ARCTIC TERRITORY
NORTH POLE CIRCUIT COURT
CIVIL ACTION FILE NO. 2011-CI-________
COMPLAINT
RUDOLPH THE REINDEER PLAINTIFF
v.
NORTH POLE DISTRIBUTING, INC. DEFENDANTS
KRIS KRINGLE
COMET THE REINDEER
Comes now the Plaintiff, Rudolph the Reindeer, and for his claim herein against the Defendants, states and alleges as follows:
1. Plaintiff Rudolph the Reindeer (“Rudolph”) resides at 283 Cave St., Christmastown, North Pole.
2. Defendant North Pole Distributing, Inc. is a corporation with its principal place of business located at 100 Santa Claus Ln., Christmastown, North Pole.
3. Defendant Kris Kringle (aka Santa Claus) (“Kringle”) is an individual residing at 200 Santa Claus Ln., Christmastown, North Pole, and is the President, CEO, and self-proclaimed “King of Jingling” of North Pole Distributing, Inc.
4. Defendant Comet the Reindeer (“Comet”) is an individual residing at 242 Cave St., Christmastown, North Pole, and is an employee of North Pole Distributing, Inc.
5. Defendant North Pole Distributing, Inc. runs a youth training program, commonly known as Reindeer Games, for applicants to its distribution center’s transport division.
6. Defendant Comet is the immediate supervisor to all trainee applicants and makes hiring recommendations to the President and CEO of North Pole Distributing, Inc.
7. Defendant Kringle makes all hiring decisions for North Pole Distributing, Inc.
8. Rudolph applied to the Reindeer Games training program and participated in a single session.
9. During said session, Defendants Comet and Kringle observed Rudolph and commented positively about his abilities as a reindeer.
10. During said session, Comet and the other trainees discovered that Rudolph suffers from a physical impairment known as erythema nasalis, which makes his nose shine bright red, but causes no medical problems other than aesthetic ones.
11. When the other trainees discovered Rudolph’s impairment, they called him disparaging names, including, but not limited to fire snoot, bright schnozz, rainbow puss, neon nose, and Rudolph the red-nosed reindeer.
12. Defendant Comet did nothing to curtail the taunts made by trainees under his supervision, and in fact joined them, stating “From now on, gang, we won’t let Rudolph join in any of our Reindeer Games.”
13. Defendant Kringle was present during the training session and concurred with Comet, telling Rudolph’s father “You should be ashamed of yourself. What a pity. He had a nice takeoff too.”
14. Kringle was previously made aware of Rudolph’s disability and told Rudolph’s parents that Rudolph was “smart” but that they had better hope the disability went away if he was ever going to pull Kringle’s sleigh.
Reindeer with Disabilities Act (RDA) (42 Arctic Territory Code § 12111 et seq.)
15. Plaintiff incorporates herein as if set forth verbatim hereafter, each of the allegations contained paragraphs 1 through 14 above.
16. Rudolph’s abilities and superior performance in the Reindeer Games training program clearly qualified him for consideration and placement in North Pole Distributing, Inc’s transport division.
17. Although Defendants Comet and Kringle admitted to Rudolph’s superior aptitude, they would not consider him as an employment candidate and barred him from further training strictly due to his disability.
18. The actions of Defendants constitute intentional and insidious discrimination against a reindeer with disabilities in violation of the Reindeer with Disabilities Act (RDA) 42 A.T.C. § 12111 et seq.
19. Plaintiff is entitled to damages for loss of income, and punitive damages as provided by statute.
Intentional Infliction of Emotional Distress
20. Plaintiff incorporates herein as if set forth verbatim hereafter, each of the allegations contained paragraphs 1 through 19 above.
21. Defendant Comet encouraged and participated in the public taunting of Plaintiff due to his disability.
22. Defendant Kringle made multiple suggestions to Rudolph’s parents, in front of Rudolph, that they should be ashamed for having a disabled child.
23. Defendants have intentionally, recklessly, and maliciously engaged in outrageous conduct.
24. Plaintiff has incurred damages as a result of the severe mental distress caused by Defendant’s actions.
WHEREFORE, Plaintiff Rudolph the Reindeer respectfully requests as follows:
1. Judgment against Defendants for damages exceeding the jurisdictional minimum amount of this Court;
2. Punitive damages for intentional tortious action by Defendants;
3. Plaintiff’s costs;
4. Any other remedy this Court may grant.
_______________________________
Jack Frost, Esq.
1400 Frost King Rd., Suite 300
Kaffeklubben Island, Greenland
Next year tune in for State v. Yukon Cornelius and Hermey the Elf, both charged with animal cruelty against an endangered yeti.