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

Size: px
Start display at page:

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

Transcription

1 // :: 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 Oregon corporation; and MICHAEL LIPPMANN, individually; Defendants. Case No. COMPLAINT (Negligence Wrongful Death) Amount of Claim: $,00, Fee Authority: ORS.0(1)(d) Claim More Than $0,000 Not Subject to Mandatory Arbitration JURY TRIAL REQUESTED Plaintiff alleges: 1. Plaintiff Amanda Fritz ( Plaintiff Fritz ) is the duly appointed Personal Representative of the Estate of Steven Fritz ( Dr. Fritz ), pursuant to an Order entered in Multnomah County Circuit Court, State of Oregon, dated May 1,. Plaintiff Fritz is Dr. Fritz s widow. Dr. Fritz died on September, as a result of the automobile collision described herein.. At all times mentioned herein, Defendant CARSON OIL CO., INC. ( Defendant Carson ) was and is an Oregon corporation with a principal place of business in Portland, Oregon. Page 1 - COMPLAINT PORTLAND, OR TELEPHONE: (0) - FACSIMILE: (0) -0

2 1 1. On information and belief, at all times mentioned herein, Defendant MICHAEL LIPPMANN ( Defendant Lippmann ) was and is a resident of the State of Oregon.. On or about September,, Dr. Fritz was traveling southbound on Interstate through Salem, Oregon heading to work at Oregon State Hospital. He was travelling in a Nissan Sentra accompanied by passenger Cary Fairchild. It was raining heavily and visibility was poor.. At the same time as Dr. Fritz and Mrs. Fairchild were traveling southbound, Defendant Lippmann was traveling northbound on Interstate through Salem, Oregon.. An oil truck owned by Defendant Carson was also traveling northbound on the same stretch of Interstate. The truck was operated by an employee of Defendant Carson, Ryan Wilson.. The oil truck was traveling at a high rate of speed in the right lane of the highway prior to moving into the center lane to pass vehicles in the right lane. As it traveled in the center lane, Defendant Lippmann was traveling in the far left lane at a high rate of speed and started to pass the oil truck.. The speed of the oil truck, the standing water splash and spray from the oil truck onto Defendant Lippmann s vehicle, and standing water on the highway combined to cause Defendant Lippmann to lose control of his vehicle. Defendant Lippmann began to fishtail and his right rear bumper collided with the side of the oil truck. The collision redirected Defendant Lippmann s vehicle propelling him off I- and launching him over the grassy berm. There was no concrete Page - COMPLAINT PORTLAND, OR TELEPHONE: (0) - FACSIMILE: (0) -0

3 1 1 or cable divider between the northbound and southbound traffic along this stretch of Interstate ; instead, there was simply a grassy berm. Defendant Lippmann s vehicle launched off the berm into oncoming southbound Interstate traffic.. Defendant Lippmann s vehicle collided head-on with Dr. Fritz s vehicle driven by Dr. Fritz in the right lane of the southbound side of the highway.. Dr. Fritz was killed instantly as a result of the collision. Mrs. Fairchild suffered extensive related injuries that resulted in her death on October, at Salem Hospital. FIRST CLAIM FOR RELIEF (Negligence Wrongful Death) (Plaintiff Against Defendant Lippmann). Plaintiff realleges paragraphs 1 through. 1. Defendant Lippmann owed a duty to Dr. Fritz to operate his vehicle in a reasonably safe manner, including driving at an appropriate speed and maintaining control over his vehicle. 1. Defendant Lippmann breached that duty by driving at a speed that was excessive under the circumstances then and there existing, and by failing to maintain control of his vehicle.. Defendant Lippmann knew, or in the exercise of reasonable care should have known, that each of the foregoing acts or omissions would create an unreasonable risk of harm to others, including Dr. Fritz.. The negligence of Defendant Lippmann in one or more of the foregoing described ways Page - COMPLAINT PORTLAND, OR TELEPHONE: (0) - FACSIMILE: (0) -0

