Thomas, Means, Gillis & Seay join forces with Cory, Watson, Crowder & DeGaris To Represent Victim of Bremen, GA. Fatal Motel Explosion

Size: px
Start display at page:

Download "Thomas, Means, Gillis & Seay join forces with Cory, Watson, Crowder & DeGaris To Represent Victim of Bremen, GA. Fatal Motel Explosion"

Transcription

1 Thomas, Means, Gillis & Seay join forces with Cory, Watson, Crowder & DeGaris To Represent Victim of Bremen, GA. Fatal Motel Explosion Suit names Atlanta Gas Light Company, Atlanta Gas Services, Inc., Alpine Gas, Inc., Cox Plumbing & Septic, Inc. and the motels owners as responsible for the explosion ATLANTA July 18, 2006 Thomas, Means, Gillis & Seay, P.C. today announced that they have joined forces with Cory Watson Crowder & DeGaris to seek justice for the family of Mr. Reese Helton, the victim of last month s explosion at a Bremen, Georgia motel. The lawsuit has been filed against Atlanta Gas Light Company, Atlanta Gas Light Services, Inc., Alpine Gas, Inc., Cox Plumbing & Septic, Inc., and the motel s owners, Devendra Patel, Kirit Patel, and Hemlata Patel. The victim, Reese Helton, was doing work at the Great Western Inn in the motel laundry room at the time of the explosion. The blast occurred after the motel s owners hired Alpine Gas, Inc. to install a liquid propane tank and run gas lines to the motel s gas appliances when their natural gas service was disconnected due to non-payment. Sometime prior to the explosion, however, Atlanta Gas Light Company returned to restart the natural gas service to the motel. Investigators at the scene found an open gas line which seeped gas into the laundry room where it ignited causing an explosion and fire and killing Mr. Helton. According to witnesses who heard his screams and pleas for help, Mr. Helton was trapped in the laundry room as the building burned. Several guests had checked out of the motel only hours before the explosion. The number of ways this tragedy could have easily been prevented is staggering, said Quinton Seay, of Thomas, Means, Gillis & Seay. Had the Patels put public safety ahead of profits, they wouldn t have put people s lives at risk. Had Alpine Gas, Inc., Atlanta Gas Light Company, Atlanta Gas Light Services, Natural Gas Company and Cox Plumbing properly checked the lines and connections, this explosion would never have occurred, said Ernie Cory of Cory, Watson, Crowder & DeGaris. Reese Helton had done work for the Great Western Inn for one and a half years. Mr. Helton was known to be a hardworking man and devoted father. He is survived by his three children and his mother, whom he helped to support, along with three brothers.

2 Authorities are still attempting to positively identify the victim s body because, according to officials, it was burned beyond recognition by the blast. The Helton family appreciates all that State and local law enforcement have done to help them identify the body and the source of the explosion, added Jason Shamblin of Cory, Watson, Crowder & DeGaris. We are working closely with the proper authorities to help bring justice to the Helton family and give them the opportunity to give Reese a proper burial. About Thomas, Means, Gillis & Seay, P.C. Celebrating 25 years of service, Thomas, Means, Gillis & Seay, P.C. (www.tmgslaw.com) is a law firm comprised of professionals dedicated to making the justice system work. Our legal expertise spans the civil litigation spectrum which includes cases of wrongful death, serious personal injury and product liability case work in addition to legal expertise for a variety of government agencies and high profile white-collar criminal defense cases. Our firm has handled some of the most challenging and notable plaintiff and defense cases tried in the southern United States for a quarter of a century, with more than 50 milliondollar and multi-million dollar claims grossing more than $250 million in verdicts and settlements. Established in 1981, Thomas, Means, Gillis & Seay maintains offices and staff in Birmingham, Ala., Livingston, Ala., Montgomery, Ala. Hayneville, Ala. and Atlanta, Ga. About Cory Watson Crowder & DeGaris Cory Watson Crowder & DeGaris (www.cwcd.com) was founded in 1995 and has become known as one of the region's leading law firms devoted to representing individuals and businesses injured by the wrongful conduct of others. Some of the senior shareholders in the firm have 25 years of legal experience and have represented clients all across the United States and beyond including Africa, Greece, Latin America and Canada. Cory Watson's 12 experienced attorneys and staff of over 40 handle a variety of cases. The largest area of the firm s practice is Products Liability, including litigation of defective consumer and household products, motor vehicles, medical devices and pharmaceuticals. Other practice areas include business litigation, personal injury, nursing home negligence, insurance law, civil rights, class action lawsuits, employment law, workers' compensation, and construction accidents. ### Media contact: Jennifer Jones

3 IN THE STATE COURT OF FULTON COUNTY STATE OF GEORGIA SHIRLEY DOBBS, as next : friend of TAURIE HELTON; : LAMESHA HELTON; and, : CYNTHIA POTTS, as next friend of : DONOVAN REDDISH, : : Civil Action File No.: Plaintiffs, : : vs. : JURY TRIAL DEMANDED : ALPINE GAS, INC.; ATLANTA GAS : LIGHT COMPANY; ATLANTA GAS : LIGHT SERVICES, INC.; COX : PLUMBING & SEPTIC, INC.; GREAT : WESTERN INN; DEVENDRA PATEL; : KIRIT PATEL and HEMLATA PATEL, : : Defendants. : COMPLAINT FOR DAMAGES COME NOW the Plaintiffs herein and file their Complaint for Damages, respectfully showing this Honorable Court the following: PARTIES, JURISDICTION AND VENUE 1. Plaintiffs, Taurie Helton, Lamesha Helton and Donovan Reddish are the surviving children of Reese Helton. This action is brought on their behalf to recover damages for the mental and physical pain and suffering and wrongful death of their father, Reese Helton. 2. Taurie Charonne Helton is an incompetent adult who appears as a plaintiff in this action by and through his mother and next friend, Shirley Ann Dobbs. Mr. Helton and Ms. Dobbs are citizens of the State of Georgia and reside at 646 Old Town Road, Villa Rica, Georgia

