Catelyn Stark Case

Statement of Facts Catelyn Stark (“Cate”) has a claim for Negligent Infliction of Emotional Distress (“NIED”). Cate has an adult son, Jon, born between Eddark Stark (“Ned”) and Wylla Starfall (“Wylla”). Jon was 1 year old when Ned married Cate. 15 months after the marriage, Ned left Jon with Cate and has not contacted them since. Cate never formally divorced Ned or adopted Jon. She had briefly obtained brief custody of Jon but never renewed it since its expiration in 1997. As years passed, both have become very emotionally attached. Jon has always called Cate “mom”, and Cate has always raised him like her own, referring to him as her “son”. Jon briefly attended college before dropping out to pursue his fencing career in order to compete in the Olympics in fencing. On December 23, 2016, Cate was waiting for Jon and his girlfriend Ygritte in the bar area inside the Westeros Restaurant (“Westeros”) at Times Square for a holiday celebration dinner. It was dark and snowing on that evening. The bar area was situated a few feet past the foyer of the restaurant and was open to the dining area with no wall in-between. The front entrance was not easily visible from the bar area. At the time, as a customer attraction, the restaurant had a hovering drone fitted with a camera and mistletoe that hovered outside the restaurant. It flew around filming
the festivities and the people outside the storefront. Many visitors would kiss under the mistletoe and come into the restaurant to eat. The live feed would then be broadcasted through the television screen at the bar area. The drone was operated by Tyrion, the bartender at Westeros. That particular evening, the feed was in black and white and unclear. Tyrion told Cate that the camera was not functioning properly day and blamed the cold weather for the technical issue. At one point, when Cate showed fascination towards the drone, Tyrion flew the drone into the restaurant and let it hover over Cate for few minutes before sending it back outside. Cate continued to watch the live TV feed from the bar and she saw someone that had a vague resemblance of Jon walking towards the entrance.
There were eight people in the camera view and everyone was wearing the similar Black attire. The man had messy dark curly hair and was wearing a dark ivy cap that looked similar to what Jon owned. When he looked up at the mistletoe and paused directly under the drone, Cate saw pieces of fragments fly across the screen, and the screen went blank. She then heard a loud crash, and with that, the storefront window shattered. Pieces of drone flew into the dining area and the place went
chaotic. When the screen became clear, she saw a man lying on the ground. She immediately ran outside calling out Jon. Once she was outside, she was able to confirm that the man on the ground was her son. He was unconscious. One of the flying propellers from the explosion tore off much of his face and significantly injured both of his arms. Upon witnessing her son’s injury, Cate fainted and hit her head on the pavement. Meanwhile, Westeros maintains that this was a freak accident and continues to claim that drones are largely safe.