State Court of Fulton County

***EFILED***
File & ServeXpress
Transaction ID: 63386818
IN THE STATE COURT OF FULTON COUNTY Date: Jun 21 2019 12:00AM
STATE OF GEORGIA LeNora Ponzo, Chief Clerk
Civil Division
ANGELA KEELING, Individually and as
)
Surviving Spouse of MARVIN TODD)
KEELING, and ANGELA KEELING, as)
Administrator of the Estate of MARVIN
)
TODD KEELING, deceased, )
) CIVIL ACTION FILE No.
Plaintiffs, )
)
v. )
)
ATLANTA NATIONAL LEAGUE )
BASEBALL CLUB, LLC; DELAWARE )
NORTH COMPANIES SPORTSERVICE, )
INC.; ATLANTA SPORTSERVICE, )
INC.; DRAFT BEER SERVICES OF )
ATLANTA, INC.; BRAVES STADIUM )
COMPANY, LLC; BRAVES )
CONSTRUCTION COMPANY, LLC; )
BRASFIELD & GORRIE, LLC; M.A. )
MORTENSON COMPANY; BARTON )
MALOW COMPANY; NEW SOUTH )
CONSTRUCTION COMPANY, INC.; )
IMPERIAL BROWN, INC.; BARING )
INDUSTRIES, INC.; ESG INSTALL, )
LLC; PERLICK CORPORATION; ART )
PLUMBING CO.; BEVSTREAM )
CORPORATION; A-HEAD FOR )
PROFITS OF GEORGIA, LLC; S2O )
CONSULTANTS, INC.; J.F. DUNCAN )
INDUSTRIES, INC., d/b/a DURAY; )
XYLEM WATER SYSTEMS U.S.A., )
LLC; and UNITED DISTRIBUTORS, )
INC. )
)
Defendants. )

COMPLAINT

COME NOW Plaintiffs in the above-styled action and hereby file this Complaint as

follows:
 PARTIES, JURISDICTION, AND VENUE

1.

On or about June 26, 2018, Marvin Todd Keeling died intestate, survived by his wife

Angela Keeling, and his four (4) children. Plaintiff Angela Keeling became the duly-appointed

Administratrix of the Estate of Marvin Todd Keeling by virtue of the Order dated September 19,

2018, of the Probate Court for Ramsey County, Minnesota attached hereto as Exhibit “A.”

2.

Plaintiff Angela Keeling, individually and as the surviving spouse, and Plaintiff Angela

Keeling, as Administratrix of the Estate of Marvin Todd Keeling, hereby state Plaintiffs’

intention to bring each and every claim permissible under Georgia law arising from the injuries

to and death of Marvin Todd Keeling, including all individual claims, personal injury claims,

wrongful death claims, and Estate-based claims. Plaintiffs seek all medical expenses, funeral

and burial expenses, necessary expenses, pain and suffering, wrongful death, estate damages, and

all compensatory, special, actual, consequential, economic, general, punitive, and all other

damages permissible under Georgia law.

3.

Defendant Atlanta National League Baseball Club, LLC (hereinafter “ANLBC” or

“Defendant(s)”) is a Georgia Corporation authorized to transact business in the State of Georgia

and may be served through its registered agent, Corporation Service Company, 40 Technology

Pkwy South, #300, Norcross, GA 30092.

4.

Jurisdiction and venue are proper as to Defendant ANLBC.

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 5.

Defendant ANLBC has been properly served with process in this action.

6.

Defendant Delaware North Companies Sportservice, Inc. (hereinafter “Delaware North”

or “Defendant(s)”) is a New York corporation authorized to transact business in the State of

Georgia, and may be served through its registered agent, Cogency Global Inc., 900 Old Roswell

Lakes Parkway, Suite 310, Roswell, GA, 30076.

7.

Jurisdiction and venue are proper as to Defendant Delaware North.

8.

Defendant Delaware North has been properly served with process in this action.

9.

Defendant Atlanta Sportservice, Inc. (hereinafter “Atlanta Sportservice” or

“Defendant(s)”) is a New York corporation authorized to transact business in the State of

Georgia, and may be served through its registered agent, Cogency Global Inc., 900 Old Roswell

Lakes Parkway, Suite 310, Roswell, GA, 30076.