4 3. Donovan Reddish is a minor and appears as a plaintiff in this action by and through his mother and next friend, Cynthia Reddish Potts. Lamesha Helton, Donovan Reddish and Cynthia Potts reside at 495 Henson Circle, Carrollton, Georgia Defendant Alpine Gas, Inc. (hereinafter referred to as Alpine ) is a corporation which exists under the laws of the state of Georgia. Defendant Alpine is subject to the jurisdiction of this Court and may be served with a copy of the Summons and Complaint through its registered agent for service of process, Bledsoe Harwell, who is located at 3857 North Highway 27, Carrollton, Carroll County, Georgia Defendant Atlanta Gas Light Company (hereinafter referred to as AGL Co. ) is a corporation existing under the laws of the state of Georgia. Defendant AGL Co. is subject to the jurisdiction of this Court and may be served with a copy of the Summons and Complaint through its registered agent for service of process, Paul R. Shlanta, who is located at 10 Peachtree Place, Suite 1000, Atlanta, Fulton County, Georgia Defendant Atlanta Gas Light Services, Inc. (hereinafter referred to as AGL Services ) is a corporation existing under the laws of the state of Georgia. Defendant AGL Services is subject to the jurisdiction of this Court and may be served with a copy of the Summons and Complaint through its registered agent for service of process, Paul R. Shlanta, who is located at 10 Peachtree Place, Suite 1000, Atlanta, Fulton County, Georgia Defendant Cox Plumbing & Septic, Inc. (hereinafter referred to as Cox Plumbing ) is a corporation which exists under the laws of the state of Georgia. Defendant Cox Plumbing is subject to the jurisdiction of this Court and may be served with a copy of the Summons and 2

5 Complaint through its registered agent for service of process, John E. Cox, who is located at 109 Thornbrook Court, Carrollton, Carroll County, Georgia Defendants Alpine, AGL Co, AGL Services and Cox Plumbing are all engaged in the business of installing and/or maintaining pipes and equipment for the supply of natural gas and/or liquid propane gas and selling and supplying natural gas and/or liquid propane gas to customers in the Carroll County area, including the Great Western Inn, which is located in Bremen, Georgia. 9. Great Western Inn is a business entity created and maintained for the purpose of operating a hotel located at 1077 Alabama Avenue, Bremen, Georgia The exact nature and extent of the business structure of Great Western Inn is unknown to the Plaintiffs at this time. 10. Defendants Devendra Patel, Kirit Patel and Hemlata Patel are the owners and/or operators of the Great Western Inn. Devendra Patel, Kirit Patel and Hemlata Patel are subject to the jurisdiction of this Court and may be served with a copy of the Summons and Complaint at their place of residence, The Great Western Inn, located at 1077 Alabama Avenue, Bremen, Georgia This Court may exercise jurisdiction over the subject matter of this action. 12. Venue as to each of the Defendants is properly laid in this Court. PRELIMINARY STATEMENT OF FACTS 13. Plaintiffs adopt and incorporate by reference paragraphs 1 through 12 of their Complaint for Damages as if said paragraphs are set forth fully herein. 3

6 14. This case is brought by the Plaintiffs for the death of their father, Reese Helton, who died as a proximate result of an explosion and fire caused by a gas leak on the property of Great Western Inn on or about June 27, Defendants AGL Co. and AGL Services installed, owned and maintained the pipes and fixtures which supplied natural gas to Great Western Inn and they sold or supplied natural gas to Great Western Inn on the date of the subject explosion and fire. 16. Defendant Alpine installed, owned and maintained the tank, pipes and fixtures which supplied liquid propane gas to Great Western Inn and it sold or supplied liquid propane gas to Great Western Inn on the date of the subject explosion and fire. 17. Defendant Cox Plumbing performed work, installation, maintenance and repairs on the pipes and fixtures which supplied natural gas and liquid propane gas to Great Western Inn prior to the explosion and fire in this case. 18. The explosion and fire which caused the death of Reese Helton occurred in the maintenance area of the Great Western Inn and resulted from ignition of gas vapors. 19. At the time of the explosion and fire, Reese Helton was working as an independent contractor performing custodial and janitorial work for Defendants Devendra Patel, Kirit Patel, Hemlata Patel and Great Western Inn. Therefore, Reese Helton was an invitee on the premises of Defendants Devendra Patel, Kirit Patel, Hemlata Patel and Great Western Inn at the time of the explosion and fire. 4

7 COUNT I NEGLIGENCE OF ALPINE GAS, INC., ATLANTA GAS LIGHT COMPANY, ATLANTA GAS LIGHT SERVICES, INC. and COX PLUMBING & SEPTIC, INC. 20. Plaintiffs adopt and incorporate by reference paragraphs 1 through 19 of their Complaint for Damages as if said paragraphs are set forth fully herein. 21. Defendants Alpine, AGL Co., AGL Services and Cox Plumbing owed a duty to exercise reasonable care in the installation, maintenance and repair of the pipes and equipment which supplied natural gas and/or liquid propane gas to their customers, including Devendra Patel, Kirit Patel, Hemlata Patel and Great Western Inn. 22. The Defendants negligent failure to exercise reasonable care in installing, maintaining and repairing pipes, fixtures and equipment and in supplying natural and/or liquid propane gas proximately caused the untimely death of Reese Helton. 23. As an actual and proximate result of the negligence of Defendants Alpine, AGL Co., AGL Services and Cox Plumbing, Plaintiffs father, Reese Helton, sustained catastrophic injuries, including but not limited to burns, and subsequently died. COUNT II NEGLIGENCE OF GREAT WESTERN INN, DEVENDRA PATEL, KIRIT PATEL and HEMLATA PATEL 24. Plaintiffs adopt and incorporate by reference paragraphs 1 through 23 of their Complaint for Damages as if said paragraphs are set forth fully herein. 5

