Jenner is asking that the paparazzi be held responsible for any liability she may incur.
In court documents obtained by PEOPLE Jenner accuses the photographers – collectively referred to as “the Stalker Defendants” – of “harassing [her] throughout the day up through the time of the accident.”
Jenner describes the alleged harassment as driving too close to her vehicle in order to snap photos, tailgating her and overall driving in a reckless manner in attempts to get their pictures.
“As a direct consequence and result of this stalking, harassing and distracting conduct, [Jenner] was visually distracted, and the negligence and reckless conduct of the Stalker Defendants did contribute to the cause of an accident where seconds and split seconds mattered,” the document reads.
In the lawsuit, Jenner is asking that the accused parties be held at least partially responsible for any liability Jenner ensues, and that they bear the financial responsibility of any damages and legal proceedings that occurred as a result of the accident.
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The incident in question occurred in February of last year when Jessica Steindorff stopped for unknown reasons in front of a vehicle driven by Kim Howe, causing Howe to slam on her breaks. Travelling in the car behind Howe was Jenner, who subsequently rear-ended Howe, causing her to swerve into oncoming traffic, which resulted in her death.
Although Jenner settled a separate lawsuit with Steindorff in December, Steindorff is listed in her current complaint, as Jenner accuses the woman of “sitting stopped in the middle of Pacific Coast Highway looking at her cellphone,” and “driving at a speed (zero) unreasonable for the conditions,” and “driving with a suspended license.”