause cannot be
ascertained.
10.
Yes, if shown that Ms. Zeemy had knowledge of her dogs
vicious propensities.
11.
No, Moshroff acted reasonably in self-defense.
12.
Yes, Moshroff can be held liable.

Facts
Fifty thousand supporters have gathered in support of Mr.
Marankan and Mr. Cordery, in the capital of Kapistan, outside
Moshroffs residence.

These rowdy protestors impede public works,

have littered the streets and contributed to an unsanitary environment.

They have made driving in that area impossible; Moshroff often have to
leave by foot. At times they hit Moshroff and at times tear up his
clothes.
Moshroff heard a crunching sound while backing his car out of
driveway and upon inquiry found that the wheels of his car were on the
chest and thighs of Gluebutton who was sleeping on the road. Moshroff
was unable to see him because Gluebutton had disabled the
streetlights. When Gluebutton asked for removal of the fancy car,
Moshroff explained his car was light and encouraged Gluebutton to
push it off. Gluebutton died while trying.
Pollybutton, seeing his uncles corpse, smashed the windshield of
Moshroffs car in anger. He was injured by the pieces of glass. He asked
Moshroff to take him to hospital, Moshroff refused to help. Moshroff,
believing that Pollybutton was blinded by injuries, took 10,000 rupees
from his wallet to account for the windshield.

Moshroff then went to a protest organized by Mrs. Razia and

Pseudo Kapistan. Lights went out at the protest for fifteen minutes, in
this pitch black darkness the protestors grew restless and began to
rush and many were trampled as a result. Moshroff in his self-defense,
thinking that protestors might attack him, grabbed a chair and swung
it

around

to

deter

people

from

indeterminate number of thuds.

coming

close.

He

heard

an

Twenty people were found lying

motionless when the lights came on. Moshroff denied responsibility by

saying that they might have been injured due to the rush.
On his way back, he was attacked by five domestic dogs. Among
them were two Chihuahuas of Ms. Zeemy and a Rottweiler belonging to
Monsieur Phillippe. Mohroff was able to dispel the other three dogs by
punching them but the Chihuahuas that slipped out Ms. Zeemys purse
gave Moshroff several minor cuts at his feet. Rottweiler collapsed at
the spot because of the punch and now Monsieur Phillippe wants
Moshroff to pay for the medical expenses.
Few days later, Multibutton came at Moshroffs place to avenge
him for his nephews, Gluebutton, death. He was let on the terrace
where he pointed a revolver at Moshroff. Moshroff proposed the game
of Russian Roulette to settle the dispute and let providence decide.
Moshroff instructed Multibutton to first aim the gun at his own head

and if the gun jams then aim at Moshroff. Multibutton inquired about
the removal of all bullets but one, Moshroff however encouraged him to
go ahead with fully loaded gun. Multibutton pulled the trigger and died.
Discussion
1. Mr. Marankan and Mr. Cordery can be held for public
nuisance and therefore Moshroff can bring a private
action against them.
Fifty thousand protestors had gathered in support of Mr. Marankan
and Mr. Cordrey. These protestors described as rowdy, impeded the
public works and littered the surroundings and led to an unsanitary
environment. Driving in the neighborhood was impossible; Moshroff,
resident of that area, often had to leave his house on foot. Protestors
would at times hit him with a bat or stick or tear his clothes.
According to the Restatement(Second) of Torts 821B a public
nuisance is an unreasonable interference with a right common to the
general public Restatement(Second) of Torts 821B(2)(a) defines a
right common to general public as rights of public health, public
safety, public peace, public comfort, and public convenience. The
Court in Cantwell v. Connecticut, 310 US, held when clear and present
danger of riot, disorder, interference with traffic upon the public

streets, or other immediate threat to public safety, peace, or order,

appears, the power of the State to prevent or punish is obvious. The
Court in IN RE DEBS 158 U.S. 564 (1895) ruled an individual can bring
a private action given that he suffers special damage under public
nuisance.
The protestors of Marankan and Cordrey interfered with public rights
through their conduct as they 1) caused hindrance in the deliverance
of facilities provided by the government for the benefit of general
public,

2)

environment

littered
4)

the

street

disturbed

the

3)

contributed

traffic.