8 25. On or about June 27, 2006, Plaintiffs decedent, Reese Helton, was working as an independent contractor at the Great Western Inn. As such, Mr. Helton held the status of a business invitee. As the owners and operators of the Great Western Inn, Defendants Devendra Patel, Kirit Patel and Hemlata Patel owed a duty to maintain said premises in a condition that was safe for business invitees, including Reese Helton. 26. Defendants Devendra Patel, Kirit Patel and Hemlata Patel negligently failed to maintain the premises of the Great Western Inn in a safe condition. The proximate result of their negligence was an explosion and fire which catastrophically injured and caused the death of Reese Helton. 27. Defendants Devendra Patel, Kirit Patel and Hemlata Patel further breached a duty of care owed to Plaintiffs decedent by failing to warn him of the existence of a gas leak on the premises and the potential for an explosion and fire. 28. As an actual and proximate result of the negligence of Defendants Devendra Patel, Kirit Patel and Hemlata Patel, Reese Helton sustained catastrophic injuries, including but not limited to burns, and died. COUNT III PUNITIVE DAMAGES 29. Plaintiffs adopt and incorporate by reference paragraphs 1 through 28 of their Complaint for Damages as if said paragraphs are set forth fully herein. 30. All of the Defendants acted with reckless disregard for the safety and well-being of the public, including Reese Helton, when the Defendants created or allowed an unreasonably 6

9 dangerous condition to exist on the Great Western Inn property, namely a gas leak, without providing any safeguards or warnings for Reese Helton, even though each of them knew that this dangerous condition could result in injury and death. 31. The Defendants actions showed willful misconduct, malice, fraud, wantonness, oppression or that entire want of care which would raise the presumption of conscious indifference to consequences so as to entitle Plaintiffs to punitive damages against all Defendants in accordance with O.C.G.A PRAYER FOR RELIEF WHEREFORE, Plaintiffs respectfully request that they be granted the following relief: (a) that a copy of the Summons and Complaint be served upon each of the Defendants; (b) that they have a trial by jury as to each and every appropriate issue; (c) a judgment against each Defendant; (d) the recovery of funeral and burial expenses in an amount to be set forth more specifically by way of amendment and/or at trial; (e) the recovery of out of pocket expenses in an amount to be set forth more specifically by way of amendment and/or at trial; (f) the recovery of lost income in an amount to be set forth more specifically by way of amendment and/or at trial; (g) the recovery of compensatory damages for the physical pain, mental anguish and emotional distress of Plaintiffs decedent, Reese Helton; (h) the recovery of compensatory damages for the conscious pain and suffering of Plaintiffs decedent, Reese Helton; (i) the recovery of an amount equal to the full value of the life of Reese Helton; (j) an award of punitive damages in an amount sufficient to deter future similar conduct by the Defendants; 7

10 (k) the recovery of reasonable attorney s fees and expenses of litigation; (l) that all costs of this action be cast against the Defendants; and (m) any and all such further relief as the Court may deem just and appropriate. This 17th day of July, THOMAS, MEANS, GILLIS & SEAY, P.C. // S// Quinton S. Seay 191 Peachtree Street, N.E. Suite 3550 Quinton S. Seay Atlanta, GA Georgia Bar No (404) ATTORNEYS FOR PLAINTIFFS 8

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * *

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * * IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA vs. Plaintiffs, CIVIL ACTION NUMBER CV-99-792 Defendants. COMPLAINT 1. Plaintiffs, Bryan K. Bunten and Lisa Bunten, are over the age of nineteen (19) years

More information

GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent

GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent POMPELIO, FOREMAN & GRAY, L.L.C. 760 ROUTE 10 WEST, SUITE 203 WHIPPANY, NEW JERSEY 07981 PH: 973-240-7313 F: 973-240-7316 Attorneys for Plaintiff Henry Kent HENRY KENT, vs. Plaintiff, SMILES II RESTAURANT,

More information

IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI

IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI STEPHANIE BRUNO, 3900 NW 60 th Place Kansas City, Missouri 64151 and JOHN AND C.D. BRUNO, 4702 NW Linden Rd Kansas City,

More information

IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA

IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA (1) PETE GUY, as the Administrator ) of the Estate of Annie Guy, ) deceased; and ) (2) PETE GUY, LINDA SMITH, ) CIVIL ACTION FILE NO. NAYLOR GUY, JR.,

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES Fernando F. Chavez, Esq. SBN 0 CHAVEZ LAW GROUP 00 West Beverly Blvd., Montebello, Ca 00 Phone: () 00-0, Facsimile: (0) 1-01 E-mail: ffchavez0@gmail.com Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE

More information

PREVIEW PLEASE DO NOT COPY THIS DOCUMENT THANK YOU. LegalFormsForTexas.Com

PREVIEW PLEASE DO NOT COPY THIS DOCUMENT THANK YOU. LegalFormsForTexas.Com Form: Plaintiff's original petition-wrongful Death [Name], PLAINTIFF vs. [Name], DEFENDANT [ IN THE [Type of Court] COURT [Court number] PLAINTIFF'S ORIGINAL PETITION 1. DISCOVERY CONTROL PLAN 1.1 Plaintiff

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA VERIFIED COMPLAINT FOR PERSONAL INJURY DAMAGES AND DEMAND FOR TRIAL BY JURY

IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA VERIFIED COMPLAINT FOR PERSONAL INJURY DAMAGES AND DEMAND FOR TRIAL BY JURY IN THE STATE COURT OF COBB COUNTY STATE OF GEORGIA CARINA ROCK, Plaintiff, CIVIL ACTION FILE NO. v. JO-ANN L. MOORE, Defendant. VERIFIED COMPLAINT FOR PERSONAL INJURY DAMAGES AND DEMAND FOR TRIAL BY JURY

More information

1416-CV14463. 1. Plaintiff is a resident of Jackson County, Missouri and is the biological mother of

1416-CV14463. 1. Plaintiff is a resident of Jackson County, Missouri and is the biological mother of IN THE CIRCUIT COURT FOR JACKSON COT]NTY, MISSOURI AT INDEPENDENCE TAMMY BRYANT, Natural Mother of Kevin'Wahlers, Deceased, vs. Plaintiff ASRA, LLC dlbla 40 HIGHV/AY SINCLAIR Serve Registered Agent: Rizwan

More information

FULTON COUNTY STATE COURT STATE OF GEORGIA * * * * * * * * * *

FULTON COUNTY STATE COURT STATE OF GEORGIA * * * * * * * * * * FULTON COUNTY STATE COURT STATE OF GEORGIA JENNIFER GARRISON, vs. Plaintiff, MONTAG REALTY COMPANY, LLC d/b/a VERONA APARTMENTS, THE REALTY FUND III, L.P. and JOHN DOES 1-5, JURY TRIAL DEMANDED CASE NUMBER:

More information

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY STATE OF UTAH. Case No. : Judge:

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY STATE OF UTAH. Case No. : Judge: Alan W. Mortensen (6616) DEWSNUP, KING & OLSEN 36 South State Street, Ste. 2400 Salt Lake City, UT 84111 Telephone (801) 533-0400 Facsimile (801) 363-4218 Attorneys for Plaintiffs IN THE THIRD JUDICIAL

More information

Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM

Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM PENELOPE BELVOIR, as Executor de son Tort for the Pending Estate of Robert Belvoir, Deceased, vs. Plaintiff, ROPES COURSES, INC., FB ORLANDO

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DECLARATORY JUDGMENT

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DECLARATORY JUDGMENT Case 1:15-cv-02184-ODE Document 1 Filed 06/17/15 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION BANKERS STANDARD INSURANCE COMPANY, Plaintiff, v.