10.

Jurisdiction and venue are proper as to Defendant Atlanta Sportservice.

11.

Defendant Atlanta Sportservice has been properly served with process in this action.

12.

Defendant Draft Beer Services of Atlanta, Inc. (Hereinafter “Draft Beer Services” or

“Defendant(s)”) is a Georgia corporation authorized to transact business in the State of Georgia,

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and may be served through its registered agent, Draft Beer Services of Atlanta, 133 Bethea Road,

Suite 801, Fayetteville, GA 30214.

13.

Jurisdiction and venue are proper as to Defendant Draft Beer Services.

14.

Defendant Draft Beer Services has been properly served with process in this action.

15.

Defendant Braves Stadium Company, LLC (hereinafter “Braves Stadium Company” or

“Defendant(s)”) is a Delaware limited liability company authorized to transact business in the

State of Georgia, and may be served through its registered agent, Corporation Service Company,

40 Technology Parkway South, Suite 300, Norcross, GA 30092.

16.

Jurisdiction and venue are proper as to Defendant Braves Stadium Company.

17.

Defendant Braves Stadium Company has been properly served with process in this

action.

18.

Defendant Braves Construction Company, LLC (hereinafter “Braves Construction” or

“Defendant(s)”) is a Delaware limited liability company authorized to transact business in the

State of Georgia, and may be served through its registered agent, Corporation Service Company,

40 Technology Parkway South, Suite 300, Norcross, GA 30092.

19.

Jurisdiction and venue are proper as to Defendant Braves Construction.

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 20.

Defendant Braves Construction has been properly served with process in this action.

21.

Defendant Brasfield & Gorrie, LLC (hereinafter “Brasfield & Gorrie” or “Defendant(s)”)

is an Delaware limited liability company authorized to transact business in the State of Georgia,

and may be served through its registered agent, C T Corporation System, 289 S Culver Street,

Lawrenceville, GA 30046.

22.

Jurisdiction and venue are proper as to Defendant Brasfield & Gorrie.

23.

Defendant Brasfield & Gorrie has been properly served with process in this action.

24.

Defendant M. A. Mortenson Company (hereinafter “M. A. Mortenson” or

“Defendant(s)”) is a Minnesota corporation authorized to transact business in the State of

Georgia, and may be served through its registered agent, Corporation Service Company, 40

Technology Parkway South, Suite 300, Norcross, GA 30092.

25.

Jurisdiction and venue are proper as to Defendant M. A. Mortenson.

26.

Defendant M. A. Mortenson has been properly served with process in this action.

27.

Defendant Barton Malow Company (hereinafter “Barton Malow” or “Defendant(s)”) is a

Michigan corporation authorized to transact business in the State of Georgia, and may be served

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through its registered agent, C T Corporation System, 289 S Culver Street, Lawrenceville, GA

30046.

28.

Jurisdiction and venue are proper as to Defendant Barton Malow.

29.

Defendant Barton Malow has been properly served with process in this action.

30.

Defendant New South Construction Company, Inc. (hereinafter “New South

Construction” or “Defendant(s)”) is a Georgia corporation authorized to transact business in the

State of Georgia, and may be served through its registered agent, Corporation Service Company,

40 Technology Parkway South, Suite 300, Norcross, GA 30092.

31.

Jurisdiction and venue are proper as to Defendant New South Construction.

32.

Defendant New South Construction has been properly served with process in this action.

33.

Defendant Imperial Brown, Inc. (hereinafter “Imperial Brown” or “Defendant(s)”) is an

Oregon corporation that does substantial business in and derives substantial revenue from the

State of Georgia. Defendant Imperial Brown may be served through its registered agent,

Christopher Blattner, 117 SW Taylor Street, STE 300, Portland, OR 97204.

34.

Jurisdiction and venue are proper as to Defendant Imperial Brown.

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 35.

Defendant Imperial Brown has been properly served with process in this action.

36.

Defendant Baring Industries, Inc. (hereinafter “Baring Industries” or “Defendant(s)”) is a

Nevada corporation authorized to transact business in the State of Georgia, and may be served

through its registered agent, Cogency Global, Inc., 900 Old Roswell Lakes Parkway, Suite 310,

Roswell, GA 30076.

