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IN THE CIRCUIT COURT nofi-u .e q

0J couNrY, TENNESSEE

DANrE R. SATTERFIELD, 20lt JUL - I Pll

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Plaintiff/Counter-Defendant, l
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TAJAE SHARPE, and ) JURY DEMANDED

SEBASTIAN TRETOLA )
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D efen d ants/C o u nter-Pl aintiffs. )
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COUNTERCLAIM

Come now Defendants/Counter-Plaintiffs, Tajae Sharpe and Sebastian Tretola, by and

through counsel, and asseft the following counterclaim against Plaintiff/Counter-Defendant, Dante

R. Satterfield:

PARTIES

1. Counter-Plaintiff Tajae Sharpe ("Sharpe") is a citizen ancl resident of Nashville,

Davidson County, Tennessee.

2. Counter-Plaintiff Sebastian Tretola ("Tretola") is a citizen and resident of

Nashville, Davidson County, Tennessee'

3. Upon information and belief, Counter-Defendant Dante R. Satterfield

("Satterfield") is a resident of Nashville, Davidson County, Tennessee.

JURISDICTION AND VENUE

4. The allegations of Paragraphs 1 through 3 of this Counterclaim are incorporated by

reference as if fully set forth herein.

5. The events described in the Counterclaim upon which the causes of action arise

occurred in Davidson County.

 6, Venue is appropriate in Davidson County pursuant to T.C.A. $ 20-4-101(a) and (b).

7 . This Court has jurisdiction pursuant to 'l"C'A. li 16-10-101.

FACTS

8. The allegations of Paragraphs 1 through 7 of the Counterclaim are incorporated by

reference as if fully set forth herein.

g. On the evening of April 27,2011, Sharpe and Tretola met each other at the Green

Room at Tin Roof Demonbreun ("Tin Roof') to socialize.

10. Later in the evening, Sharpe and Tretola were approached by Satterfield, who

appeared to want to socialize with them.

1 i. Prior to Ap|27,2017, Sharpe and Tretola had never met Satterfield.

12. After speaking politely with Satterfield as they would any other fan, Sharpe and

Tretola returned to their private conversation.

13. Satterfield continued to try to socialize with Sharpe and Tretola, and kept placing

his hands on the shoulder and back of Sharpe.

14. Satterfield became increasingly inebriated and persistent as the night grew on, and

continued to approach Sharpe and Tretola.

15. Sharpe specifioally and politely told Satterfield to stop placing his hands on him.

16. Satterfield persisted and continued touching Sharpe.

17. At this point, Sharpe and Tretola told Satterfield in no uncertain terms that they

wanted to be left alone and directed him to leave.

18. Satterfield became extremely agitated and belligerent, and began shouting, cursing,

and threatening Sharpe as witnessed by many individuals at Tin Roof. Satterfield claimed that he

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was a gang member from East Nashville and he made clear from his words and actions that he was

threatening Sharpe' s physical safety.

. After an exchange of words, Sharpe and Tretola left Tin Roof and proceeded

southwest up the hill on Demonbreun Street.

20. Satterfield followed the two out of Tin Roof, walking about ten feet behind them

and continuing to shout, curse, and threaten Sharpe and Tretola.

21. It was obvious by this point that Satterfeld was not going to leave Sharpe and
Tretola alone; Satterfield made it clear that he was determined to have an altercation with Sharpe

and Tretola.

22. Sharpe turned around and stopped. Satterfield continued walking up to Sharpe, and

made it clear by his words and actions that he was about to strike Sharpe.

23. As Satterfield drew back to punch Sharpe, Sharpe threw a single punch with his

right hand to Satterfield's face, knocking him to the ground.

24. Sharpe walked away aftet Satterfield fell to the ground.

25. Satterfield became enraged, and got up from the ground and sprinted after Sharpe,

who was now in proximity with Tretola.

26. Tretola turned around and saw Satterfield screaming and sprinting towards him.

Tretola instinctively turned and threw Satterfield to the side, using Satterfield's own momentum

against him. Satterfield impacted the wall and floor of the alley with his face.

27. With the threat now neutralized, Sharpe and Tretola continued on their way.

28. After impacting the ground, Satterfield got up and continued to talk in an offensive

manner to Sharpe and Tretola, but made it clear he no longer was interested in continuing the

altercation.

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 COUNT I _ ASSAULT AGAINST SHARPE

29, The allegations of Paragraphs 1 through 28 of the Counterclaim are incorporated

by reference as if fully set forth herein.

30. Satterfield intended to cause a harmful or offensive contact with Sharpe, or intended

to cause an imminent apprehension of such contact, and did contact Sharpe in an offensive manner.

31. Sharpe was reasonably put in imminent apprehension of a harmful or offensive

contact by Satterfield.

AGAINST TRE L

32. The allegations of Paragraphs 1 through 31 of the Counterclaim are incorporated

by reference as if fully set forlh herein.

33. Satterfield intended to cause a harmful or offensive contact with Tretola, or

intended to cause an imminent apprehension of such contact.

34. Tretola was reasonably put in imminent apprehension of a harmful or offensive

contact by Satterfield.

COUNT III. PUNITIVE DAMAGES

35. The allegations of Paragraphs 1 through 34 of the Counterclaim are incorporated

by reference as if fully set forth herein.

36. Counter-Plaintiffs are further entitled, by virtue of the willful, wanton, reckless and

intentional nature of the wrongs of Counter-Defendant, to an award of exemplary and punitive

damages in an amount sufficient to punish Counter-Defendant for his wrongdoing and to deter him

and others like him from committing such acts again in the future.

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 V/HEREFORE, PREMI SES CON SIDERED, Counter-Plaintiffs demand the following :

1. That a jury be impaneled to try this cause;

2. That Counter-Plaintiffs be awarded a judgment against Counter-Defendant in an

amount to be determined by the jury to be sufficient to compensate them in accordance with law

for their damages as set forth above.

4. That the costs of this action be awarded to Counter-Plaintiffs.

5. That Counter-Plaintiffs receive such further and other general relief to which they

may be entitled.

Respectfully submitted,

NEAL & HAR\ryELLO PLC

By:
V/illiam T. Ramsey #009245
Robert A. Peal, #025629
Christopher M. Bellamy, #03 17 98
1201 Demonbreun Street, Suite 1000
Nashville, TN 37203
(615) 244-1713 - Telephone
(615) 726-0573 - Facsimile
Counsel for Counter-Plaintiffs Tjae Sharpe and
Sebastian Tretola

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 CERTIFICATE OF SERVICE

I hereby certify that on this the 7th day of July, 2017 , a copy of the foregoing was served

by email and first-class mail, postage prepaid, on

J. Alex Little
James A. Crumlin, Jr.
511 Union Street, Suite 1600
Nashville, TN 37219

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