This

is

to
an

an

unsanitary

unreasonable

interference since it poses a threat to public health and has affected

public peace, comfort and convenience. Under Cantwell v. Connecticut
Co such interference with public rights ought to be punished and
prevented by the State. This public nuisance has caused special harm
to Moshroff , who was hit by the protestors and his clothes were torn.
He can hence bring a suit against Marankan and Cordrey under the
rule in IN RE DEBS.
Marankan and Cordrey can be sued for public nuisance since their
supporters caused great inconvenience because of their interference
with public rights. Moshroff was particularly damaged by their conduct
and can therefore successfully bring a private action against them.

2. Moshroff can be held liable for his negligence in causing

injury to Gluebutton which led to his death.
Moshroff while backing his car out of his driveway heard a crunching
sound. Upon inquiry, he found his cars wheel on one of the protestors,
Gluebutton, body. Gluebutton had disabled the lights and so Moshroff
could not see him sleeping in front of his gate.
In Werium v. RKO General, Inc. (1975) 15 Cal.3d 40, the Court
discussed that a person must exercise ordinary care to prevent causing
injury to others by his action but in order to establish duty it is
important that the risk should be foreseeable. The Court further held
that the fact that a particular kind of injury has not occurred before
does not mean that such an injury is not foreseeable. In Vaughan v.
Menlove 3 Bing. (N.C) (1987), the defendant knowing that the rick of
hay on his property was likely to catch fire, allowed it to stand. The
defendant was held liable for the damaged caused by the fire to his
neighbors property. The Court reasoned that the defendant was
negligent because he failed to exercise reasonable caution as prudent
man would have exercised in such circumstances. This is known as
reasonable person standard which suggests that the conduct of the
defendant should be measured against the conduct of a reasonable
person in like circumstances.

Applying the rules set out in Werium v. RKO General and Vaughan v.
Menlove it can be seen that Moshroff was negligent in driving his car
over Gluebutton. Moshroff faced trouble driving his car in and out of his
house and hence, at times he had to leave his house on foot. This
highlights that it was foreseeable that the protestors could be sleeping
on the road outside his house. Moreover, it was common for the
protestors to impede with public works; this suggests that being out of
light was something which could have been foreseen. Knowing the
unusual circumstances prevailing because of a mob of fifty thousand, it
was Moshroffs duty to exercise such care as man of ordinary prudence
would observe. A reasonable man would have assured that no
protestor was in his way while driving out. Moshroffs failure to do so
caused injury to Gluebutton.
Moshroff had a duty to take care under the reasonable man
standard, his breach of duty caused injury to Gluebutton and thus he
can be held liable for his negligence.
3. Gluebutton was contributorily negligent for his injuries
by switching off the lights.
Gluebutton has disabled the lights around Moshroffs house and was
found sleeping outside the gate of his house.

The Court elucidated upon contributory negligence in Walter v. WalMart Stores, Inc 2000 ME 63 (2000). It was defined as negligence by
the plaintiff that unites with the negligence of defendant and makes
the damage the direct result of both the defendants negligence and
plaintiffs contributory negligence. In Crosby v. Plummer 111 ME. 335,
357, 89 A. 145, 146 (1913) it was held that contributory negligence
does not take way the plaintiffs right to recovery only the amount of
damages maybe affected.
Gluebutton was negligent in turning off the lights and then sleeping
on the road right in front of the driveway, as a reasonable man would
have appreciated the risks of this conduct. Gluebutton was responsible
for his injuries; he was the one who had redirected the lights making it
dark and hence difficult for Moshroff to see him. This contributory
negligence would not discharge Moshroff of his duty to exercise care
but it would result in mitigation of the damages paid to the plaintiff
because of plaintiffs unreasonable conduct and failure to exercise
care.
The injury that resulted was due to the failure to exercise care as a
reasonable person would have not only by Moshroff and but also by
Gluebutton.
negligence.

