10. On February 17, 2013, Plaintiff Lealao was in Module 2B Quad 3 at HCF when he was viciously attacked by numerous violent and/or dangerous inmates from another Quad ("assailants").
11. During the subject incident, Plaintiff Talitiga was also attacked while trying to stop assailants from mauling Plaintiff Lealao.
12. Prior to the subject attack, ACO Billy Makaila, an officer, agent and/or employee of Defendants, allowed and/or permitted assailants to attack Plaintiffs by opening the assailants' secured Quad door, allowing and/or permitting assailants to travel down the stairs to Plaintiffs' Quad, and opening Plaintiffs' secured Quad 3 door.
13. As a direct and proximate result of the attack described above, Plaintiff Lealao nearly died, and he sustained severe and permanent catastrophic, life-threatening, and debilitating physical, mental, and emotional injuries, pains, limitations, and disabilities, including but not limited to, traumatic brain injury with physical and psychological residuals, intracranial hemorrhage, epidural and/or subdural hematoma, loss of consciousness, left facial laceration, left upper lip laceration, bilateral nasal bone fractures, fracture of the nasal septum and the nasal spine, anorexia, headaches, visual disturbances, visual flashes, weakness, sleep deprivation, lightheadedness, nausea, memory loss, dizziness, blacking out, PTSD, anxiety, nightmares, head pain, face pain, neck pain, back pain and other damages and/or injuries to be proven at trial.
14. As a direct and proximate result of the attack described above, Plaintiff Talitiga sustained severe and permanent physical, mental, and emotional injuries, pains, limitations, and disabilities, including but not limited to, head pain, face pain, teeth injuries, jaw pain, neck pain, back pain, leg pain, knee pain, hip pain, headaches, and other damages and/or injuries to be proven at trial.