IN THE CIRCUIT COURT FOR HAMILTON COUNTY, TENNESSEE BARRY GALINGER and GRETCHEN GALINGER, individually and as next ) friends to, ETHAN GALINGER and ) HAILEY GALINGER, minors, ) ) Civit Action No JOC 34 Plaintiffs, ) ) JURY DEMANDED (12) ve ) + ) Z JANET ELAINE HINDS, ) \ ) Defendant. ) S COMPLAINT ntiffs, Barry Galinger and Gretchen Galinger, individually ait asext Come now, the Pl friends to, Ethan Galinger and Hailey Galinger, pursuant to Tenn. R. Civ. P, 17.03, and for their Complaint against the Defendant, Janet Elaine Hinds (“Ms. Hinds”), state as follows: 1 PARTIES 1. Barry Galinger and Gretchen Galinger are the parents of Chattanooga Police Officer, Nicholas Scott Galinger (“Officer Galinger”), a deceased adult resident of Hamilton County, Tennessee, having been killed by Ms. Hinds on February 23, 2019, while in the line of duty. Ethan Galinger and Hailey Galinger are the minor children of Officer Galinger. 2. Ms. Hinds is a citizen and resident of Hamilton County, Tennessee. Upon information and belief, Ms. Hinds may be served with process at 207 Port Drive, Hixon, Tennessee 37343. tl. FACTS: 3. Officer Galinger was, and is, the beloved son and father of the Plaintiffs. However, Officer Galinger’s life was tragically ended by the egregious conduct of Ms. Hinds as set forth herein,4. In January of 2019, Officer Galinger fulfilled his dream of becoming a law enforcement officer, and joined the Chattanooga Police Department. In his short time as a police officer, Officer Galinger earned the respect and admiration of his fellow officers and the Chattanooga community at-large. 5. In the evening of February 23, 2019, Officer Galinger traveled to the 2900 block of Hamill Road in Chattanooga, Tennessee, along with fellow Chattanooga Police Officer Jarred Justice (“Officer Justice”), to respond to a call concerning an overflowing manhole cover. At or around approximately 11:00 P.M. shortly after their arrival at the subject manhole on Hamill Road, Officer Galinger began inspecting the manhole with a flashlight. 6. At that time, Ms. Hinds came speeding north in the center of Hamill Road in a white Honda CR-V traveling between approximately 47 and 52 miles per hour, well-over the 35 miles per hour speed limit, Upon information and belief, Ms. Hinds was driving while intoxicated and was returning to her home in Hixon, Tennessee, from one or more restaurants in Ringgold, Georgia, where she drank alcohol to the point of intoxication until approximately 10:33 P.M. 7. Unfortunately, Ms. Hinds violently struck Officer Galinger with her vehicle at approximately 11:05 P.M, causing his body to brutally crash into the windshield, and careen up over the top of the vehicle. Officer Galinger’s body eventually landed approximately 160 feet, down Hamill Road. Although Ms. Hinds was aware, or should have been aware, of the fact that she had just violently struck Officer Galinger causing his body to careen far down Hamill Road, Ms, Hinds fled the scene without an ounce of remorse. 8 Ms. Hinds caused Officer Galinger to suffer significant and catastrophic injuries. After Officer Justice, other police officers, and emergency personnel attempted to save OfficerGalinger’s life at the scene of the accident, Officer Galinger was transported to a Chattanooga hospital. Despite his physicians’ best efforts, Officer Galinger tragically succumbed to his injuries and was pronounced deceased at approximately 11:40 P.M. As a result, Ms. Hinds caused Officer Galinger to suffer severe and excruciating injuries causing great pain and suffering from the moment Ms. Hinds violently struck him with her vehicle until the moment of his untimely death 9. Ms. Hinds was later apprehended after being named by the Tennessee Bureau of Investigation as a fugitive from the law on its “Top Ten Most Wanted” list, and was charged with vehicular homicide, reckless driving, and other criminal offenses. 10. Notwithstanding, upon information and belief, Ms. Hinds has taken the position through her attomey that her collision with Officer Galinger was simply an unfortunate accident for which she is not responsible. Il, CLAIMS FOR RELIEF COUNT 1 Negligence 11. The Plaintiffs restate the allegations contained within Paragraphs 1 through 11 of this Complaint and incorporate those allegations by reference as if fully restated herein, 12, Ms, Hinds was generally negligent in the operation of her vehicle at the time she violently struck Officer Galinger. The accident and resulting injuries sustained by Officer Galinger causing his untimely death were directly, proximately, and foreseeably caused by the negligent acts, omissions, and breaches of duty by Ms. Hinds, including, but not limited to, the following: (a) Negligently, carelessly, and without caution driving her vehicle violently and directly into Officer Galinger; (b) Failing to operate her vehicle in a safe and prudent manner in view of the conditions which existed at the time she struck Officer Galinger; (c) Failing to see