4 was a substantial factor in causing the collision.. As a direct and proximate cause of Defendant Lippmann s negligence, Dr. Fritz suffered fatal injuries resulting in his death.. Plaintiff Fritz, on behalf of the beneficiaries of Dr. Fritz s estate, is entitled to recover: 1 1 (a) (b) (c) (d) The pecuniary loss to the estate, including, but not limited to, reasonable charges for burial and memorial services rendered for the decedent; The pecuniary loss to the estate for the loss of Dr. Fritz s future support, income and services to the estate; Compensatory damages to compensate for the pain and suffering experienced by Dr. Fritz after his injury and prior to his death; and Compensatory damages for the loss of companionship, society and comfort of Dr. Fritz.. For these damages, Plaintiff Fritz should be awarded an amount to be determined at trial, but in no event less than $,00,000.. Plaintiff should be awarded its costs and disbursements against Defendant Lippmann. SECOND CLAIM FOR RELIEF (Negligence Wrongful Death) (Plaintiff Against Defendant Carson). Plaintiff realleges paragraphs 1 through.. In operating the oil truck involved in the accident, Ryan Wilson acted in the course and Page - COMPLAINT PORTLAND, OR TELEPHONE: (0) - FACSIMILE: (0) -0

5 1 1 scope of his employment with Defendant Carson, and Defendant Carson is vicariously liable for his actions.. Mr. Wilson owed a duty to Dr. Fritz to operate his vehicle in a reasonably safe manner, including driving at an appropriate speed and maintaining control over his vehicle.. Mr. Wilson breached that duty by driving at a speed that was excessive under the circumstances then and there existing, by failing to stay in the right lane pursuant to ORS. and, instead, attempting to pass other vehicles in a heavy downpour and poor visibility, and by driving in such as manner as to create excessive splash and spray on vehicles around him.. Mr. Wilson knew, or in the exercise of reasonable care should have known, that each of the foregoing acts or omissions would create an unreasonable risk of harm to others, including Dr. Fritz.. The negligence of Mr. Wilson in one or more of the foregoing described ways was a substantial factor in causing the collision.. As a direct and proximate cause of Mr. Wilson s negligence, Dr. Fritz suffered fatal injuries resulting in his death.. Plaintiff Fritz, on behalf of the beneficiaries of Dr. Fritz s estate, is entitled to recover: (a) (b) The pecuniary loss to the estate, including, but not limited to, reasonable charges for burial and memorial services rendered for the decedent; The pecuniary loss to the estate for the loss of Dr. Fritz s future support, income and services to the estate; Page - COMPLAINT PORTLAND, OR TELEPHONE: (0) - FACSIMILE: (0) -0

6 (c) (d) Compensatory damages to compensate for the pain and suffering experienced by Dr. Fritz after his injury and prior to his death; and Compensatory damages for the loss of companionship, society and comfort of Dr. Fritz.. For these damages, Plaintiff Fritz should be awarded an amount to be determined at trial, but in no event less than $,00,000.. Plaintiff should be awarded its costs and disbursements against Defendant Carson. 1 WHEREFORE, Plaintiff requests a trial by jury and requests the Court should grant judgment in favor of Plaintiffs and grant the following relief: 1 (a) On Plaintiff s First Claim for Relief against Defendant Lippmann, compensatory damages in an amount to be determined at trial but in no event less than $,00,000, plus costs and disbursements; (b) On Plaintiff s Second Claim for Relief against Defendant Carson, compensatory damages in an amount to be determined at trial but in no event less than $,00,000, plus costs and disbursements; (c) (d) circumstances. Prejudgment and post-judgment interest at the legal rate; and For such other and further relief as the Court may deem appropriate in the Dated this th day of June,. KELL, ALTERMAN & RUNSTEIN, L.L.P. /s/ Michael T. Wise Michael T. Wise, OSB #0 Page - COMPLAINT PORTLAND, OR TELEPHONE: (0) - FACSIMILE: (0) -0

