CIV 161208 CIV DS1621023 CASEEN 093702

Scanned Document Coversheet

System Code

CIV

Case Number

DS1621023

CaseType

CIV

Action Code

CASEEN

Action Date

12 08 16

ActionTime
a c an

seq

Printed

by

9 37

THIS COVERSHEET IS FOR COURT

PURPOSES ONLY AND THIS IS NOT
A PART OF THE OFFICIAL RECORD
YOU WILL NOT BE CHARGED FOR

0002

TH I S PAG E

DMOND

Complaint and Party information entered

NEW FILE

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2016 12 07 23 59 10

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2132323255 From GERAGQS

iLED Centrai t tstri

SUPERIOR COUR1

SAN BEFtNARDINO CQllt tiY

X

GERA GOS

GERAGOS

A 1 RpF E SSIC NA1 CORF C RA77

026

LA VYeRS

HISTJR C FNGINE CO NO 2E3

Ei 4 SOt1Tti F3G1 EF Qa STREEf
LOS ANGELES CALIF VftNIA
TEI

PHO1 lE

FncstM

213

7Q i 7

2J
23

n
3255

GE RAGC3S @Ci E RAGOS CC M

iRiliiY

M A RK J

GEI2 AG S
BFN T ii IEIS LAS
ALEX AL RCC I

SBN 10832
SBN 27741
SBN 305537
Attorneys for Plaintiffs Z II E ESTATE OF JAMFS IIALL MERRY JA11r

7A VI77

H r1LL K REN I 1LI and JC1I II KARBCrINSKY

StiPER C1R CQURT OF TI3

ST T E OF CALi t RNIA

FOI2 THE C4CENTY QF SAN BERNt1RDIN0

10
THE FS FATEOF JA MES HAL L
11

MFRR

J M FS

I1 1 LL
1

yZ

13

incli viclual

c i vi dc

JU LIEK 1R l3GINSI Y

anet

an

Plaintitfs
5

10

5 r tz

4
16
7

18
1

CITYC F FONTr1I F 1 FFJN I INtI

FT 1
inc ivic
an
an

k R
ua l

aia

i ndiui

an

TT DAVT D LAL

6
X

indi vidual

O FFTC R I AfitE MeC

Y
individu l C3F IC ER S I 1V4
C 4RY

r i ndr idrial C FFICE RRY N

21
2

V 1 NDE L L

an

indi

idu i f

F CF

GI C V 41 Ii III 1 CRi r1IVD F 7 ar incli v icival

TFIC RCI IRISTtJPi IER

DR Y I2 an 4
23

i ncii viciw l
Al tiCON A
4l

25

26
27

F F iC F R n

vIEI IC 3

an t ndi xicival

D E EWI I ACK

EI

i fl TT

ER

an

FF1 C 1
iv dual
as

i ndi vieiva l OTFICER ST VFN ROE an

inciividual and D4E OFFICERS 1 20
Defent ants

VIC L TItJN t F CIVII RIGHT5

FAMILIAL RELATTONSHIP
VIOLAT ON OF CIVIL T IGfITS
E
MiLI 1 L R L I 1tJNSHIP
V OLAT t N C F CIVIL C
52 1

ual

R F R T CJ LAC

SERGE

1983

VIOLATI4N OF CIVIL RIGN TS

VIO NELL

f C t1 CE DEPf RT MENT OFFTC ER

NEIL BACI II AN

AfONELL CLAIM
3

1i

iu

1ti1PLA1NT FOR DA1 IAGES

L3 S C
Z

14

iv

Nn

VICILAT ON CJF CIVIL RIGHTS

ase

YlllAV1 ll

ri ldividual K 1RE 1 H A L L a

indi icieta l
ii

an

DE

WR fNCFUL DEAT II
NEGLIGE tCE

DEMAND FOR JURY TRIAL

GERAGOS

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GMT

GERAGOS

1
2

Plaintit fs hereby allege as follows

I TRQDUCTI

3
4

At

approxim

tely

a m on Novemt er 22 2415 L c cedent Jamc s Ha1L a

blind indivitival suffering trotn

zu
s
x

disorder

Chevron

leg lly

Station

conducting himsclt peacetully

contlict

county oraner s of ce fo weeks bef ore his family vas tinall r grantcci access to ii