37.

Jurisdiction and venue are proper as to Defendant Baring Industries.

38.

Defendant Baring Industries has been properly served with process in this action.

39.

Defendant ESG Install, LLC (hereinafter “ESG Install” or “Defendant(s)” is a Georgia

limited liability company authorized to transact business in the State of Georgia, and may be

served through its registered agent, David Decker, 472 Bartam Street, Atlanta, GA 30316.

40.

Jurisdiction and venue are proper as to Defendant ESG Install.

41.

Defendant ESG Install has been properly served with process in this action.

42.

Defendant Perlick Corporation (hereinafter “Perlick” or “Defendant(s)”) is a Wisconsin

corporation that does substantial business in and derives substantial revenue from the State of

Georgia. Defendant Perlick may be served through its registered agent, Steven J. Bergum, 8300

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W Good Hope Road, Milwaukee, WI 53223.

43.

Jurisdiction and venue are proper as to Defendant Perlick.

44.

Defendant Perlick has been properly served with process in this action.

45.

Defendant Art Plumbing Co. (hereinafter “Art Plumbing” or “Defendant(s)”) is a Georgia

corporation authorized to transact business in the State of Georgia, and may be served through its

registered agent, Sharon Titus McCoy, 775 West Ave., Suite E, Cartersville, GA 30120.

46.

Jurisdiction and venue are proper as to Defendant Art Plumbing.

47.

Defendant Art Plumbing has been properly served with process in this action.

48.

Defendant BevStream Corporation (hereinafter “BevStream” or “Defendant(s)”) is an

Illinois corporation that does substantial business in and derives substantial revenue from the

State of Georgia. Defendant BevStream may be served through its registered agent, Michael S.

Roberts, 305 N Peoria Street, STE 200, Chicago, IL 60607.

49.

Jurisdiction and venue are proper as to Defendant BevStream.

50.

Defendant BevStream has been properly served with process in this action.

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 51.

Defendant A-Head for Profits of Georgia, LLC (hereinafter “A-Head” or “Defendant(s)”)

is a North Carolina limited liability company authorized to transact business in the State of

Georgia, and may be served through its registered agent, Mark Davis, 255 Ottley Drive, Atlanta,

GA 30324.

52.

Jurisdiction and venue are proper as to Defendant A-Head.

53.

Defendant A-Head has been properly served with process in this action.

54.

Defendant S2O Consultants, Inc. (hereinafter “S2O” or “Defendant(s)”) is an Illinois

corporation that does substantial business in and derives substantial revenue from the State of

Georgia. Defendant S2O may be served through its registered agent, Kenneth D. Bellah, 525 W

Montroe Street, STE 2360, Chicago, Illinois, 60661.

55.

Jurisdiction and venue are proper as to Defendant S2O.

56.

Defendant S2O has been properly served with process in this action.

57.

Defendant J. F. Duncan Industries, Inc. d/b/a Duray (hereinafter “J. F. Duncan” or

“Defendant(s)”) is a California corporation authorized to transact business in the State of

Georgia, and may be served through its registered agent, Corporation Service Company, 40

Technology Parkway South, Suite 300, Norcross, GA 30092.

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 58.

Jurisdiction and venue are proper as to Defendant J. F. Duncan.

59.

Defendant J. F. Duncan has been properly served with process in this action.

60.

Defendant Xylem Water Systems U.S.A., LLC (hereinafter “Xylem” or “Defendant(s)) is

a New York corporation authorized to transact business in the State of Georgia, and may be

served through its registered agent, C T Corporation System, 289 S Culver St, Lawrenceville,

GA 30046.

61.

Jurisdiction and venue are proper as to Defendant Xylem.

62.

Defendant Xylem has been properly served with process in this action.

63.

Defendant United Distributors, Inc. (hereinafter “United” or “Defendant(s)”) is a Georgia

corporation, and may be served through its registered agent Mark Popowski, 5500 United Drive,

Smyrna, GA 30082.

64.

Jurisdiction and venue are proper as to Defendant United.

65.

Defendant United has been properly served with process in this action.

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 BASIC FACTS

66.

On or about June 26, 2018, and at all relevant times, Marvin “Todd” Keeling was an

invitee servicing and finalizing the installation of a beer tap system installed at SunTrust Park,

located at 755 Battery Ave. SE, Atlanta, Georgia 30339, also known as the Braves Stadium.