7 Blair Townsend, OSB # Of Attorneys for Plaintiff against all Defendants Ted E. Runstein, OSB # Scott J. Aldworth, OSB #1 Telephone: (0) -1 Fax: (0) -0 Of Attorneys for Plaintiff against Defendant Lippmann only 1 1 Page - COMPLAINT PORTLAND, OR TELEPHONE: (0) - FACSIMILE: (0) -0

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

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

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 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

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

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION. Plaintiff, Defendant. JURISDICTION 1.

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION. Plaintiff, Defendant. JURISDICTION 1. RICHARD A. MANN, OSB No. 001640 Internet Email Address: rmann@brownsteinrask.com BROWNSTEIN RASK SWEENY LLP 1200 SW Main Street Portland, OR 97205 Telephone: (503) 412-6735 Facsimile: (503) 221-1074 DEVIN

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

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

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

CIVIL ACTION COMPLAINT

CIVIL ACTION COMPLAINT Gregg D. Trautmann, Esq. TRAUTMANN PRYOR & LUTHER, LLC 262 East Main Street Rockaway, NJ 07866 (973) 316-8100 Attorney for Plaintiff ROBYN KLEINHANS Plaintiff vs. RALPH CLAYTON AND SONS, INC. (A New Jersey

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

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

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. COMPLAINT AT LAW COUNT ONE- NEGLIGENCE

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. COMPLAINT AT LAW COUNT ONE- NEGLIGENCE IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION INJURED PERSON Plaintiffs, v. RESPONSIBLE PARTIES Defendants. No. COMPLAINT AT LAW COUNT ONE- NEGLIGENCE NOW COMES the Plaintiff,

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

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

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 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

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. COMPLAINT AT LAW

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. COMPLAINT AT LAW IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION INJURED PERSON, Plaintiff, v. RESPONSIBLE PARTIES Defendants. No. COMPLAINT AT LAW COUNT ONE NEGLIGENCE-RESPONSIBLE PARTY NOW

More information

KIESEL LAW LLP. Vance J. Owen, Pro Hac Vice Pending OWEN & ASSOCIATES LLP 1201 Sealane Corpus Christi, TX 78412 Tel: 361-884-3939 Fax: 361-884-0833

KIESEL LAW LLP. Vance J. Owen, Pro Hac Vice Pending OWEN & ASSOCIATES LLP 1201 Sealane Corpus Christi, TX 78412 Tel: 361-884-3939 Fax: 361-884-0833 Paul R. Kiesel, State Bar No. email: kiesel@kiesel-law.com Steven D. Archer, State Bar No. email: archer@kiesel-law.com Mariana Aroditis, State Bar No. email: aroditis@kiesel-law.com KIESEL LAW LLP Wilshire

More information

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH. Plaintiff,

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH. Plaintiff, // :: PM CV0 1 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH MARSHALL WATTMAN-TURNER, Case No. v. Plaintiff, COMPLAINT (ORS A.1 Discrimination; A.00(1)(g) Aiding and Abetting

More information

Courthouse News Service

Courthouse News Service Case 3:15-cv-00168-HZ Document 1 Filed 01/30/15 Page 1 of 6 Samuel T. Stanke OSB No. 034631 E-mail: sam@stankelaw.com, LLC 1400 SW Montgomery Street Portland, OR 97201 Telephone: 503-224-1127 Facsimile:

More information

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY]

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY] IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY] [PLAINTIFF], CASE NO. Plaintiff, (Negligence Medical Malpractice v. Claim Not Subject to Mandatory Arbitration [NAMES] (Prayer Amount

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 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 1 1 JANE DOE, an individual, IN THE CIRCUIT COURT OF THE STATE OF OREGON Plaintiff, JOSEPH SCOTT HALL, an individual, v. Defendant. FOR THE COUNTY OF MULTNOMAH PlaintiffJane Doe (hereinafter