sc

ras c utsid

of

A group of FUntana Police Departrnent ofticers enao intered I I 1L who was

and

ventuaily

fficers escalated their encounter with Hall into a

The
letha

t eplc yed

fc

rce

killin

IIatL

Ha1t

c cly u as kept at zhe

THE PaRTIES

11

PlaintiffMerry J3r es is an heir tc Llecedent Janaes II 11

l2

Plaintiff D vid Hall is an heir ta Dececient James I Ial1

l3

Plaintiff Kai en Hrxil is

14

Plaintiff iulie Karb g insky is an heir to D cedenk James Hall

15

fi

At a11 times herein mentioned Defendant City f Fantlna was a govcrnmenta

w
n

izoaffective

10

n heir tu Decedez t 3a nes 1 1a11

p y wwi
r
q

16

entSt r organized and e xisting under tf e la vs of the State c f Califarnia

17
18

7
governmental

23
24
25
26
27
2

entity

tirnes hereiT

rganized

intic l ec

ud e

istin

De1 endant Fontana I

under

lace Depart

the laws of tlle State c

as

at

all

relcvant

nent

as

Califamia

times

police

ofEicer

employ d by the City t f F n ana acting uncier col r of autIiority

9

21
22

all

Defendant C fficer Neil Bachman

19

20

at

en

Defendant tJf cer R

bert GIace u s

at all

rele rant times

a palice ofticer

lo ed by the City of Fontana actin uncier color of auth rity

10

Defenc ant Scrgeant David Lally was at all relevant times a police oftic r

cn ployeci by the City of Fontan i acting uncier c lor of aUthority

1 1

Defendant Officer Shane McCc y

was

at

li

retevant

tizncs

c lice vfficer

employcci by the City ot Fantana acting ur der cr it r of i athc rity

1

efendant

Offic

Sl

av m

Cory

as

at all relevant tirnes

emplovcci by the City of rontanl aeting u der ec lor o1 authc rity

CO

1PLAINT FOR DA 1AGES

a police off cer

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20

of

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1
2

13

14

15

16

17

Defendant Officer C iovanni

Iernandez was

at all relevant times

a police

Defendant Ofticer t hristopher Draycr

was

at

all

relevant times

police

Defendant C fficer pom riico Aricona was at all relevant times a police officer

Detendant Offcer Andre4v Hackett was at all relevant times a police officer

employed by the City of I ontana acting under color of authority

11

18

vas at all relevant timcs a police of ticer

employed by the City of Fontana acting under color of authority

9
10

GERAGOS

ofticer employed by the City of Fontana acting under color of authority

7
8

From GERAGOS

ofticer employed by the City of Fontana acting under color of authe rity

5
6

Defendant Ufficer Ryan Windell

2132323255

employed by the City of Fontana acting under color of authority

3
4

GMT

Defcndant Officer Casey Vlutter was at ali relevant times a police nfficer

12

employed by the City of Fontana acting under color of authority

13

Defendant

Officer Steven Roe

was

z ozx
ZLL
a

C
Q
s

14

at all re evant times

a police ofCcer

employed by the City of Fontana acting under color of authority

20

Plaintiffs are unaware ot the true names and capacities of the Defendants

Vw
c

16

named herein as DOE OFFICERS 1 throu h 2U inclusive and therefore sue said Defendants

17

by such tictitious names Plaintiffs will seek leavc of court to amend this complaint to allege

18

the true

19

are inf ormed and believe and t iereon alle e that each of the atoresaid fictitiously named

20

Defendants sre responsible in sotne manner for the happenings and occurrcnces hereinafter