More information

AN OVERVIEW OF DAMAGES IN GEORGIA. By Craig R. White

AN OVERVIEW OF DAMAGES IN GEORGIA. By Craig R. White AN OVERVIEW OF DAMAGES IN GEORGIA By Craig R. White SKEDSVOLD & WHITE, LLC. 1050 Crown Pointe Parkway Suite 710 Atlanta, Georgia 30338 (770) 392-8610 FAX: (770) 392-8620 EMAIL: cwhite@skedsvoldandwhite.com

More information

vs. JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Plaintiff JAMES SCHAIRER, by and through undersigned counsel, hereby sues

vs. JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Plaintiff JAMES SCHAIRER, by and through undersigned counsel, hereby sues IN THE CIRCUIT COURT OF THE th 16 JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. JAMES SCHAIRER, individually, Plaintiff, vs. JURY TRIAL DEMANDED PAUL KERCHER,

More information

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in Weld County, Colorado, District Court, 901 9 th Avenue Greeley, CO 80631 970.351.7300 Plaintiff: vs. Defendants: JENNIFER BELL, individually and on behalf of all others similarly situated, BRADLEY PETROLEUM,

More information

PLAINTIFF S FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL. MYRIAM DEL SOCORRO LOPEZ, by and through his undersigned counsel, and files this First

PLAINTIFF S FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL. MYRIAM DEL SOCORRO LOPEZ, by and through his undersigned counsel, and files this First IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 08-56892 CA 27 WILSON TORRES, individually, and as Personal Representative

More information

COMPLAINT. COMES NOW the Plaintiffs, JERRY BYNUM, as Personal Representative of the Estate

COMPLAINT. COMES NOW the Plaintiffs, JERRY BYNUM, as Personal Representative of the Estate IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JERRY BYNUM, as Personal Representative of the Estate of REGINA BYNUM, deceased; and JERRY BYNUM, individually, Plaintiffs,

More information

Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PAMELA ANDERSON, Individually and ) as Independent

More information

CASE NO.: CIVIL DIVISION COMPLAINT. through undersigned counsel, and hereby sues Defendant, Winn-Dixie Stores, Inc., a Florida GENERAL ALLEGATIONS

CASE NO.: CIVIL DIVISION COMPLAINT. through undersigned counsel, and hereby sues Defendant, Winn-Dixie Stores, Inc., a Florida GENERAL ALLEGATIONS IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA, vs. Plaintiff, CASE NO.: CIVIL DIVISION WINN-DIXIE STORES, INC., Defendant, / COMPLAINT COMES NOW Plaintiff,,

More information

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION Form 2:40-2 Complaint Negligence, Motor Vehicle IN THE CIRCUIT COURT OF THE ## JUDICIAL CIRCUIT IN AND FOR [COUNTY], FLORIDA [PLAINTIFF], Plaintiff, CASE NO.: ##-##### ## ## GENERAL JURISDICTION vs. [DEFENDANT

More information

IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA. v. Civil Action No.:CL12-1617 Plaintiff Demands Trial by Jury COMPLAINT

IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA. v. Civil Action No.:CL12-1617 Plaintiff Demands Trial by Jury COMPLAINT IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA MIGUEL RUIZ, HUSAIN SALAH, MOHAMED ABDELWAHAM, ANDREW BRZEZINSKI, MARIO CLOTTER, HECTOR SANCHEZ, CLIFFORD LACON, and JIMMY SABGA, RICHARD HICKS Plaintiff,

More information

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL. Plaintiff, TARIN SAROKA, individually, and as the Personal Representative of the

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL. Plaintiff, TARIN SAROKA, individually, and as the Personal Representative of the IN THE CIRCUIT COURT FOR THE 15 TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA TARIN SAROKA, individually and as the Personal Representative of the Estate of ALAN BAZINET, CIVIL DIVISION CASE

More information

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI DIVISION

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI DIVISION IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI DIVISION 1431-CC00377 STACEY BARFIELD c/o RANSIN INJURY LAW 1650 E. BATTLEFIELD RD, #140 SPRINGFIELD, MISSOURI 65804 and Case No: MARKUS RYAN OWENS c/o RANSIN

More information

COMPLAINT. Plaintiffs, Dileida Vizcaino and Norma Vizcaino, as Co-Personal Representatives of the

COMPLAINT. Plaintiffs, Dileida Vizcaino and Norma Vizcaino, as Co-Personal Representatives of the IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA DILEIDA VIZCAINO AND NORMA VIZCAINO, AS CO-PERSONAL REPRESENTATIVES OF THE ESTATE OF FEDERICO VIZCAINO; ANANDA C.

More information

Table of Contents. Selected Iowa Wrongful Death Laws and Rules

Table of Contents. Selected Iowa Wrongful Death Laws and Rules Table of Contents 1. What is a wrongful death claim?... 2 2. Who may recover compensation for a wrongful death?... 3 3. How is a wrongful death claim commenced?... 4 4. What types of losses are compensated

More information

Complaint - Walmart Substance on Floor in Frozen Food Dept.