While at the Braves Stadium, Mr. Keeling sustained serious injury later resulting in his death

when he was trapped inside of Cooler 331, which filled with carbon dioxide and had no means of

egress due to Defendants’ negligence, due in part to a faulty door release mechanism that was

improperly constructed, assembled, maintained, and allowed to exist despite notice of same.

67.

At all relevant times, Defendants Delaware North, Atlanta Sportservice, ANLBC, and/or

Braves Stadium Company either independently or jointly controlled, oversaw, managed,

directed, inspected, operated, and maintained the stadium at SunTrust Park, including but not

limited to Cooler 331, the carbon dioxide systems, and the beer dispensing systems, and were

responsible for the safety of invitees and individuals entering coolers on the premises.

68.

Although Cobb-Marietta Coliseum and Exhibit Hall Authority and/or Cobb County owns

the land upon which the subject stadium sits, per contract, it appears that Cobb-Marietta

Coliseum and/or Cobb County are out-of-possession owners and had turned over operation of the

property in whole to one or more of the named Defendants. Although it is not anticipated, in the

event it is later determined that Cobb-Marietta Coliseum and/or Cobb County are potentially

liable for the negligent acts described herein, Plaintiffs have complied with any pre-requisite

ante-litem requirements, to the extent any ante-litem notice was required.

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 69.

Prior to June 26, 2018, Defendants Brasfield & Gorrie, M.A. Mortenson, Barton Malow,

and New South Construction engaged in a joint venture known as “American Builders 2017” for

construction of SunTrust Park, and Defendant Braves Construction acted as construction

administrator. These entities jointly and/or individually controlled, oversaw, managed, directed,

and/or inspected the construction of SunTrust Park, to include the cooler and subcomponents

contained therein. These Defendants received an email before Todd Keeling’s death that there

were issues with the door release mechanisms in coolers throughout the stadium.

70.

The construction of SunTrust Park involved assembly and installation of various beer

coolers throughout the stadium, including Cooler 331 where the subject incident occurred. Based

upon information and belief, prior to June 26, 2018, Defendant Imperial Brown sold the cooler

and put the cooler package together for assembly, and Defendants Baring Industries, ESG Install,

and S2O also participated and manufactured, sold, assembled, installed, and serviced the walk-in

beer coolers utilized in SunTrust Park, including Cooler 331 and the inside door release

mechanism meant to provide a means of egress from Cooler 331.

71.

Construction of SunTrust Park also involved installation of a draft beer system and

accompanying carbon dioxide systems for carbonating and dispensing beer sold at the stadium.

Based on information and belief, Defendants Perlick, A-Head for Profits, Art Plumbing,

BevStream, Draft Beer Services, S2O, Baring Industries, and/or J.F. Duncan negligently

manufactured, sold, assembled, installed, maintained, and/or serviced the carbon dioxide and

draft beer system(s) used at SunTrust Park and in Cooler 331.

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 72.

Upon information and belief, Defendant Xylem manufactured, and sold to dealers and

distributors, a Flojet beer pump, model H56B0000, which Defendant Perlick installed on the

carbon dioxide and draft beer system panels used in Cooler 331. Upon information and belief

this Flojet beer pump was a leaking source of carbon dioxide, among others.

73.

Upon information and belief, Defendant United Distributors delivered and installed beer

kegs and maintained and cleaned the beer lines utilized in the carbon dioxide and draft beer

system in and/or connected to Cooler 331, which was another source of leaking carbon dioxide,

among others.

74.

At all relevant times, Defendants contributed to and collectively supervised, managed,

installed, serviced, occupied, and managed SunTrust Park, including all beer systems,

carbonation systems, coolers, and doors. Defendants had actual knowledge that individuals were

regularly inside of coolers at SunTrust Park, including but not limited to Cooler 331.

75.

At all times mentioned herein, Defendants had the legal duty to keep the premises and

subject cooler in a safe condition with the due regard of their invitees and business invitees,

including Marvin Todd Keeling.

76.