21

alleged

22

cunduct ot said De endants

names

and

and capaeities of said

the

23

Plaintiffs

Defcnciants

21

the same ai e ascei tained

Alaintif fs

damages and injuries as herein allegcd were caused by the

JURISUIC 1 ION

24

when

This Court has jurisdiction

CVUC
ov

ND tiUTICE

the entire action

by

rtue of the fact that this

25

is a civil actian wherein the inatter in c ontroversy e clusive c f interests nd costs exceeJ

26

the

27

months trom the City of T onCana s lune l3 2016 rejectiot of Plaintiffs Govea nment Tort

28

Claim

jurisdictional

minimum

ot

the

CO

Court

I he instant action is timcly brought within 6

PLAINT i OR DAMAC ES

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From GERAGOS

GERAGOS

FACTUAL BACKGROUND

2
3

2132323255

GMT

22

Decedent

Ia11 was a legally bli d individual known by Det endant Fontana

Police Department to suCfer from schizoaffeative disorder

23

Decedent

Iall

vas

a peacefiil person

wh

had pr eviously becn award d for his

community seiti ice

6
7

24

nature Additionally the residents of his community were fully aware of his disabilities

On

25

or about

November 22 2015

at

ap roximately 4 15

a m

Decedent James

Hall was outside a Chevron station on the corner of Sierra Avenue and Slover Avenue

10

Decedent I Iall was well known throughout his neighhorhood for his peaceful

26

lleeedent Hall entered the convenience stoi e located at the Chevron station

and began walk ing around inside

1
1

13

o z
a Ua ce

27

After Decedent Hall tlad spent a few mi rutes browsing around the com eniencc

W
U J

store one of the Defendant officers approached him vith a hancigun drawn

14

28

The

officer

kept his

gun

pointcd

ZL4

U
15

policeman

1G

locked on Dccedent Hall

who

was wieli

ing

a lar

tirear

t Hall and was soon joined by a second

This

second

fficer also k pt his weapon

flN
J
0

17

29

The tirst two officers were soon joined by a third ofticer and a police dog

18

30

A fourth officer joined the roup shortly therealter and also quickly pr dueed

19

a handgun which he aimed direct ly at Decedent Hall

20

31

A t11th ofticer then approached the door Co tl e convenience store drew his

21

Cireartn

and pointed

22

fircarm

was

23
24

being

it

ai

Decedent Hall

threatened

by

At this point

Dccedent Hall who c ried no

ficers

Three of these policemen were

team of

five

ned with handguns one with a larger tircarm and ihe f inal officer with a trained police
dog

32

One of the Deiendant oi licers tic d a shot in Decedent Hall s direction and the

26

entire

27

Defe ndant officcrs drew an ele ctric stun weapon

28

of

group

33

subs

yuently be

an

Co move

in

on

Decedent F

all

t this point

one of the

The Def endant ofticers i eteased I7eir polic e dog on Decedent I all and he
3
CONIPLAIV