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

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

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY THE HONORABLE CAROL MURPHY 1 1 1 1 1 SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY TARVA LEE, ) ) No: --00- Plaintiff, ) ) v. ) COMPLAINT FOR BREACH OF ) CONTRACT, BAD FAITH, FARMERS INSURANCE COMPANY

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

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

STATE OF MICHIGAN COURT OF APPEALS

STATE OF MICHIGAN COURT OF APPEALS STATE OF MICHIGAN COURT OF APPEALS ESTATE OF TIMOTHY HUGHES, Plaintiff-Appellee, UNPUBLISHED January 23, 2007 v No. 259987 Oakland Circuit Court CITIZENS INSURANCE COMPANY, LC No. 2000-024949-CZ and Defendant/Cross-Defendant-

More information

STATE OF INDIANA ) IN THE MARION COUNTY SUPERIOR COURT ) SS: COUNTY OF MARION ) CAUSE NO.:

STATE OF INDIANA ) IN THE MARION COUNTY SUPERIOR COURT ) SS: COUNTY OF MARION ) CAUSE NO.: STATE OF INDIANA ) IN THE MARION COUNTY SUPERIOR COURT ) SS: COUNTY OF MARION ) CAUSE NO.: KURT WEEKLY ) and MARY MILLS ) ) Plaintiffs, ) ) vs. ) ) DAVID M. BISARD, the CITY OF ) INDIANAPOLIS, and the

More information

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH ) ) ) ) ) ) ) ) ) ) ) ) ) ) FIRST CLAIM FOR RELIEF

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH ) ) ) ) ) ) ) ) ) ) ) ) ) ) FIRST CLAIM FOR RELIEF IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH 1 1 MATTHEW MARINO and AMY BENTON, Personally and as Guardians Ad Litem for LUCA MARINO, v. Plaintiffs, LEGACY HEALTH, LEGACY EMANUEL

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

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

Case: 1:12-cv-04340 Document #: 1 Filed: 06/04/12 Page 1 of 12 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

Case: 1:12-cv-04340 Document #: 1 Filed: 06/04/12 Page 1 of 12 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION Case: 1:12-cv-04340 Document #: 1 Filed: 06/04/12 Page 1 of 12 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION BENJAMIN PEREZ and BOBBY ) MILTON, ) ) Plaintiffs,

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 CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA DEAN KUMANCHIK, vs. Plaintiff, Case No.: UNIVERSAL CITY DEVELOPMENT PARTNERS, LTD d/b/a UNIVERSAL STUDIOS, a Florida

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 ) ) ) ) ) ) ) ) ) ) ) ) IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH 1 GLENDA MONROE, v. Plaintiff V. JAMES MAKKER, M.D.; EAST PORTLAND SURGERY CENTER, LLC; and PROVIDENCE HEALTH SYSTEM - OREGON, an

More information

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

IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH IN THE CIRCUIT COURT OF THE STATE OF OREGON IN AND FOR THE COUNTY OF MULTNOMAH LAURIE PAUL, individually and on behalf of all other similarly-situated individuals, Plaintiff, vs. PROVIDENCE HEALTH SYSTEMS-

More information

Case 6:14-cv-01521-AA Document 14 Filed 01/19/15 Page 1 of 5

Case 6:14-cv-01521-AA Document 14 Filed 01/19/15 Page 1 of 5 Case 6:14-cv-01521-AA Document 14 Filed 01/19/15 Page 1 of 5 Portland, OR 97210-3408 Telephone: (503 299-6116 Facsimile: (503 299-6106 E-mail: rsw@miller-wagner.com sml@miller-wagner.com Of Attorneys for

More information

IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO. : v. : COMPLAINT FOR WRONGFUL : : : : : : : : : : : : : : : : :

IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO. : v. : COMPLAINT FOR WRONGFUL : : : : : : : : : : : : : : : : : IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO Paul W. Vincent, as Administrator of the Estate of Daniel L. Vincent, and on behalf of the surviving spouse, CASE NO. children, parents and siblings of

More information

Case: 1:15-cv-09957 Document #: 1 Filed: 11/04/15 Page 1 of 10 PageID #:1

Case: 1:15-cv-09957 Document #: 1 Filed: 11/04/15 Page 1 of 10 PageID #:1 Case: 1:15-cv-09957 Document #: 1 Filed: 11/04/15 Page 1 of 10 PageID #:1 JACLYN PAZERA Plaintiff, IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION v. Case No.

More information

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION Peter E. Heuser, OSB # 811281 Email pheuser@schwabe.com Devon Zastrow Newman, OSB #014627 Email dnewman@schwabe.com Telephone: 503.222.9981 Facsimile: 503.796.2900 Sean G. Gallagher, pro hac vice pending

More information

Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 OSB#013943 sean.riddell@live.com Attorney At Law 4411 NE Tillamook St Portland, OR 97140 971-219-8453 Attorney for Plaintiff IN

More information

NOTICE OF CLAIM. Claimant, -against-

NOTICE OF CLAIM. Claimant, -against- SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE -------------------------------------------------------------------------x In the Matter of the Claim of JEAN H. PIERRE, JR., AS NATURAL PARENT AND

More information

BNSF RAILWAY COMPANY as Successor in Interest to the ATCHISON, TOPEKA & SANTA FE RAILWAY COMPANY, C O M P L A I N T

BNSF RAILWAY COMPANY as Successor in Interest to the ATCHISON, TOPEKA & SANTA FE RAILWAY COMPANY, C O M P L A I N T FILED IN MY OFFICE DISTRICT COURT CLERK 2/10/2012 9:16:03 AM GERI LYNN SANCHEZ STATE OF NEW MEXICO COUNTY OF VALENCIA THIRTEENTH JUDICIAL DISTRICT COURT KAREN R. SALAZAR, Individually and as Personal Representative

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

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

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

Plaintiffs, Defendants.

Plaintiffs, Defendants. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK DANIEL SCHULER, as Administrator of the Goods, Chattels and Credits of ERIN M. SCHULER, Deceased, and DANIEL SCHULER, as Father and Natural Guardian

More information

but does not include

but does not include WRONGFUL DEATH ACCOUNTABILITY ACT SEPTEMBER 2011 Contents 1 Definitions 2 Actions for Wrongful Death Scope 3 Action to be Prosecuted on Behalf of Decedent s Estate Time Limits 4 Types of Damages Recoverable

More information

Case 2:10-cv-00054-GZS Document 69 Filed 04/12/11 Page 1 of 5 PageID #: 363 UNITED STATES DISTRICT COURT DISTRICT OF MAINE

Case 2:10-cv-00054-GZS Document 69 Filed 04/12/11 Page 1 of 5 PageID #: 363 UNITED STATES DISTRICT COURT DISTRICT OF MAINE Case 2:10-cv-00054-GZS Document 69 Filed 04/12/11 Page 1 of 5 PageID #: 363 UNITED STATES DISTRICT COURT DISTRICT OF MAINE DAVID FITZPATRICK, as Personal Representative of the ESTATE OF RYAN R. FITZPATRICK,

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

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO 1 1 1 1 1 1 1 1 0 1 LAW OFFICES OF FERNANDO F. CHAVEZ Fernando Fabela Chavez, Esq., (SBN: 0 10 The Alameda #01 San Jose, CA 1 (0 1-0 Telephone / (0 1-0 Facsimile Attorneys for Plaintiffs GUILLERMINA MORALES