Prior to June 26, 2018, and unbeknownst to Mr. Keeling, Defendants had actual and

constructive knowledge that cooler doors were malfunctioning, to include Cooler 331, and that

the cooler doors had a faulty, misassembled, and/or malfunctioning interior release mechanism

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such that persons could become and had in fact been trapped inside of the cooler(s). The

mechanism was out of plumb, would not properly engage, and would separate from the proper

slide mechanism and door, but Defendants negligently allowed the condition to remain unabated.

This created an unreasonable risk of injury to individuals who entered Cooler 331, including but

not limited to Marvin Todd Keeling.

77.

Also prior to June 26, 2018, Defendants had actual and constructive knowledge of carbon

dioxide leaks in the entire distribution system, to include Cooler 331, and the associated hazards,

but negligently allowed the leaks to remain unabated. Further, Defendants negligently failed to

install or equip Cooler 331 with a functioning carbon dioxide monitor or alarm or a proper

ventilation system. This created an unreasonable risk of injury to those individuals inside of and

around Cooler 331, including Marvin Todd Keeling.

78.

On the afternoon of June 26, 2018, upon information and belief, Mr. Keeling was at

SunTrust Park for maintenance and continued installation of the beer tap system and entered

Cooler 331. While and before Mr. Keeling was inside of the walk-in cooler, leaks in the cooler’s

carbon dioxide system caused carbon dioxide, a colorless, odorless, and asphyxiating gas, to

accumulate inside of the cooler. As the gas filled the cooler, Mr. Keeling attempted to exit, but

could not exit due to the faulty and/or malfunctioning interior release mechanism, resulting in

massive pain and suffering and ultimately his death from asphyxia due to carbon dioxide and

entrapment.

79.

As a proximate result of Defendants’ negligence, omissions and the various premises and

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product defects described herein, Marvin Todd Keeling sustained physical and emotional

injuries, and was aware and conscious of his impending death. Defendants’ acts were a cause-in-

fact and a proximate cause of all such injuries, pain and suffering, and death to Marvin Todd

Keeling. All Defendants are jointly and severally liable for the acts and claims set forth herein.

80.

At all relevant times and under the circumstances then existing on June 26, 2018, Marvin

Todd Keeling exercised ordinary care and diligence and was a victim free of any contribution to

his death.

LEGAL CLAIMS

COUNT ONE

(Negligence of all Defendants)

81.

Plaintiffs incorporates Paragraphs 1 through 80 as if fully restated herein verbatim.

82.

Defendants negligently failed to properly manufacture, install, assemble, maintain,

service, and repair the interior door release mechanism inside of Cooler 331.

83.

At the time of the subject incident, Defendants had actual and constructive knowledge of

the broken and malfunctioning interior release mechanism in Cooler 331, but negligently

permitted the hazard to exist and remain. In fact, one Delaware North employee had complained

to a variety of Defendants that he himself, and at least 6 or 7 others, had similarly been locked in

a cooler before the event at issue due to the known problems with the manufacture, install,

assembly, and/or maintenance of the same or similar coolers and locking mechanisms.

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 84.

Defendants negligently failed to provide a means of egress from Cooler 331 thereby

negligently creating an unreasonable risk of injury to individuals working in the subject cooler,

including Marvin Todd Keeling.

85.

Defendants were negligent in failing to establish and implement a procedure for

inspection, maintenance, and repair at regular intervals of all coolers and interior door release

mechanisms at SunTrust Park, including but not limited to the door release inside of Cooler 331.

86.

Defendants negligently failed to properly manufacture, install, assemble, and maintain

the carbon dioxide system(s) and beer dispensing system(s) at SunTrust Park such that it would

not leak or create life threatening build-up in enclosed environments.

87.

Defendants negligently installed, maintained, and secured the lines, valves, pumps, and

couplings for the carbon dioxide lines feeding the tap system at issue.

88.

Defendants negligently caused or created leaks in Cooler 331, including a leak on a Flojet

beer pump and in the vent system, and negligently failed to have a trained and qualified CO2

professional seal and close the carbon dioxide system once leaks were known, and rather asked

random suppliers to fix leaks as they encountered them.

89.

Defendants negligently failed to properly install, maintain, or secure condensation

reducing manifolds on the carbon dioxide system.

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 90.