FOR DAM AGES

I

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2132323255

D fenci nt of icers c hasec Dececient Hall w ith his firearn raised

34

35

36

bac y

As the DetendanC office rs continued to siirround I ecedent Hall csne of them

died

A tea rn oI 4 pprcaximaCely t n officers swarmed Decedent Ilalt s rnc7tionless

37

11

office

l2

substantial

wcapons still

ciraw n

By

aint hc weti er Dececient Hall had alre dy

this

After L ecedent Iall s death his body was held far wceks at the coroner s

without

Decedent s family was denied access to his body far a

justi ficatic n

erio

while Decedcnt s body vas detained at the cac oz er s office

rm
q

One of the

Tfie Defendant o ticers cornered Decedent Hall in the rear of the convenience

ith their

10

ZK

GERAGOS

opened fire an him and I ecedent I Iall fell to the ground

fNWQ

ran

GERAGOS

store b andishir g irearms inncludin an assault ritle

5
6

startled

Froir

to the rear ot the ct nvenience store and cowere d there

became

GMT

He

YO

13

CTIQN

EIRST CAUSE QF

wUCGcS

w
w

ti

14

Violation

l5

r4

of

42 U S C

Civil Rights

Plaintiffs against Of

1983

c r Uefendants

f tt U
w
VG

16

38

Plaintifts

reallege

and

ncarpc rate l y referez 4e e ch and every allegation

car tained iti the precedin

18

39

para raphs as if full

Defendants

fficer

set fc rth tzcrein

Neil Bach nan

Ufiicer Rc bert GJace

Sergeant David

19

Lallyr CJfticer Shane 1VIcCoy Officer Shawn Cary 01 icer Ryan Winc ell Officer GiavarYni

20

Hernan

21

fticer

22
23
24
2S

6
27
2

Casey

referred

vith

fticer Christopher Drayer Officer I7cfinenico Ancona Officer Andrew Hackeit

ez

to

as

Nl

utter

Officer Steven Rve

Ofticer Defenc

the Fontana Police

40

and

wei c

ants

eplrtn ent who

c e

l icers 1

Q hereinat er cc lectively

at all relevant times

law c nforcement c

ficers

ere acting un ler color raf siale law

I laintiff s bring tl is claim for relief in their capacities as the succcssoi s in

interest anc personal represet tatives of l ecec ent fames Ha l

41

The fc

regoin

elaim

t t r relief

arnse

in Decedent

favc r

and

Decedent

ould

hav been the plaintiff vith res ect to this claim for relief had he lived
42

Of

icer

Defendai ts

aciing

rnder

color

of

co

Pt A NT rc rz r atiancrs

state

la

deprived Dec dent of

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2132323255

From GERAGOS

GERAGOS

rights privilcges and immunities secured by the Constitution and laws of the United States

inctuding those enumcrated in and secured by tl e T ourth Fi th an d Fout teenth Amendments

to the Constitution by subjecting Decedent to excessive force when th y shot and killed him

4
5

43

I he wrongfiil acts alleged herein above of Officer Defendants were the causc

o f Decedent s death

44

A5 a proximate result of the foregaing vrongful acts of Officcr Defendants

and each of them Decedent sustained general damages i icluding pain and suffering and a

loss of the enjoyment of lifi and other hedonic damages in ai1 amount in acco dance with

proof

10

45

in

In doing the foreg ing wrongful acts Officer Defendants and each of them

11

acted

wrongful acts

warranting the lward of punitive damages against each individual Ofticer Delendant in an

l4

amount

reekless

and

eallous

disregard

fi

the constitutional

rights

of

Decedent

The

M
NU

and each of them

were wilfiil oppressive

fraudulent and malicious

thus

z oZ

usa

dequate to punish the wrongdoers and deter tuture misconduct

l W1U
I

15

4i

sW

Due to th

conduct of Oft7cer Defendants and each of them I laintiffs ha e

16

been rcquired to incur attorneys fees and will continue to incur attorneys tees and pursuant

17

to 42 U S C

1988 are zntitled to recovcry of saiu iees

18

SEC

19

Violation

20

47

Vlorrell Claim

Plaintiffs rcallege and incc rpt rate by refercnce the allegations contained in the

Plaintiffs bring this claim f tr relief in the ir capaciCies as tl c successi rs in

interest and personal i epresentatives of Deccdent James H all

5
26

Civil Rights

preccding paragraphs of this complaint as thoug 1 fully set forth hcreitl

23
24

of

Plaintiffs against Defendants City of Fontana and Fontana Police Department

21
22

ND CAUSE OF ACTION

9
ross

De en l ints C ity oE Fontana and Fontana Police De artment knowingly with

negligence

and in deliberate indifference to the ConstitutionaJ rights of citizens

27

maintain and perinit an ofticial policy and custom of permittin

28

of vrongs set forth hereinabove and hereafter

5
CONIPL

INT FOR D

iv1AGES

the occurrcnce oi the types

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50

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From GERAGOS

GERAGOS

Thesc policies and customs include but are not limited to the delibe ately

indifferent training of law enforcement ofticers in the use of excessive force the express