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

UNITED STATES DISTRICT COURT DISTRICT OF MAINE ORDER ON AMENDMENT TO WRONGFUL DEATH STATUTE

UNITED STATES DISTRICT COURT DISTRICT OF MAINE ORDER ON AMENDMENT TO WRONGFUL DEATH STATUTE UNITED STATES DISTRICT COURT DISTRICT OF MAINE DAVID FITZPATRICK, as Personal Representative of the ESTATE OF RYAN R. FITZPATRICK, Plaintiff, v. Docket No. 2:10-CV-54-GZS KENNETH P. COHEN, Defendant. ORDER

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

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

DISTRICT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO Court Address: 1437 Bannock Street Denver, Colorado 80202

DISTRICT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO Court Address: 1437 Bannock Street Denver, Colorado 80202 DISTRICT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO Court Address: 1437 Bannock Street Denver, Colorado 80202 DATE FILED: June 20, 2014 12:58 PM FILING ID: 592F22DEF1397 CASE NUMBER: 2014CV31778

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

Case 15-02065 Doc 1 Filed 04/07/15 Entered 04/07/15 11:42:31 Desc Main Document Page 1 of 13

Case 15-02065 Doc 1 Filed 04/07/15 Entered 04/07/15 11:42:31 Desc Main Document Page 1 of 13 Document Page 1 of 13 George Hoffman (10005) Benjamin J. Kotter (9592) Adam H. Reiser (13339) COHNE KINGHORN, P.C. 111 East Broadway, 11 th Floor Salt Lake City, Utah 84111 Telephone: (801) 363-4300 Facsimile:

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

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

Case 1:07-cv JJF Document 33 Filed 03/28/2008 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE

Case 1:07-cv JJF Document 33 Filed 03/28/2008 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE Case 1:07-cv-00218-JJF Document 33 Filed 03/28/2008 Page 1 of 11 STEPHEN HALCHUK, IN THE UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE VS. Plaintiff, Civil Action No. 07-218 ROBERT L. WILLIAMS d/b/a

More information

Case 2:14-cv-06333-JS-ARL Document 1 Filed 10/28/14 Page 1 of 13 PageID #: 131. : : - against - : : : Defendant.

Case 2:14-cv-06333-JS-ARL Document 1 Filed 10/28/14 Page 1 of 13 PageID #: 131. : : - against - : : : Defendant. Case 214-cv-06333-JS-ARL Document 1 Filed 10/28/14 Page 1 of 13 PageID # 131 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ---------------------------------------------- x MONTAJ, INC., Plaintiff,

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION NANCY PRITCHARD, v. Plaintiff, Case No.: KAPLAN HIGHER EDUCATION CORPORATION; KAPLAN HIGHER EDUCATION CORPORATION, as PLAN ADMINISTRATOR;

More information

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

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

SIXTH AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL GENERAL ALLEGATIONS

SIXTH AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL GENERAL ALLEGATIONS THE ESTATE OF LIDIA GIANGRANDI, by and through LILI CARISSA GIANGRANDI as Personal Representative of the Estate, vs. Plaintiffs, 50 STATE SECURITY SERVICE, INC., LOCH LOMOND HOMEOWNERS ASSOCIATION, INC.,

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

COMPLAINT AND JURY DEMAND

COMPLAINT AND JURY DEMAND DISTRICT COURT, JEFFERSON COUNTY, COLORADO 100 Jefferson County Parkway Golden, CO 80401 (303) 271-6145 Plaintiffs: NORMAN NEWELL and LINDA NEWELL, v. Defendants: COURT USE ONLY APRIA HEALTHCARE, INC.;

More information

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES STANLEY MOSK COURTHOUSE

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES STANLEY MOSK COURTHOUSE Stephen R. Cornwell, CA Bar #0 CORNWELL & SAMPLE, LLP Attorneys at Law 0 N. Fruit Avenue Fresno, CA -01 Telephone: () 1- Facsimile: () -1 Attorneys for Plaintiffs MARNI ILENE KATZ COTTER; REN VINCENT COTTER