Defendants negligently failed to properly install or maintain the ventilation system in

Cooler 331, and Defendants had actual and constructive knowledge that Cooler 331 was not

properly ventilated, but negligently permitted the hazard to exist and remain.

91.

Defendants negligently failed to install a vaporizer system to regulate and reduce

condensation on the carbon dioxide system.

92.

Defendants failed to equip Cooler 331 with a carbon dioxide detector or alarm, panic

button, or other alarm or siren, and failed to provide an appropriate means of communication for

those inside the cooler to talk to others outside, especially given poor cell phone service

throughout the stadium and coolers.

93.

Defendants negligently permitted known and unabated carbon dioxide leaks to occur

throughout the stadium and in Cooler 331 thereby creating an unreasonable risk of injury to

individuals working in the subject cooler, including Marvin Todd Keeling.

94.

Defendants were negligent in failing to advise, instruct, inform, and warn Marvin Todd

Keeling that his work would or could bring him into a cooler without a means of egress and

containing carbon dioxide leaks. Defendants negligently failed to provide a working interior

door release mechanism, properly install equipment to prevent carbon dioxide leaks, or otherwise

properly ventilate the subject cooler.

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 95.

Defendants were negligent in failing to establish and implement a procedure for

inspection and maintenance at regular intervals of all piping, tubing, hoses, pumps, and fittings

relating to the carbon dioxide supply system at SunTrust Park, including but not limited to those

in or attached to Cooler 331.

96.

Defendants negligently failed to enact, promulgate, implement, and/or enforce policies

and procedures for the safe operation of Cooler 331.

97.

Defendants negligently employed, retained, trained, and supervised employees and agents

on the subject premises and are liable under theories of agency, respondeat superior, and

vicarious liability.

98.

Defendants were negligent in failing to provide adequate onsite safety supervision of

employees, independent contractors, subcontractors, agents, and other business invitees.

99.

The Defendants’ negligence was the cause-in-fact and proximate cause of the injuries

leading to Mr. Keeling’s death. Said negligence included but was not limited to:

a) Violation of O.C.G.A. § 51-3-1 by failing to exercise ordinary care to keep the premises

safe;

b) Violation of 29 C.F.R. §§ 1910.36, 1910.37 in failing to provide an useable and

unobstructed exit route from Cooler 331;

c) Violation of additional federal, state, and local rules and regulations to be proven at trial;

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d) Violation of established industry standards to be proven at trial;

e) Negligently failing to properly inspect and maintain the premises;

f) Negligently operating Cooler 331 in an unsafe condition;

g) Negligently failing to suspend operation of Cooler 331;

h) Negligently failing to properly correct, modify, and repair the premises;

i) Negligently failing to design, install, maintain, manufacture, assemble, or repair the

interior door release mechanism in Cooler 331;

j) Negligently failing to design, install, maintain, manufacture, assemble, or repair the

carbon dioxide system in Cooler 331;

k) Negligently failing to install a carbon dioxide monitor or alarm in Cooler 331;

l) Negligently failing to ensure Cooler 331 was properly ventilated;

m) Negligently failing to properly correct and repair carbon dioxide leaks in Cooler 331;

n) Negligently failing to have appropriate emergency evacuation plans, policies, and

procedures in place;

o) Negligently failing to establish policies and procedures for inspection and maintenance,

at regular intervals, of Cooler 331, including but not limited to the interior door release

mechanism;

p) Negligently failing to establish policies and procedures for inspection and maintenance,

at regular intervals, of all piping, tubing, pumps, hoses, and fittings relating to the carbon

dioxide and beer supply system inside of and/or connected to Cooler 331;

q) Negligently failing to warn of the danger of the malfunctioning and/or interior door

release mechanism in Cooler 331;

r) Negligently failing to affix a sign to warn of the dangers of carbon dioxide exposure and

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 dangers presented by Cooler 331;

s) Negligently damaging a beer pump in Cooler 331;

t) Negligently failing to warn of the dangers on the premises;

u) Negligently retaining, entrusting, hiring, training, and supervising said employees and

agents; and

v) All other negligence to be proven at trial.

100.

Defendants were and are negligent per se.

101.

The injuries and death sustained by Marvin Todd Keeling were and are the direct and

proximate result of the negligence of the Defendants. But for said negligence, Marvin Todd

Keeling would not have suffered injuries and died.