and or tacit encouragement of excessive force the ratiticatian of police misconduct and the

failure to conduct adequate unbiased investigations of police rnisconduct such that future

viol tic ns d

51

not occur

Plaintiffs

re informed and believe and thereon allege

that the c stams and

policies were the moving force behind the violations of Plaintiffs and Decedent s rights

Based upon the principles set forth in r onell v New York City Dep t vf Social Services

Defendants

10

City

of

Fontana

and

Fontana Police Department

are

liabl

for all of the injuries

sustained by Decedent and Plaintiffs as set forth aUove

1 1

52

As a proxim te result of the foregoing wrongtul acts c P Defendants and each

J
JJ W

12

of

13

cnjo rnent of life and othen c donic ciamages in an amowlt in accordarice with proof

them

Decedent

sustained

eneral

darn

includin

es

a8
4

yU

Pain and

sutfcrin

and a loss of thc

rt

14

53

Uue to thc conduct of Defendants and eaeh of them

Plaintiffs have bee n

15

required to incur attorneys fees and tivill continue to incur attorneys fees and pursuant to 42

16

LJ S C

Uu

C 7

1988 re entitlec to recavery of said fees

17

18

TFiIRD CAUSE OE ACTI

Violation

of

12 U S C

Civil Rights

1983

Deprivation of the Rights of Plaintiffs to

19

a Familial Relationship with the Decedent

20

Plaintiffs against Officer Defendants

21
22

54

receding

Ylaintifil s reallege anc incorporaCe by refierence the allegations contained in the

para

23

raplis of

Ofiic

this Complaint

Defenda

as

tliou

h ftill

r coior c

set torth hercin

te law
i

icprived Plaintlffs of thei

24

rigl

unjustifiied

26

pruvocation all in violation af rigl ts privilcges and immuniCic s secured by the First and

27

Fourte nth AmendrnenCs to t11e t nit

28

t to

S6

familial
cce

As

rela

cai

tion5hip
ng

a result oP

ithout 1ue C rocess ot law by Ofticer Defendants use ol

injurie

the

ich

sulted

in

l7ecedent

death

all

witho

1 States C onstituti on

foregoing

rungful acts of

6
COMPI

r11

T FOR D

19AGES

fficer Defendanis and each of

To

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of

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2016 12 07 23 59 10

thcm

sut erin

an amount

2132323255

From GERAGOS

GERAGOS

eneral damagcs includii g rici emotional distress and pain and

sustained

and loss of comfort and society and special damages including loss of suppoi C in
in

57

ith proof

accordance

tn doing the foi egoing wron t ul acts Of ticer Defendants and cach of them

acted in reckless and callous disregard fior the C onstitutional rights of Plaintiffs when they

killed Decedent

and malicious

Officer Defendant in a l amount adcquate to punish the wron doers and deter future

misconduct

1 U

Plaintiffs

GMT

58

The wrongful acts and each of thern were wil ful oppressive traudulent
thus warranting the award of puniCive damages againsi each individual

Due to the conduct of Ofticer Defendants and each of them Plaintiffs have

1 1

been re uirc d to incur attorneys fees and will continue to incur attorneys fees and pursuant

12

mf
NW

42 U S C

1988 are entitled to recoveiy of saicl fees

o
rn

1 3

L i
w
f

14

Violation

of

s
J

W
sW

FOUIt C N C USE OF ACTION

Civil Rights

15

t2 U S C

16

Familial

1983

Relationship

r rith

Deprivation of the Rights of Plaintiffs to

the Decedent

Mvneln

Plaintifls against Defendants City of P ontana and Fontana Police Department

17
18

59

F laintiffs reallege and incorporate by reCerence ehe al egations contained in the