Complaint - Walmart Substance on Floor in Frozen Food Dept. Home Slip and Fall - Pleadings Main Index - Complaint Walmart Frozen Food Dept Complaint - Walmart Substance on Floor in Frozen Food Dept. IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Harvey C. Berger (SBN POPE & BERGER 0 West "C" Street, Suite 100 San Diego, California 1 Telephone: (1-1 Facsimile: (1 - Attorneys for Plaintiff PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:13-cv-02282-RWS Document 1 Filed 07/09/13 Page 1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION DE ANGELO BENTLEY, ) MARQUES ROBERTSON, ) IKEYMA MCKENTRY, ) individually,

More information

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION COMPLAINT

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, CASE NUMBER: JUDGE: vs. Defendant. / COMPLAINT COMES NOW, Plaintiff,, and hereby sues

More information

14-05313-16 CAUSE NO. JULIE TORBERT, as next friend of IN THE DISTRICT COURT PHILIP ORMSTON V. DENTON COUNTY, TEXAS

14-05313-16 CAUSE NO. JULIE TORBERT, as next friend of IN THE DISTRICT COURT PHILIP ORMSTON V. DENTON COUNTY, TEXAS 14-05313-16 CAUSE NO. FILED: 7/15/2014 1:32:23 PM SHERRI ADELSTEIN Denton County District Clerk By: Heather Goheen, Deputy JULIE TORBERT, as next friend of IN THE DISTRICT COURT PHILIP ORMSTON Plaintiff

More information

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI JANE DOE INDIVIDUALLY ) and on BEHALF OF ) THE CLASS OF PERSONS ) DESIGNATED BY 537.080, ) ) Plaintiff, ) ) Case Number *************** vs. ) ) DEFENDANT

More information

COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO

COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO JAMES JASPER CASE NO. 4972 State Route 276 Batavia, OH 45103 Judge And MINOR CHILDREN OF JAMES AND ELIZABETH JASPER 4972 State Route 276 Batavia, OH 45103 And

More information

ACCIDENT CASE SUE IN AN AUTOMOBILE IN FLORIDA? When you are involved in an automobile accident, you suffer physical, emotional and financial damages

ACCIDENT CASE SUE IN AN AUTOMOBILE IN FLORIDA? When you are involved in an automobile accident, you suffer physical, emotional and financial damages CAN FAMILY MEMBERS SUE IN AN AUTOMOBILE ACCIDENT CASE IN FLORIDA? When you are involved in an automobile accident, you suffer physical, emotional and financial damages 1 When you are involved in an automobile

More information

PREVIEW. 1. The following form may be used to file a personal injury lawsuit.

PREVIEW. 1. The following form may be used to file a personal injury lawsuit. Information or instructions: Plaintiff's original petition-auto accident 1. The following form may be used to file a personal injury lawsuit. 2. It assumes several plaintiffs were rear-ended by an employee

More information

Case 4:09-cv-00502-RCC Document 1 Filed 09/04/09 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff,

Case 4:09-cv-00502-RCC Document 1 Filed 09/04/09 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, Case :0-cv-000-RCC Document Filed 0/0/0 Page of DAVID MONROE QUANTZ, P.L.C. E. Camp Lowell Dr. Tucson, Arizona ( -00 David Monroe Quantz State Bar No: 000 david@quantzlawfirm.com Attorney for Plaintiff

More information

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY, UTAH

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY, UTAH Robert G. Gilchrist (3715) Jeff M. Sbaih (14014) EISENBERG GILCHRIST & CUTT 900 Parkside Tower 215 South State Street Salt Lake City, Utah 84111 Phone: (801) 366-9100 Email: rgichrist@egclegal.com Email:

More information

Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION BRENDA L. HONEYCUTT, * * Plaintiff, * * v. * CIVIL ACTION

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL

More information

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA JEANNE BEEN as executrix of the estate of ROBERT JENKINS, Deceased, Plaintiff, v. Case No. CJ-2003-02541 JASON M. WEED and LANDMARK EDUCATION CORPORATION,

More information

Case 1:13-cv-00001-SEB-TAB Document 1 Filed 01/02/13 Page 1 of 7 PageID #: 1

Case 1:13-cv-00001-SEB-TAB Document 1 Filed 01/02/13 Page 1 of 7 PageID #: 1 Case 1:13-cv-00001-SEB-TAB Document 1 Filed 01/02/13 Page 1 of 7 PageID #: 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION JAIME MILLER, Plaintiff v. No.: 1:13-cv-1 CITY

More information

CAUSE NO. JUSTIN GROGG IN THE DISTRICT COURT OF Plaintiff, vs. DALLAS COUNTY, TEXAS

CAUSE NO. JUSTIN GROGG IN THE DISTRICT COURT OF Plaintiff, vs. DALLAS COUNTY, TEXAS CAUSE NO. Filed 13 May 7 P9:22 Gary Fitzsimmons District Clerk Dallas District JUSTIN GROGG IN THE DISTRICT COURT OF Plaintiff, vs. DALLAS COUNTY, TEXAS RED LOBSTER OF TEXAS, INC. D/B/A RED LOBSTER OF

More information

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ELECTRONICALLY FILED 5/18/2012 2:30 PM CV-2012-901583.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ZACHARY

More information

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH // :: PM CV 1 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH 1 1 AMANDA FRITZ, as Personal Representative for the ESTATE OF STEVEN FRITZ; v. Plaintiff, CARSON OIL CO., INC., an

More information

Products Liability: Putting a Product on the U.S. Market. Natalia R. Medley Crowell & Moring LLP 14 November 2012

Products Liability: Putting a Product on the U.S. Market. Natalia R. Medley Crowell & Moring LLP 14 November 2012 Products Liability: Putting a Product on the U.S. Market Natalia R. Medley Crowell & Moring LLP 14 November 2012 Overview Regulation of Products» Federal agencies» State laws Product Liability Lawsuits»

More information

Case 2:10-cv-01234-NBF Document 1 Filed 09/17/10 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

Case 2:10-cv-01234-NBF Document 1 Filed 09/17/10 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA Case 2:10-cv-01234-NBF Document 1 Filed 09/17/10 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA EILEEN M. CONROY, Plaintiff, vs. PENNSYLVANIA TURNPIKE COMMISSION

More information

Automobile Negligence Lawsuits

Automobile Negligence Lawsuits SOG/DGL, CH, JB Page 1 of 6 Automobile Negligence Lawsuits Who Is Sued? Driver the driver is the person whose negligence gives rise to the liability. The person suing must prove that the driver negligently

More information

OREGON LAW AT-A-GLANCE

OREGON LAW AT-A-GLANCE 1. ASSUMPTION OF THE RISK: This doctrine was abolished in Oregon. ORS 31.620(2). But see Comparative Negligence below. 2. COLLATERAL SOURCE RULE: The Court may deduct from a damages award certain collateral

More information

VIRGINIA ACTS OF ASSEMBLY -- 2015 SESSION

VIRGINIA ACTS OF ASSEMBLY -- 2015 SESSION VIRGINIA ACTS OF ASSEMBLY -- 2015 SESSION CHAPTER 585 An Act to amend and reenact 38.2-2206 of the Code of Virginia and to amend the Code of Virginia by adding in Article 7 of Chapter 3 of Title 8.01 a

More information

Chapter 4 Crimes (Review)

Chapter 4 Crimes (Review) Chapter 4 Crimes (Review) On a separate sheet of paper, write down the answer to the following Q s; if you do not know the answer, write down the Q. 1. What is a crime? 2. There are elements of a crime.