Hence,

Gluebutton

can

be

sued

for

contributory

4. Moshroff can be held liable for his failure to assist

Gluebutton after the accident and thereby increasing the
risk of harm.
Moshroffs car accidently hit Gluebutton, the wheels of his car were
on Gluebuttons chest and thighs. When Gluebutton, in a weak state,
asked for removal of fancy car, Moshroff went on to explain how it
was just an auto-rickshaw and encouraged Gluebutton to push it off
himself because it was that light.
In South v. Amtrak 290 N.W.2d 819(1980), the Court held that the
railway engineer owed a duty to assist plaintiff injured in collision with
the train operated by the said engineer. The decision was based on the
Restatement(Second) of Torts 322, If the actor knows or has reason
to know that by his conduct, whether tortious or innocent, he has
caused bodily harm to another as to make him helpless and in danger
of further harm, the actor is under a duty to exercise reasonable care
to prevent further such harm. A similar decision was reached by the
court in Tubbs v Argus, 140 Ind. App 696 (1967). The court held that
the defendant owes a duty to provide reasonable aid to the helpless
victim who was injured by the instrumentality in control of the
defendant.

Using South v. Amtrak and Tubbs v. Argus, it is evident that Moshroff

owed a duty to assist Gluebutton. The instrumentality causing injury
was in Moshroffs control. It was his car and he failed to remove it,
knowing that the defendant was helpless and in danger; he saw the
wheels of his car on Gluebuttons chest and thigh. It does not matter if
Moshroff was at fault or not while driving his car over Gluebutton as
duty is owed regardless of the fact that the original conduct was
tortious or innocent. Moshroff instead of immediately removing the car
indulged in a conversation with the injured and increased the risk of
harm.
Moshroff could possibly argue in his defense that the plaintiff was in
such condition that even if he had been provided reasonable
assistance, he could not have been saved. However, the Court could
hold him liable by the doctrine of loss of chance spelled and out in
Restatement (Second) of Torts

323(a), Once a plaintiff has

introduced evidence that defendants negligent act or omission

increased the risk of harm to a person in plaintiffs position, and that
the harm was in fact sustained, it becomes a question for the jury as to
whether or not that increased risk was a substantial factor in producing
the harm

Using this doctrine in Beswick v Carestat (2001) 185

F.Supp.2d 418, the Court held that defendant was negligent in his

failure to aid the plaintiff even though the plaintiff only had a 34%
chance of survival.
Moshroff since he had originally injured Glubeutton, can be held
liable for his failure to remove the car and increasing the risk, let alone
his active encouragement to push off the car.
5. Moshroff cannot be held liable for his refusal to take
Pollybutton to the hospital.
Moshroff was driving out when Pollybutton, seeing his uncle
Gluebuttons body in front of Moshroffs gate, smashed the windshield
of. Moshroffs car. Pollybutton was injured by the pieces of glass flying
everywhere. He asked Moshroff to take him to hospital, Moshroff
refused.
In Theobald v Dolcimascola 299 N.J.Super.299 (1997), the question
was whether the friends of the victim, who died playing Russian
Roulette, could be held responsible. The court distinguished between
being actively participating in the game and merely giving instructions
on how to play. It was held that the friends were not liable since there
was no evidence that the friends actively participated or induced the
victim to play and hence they were mere bystanders and owed no duty
to protect him. According to the Restatement(Second) of Torts 314,

the fact that the actor realizes or should realize that action on his part
is necessary for anothers aid or protection does not of itself impose
upon him a duty to take such action. This is illustrated through the
example that a person, who is in position to save a blind man stepping
in way of an automobile, owes no duty towards a blind man.
Pollybutton acted on his own accord and assumed the risks of his
conduct when he smashed the windshield of Moshroffs car. He was not
encouraged by Moshroff to break the glass. The fact that he acted in
anger when he saw the body of his uncle is not sufficient to change the
status of Moshroff from a mere bystander in this particular incident.
Under the above mentioned rule, Moshroff had no duty to rescue
Pollybutton and take him to the hospital.
Moshroff cannot be held liable for his refusal to take Pollybutton to
the hospital since law does not impose a duty to rescue those in peril.
6. Moshroff can be sued under conversion for taking 10,000
rupees from Pollybuttons wallet.
After Pollybutton had smashed the windshield of Moshroffs car,
Moshroff believing that Pollybutton was blinded from the injuries,
reached for Pollybuttons wallet and took 10,000 rupees for the
damage done to the windshield.

