10/22/2025 9:42 AM Jacquell WAYNE COUNTY CLERK 25-016609-CZ FILED INMY OFFICE Cathy M. Garrett AYAD LAW, P.L.L.C. Ps (212) 883-4600 | Fr (312) 983-4665 IN THE STATE OF MICHIGAN IN THE THIRD JUDICIAL CIRCUIT COURT FOR THE COUNTY OF WAYNE S.M. a minor, by her Next Friend, Amirah Shathan, FAWZIA FAREA, And AMIRAH SHARHAN, individually, Case No.: 2024- CZ Plaintiff, Hon, vs. GARY LANSKY Defendant, AYAD LAW, PLLC Nabih H. Ayad (P59518) William D. Savage (P82146) Attorney for Plaintiff 645 Griswold St., Ste. 2202 Detroit, MI 48226 P: 313-983-4600 [email protected] There is no other civil action between these parties arising out of the same transaction or occurrence as alleged in this Complaint pending in this Court, nor has any such action been previously filed or dismissed or transferred after having been assigned 0 a Judge. PLAINTIFF S.M., AMIRAH SHARHAN, AND FAWZIA FAREA’S COMPLAINT NOW COME, Plaintiffs, S.M., Amirah Sharhan, and Fawzia Farea by and through her attorneys, AYAD LAW PLLC, by Nabih Ayad, and in support of her Complaint for damages against Defendant Gary Lansky and allege the following: 1|Page2|Pa NATURE OF THE ACTION ‘This is an action for damages for assault and battery and intentional infliction of emotional distress under MCLS § 600.5805 and the common law. PARTIES Plaintiff, S.M., is an individual, United States Citizen, who currently resides in Dearborn, Michigan. Plaintiff Amirah Sharhan is an individual, United States Citizen, and mother of Plaintiff S.M., who currently resides in Dearborn, Michigan. Plaintiff Fawzia Farea is an individual, United States Citizen, and grandmother of S.M. who currently resides in Dearborn, Michigan. Defendant Gary Lansky is an individual, United States Citizen, and resident of Detroit, Michigan, JURISDICTHON AND VENUE This matter is properly before this Honorable Court as the parties all reside in the County of Wayne, where the events giving rise to this action took place. Jurisdiction is proper pursuant to 600.605 and MCL 600.601 as this court has original jurisdiction to hear and determine all civil claims and remedies, except where exclusive jurisdiction is given in the constitution or by statute to some other court or where the circuit, courts are denied jurisdiction by the constitution or statutes of this state, Jurisdiction is also proper pursuant to MCL 600.8301 as the amount in controversy exceeds $25,000.00 exclusive of interest, cost, and attorney's fees. ‘Venue in this Court is proper pursuant to MCL 600.1627 as all of the events giving rise to this cause of action occurred in the City of Dearborn, Wayne County, MLAYAD LAW, P.L.L.C. Ps (212) 883-4600 | Fr (312) 983-4665 10. Venue in this Court is also proper pursuant to MCL 600.1621 as Defendant Walmart has a place of business and conducts business in Wayne County, MI FACTUAL ALL GATIONS 11, Tuesday, October 8, 2024, was a warm day in Dearborn, perfect for children to go play at the park 12, Also on that day, a loving grandmother was visiting her granddaughter. 13, Plaintiff (NAME) and S.M. were sure that there would be plenty of children playing on the playground at the nearby Ryan Park, which S.M. loved, and together decided they would g0 to the park so that S.M. could run and play with the other children. 14, Unbeknownst to this grandmother and granddaughter, elsewhere, Defendant Gary Lansky was driving around, daydreaming about slashing a child’s throat in front of the child’s parent’s and peers. 15. Unfortunately, on Tuesday, October 8, 2024, while Fawzia Farea watched S.M. run and laugh with the other children on the playground, Gary Lansky drove from his home in Detroit to Ryan Park in Dearborn. 16, Upon seeing S.M., Defendant Gary Lansky parked his van and, without hesitation, walked up to S.M., a 7-year-old gir! playing in the public park, grabbed her by the chin, yanked back her head, with one hand and with the other manifested his sadistic fantasy. He dragged his knife across S.M.’s delicate neck, opening it. 17. Blood gushed out from S.M., throat, but Lansky was not satisfied. He then attempted to gut little S.M., by ramming his blade into her stomach 3|Page18. 19, 20. 21 22. 