More information

CASE NO: DIVISION: COMPLAINT. Jurisdiction and Venue 1. This is an action for damages in excess of $15,000.00, exclusive of costs and interest,

CASE NO: DIVISION: COMPLAINT. Jurisdiction and Venue 1. This is an action for damages in excess of $15,000.00, exclusive of costs and interest, IN THE CIRCUIT COURT, EIGHTEENTH JUDICIAL CIRCUIT, IN AND FOR BREVARD COUNTY, FLORIDA CASE NO: DIVISION: JEANETTE McMAHON, as Personal Representative of the Estate of Michael McMahon, TRACY GROGAN, as

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

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

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

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

IN THE CIRCUIT COURT FOR THE STATE OF OREGON COUNTY OF MULTNOMAH //01 ::00 AM 1CV IN THE CIRCUIT COURT FOR THE STATE OF OREGON COUNTY OF MULTNOMAH THE ESTATE OF ALEXANDER T. CALDERWOOD by its personal representative Thomas B. Calderwood, v. Plaintiff, ACE HOTEL PORTLAND

More information

$24.55 4.4.12 2012 WL

$24.55 4.4.12 2012 WL Cook County Jury Awards $24.55 Million to Woman Paralyzed in Car Accident 4.4.12 This case was reported informally by Patrick Dowd, Chicago, Illinois attorney, and the jury verdict was reported by Westlaw

More information

AMENDED CLASS ACTION COMPLAINT

AMENDED CLASS ACTION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. KIM WALLANT and LOUIS BOREK, on behalf of themselves and all others similarly situated, vs. Plaintiffs, FREEDOM

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

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. INFANT SWIMMING RESEARCH, INC., v. Plaintiff, FAEGRE & BENSON, LLP, MARK FISCHER, JUDY HEUMANN, NORMAN HEUMANN, BOULDER

More information

Case 3:14-cv-00039-MMD-VPC Document 12-1 Filed 02/12/14 Page 1 of 14 EXHIBIT 1

Case 3:14-cv-00039-MMD-VPC Document 12-1 Filed 02/12/14 Page 1 of 14 EXHIBIT 1 Case :-cv-000-mmd-vpc Document - Filed 0// Page of EXHIBIT EXHIBIT Case :-cv-000-mmd-vpc Document - Filed 0// Page of JOHN OHLSON, ESQ. NV Bar No. Hill Street, Suite 0 Reno, Nevada 0 Telephone: () -00

More information

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA ) R. Andrew Ketner and Stephen Baker, ) individually and on behalf of all other ) COMPLAINT similarly situated individuals,

More information

Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ZIPLINK, INC., Plaintiff, Civil Action No. v. VERIZON COMMUNICATIONS, INC., JURY

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

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

AMANDA K. HORTON; and KEITH ALSTRIN, No. CV06-2810 PHX DGC. Plaintiffs, AMENDED COMPLAINT

AMANDA K. HORTON; and KEITH ALSTRIN, No. CV06-2810 PHX DGC. Plaintiffs, AMENDED COMPLAINT SURRANO LAW OFFICES Charles J. Surrano (00) John N. Wilborn (0) 0 North Central Avenue, Suite 00 Phoenix, Arizona 0 Phone: (0) - Attorneys for Plaintiffs AMANDA K. HORTON; and KEITH ALSTRIN, IN THE UNITED

More information

: : : : : : : : Plaintiffs, HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, and

: : : : : : : : Plaintiffs, HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, and SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------x HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, BRETT HICKEY, AEGIS ALABAMA

More information

SUPERIOR COURT OF ARIZONA

SUPERIOR COURT OF ARIZONA Will J. Maiberger, Jr. Arizona State Bar No. 023343 Guy L. Watts (Pro Hac Vice Shalimar S. Wallis (Pro Hac Vice WATTS GUERRA LLP 811 Barton Springs Rd., Ste. 725 Austin, TX 78704 Telephone: 512.479.0500