In Moore v. Regents of University of California (1990) 51 Cal.3d 120,

the Court elucidated upon what constitutes as conversion. It was held
that, Conversion is the wrongful exercise of dominion over the
property of another. The elements of a conversion claim are: (1) the
plaintiffs ownership or right to possession of the property; (2) the
defendant's conversion by a wrongful act or disposition of property
rights; and (3) damages. Conversion is a strict liability tort. The tort
consists in the breach of an absolute duty; the act of conversion itself
is tortious. Therefore, questions of the defendant's good faith, lack of
knowledge, and motive are ordinarily immaterial In Poggi v. Scott 139
P. 815 Cal (1914), the defendant sold the barrels, which belonged to
the plaintiff, without any wrong motive. He believed the barrels were
empty. The Court held the defendant liable for conversion, ruling that
the foundation for the action of conversion rests neither in the
knowledge nor the intent of the defendant
Under Moore v. Regents and Poggi v. Scott, Moshroffs conduct
amounts as conversion. Moshroff took the cash out of Pollybuttons
wallet without Pollybuttons permission. Hence, he wrongfully took
charge of someones property. Moshroff acted in this manner with the
intention to hold Pollybutton to account for smashing the windshield of
his car. The motive behind Moshroffs action is not significant since
conversion is a strict liability tort.

Taking

someones

property

without

permission

amounts

as

conversion and since the intention does not matter in conversion,

Moshroff can be held liable for conversion.
7. Moshroff was negligent as he breached his duty to take
care even though his actions were in self-defense; this
caused injury to people around him.
When the lights went out in the gathering and the crowd grew
restless, Moshroff acting in his self-defense swung a chair around
himself to deter people from coming close to him. He heard the sound
of chair hitting people but continued to swing the chair.
According to the Restatement (Second) of Torts, 75 and 83, a
person defending himself or his property may be held liable for harm to
third persons if his acts create an unreasonable risk of harm to such
persons.
Moshroff had a duty to take care since any reasonable person could
have realized the threat posed by the blind swinging of chair in pitch
black darkness, without giving any kind of prior warning, amidst a
crowd of people. His conduct hence created an unreasonable risk of
harm to people around. Considering the Restatement, because his

conduct created an unreasonable risk of harm, Moshroff cannot be

discharged from this duty in the name of self-defense.
Moshroffs breach of duty was the proximate cause of injury to
people. It is established that Moshroff heard an indeterminate number
of thuds while swinging the chair and continued to swing the chair
even after hearing these sounds. Given that it was dark, it was
foreseeable that this swinging of chair could result in serious harm for
others around him, which it in fact did.
Moshroff had a duty to not create unreasonable risk of harm, his
breach of this duty caused harm to the protestors around him, he was
hence negligent.
8. The organizers, Mrs. Razia and Pseudo Kapistan, were
negligent in failing to ensure safety of the protestors.
Mrs. Razia and Pseudo Kapistan had organized a protest in a park.
The protest seemed well-organized with lighted stage and music. The
lights went out and the darkness made people restless who began to
rush. Due to this several people were trampled underfoot.
In U.S. v. Carroll Towing Co. 159 F.2d 169 (1947), the Court held that
the duty depends on (1) the probability of the accident occurring (P)
(2) gravity of the resulting injury if the accident does occur (L) and (3)

burden of adequate precaution (B). And duty is owed when marginal

cost of avoiding harm (B) is less than the marginal expected harm (PL).

