Clarke died in Colombo [Sri Lanka] on 19 March 2008, at the age of 90. His aide described the cause as respiratory complications and heart failure stemming from post-polio syndrome.
As a direct and proximate result of Defendants’ actions in violation of New York Civil Rights Law § 52-B, Plaintiff has suffered and continues to suffer emotional harm, including mental anguish, emotional distress, and humiliation in an amount to be determined at trial.
Plaintiff had a reasonable expectation that Defendants would not secretly record a violent rape of her and disseminate the video to others.