19

preceding paragraphs of this Complaint as Ch ugh fully set forth herein

60

Defendants City of Fontana and Funtana Police Department knowingly and

20

with gross negligcnce

21

occurrence

oL

the

maintain and pel mi t official policies and cu5t ms which allow the

types

of

rongs set forth hereinabove and below

all

in deliberate

23

indifference to the Constitutional rights oE citizens

6l

These polieies and customs includc but are not limited to the defiberately

24

indiftc rent training

25

and or tacit encouragement c f ex cessive force Further the Uefendants ratificatian of police

26

rniscoz duct along with ihe failure to conduct adequate investigations of miscanduct led to

27

the violations of the Plaintiff s ancl Che Decedent s Constit utional rights

28

62

of

law

cnforcerncnt

t i cers in the use of exces5ivc f orce the eapress

In spite of 1 iintitfs filing vf a claim Defendan s City of F ontana and Fontana

7

CO

lPL 11

T FOR Dr1V1AGES

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From GERAGOS

GERAGOS

Police Uepartment failed to make an unbiased investig3tion or take any action it1 preservin
IaintitEs

Decedent

or

rights

or verify misconduct and discipline otticers for the

misconduct

policies were the moving force behind the violations of Plaintiffs and Decedent s rights

Based

Dcfendants City of Fontana and Iontana Police Department are liable tor all of the injuries

sustained by Plaintiffs as set forth above

8
9
10

Plaintiffs are infornled and belicve

upon

63

the principles

set

forth in Monell

and thereon alle e that the customs and

1Vetiv

ork Ci j Uep t of Social Se vices

In acting as alleged herein Deferidants and each of thein caused Decedent

James Hall s demise and the resulting loss to Plaintitfs thereby causing Plaintiffs to be
damaged in an amount to be detei mined at the tirne of trial

11

64

Dtte to the conduct c f Defendants

and each of them

Plaintiffs have been

NCtl

12

reyuired

13

U S C

to

incur

attorneys

fces

ill continue to incur ltiorneys

and

fees and pursuant to 42

vG

v7 u

W z

1988 are entitled to recovery of said fees

14

FIFTFI CAUSE OF ACTION

Violation

wzc

of

Civil Cocie

52 1

N
T

16

Plaintiffs against all Defendants

J
0
17
18

65

preceding parabraphs of this complarnt as though fully set forth herein

19
20

6G

3
2 4

67

27
28

Defenda lts Gity of F ntana and Fontana Police Department are liable for thc

acts omissions and conducl oF their employees including Offic r Defendants hercin whose
negli

ent

condu

Government C

25
26

Ofticer Defendants acting within the scope of their dutics as CiCy of Fontana

employees caused the death o Jlmes Hall

21
22

Plaintiffs reallege and incorporate by refet ence the allegations containc d in the

S
et sec

dc

ch

of

the

Dccedent

pursuant

to Caliiornia

815 2

ude

PI

use

is

ti

tiled

timelv ciaim pursuant io

California Govei7

ment

Code

910

As that claim has been rejected in the past six monchs this action is timely
69

Plaintif fs are the proper parties n ith standing as successors in interest and on

behalf of Decedcnt pursue thc claims of Decedcnt basec on a violatian of his ri hts
8
C O

IPL AINT FOR Dr V1AC ifS

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2132323255 From GERAGOS

GERAGOS

The conc uct of Dcfendants constituted interference by threats int imidation or

coercion or attempted interference with th cYercise of enjoyment by Decedent James Hall

of rights secured by the Constitution and laws of the United SYates or securecl by t he

C onstitution and la s of the State of California including interfcr nce witt Decedent s

rights to be sei ure in his person and fi ee from the use of excessive force under thc Fourth