The organizers of the protest were in the best position to avoid the
harm that resulted. The probability of electric failures and being out of
light is quite high in Kapistan. The organizers should have taken
necessary precautions. They could have avoided the damage by being
equipped with back-up generators; there was no light for fifteen
minutes in a gathering of over two hundred people. The cost of taking
precautions to avoid such circumstances is much less than the
probability multiplied by the loss. It was foreseeable that the crowd
could grow restless in pitch black darkness and that it could result in
injury to the gatherers hence the organizers breach of duty was the
proximate cause of the harm. It is established that the crowd grew
restless, there was rush and several people were trampled as a result,
regardless of the actions of Moshroff.
The organizers were negligent, since that cost of taking precautions
was less than the harm, they had a duty to take care and their breach
of this duty resulted in harm to the protestors.
9. The organizers and Moshroff can be held jointly liable for
the injuries sustained by the protestors.

After the lights went out, people were trampled underfoot because
of the restlessness of the crowd. Moshroffs chair which he was blindly
swinging during this time also hit people. When the lights came on,
twenty people were found lying motionless. Moshroff denied assuming
the responsibility by saying that they might have been injured due to
the rush.
In Summers v. Tice 33 Cal.2d 80, the Court had to decide which of
the two defendants shot hit the plaintiff injuring him in face and eye.
The Court held that both the defendants were jointly liable since it was
impossible to ascertain whether the shots were from the gun of one
defendant or the other or one shot from each of them. It was further
held that in case like this where there are several tortfeasors, the
burden of proof would shift on them to show that they were innocent.
As already established twenty people were lying motionless and
both the parties were negligent. Some of these people might have
suffered harm due to being trampled underfoot; others might have
been harmed because of being hit by the chair. It is not possible to
ascertain how exactly these twenty people suffered injuries. Therefore,
Moshroff and organizers could be held liable joint and severally and the
burden of proof would be on them to show that they their actions were
not the cause of injury to these twenty people.

Since, the sole cause of harm cannot be ascertained and both the
parties were negligent; Moshroff and the organizers can be joint and
severally liable.
10.

Moshroff was injured by Ms. Zeemys dog and can

possibly hold her liable.

Moshroff was set upon by five domestic dogs. He was able to get rid
of first three dogs; the other two, belonged to Ms. Zeemy, however,
were able to cause several minor cuts at Moshroffs feet.
Restatement(Second) of Torts 509 talks about dangerous domestic
animals a possessor of a domestic animal which he has reason to
know has dangerous propensities abnormal to its class, is subject to
liability for harm caused thereby to others although he has exercised
utmost care to prevent it from doing the harm In Matthew Collier v.
Charles Zambito N.Y. 3d 444 (2004) the Court elucidated upon what
could constitute as proof of knowledge of vicious propensities. It held
that the evidence that the dog has been known to growl, snap or
bare its teeth and whether the owner chose to restrain the dog, and
the manner in which the dog was restrained could suggest that the
owner was aware of vicious propensities.

Moshroff sustained several cuts at his feet due to the nipping of

Chihuahuas belonging to Ms. Zeemy. He can hold her liable only if it is
proved that Ms. Zeemy had prior knowledge of her dogs vicious
propensities. Ms. Zeemy had restrained the dogs and that too in her
bag. This suggests it is highly likely that Ms. Zeemy was aware that her
dogs were a danger to others and thus she had restrained them in
such an unusual manner.
Moshroff can also hold the other dog owners liable if (1) it is
established that the owners had knowledge of the dangerous
tendencies of their dogs, for example their dog was known to attack (2)
Moshroff suffered any kind of harm because of the attack. Harm may
include trauma or distress. However, it will be difficult to establish this
claim since there is no sufficient evidence of physical injuries.
Therefore, Moshroff can hold Ms. Zeemy liable for his injuries if
there is sufficient evidence to suggest Ms.Zeemy had knowledge about
the dangerous propensities of her dogs.
11.

Moshroff

cannot

be

held

liable

to

pay

for

Rottweilers medical expenses.

