From the Statement of Claim:
Liability of Ford, Aboodowleh, and Petros
55. Ford, Aboodowleh, and Petros conspired among themselves and with others whose identity is known to them but not known to the plaintiff, to arrange for the attack on the plaintiff and to cause him serious harm. In particular, Aboodowleh, acting as Ford's agent and with Ford's explicit or tacit approval, contacted Petros and Williams and instructed them to send a message to the plaintiff, first in the form of threats of physical harm, and then in the form of a brutal assault and battery of the plaintiff.
56. Ford and Aboodowleh arranged for persons employed by MWDC, whose identity is known to Ford and Aboodowleh but not known to the plaintiff, to facilitate the exposure of the plaintiff to Petros, and to facilitate the attack on the plaintiff on March 23, 2012, and more particularly, to arrange for the plaintiff’s detention in range 1B, and to ensure that there was no supervision or surveillance of the area where the plaintiff was assaulted.
57. Petros agreed to and ultimately did carry out the instructions of Ford and Aboodowleh, or in the alternative arranged for others to do so.
58. The various matters set out in paragraphs 55 to 57 above and elsewhere in this statement of claim were the subject of communications between the defendants during visits by Ford and Aboodowleh (or either of these) to MWDC, and on calls and messages sent and received by the defendants on their mobile telephones.
59. Ford and Aboodowleh knew that the plaintiff would suffer physical harm as a result of their actions, which included instructing Petros to send a message to the plaintiff that he should not expose Ford's illicit drug use or his association with criminals.
60. As a result of the conduct of the defendants, or the conduct of those for whom the defendants are liable, as set out above, the plaintiff has suffered damages as set out above.
61. The conduct of the defendants, or those for whom they are vicariously liable, is sufficiently reprehensible, oppressive and high-handed so as to justify the court's denunciation with an award of exemplary damages, and further justifies penal damages.