More information

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO DAVID ASHE Plaintiff, CIVIL NO. 10-2236 ( DRD ) vs. DISTRIBUIDORA NORMA,

More information

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION Case 3:14-cv-03585-N Document 1 Filed 10/03/14 Page 1 of 16 PageID 1 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION DAVID HARRISON, Individually and as Personal Representative

More information

TERRENCE and Marie Domin, Plaintiffs, v. SHELBY INSURANCE COMPANY, a foreign corporation, Defendant.

TERRENCE and Marie Domin, Plaintiffs, v. SHELBY INSURANCE COMPANY, a foreign corporation, Defendant. Circuit Court of Illinois. County Department Chancery Division Cook County TERRENCE and Marie Domin, Plaintiffs, v. SHELBY INSURANCE COMPANY, a foreign corporation, Defendant. No. 00CH08224. 2008. Answer

More information

virtue of Title VIII of the Sarbanes-Oxley Act of 2002, Section 806 of the Corporate and

virtue of Title VIII of the Sarbanes-Oxley Act of 2002, Section 806 of the Corporate and IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA 1 +. DIVISION DIANA WINGARD, 2091 QLT -q (O: 2I Plaintiff, V. Civil Case No. 2:07-CVAC 1 `- < < ) Plaintiff Demands Jury Trial COUNTRYWIDE

More information

CASE NO.: COMPLAINT. Plaintiff, [PLAINTIFF S NAME], by and through her parent and natural guardian

CASE NO.: COMPLAINT. Plaintiff, [PLAINTIFF S NAME], by and through her parent and natural guardian Form 2:150 Dog Bite Sample Complaint IN THE CIRCUIT COURT OF THE TH JUDICIAL CIRCUIT IN AND FOR COUNTY, FLORIDA [PLAINTIFF S NAME], by and through her parent and natural guardian, [PLAINTIFF S PARENT S

More information

Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1

Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1 Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TRAVELERS CASUALTY AND SURETY COMPANY

More information

Defense of State Employees: LIABILITY AND LAWSUITS. UNCW Office of General Counsel January 2010

Defense of State Employees: LIABILITY AND LAWSUITS. UNCW Office of General Counsel January 2010 Defense of State Employees: LIABILITY AND LAWSUITS UNCW Office of General Counsel January 2010 COMMON CAUSES OF ACTION (or what could we be sued for) Tort claims Contract claims Discrimination/Harassment

More information

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5 , '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5 , '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5, '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA D \ \..': t', I ' NORTHERN DIVISION " \ NASH J. COOLEY ) FILED

More information

Cohen. Battisti LEGAL ASSIGNMENT OF INSURANCE BENEFITS Attorneys at Law INSIDER SECRETS: ! 2%34/2!4)/.

Cohen. Battisti LEGAL ASSIGNMENT OF INSURANCE BENEFITS Attorneys at Law INSIDER SECRETS: ! 2%34/2!4)/. Cohen INSIDER SECRETS: Battisti LEGAL Attorneys at Law ASSIGNMENT OF INSURANCE W R O N G F U L D E AT H BENEFITS! 2%34/2!4)/. 1211 ORANGE AVENUE, SUITE 200 WINTER PARK, FLORIDA 32789 #/-0!.9 3 '5)$% 4

More information

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES (SPACE BELOW FOR FILING STAMP ONLY) LAW FIRM OF KAISER, DEBIASO. ANDREW AND SWINDELLS SUMfTOMO TOWER NINTH FLOOR 444 WEST OCEAN BOULEVARD LONG BEACH, CALIFORNIA 90802-4516 (310) 590-8471 ERIC C. DEMLER

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION PLAINTIFF MCAFEE, INC. S THIRD AMENDED COMPLAINT

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION PLAINTIFF MCAFEE, INC. S THIRD AMENDED COMPLAINT UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION McAFEE, INC. v. Plaintiff, WILMER, CUTLER, PICKERING, HALE AND DORR, L.L.P JURY REQUESTED No. 4:08-cv-160 MHS-DDB Defendant.

More information

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND District Court, Denver County, Colorado 1437 Bannock Street Denver, Colorado 80202 GUILLERMO ARTEAGA-GOMEZ, Individually and on behalf of all others similarly situated, DATE FILED: January 22, 2015 6:02

More information

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION LAURA HIMES-RUETH, CASE NO.: Plaintiff, vs. DR. MANUEL ABREU and ALL CARE MEDICAL CONSULTANTS PA, a

More information

COMPENSATION IN A TENNESSEE PERSONAL INJURY LAWSUIT

COMPENSATION IN A TENNESSEE PERSONAL INJURY LAWSUIT COMPENSATION IN A TENNESSEE PERSONAL INJURY LAWSUIT If You Have Been Injured in a Personal Injury Accident and Someone Else s Negligence Caused, or Contributed to, the Accident, You May Be Entitled to

More information

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) IN THE SUPERIOR COURT OF THE STATE OF DELAWARE IN RE ASBESTOS LITIGATION: STEVEN P. SCHULTZ and KIMBERLY S. SCHULTZ, Plaintiffs, v. COLGATE-PALMOLIVE COMPANY; COTY, INC.; CYPRUS AMAX MINERALS COMPANY (sued