23. Miraculously, S.M., fell from Lansky’s grasp landing on her back before the knife could pierce her stomach and was able to kick Defendant away as he fumbled to catch her once again S.M. scurried away from her attacker and driven completely by unthinking terror, sprinted the entire way to her home while holding her open neck wound with her hands to avoid bleeding out. By the time all of this had occurred, Plaintiff Farea was approaching Defendant Lansky to protect her grandchild with her life if needed. Defendant Lansky was moving towards Farea to slash her when bystanders at the park began yelling that he had a knife. Like many fiends, Defendant Lansky is also a coward and lost his nerve at the sound of the crowd’s outrage. Defendant then ran to his van and fled the park, no doubt in the hopes of being able to strike again at a random time.! When SM. burst into her home, her family was immediately alerted by her franticness. S.M. asked frantically for paper towels for her neck Her family had to convince her to remove her hands, and words cannot describe what it was to see seven-year-old S.M’s slashed throat. S.M. was transported to a Corewell hospital via ambulance, where she received 20 stitches on her throat, ' This was not Defendant Lansky’s first knife attack, as two weeks before he had stabbed two women, 4|Pa28, Defendant was apprehended by Detroit Police shortly after the attack. He was subsequently arrested and charged with assault with intent to murder. 29. S.M. is currently recovering from her physical wounds 30. S.M. is also currently in therapy to try to make sense of and heal from her deep psychological trauma caused by Defendant's attack. 31, Because of Defendant's attack, S.M. has suffered great psychological harm in addition to her physical wounds. 32, Since the attack, S.M. has been attacked again and again in her ni times. To this day, multiple nights a week, Plaintiff Amirah is awakened by S.M’s cries and screams in the middle of the night that she is being attacked. Plaintiff Amirah must rush into $.M’s room and calm her daughter down, holding her and crying with her. 33. S.M. suffers from constant nightmares that prevent her from sleeping, post-traumatic stress disorder, anxiety, and depression. 5|Page34, 36. 37. 38, 40. 6|Pa S.M. is not only afraid to leave her house but is also afraid to be separated from her mother even when both of them are in the same house, S.M. has been unable to go to school, the park, or most public spaces. She is afraid of all strangers getting close to her, and she is especially afraid of older men because she was targeted by one. S.M. is not the only victim of Defendant. Her mother, Plaintiff Amirah Sharhan, has also been traumatized by Defendant. Plaintiff Amirah Sharhan also suffers from post-traumatic stress disorder, anxiety, depression, and nightmares, over what happened to her 7-year-old daughter. Plaintiff Amirah Sharhan was traumatized at the sight of her daughter holding her sliced and bleeding neck, the surgery her daughter had to endure and not knowing whether she \was going to live or die, and from the trauma that her daughter faces. Plaintiff Farea also suffers from post-traumatic stress disorder and anxiety due to Defendant's assault COUNT I ASSAULT (As to Plaintiff S.M, and Plaintiff Fawzia Farea The tort of assault is well established in Michigan. The Court of Appeals has stated: “An assault is defined as any intentional unlawful offer of corporal injury to another person by force, or force unlawfully directed toward the person of another, under circumstances which create a well-founded apprehension of imminent contact, coupled with the apparent present ability to accomplish the contact.” Tinkler v Richter, 295 Mich 396, 401; 295 NW 201 (1940); Prosser & Keeton, Torts (Sth ed), § 9, p 39. wae “The intent necessary to make out a tortious assault is either an intent to commit a battery or an intent to create in the victim a reasonable fear or apprehension of an immediate battery.”Pr (1a) 4 42. 43. 44. 4s, 46. 7|Pa The Restatement of Torts provides: "§ 21. Assault (1) An actor is subject to liability to another for assault if (a) he acts intending to cause a harmful or offensive contact with the person of the other or a third person, or an imminent apprehension of such a contact, and "(b) the other is thereby put in such imminent apprehension. "§ 32. Character of Intent Necessary "(1) To make the actor liable for an assault, the actor must have intended to inflict a harmful or offensive contact upon the other or to have put the other in apprehension of such contact.” Mitchell v. Daly, 133 Mich. App. 414, 426 Here, Defendant assaulted S.M. when he intentionally and unlawfully approached her to cut her neck and stab her in the belly. Defendant assaulted S.M. when he reached for her neck with a knife, because he intentionally put her in immediate fear that he was going to hurt her by cutting her neck. Defendant also assaulted S.M. when he intentionally and unlawfully lunged his knife toward her belly, intentionally trying to stab her, and putting her in immediate fear that he was going to stab her in the belly. Defendant also assaulted Fawzia Farea when he turned his attention and knife towards her and approached her with his knife to attack before having to run away due to the increasing screams in fear at the park. Farea saw Defendant unlawfully and intentionally approaching her with his knife directed towards her intending to hurt her and screamed in fear that Defendant was going to attack her with the knife. Defendant would have attacked Farea, had she not yelled in fear so loudly as to draw attention to him. Asa direct and proximate cause of Defendant’s conduct, Plaintiff, S.M., and Fawzia Farea, has suffered severe mental anguish and psychological trauma, manifesting itself in physicalPr (1a) 47. 