102.

Defendants are liable for Marvin Todd Keeling’s injuries, pain and suffering, death, and

all other elements of damages allowed under the laws of the State of Georgia. Defendants are

liable to Plaintiffs directly as well as under theories of respondeat superior and agency principles.

103.

Each of the foregoing acts and omissions of Defendants constitutes an independent act of

negligence on the part of Defendants, and one or more or all above-stated acts were the

proximate cause of all injuries and death of Marvin Todd Keeling. Defendants are liable for the

injuries sustained, pain and suffering, expenses of treatment, and wrongful death of Marvin Todd

Keeling, and for all other elements of damage recoverable under Georgia law, including all

special, compensatory, incidental, consequential, economic, and punitive damages.

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 COUNT TWO

(Products Defect – Cooler 331 Interior Door Release Mechanism)

104.

Plaintiffs incorporate Paragraphs 1 through 103 as if fully restated herein verbatim.

105.

At all times relevant to this Complaint, Defendants were engaged in the business of

designing, manufacturing, assembling, marketing, testing, selling, installing, warning, and/or

maintaining Cooler 331, including the interior door release mechanism, and placed the subject

product into the Georgia and national stream of commerce when it was neither merchantable nor

reasonably suited for the use for which it was intended and was otherwise defective and

dangerous.

106.

As the designer, manufacturer, assembler, and installer of Cooler 331, those Defendants

that manufactured the cooler owed a duty to exercise reasonable care to design, test,

manufacture, inspect, assemble, and install a cooler that is merchantable, reasonably suited to the

use intended, and free of unreasonable risk of harm to users, including Marvin Todd Keeling.

Defendants also owed a duty to the general public and users, including Marvin Todd Keeling, to

warn and adequately communicate warnings about foreseeable dangers from normal use of the

product.

107.

Cooler 331, including the interior door release mechanism, was in its defective and

dangerous condition when it left the manufacturer’s possession, and the defective nature of the

product was a direct and proximate cause of the catastrophic injuries and death at issue in this

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case. At the time of the subject incident, Cooler 331 was in the same or substantially same

condition in which it was sold and was not altered or misused by Marvin Todd Keeling in any

way. Defendants knew or should have known prior to its production and sale that Cooler 331

was defective and did not provide a means of egress or proper ventilation. Marvin Todd Keeling

had no knowledge of the defects identified herein and was a foreseeable user of Cooler 331.

108.

Defendants are strictly liable to Plaintiffs under Georgia law, including as set forth in

O.C.G.A. § 51-1-11, as well as Georgia’s interpretive case law regarding strict product liability.

Cooler 331 was defectively designed, manufactured, assembled, and installed and not reasonably

suited for its intended use because its inherent risks outweighed its utility. In particular, Cooler

331’s interior door release mechanism was defectively designed, manufactured, inspected,

assembled, and installed in the following ways, among others:

(a) Defendants designed and manufactured the exit release with a faulty latching mechanism;

(b) Defendants failed to use or install a properly sized push rod allowing the end of the

release to come out of alignment;

(c) Defendants failed to follow common and accepted specifications for the interior door

release mechanism;

(d) Defendants failed to use reliable and proper materials for the design and manufacturing

of the subject interior door release mechanism;

(e) Defendants employed a defective design and manufacturing process in making,

marketing, and distributing the interior door release mechanism at issue;

(f) The product and components were defective due to Defendants’ failure to test or

adequately test its foreseeable use to ensure it was reasonably safe and suitable for its

22
 intended purpose and use;

(g) The product and its component parts were defective due to inadequate or absent warnings

and/or proper notice to alert users regarding the hazardous condition as described herein;

(h) At the time the product left Defendants’ control, they could have adopted safer, practical,

feasible, and otherwise reasonable alternative designs and/or manufacturing process that

would have eliminated or minimized the defects without compromising the part’s

usefulness, practicality, and desirability;

(i) Defendants’ product was further defective for improper marketing/packaging defects,

failure to warn, defective labeling, and breaches of the implied warranties and warranties

of merchantability;

(j) In the event Defendants repaired or refurbished Cooler 331, Defendants failed to properly

repair and refurbish the interior door release mechanism, and negligently failed to recall

the product;

(k) Pursuant to O.C.G.A. § 51-1-11, et seq., the product at issue was not merchantable nor

reasonably suited to the use intended and its condition when sold was the proximate

cause of the injury to Plaintiffs’ decedent, and Defendants were negligent per se; and

(l) All other defects identified and disclosed as the case and discovery proceeds.