Moshroff was set upon by five dogs; among them was a Rottweiler
which belonged to Monsieur Phillippe. Moshroff was able to dismiss the

dogs by punching them and because of the punch Rottweiler collapsed

on the spot. Monsieur Phillippe wants Moshroff to pay for his dogs
medical expenses.
In Stanley Devincenzi v. Douglas Lovejoy Faulkner 174 Cal.App.2d
250 (1959), the defendant was not held liable for killing a dog ,which
he believed was about to attack a fifteen year old. The Court reasoned
that one is privileged to destroy an animal for the purpose of
defending himself or third persons against harm threatened by the
animal, (a) if its actions led him to know or reasonably believe that the
animal would inflict such harm and (b) the destruction was reasonable
in view of the gravity of the harm threatened and (c) the person
reasonably believed the harm could be prevented only by immediate
destruction of the animal.
Applying these rules, it can be seen that Moshroff is not liable to pay
the medical bills. Moshroff was attacked by five dogs all of a sudden,
including the Rottweiler. It was reasonable for him to believe that they
could harm him and two of them did in fact cause several cuts.
Moshroff was able to chase away the dogs through punching, which
was a reasonable reaction in face of five dogs. Therefore, Moshroff had
a privilege to injure/destroy Rottweiler since he acted reasonably and
purely in self-defense.

Since, the dog posed considerable threat and Moshroff acted in selfdefense, he cannot be held liable to pay for the medical bills.
12.

Moshroff

can

be

held

liable

for

causing

Multibuttons death.
Mutlibutton came to Moshroffs place to avenge him for his
nephews death. Multibutton was let onto the balcony where he pulled
out a revolver and pointed it at Moshroff. Moshroff proposed the game
of Russian Roulette and to leave it on fate to decide who gets to live.
He instructed Multibutton on how to play the game and encouraged
him to go ahead with all the bullets in the revolver.
In Great Central Ins. Co v Tobias 37 (1987) Ohio St.3d 127 it was
held that inducing an individual to engage in Russian Roulette creates
a sufficiently foreseeable harm to engender potential civil liability.
The

issue

at

hand

can

be

distinguished

from

Theobald

Dolcimascola discussed in issue 5, here it can be established through

the conduct of Moshroff that he was an active participant and did
induce Multibutton to play the game. Because he (1) proposed the
game of Russian Roulette (2) gave wrong instructions on how to play it
and (3) upon inquiry by Multibutton through his reply, You are only
confirming the weakness of your faith by asking to change the odds

encouraged Mutlibutton to go ahead with the gun fully loaded.

Applying the reasoning of Court in Theobald v Dlocimascola and Great
Central Ins. Co v Tobias, Moshroff could possibly be held liable for the
death of Multibutton.
Moshroff in his defense can argue that he acted out of self-defense.
However, according to the rule in issue 7, Moshroffs conduct created
an unreasonable risk of harm by proposing a game which could
foreseeably result in Mulitbuttons death. Moshroff can also invoke
principle of comparative negligence to escape liability. The use of this
principle has been highlighted in Theobald V Dlocimascola as
decedents own negligence which, measured against any participants
breach of a duty of care, would probably preclude recovery in most
cases The decedent was negligent as any reasonable person could
have foreseen that playing such a game could result in his death.
A jury could possibly find Moshroff liable but the damages would
certainly

be

mitigated

due

to

the

comparative

negligence

of

Multibutton.
Conclusion
From the above discussion, it seems that Mr. Moshroff is likely to be
found

negligent

in

most

cases.

Using

the

principle

of

comparative/contributory negligence as his defense in the death of

Gluebutton and Multibutton can however significantly mitigate the
damages he would otherwise have to pay. In case of injuring twenty
people, if Moshroff is somehow able to prove that his chair was not the
cause of injury, he can be exempted.
It is likely that Moshroff can successfully claim damages for
inconvenience suffered because of the protestors. While Moshroff has
an actionable claim against Ms. Zeemy if it is shown that she knew
about her dogs dangerous propensities, it is a probably not a good
idea to sue her since he can be held for conversion of her dogs. The
claim against other dog owners would probably not be profitable
because of lack of evidence.