Amendment

protection frorn bodily rc straint and harm

8
9
10

71

and

Cal

Const Art l

scc

13

as well 1s

r s a direct result of Dcfendants

Calif oi nia Civil Code

Cal Civ

ode

conduct the Deceden

43 and the right of

s rights pursuant to

2 1 were violated causing injuries and damages in a i amount to be

proven at the time of trial

11

72

Due to the conduct of Defendants

and each of them

Plaintiffs have been

y
p

fv
O

5oz
r

GMT

tU

12

required to incur attorneys fees arid will continue to incur attorneys fees and pursuant to

13

California Civil Code

52 1 are cntitled to recoverv of said fees

14

SiXTH CAUSE OF ACTION

15

Negligence

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Wrongful Death

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Plaintiffs against atl Defendants

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17
18

73

preceding paragraplis af this camplaint as though fully set forth herein

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20

Plaintiffs reallege and ineorporate by reference the allegations contained in the

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Of cer Defendants acting within the scope of their dutics as City of rontana

employyecs caused the death of Deccdent James Hall

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Defendants CiCy of Fontana and F ontana Police Department are hereby liable

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for the acts omissions and conduct of their employees ineluding Defendants hercin vchose

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neeli

24

Govcrnment Code

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26
27
2

ent

76

ii

eonduet

PI

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cleath

uf

the

Decedenc

pursuant to

C llif ornia

815 2

ntiffs

tii

ely

claim pursuant

io

Califoniia Govemment Codc

91 1

et seq As that claim has bcen rejected in the past six months this action is timcly
77

1 laintiffs ure the proper parties with standing pursuant to C al Civ Proc C ode

377 60 and hereby pursue their remeclies for wr 3ngCu1 death against Defendants and each
9
C 0 1PL 11NT FOR

AMAGES

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of

2016 12 07 23 59 10

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GM

GERAGOS

GERAGOS

of them including recovery for pecuniary loss and other compensable injuries resulting ti am

the loss of the society comfort attention services and support of Decedent

3
4

78

The negligence of Defendants was also responsible ii pa rt for the death of

Decedent James Hall by acts or omissions contributing to his demise including but not
limited to thc deliberately indifferent training of lac r enforcement officers in the use of

excessive force the express and or tacit encouragement of excessive force the ra titication of

poliee

misconduct such that f uturc violations do not occur

9
10

misconduct

79

and

the

failure

conduct adequate unbiased investigations of police

Detendants are further responsible for acts and prc shoot tactics implemented

by Defendants before Decedent s death

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80

Decedent s Ic ss has and will continue to cause great and severe damages to his

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loved ones the Plaintiffs in t12is acCion al in an amount according to proof at the time of

13

trial

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As a further direct result of Defendants

acts omissii ns negligent conduct

and or reckless disregard t r the sa fety of Decedent Plaintiffs have incurred funeral and

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burial expenses in an amount according to proof at the titne oftrial

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18
19
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21

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23
24
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COMPLAINT FQR DA

GES

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WHER FORC Plaintiffs pray for judgrnent as follows

For general dai ages in a amuunt to be determined by proof at trial

For special dama es in an amount to be determined by proof at trial

For punitive and exemplary d r iages against the individual Uefendants for the
FirSt and Cfiird Causes of Action

For costs of suit

For rcasonable attorneys fees as provided by statute an d

P or such other and further relief as tl e Court deems just and pt oper

DATED

December 7

2016

GERAGOS

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APC

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RK J GFRAGOS

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By

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BEN 7

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MEISELAS

ALEX ALARCON
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Attot neys for Ylaintifis

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DE

AND FOR JURY TRIAL

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18

E laintiffs TF IE ESTA IE

F JA1 1ES H

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MERRY JAMES DAVID HALL

KAREN HALL and JULIE KARIiGINSKY hereby demand a jury trial

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Z

DATED

Decc

mber

7 2016

GERAGOS

GFRr1GUS APC

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22

gy
1

RK J GERAGOS

BLN J
24

MEISELAS

ALEX ALARC nN
Attorneys for Plainriffs

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