More information

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA H.L. WATKINS AND COMPANY, INC., ) ) PLAINTIFF, ) ) CIVIL ACTION FILE NO. v. ) ) 06-CV8980-3 THE HOT LEAD COMPANY, LLC, ) ROBERT MICHAEL HORNE, )

More information

Auto accidents can cause thousands or even millions of dollars in losses due to medical expenditures, an inability to work, a reduction in future

Auto accidents can cause thousands or even millions of dollars in losses due to medical expenditures, an inability to work, a reduction in future TEXAS AUTO ACCIDENTS Auto accidents can cause thousands or even millions of dollars in losses due to medical expenditures, an inability to work, a reduction in future earnings, or the untimely death of

More information

AMENDED COMPLAINT. Plaintiff THOMAS J. BARRY hereby files this Complaint for damages against

AMENDED COMPLAINT. Plaintiff THOMAS J. BARRY hereby files this Complaint for damages against IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO: CA 02-12996AJ THOMAS J. BARRY, vs. Plaintiff, GEICO GENERAL INSURANCE COMPANY, Defendant. / AMENDED COMPLAINT

More information

FLORIDA WRONGFUL DEATH ACT

FLORIDA WRONGFUL DEATH ACT FLORIDA WRONGFUL DEATH ACT (STATUTES) Disclaimer: This is part of the 2012 version of Florida Statutes and it is offered for general information purposes. The statutes on this site should not be relied

More information

2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County. No. CV05-045 (A)L. June 12, 2006. Second Amended Complaint

2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County. No. CV05-045 (A)L. June 12, 2006. Second Amended Complaint 2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County Charlene DUNN, Plaintiff, v. John A. MURPHY, Future Benefits, Inc. American Equity Investment Life Insurance Company,

More information

Cooper Hurley Injury Lawyers

Cooper Hurley Injury Lawyers Cooper Hurley Injury Lawyers 2014 Granby Street, Suite 200 Norfolk, VA, 23517 (757) 455-0077 (866) 455-6657 (Toll Free) YOUR RIGHTS WHEN YOU ARE INJURED ON THE RAILROAD Cooper Hurley Injury Lawyers 2014

More information

Lowcountry Injury Law

Lowcountry Injury Law Lowcountry Injury Law 1917 Lovejoy Street Post Office Drawer 850 Beaufort, South Carolina 29901 Personal Injury Phone (843) 524-9445 Auto Accidents Fax (843) 532-9254 Workers Comp DanDenton@Lawyer.com

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO 1 0 1 MARC D. ADELMAN Attorney at Law State Bar No. Liberty Station Historic Decatur Road, Suite 00 San Diego, CA - (1) -0 Phone (1) -0 Fax Email: AdelmanMD@aol.com Attorney for Plaintiff SUPERIOR COURT

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION COMPLAINT. COMES NOW, the Plaintiff, JOSEPH DELFRATE, and sues the Defendant,

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION COMPLAINT. COMES NOW, the Plaintiff, JOSEPH DELFRATE, and sues the Defendant, Case 8:10-cv-01091-SDM-AEP Document 1 Filed 05/10/10 Page 1 of 8 JOSEPH DELFRATE, UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION vs. Plaintiff, CASE NO. LIBERTY MUTUAL FIRE INSURANCE

More information

THE THREAT OF BAD FAITH LITIGATION ETHICAL HANDLING OF CLAIMS AND GOOD FAITH SETTLEMENT PRACTICES. By Craig R. White

THE THREAT OF BAD FAITH LITIGATION ETHICAL HANDLING OF CLAIMS AND GOOD FAITH SETTLEMENT PRACTICES. By Craig R. White THE THREAT OF BAD FAITH LITIGATION ETHICAL HANDLING OF CLAIMS AND GOOD FAITH SETTLEMENT PRACTICES By Craig R. White SKEDSVOLD & WHITE, LLC. 1050 Crown Pointe Parkway Suite 710 Atlanta, Georgia 30338 (770)

More information

earnings as you find AB would have earned between the date of injury and the date of death had (he, she) not been injured.

earnings as you find AB would have earned between the date of injury and the date of death had (he, she) not been injured. PJI 2:320 Damages Damages Actions for Wrongful Death and Conscious Pain and Suffering, Including Such Actions Based on Medical, Dental and Podiatric Malpractice Commenced Before July 26, 2003 Plaintiff

More information

Complaint as permitted by Case Management Order # 4 and Implementing Order PARTIES, JURISDICTION AND VENUE

Complaint as permitted by Case Management Order # 4 and Implementing Order PARTIES, JURISDICTION AND VENUE [INSERT NAME], Plaintiff(s) vs. HOWMEDICA OSTEONICS CORPORATION, a New Jersey Corporation, d/b/a STRYKER ORTHOPAEDICS, JILL DOE MANUFACTURERS (1-10), JACK DOE WHOLESALERS (1-10), JAKE DOE SELLERS (1-10),

More information

: : : : : : : : : : : x

: : : : : : : : : : : x SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------- x FELIX ANDUJAR, -against- Plaintiff, TERRACE REALTY ASSOCIATES LLC, 66-72 FORT

More information

WAIVER OF LEGAL RIGHTS TO SUE OR MAKE CLAIM FOR INJURY WITH ARBITRATION CLAUSE AND ASSUMPTION OF THE RISK AND RELEASE

WAIVER OF LEGAL RIGHTS TO SUE OR MAKE CLAIM FOR INJURY WITH ARBITRATION CLAUSE AND ASSUMPTION OF THE RISK AND RELEASE WAIVER OF LEGAL RIGHTS TO SUE OR MAKE CLAIM FOR INJURY WITH ARBITRATION CLAUSE AND ASSUMPTION OF THE RISK AND RELEASE STATE OF COUNTY OF I,, reside at the following address: (PRINT NAME) (PRINT ADDRESS)

More information

Defendant has a duty to act as a reasonable person would in like or similar circumstances to avoid causing unreasonable risk of harm to others.

Defendant has a duty to act as a reasonable person would in like or similar circumstances to avoid causing unreasonable risk of harm to others. NEGLIGENCE (Heavily Tested) (Write On the Bar): In order for Plaintiff to recover in Negligence, she or he must plead and prove: DUTY, BREACH OF DUTY, ACTUAL CAUSATION, PROXIMATE CAUSATION, AND DAMAGES.