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

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

PRACTICE GUIDELINES MEMORANDUM. RE: Sample Bankruptcy Motions and Orders for Personal Injury Practitioners and Trustees

PRACTICE GUIDELINES MEMORANDUM. RE: Sample Bankruptcy Motions and Orders for Personal Injury Practitioners and Trustees PRACTICE GUIDELINES MEMORANDUM TO: FROM: Attorneys Practicing Before Me And Other Interested Persons C. Timothy Corcoran, III United States Bankruptcy Judge DATE: January 3, 2000 1 RE: Sample Bankruptcy

More information

CAUSE NO. V. WILLIAMSON COUNTY, TEXAS. Defendant. JUDICIAL DISTRICT PLAINTIFFS ORIGINAL PETITION

CAUSE NO. V. WILLIAMSON COUNTY, TEXAS. Defendant. JUDICIAL DISTRICT PLAINTIFFS ORIGINAL PETITION CAUSE NO. MARY DOE and IN THE DISTRICT COURT JOHN DOE, Plaintiffs, V. WILLIAMSON COUNTY, TEXAS STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. JUDICIAL DISTRICT PLAINTIFFS ORIGINAL PETITION

More information

FILED: NASSAU COUNTY CLERK 07/12/2013 INDEX NO. 601780/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/12/2013

FILED: NASSAU COUNTY CLERK 07/12/2013 INDEX NO. 601780/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/12/2013 FILED: NASSAU COUNTY CLERK 07/12/2013 INDEX NO. 601780/2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/12/2013 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ----------------------------------------------------------------------}C

More information

IN THE COURT OF APPEALS OF INDIANA

IN THE COURT OF APPEALS OF INDIANA FOR PUBLICATION ATTORNEYS FOR APPELLANT: JOHN O. WORTH Worth Law Office Rushville, Indiana ATTORNEY FOR APPELLEE: JULIE A. NEWHOUSE Newhouse & Newhouse Rushville, Indiana RODNEY V. TAYLOR MICHAEL A. BEASON

More information

Case 2:13-cv-04245-JS-AKT Document 1 Filed 07/26/13 Page 1 of 11 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK. Case No.

Case 2:13-cv-04245-JS-AKT Document 1 Filed 07/26/13 Page 1 of 11 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK. Case No. Case 2:13-cv-04245-JS-AKT Document 1 Filed 07/26/13 Page 1 of 11 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ANA MARLEN MEMBRENO JIMENEZ, Plaintiff, - versus - WILLIAM DEGEL and

More information

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT INDEPENDENCE

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT INDEPENDENCE IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT INDEPENDENCE MICHELLE TALIAFERRO, ) MARIETTA TALIAFERRO and ) KEITH TALIAFERRO, ) ) Plaintiffs, ) ) v. ) Case No. 02CV233442 ) Division 16 GREEN VALLEY

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 1 MICHAEL P. VERNA(# 4070) NATHANIEL B. DUNCAN (#463) 2 JEANNE YANG (#4) BOWLES & VERNA LLP 3 N. California Blvd., Suite 75 Walnut Creek, CA 456 4 Telephone: () 35-3300 Facsimile: () 35-0371 5 Email: mverna@bowlesverna.com

More information

v. Record No. 080751 OPINION BY JUSTICE BARBARA MILANO KEENAN June 4, 2009 LOUIS N. JOYNES, II, ET AL.

v. Record No. 080751 OPINION BY JUSTICE BARBARA MILANO KEENAN June 4, 2009 LOUIS N. JOYNES, II, ET AL. PRESENT: All the Justices LEO WILLIAMS v. Record No. 080751 OPINION BY JUSTICE BARBARA MILANO KEENAN June 4, 2009 LOUIS N. JOYNES, II, ET AL. FROM THE CIRCUIT COURT OF THE CITY OF PORTSMOUTH Dean W. Sword,

More information