Jeff and his coworkers frequently visit a local bar on their way home from their second-shift factory jobs. They are anxious to reach the bar on this particular night because their favorite NFL team is playing. Jeff hopes they will arrive in time to view the fourth quarter of the game. As he enters the bar, he notes a group of noisy, obnoxious rival fans who have had too many drinks. Jeff asks the group to quiet down so he can hear the game. He is immediately approached by members of the group who ask if he wants to make an issue of the game. Before Jeff can answer, one member of the group throws a punch. Within minutes, a full bar brawl ensues. Jeff ends up with a fractured skull, which results in brain damage. What type of lawsuit will Jeff be able to file against his aggressors