48, 49. 50, symptoms, including but not limited to, depression, anxiety, sleep-deprivation, and the need for pharmaceutical and psychological treatment. COUNT BATTERY (As to Plaintiff S.M.) Plaintiffs incorporates and re-alleges paragraphs 1-46 above by this reference. The tort of battery is also well established in Michigan, The Court of Appeals has stated that “A battery is the wilful and harmful or offensive touching of another person which results from an act intended to cause such a contact.” Tinkler, supra; Prosser & Keeton, supra. Espinoza v. Thomas, 189 Mich. App. 110, 119. Here, Defendant committed a battery onto S.M. when he lifted her head up with one hand and sliced her neck open with a knife in his other hand, SM. suffered a battery at the direct and proximate cause of Defendant attacking her and physically cutting her with his knife, and as such continues to suffer severe mental anguish and psychological trauma manifesting itself in physical symptoms including but not limited to depression, anxiety, sleep-deprivation, and the need for pharmaceutical and psychological treatment. COUNT Il INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (As to all Plaintiffs.) Plaintiff incorporates and re-alleges paragraphs 1-S0 above by this reference. 2. The elements of intentional infliction of emotional distress are as follows: (1) extreme and outrageous conduct; (2) intent or recklessness; (3) causation; and (4) severe emotional distress. Jd.53. The court in Johnson held that “liability for such a claim has been found only where the conduct complained of has been so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious and utterly intolerable in a civilized community.” /d. 54. Here, the elements of intentional infliction of emotional distress, as outlined in Johnson, are met 55. Under the first element, Defendant's conduct, specifically, the fact that he walked up to a little girl in a park and slit her throat and attempted to stab her were extreme and outrageous and went beyond all possible bounds of decency and should be regarded as atrocious and utterly intolerable in a civilized community, as outlined under Johnson. 56, Under the second element, Defendant’s conduct was intentional, Defendant purposefully and knowingly with intent to cause harm and great bodily injury attacked a 7-year-old and her grandmother. 57. Under the third element, Defendant’s conduct was a direct and proximate cause of each Plaintiff's injuries. But for Defendants’ conduct, Plaintiff $.M., Amirah Sharhan, and Fawzia Farea, would not have suffered physical and psychological harm, 58. Under the fourth element, Defendant’s conduct resulted in each Plaintiff's extreme emotional distress. Namely, Plaintiff S.M. has had to seek immediate medical treatment, pharmaceutical treatment, and psychotherapy as a result of Defendant’s conduct, Plaintiff S.M., Amirah Sharhan, and Fawzia Farea have endured psychological trauma. Fareaform the near physical attack and Sharhan from having to see her daughter with a slit throat almost bleeding to death and the surgery to follow, manifesting in physical symptoms, including but not limited to, depression, anxiety, and sleep-deprivation. 9|PageAYAD LAW, P.L.L.C. Ps (212) 883-4600 | Fr (312) 983-4665 59. As such, Defendant should be held liable for committing the tort of intentional infliction of emotional distress as to each Plaintiff, CONCLUSION AND PRAYER FOR REI F Defendant Gary Lasnky has now been adjudicated competent to stand criminal trial; having been carefully evaluated by mental health professionals. In other words, he is able to understand the nature and consequences of his actions. He is a monster that has taken more from S.M, than could ever be given back to her. In an attempt to find some peace and justice, however, S.M. and her family now ask for the following: WHEREFORE, Plaintiffs respectfully requests that this honorable court grant the following remedies: a, Enter a judgment against Defendant and in favor of all Plaintiffs on all counts; b. Award Plaintiffs compensatory, exemplary, and punitive damages of at least $50,000,000; c, Award all other damages available to Plaintiff to the fullest extent allowable under the law, d. Award Plaintiffs reasonable attomeys’ fees, costs, and interest; and e, Award any further legal and equitable relief as this court deems just and proper. Respectfully submitted, AYAD LAW, PLLC AiNabih H. Ayad Nabih H. Ayad (P59518) William D. Savage (P82146) Attorney for Plaintiffs 645 Griswold St., Ste. 2202 Detroit, MI 48226 Dated: October 22, 2025 P: 313.983.4600 | F: 313.983.4556 10|Paze