More information

Case 1:15-cv-03199-MHC Document 1 Filed 09/11/15 Page 1 of 12 ORIGH~~AL

Case 1:15-cv-03199-MHC Document 1 Filed 09/11/15 Page 1 of 12 ORIGH~~AL Case 1:15-cv-03199-MHC Document 1 Filed 09/11/15 Page 1 of 12 ORIGH~~AL EXECSUMMITS, LLC, v. Plaintiff, IN THE UNITED STATES DISTRICT COURT FILEDINCLERK'Sorn NORTHERN DISTRICT OF GEORGIA u.s.o.c. -A~nCE

More information

DATED: April 29, 2002 BARRY NOVACK

DATED: April 29, 2002 BARRY NOVACK BLANCHARD E. TUAL, Administrator CASE NO. EC 034380 of the Estate of BONNY LEE BAKLEY on behalf of the Heirs of COMPLAINT FOR DAMAGES FOR said Decedent, WRONGFUL DEATH Plaintiff, vs. ROBERT BLAKE, aka

More information

WHEN IT COMES TO. Personal Injury Law, LEARN. UNDERSTAND. ACT.

WHEN IT COMES TO. Personal Injury Law, LEARN. UNDERSTAND. ACT. WHEN IT COMES TO Personal Injury Law, LEARN. UNDERSTAND. ACT. When It Comes to Personal Injury Law, Learn. Understand. Act. Although individuals may have heard the term personal injury before, many do

More information

FILED 15 JUL 27 AM 9:22

FILED 15 JUL 27 AM 9:22 FILED JUL AM : KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --- KNT JUDITH JORGENSEN, vs. SUPERIOR COURT OF WASHINGTON KING COUNTY Plaintiff, JAMES WONG and TYRA WONG, husband and wife creating

More information

4:15-cv-00432-RBH Date Filed 01/29/15 Entry Number 1 Page 1 of 10

4:15-cv-00432-RBH Date Filed 01/29/15 Entry Number 1 Page 1 of 10 4:15-cv-00432-RBH Date Filed 01/29/15 Entry Number 1 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION Ryan Michael Stinnett, on behalf of himself CASE

More information

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) )

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) ) CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA File No. Julius Chad Zimmerman, Plaintiff, v. Dave Bellows, in his individual and official

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 10 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO,

More information

Is What You Know About Injury Claims Accurate?

Is What You Know About Injury Claims Accurate? Is What You Know About Injury Claims Accurate? Presented by: Attorney Mark L. Krueger www.kh-law.net IS WHAT YOU KNOW ABOUT INJURY CLAIMS ACCURATE? Misconception No. 1 I have no claim if the responsible

More information

STATE OF OREGON TRANSPORTATION COMPENDIUM OF LAW

STATE OF OREGON TRANSPORTATION COMPENDIUM OF LAW STATE OF OREGON TRANSPORTATION COMPENDIUM OF LAW Rodney L. Umberger, Jr. Marc M. Carlton Williams Kastner 888 SW Fifth Avenue, Suite 600 Portland, OR 97204 Phone: (503) 228 7967 Email: rumberger@williamskastner.com

More information

COMPLAINT IN INTERPLEADER ON LIFE INSURANCE POLICY

COMPLAINT IN INTERPLEADER ON LIFE INSURANCE POLICY COMPLAINT IN INTERPLEADER ON LIFE INSURANCE POLICY "Redacted" IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION ) ) ) Plaintiff, ) ) CIVIL ACTION v. ) ) FILE NO.

More information

2:11-cv-00891-ASB Date Filed 04/13/11 Entry Number 1 Page 1 of 11

2:11-cv-00891-ASB Date Filed 04/13/11 Entry Number 1 Page 1 of 11 2:11-cv-00891-ASB Date Filed 04/13/11 Entry Number 1 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION JAMMIE C. TYNDALL, individually and as personal

More information

Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION CHRISTOPHER M. JENSEN, v. Plaintiff, LEON COUNTY, FLORIDA,

More information

Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564

Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564 Case: 1:10-cv-02365-SO Doc #: 22 Filed: 07/27/11 1 of 11. PageID #: 564 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION ESTATE OF FRANK TOWNSEND, (by Fiduciary and Administrator

More information

w' Floor - against - SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No.: Date Filed: TAMARA VANDERHYDEN, Plaintiff,

w' Floor - against - SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No.: Date Filed: TAMARA VANDERHYDEN, Plaintiff, SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK TAMARA VANDERHYDEN, - against - Plaintiff, PLANNED PARENTHOOD OF NEW YORK CITY, BETH ISRAEL MEDICAL CENTER, GERALD ZUPNICK, M.D., MAURE JACQUELINE

More information

Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:12-cv-03270-WJM-KMT Document 1 Filed 12/14/12 USDC Colorado Page 1 of 6 Civil Action No. 12-CV-3270 BALBOA INSURANCE COMPANY, Plaintiff v. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

More information

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R NO. MELISSA ROWE, Individually and as Mother and Next Friend of E.R VS. COMPLAINT JEFFERSON CIRCUIT COURT JUDGE DIVISION PLAINTIFF LANA KAELIN c/o Eastern High School 12400 Old Shelbyville Road Louisville,

More information

Stormwater Litigation

Stormwater Litigation Stormwater Litigation 6 th Annual Georgia Environmental Conference August 25, 2011 Jennifer G. Cooper, Esq. Baker Donelson Atlanta, Georgia Agenda Federal Claims Clean Water Act Citizen Suits State Claims

More information

Johnson, Jr., et al. v. Philip Morris Company, Inc., et al.

Johnson, Jr., et al. v. Philip Morris Company, Inc., et al. 328 MONTGOMERY COUNTY LAW REPORTER 328 (1998) ] 36 1998 MBA CIVIL PROCEDURE: Preliminary Objections - Demurer PERSONAL INJURY: Survival and Wrongful Death Actions CAPACITY TO SUE: Personal Representative

More information

STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH CASE NO. Plaintiff,

STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH CASE NO. Plaintiff, STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH Denis W. Stearns, Wis. Bar No. 1020675 MARLER CLARK, L.L.P., P.S. 701 Fifth Avenue, Suite 6600 Seattle, WA 98104 Telephone: (206) 346-1888 Facsimile:

More information