109.

The defects in the subject product were not known to Marvin Todd Keeling and were not

discoverable through reasonable inspection. The risk of the subject product in its design and

manufacture greatly outweighed the utility of Cooler 331’s design, and at the time of the

occurrence that makes the basis of this lawsuit, the product was being used for its ordinary,

intended, and foreseeable purpose and in an ordinary, intended, and foreseeable manner by

23
foreseeable users, including Marvin Todd Keeling.

110.

Defendants knew or should have known at the time of sale, assembly, and installation up

through the time of the subject incident that Cooler 331 had a faulty internal door release

mechanism.

111.

Defendants failed to warn users, including Marvin Todd Keeling, that Cooler 331 was

defectively designed and not suitable or safe for foreseeable users, including Marvin Todd

Keeling. This duty was breached at the time of the sale, installation, and assembly of Cooler

331, and the continuing duty to warn was breached through the time of the subject incident.

112.

Defendants owed a duty to exercise ordinary care in selling, marketing, distributing,

assembling, manufacturing, designing, installing, and, if necessary, recalling Cooler 331, and

owed a duty to warn and adequately communicate warnings to users of Cooler 331, including

Marvin Todd Keeling, of its known and foreseeable dangers. Defendants breached these duties

to Marvin Todd Keeling.

113.

Defendants negligently employed, retained, trained, and supervised their agents and

employees who designed, manufactured, assembled, installed, marketed, and sold Cooler 331,

and are liable under theories of agency, respondeat superior, and vicarious liability.

114.

As a direct and proximate cause of the negligence and failure to warn by Defendants,

Marvin Todd Keeling endured pain and suffering and ultimately death. Defendants are liable for

24
Plaintiffs’ damages, including but not limited to, pain and suffering, wrongful death, the

expenses of medical treatment, lost wages and other economic losses, and all other elements of

damages allowed under the laws of the State of Georgia, including all special, compensatory,

incidental, consequential, economic, and punitive damages.

115.

Defendants’ defective design, manufacture, assembly, inspection, distribution, marketing,

and sale of Cooler 331 was a proximate cause of the June 26, 2018 incident and, as a result,

Defendants are strictly liable to Plaintiffs.

116.

The product sold by the Defendants was sold in a manner not reasonably safe, suited and

fit for the use intended, but rather was defective and was unreasonably hazardous and dangerous

for normal use and, thereby, the Defendants breached their implied warranties of fitness,

merchantability, and all other warranties under Georgia Law.

117.

Plaintiffs maintain that all of the allegations herein constitute simple and ordinary

negligence and strict liability and that no malpractice or standard of care affidavit is needed.

Moreover, Plaintiffs have not directly sued a professional engineer but rather the corporate

Defendants responsible for designing, manufacturing, assembling, installing, and placing the

product into the stream of commerce, which does not require an expert affidavit. However, since

Plaintiffs have extensively consulted with experts in this case and out of abundance of caution,

contemporaneous with the filing of this Complaint and in full compliance with the requirements

of O.C.G.A. §§ 9-11-9.1 and 24-7-702, Plaintiffs file the Affidavit of Mark L. Elrod, P.E., an

expert witness qualified to testify as to the standard of care required of Defendants in this case.

25
Said Affidavit sets forth at least one negligent act or omission committed by the Defendants and

the factual basis for each such claim, and is not intended to list all acts of negligence.

Defendants are liable to Plaintiffs for their breach of the applicable professional standards of

care, and otherwise negligent acts and omissions to include, but are not limited to, negligent

engineering, assembly, installation, and design defects with Cooler 331 at issue, as alleged

above.

COUNT THREE

(Products Defect – Carbon Dioxide and Beer Distribution System)

118.

Plaintiffs incorporate Paragraphs 1 through 117 as if fully restated herein verbatim.

119.

At all times relevant to this Complaint, Defendants were engaged in the business of

designing, manufacturing, assembling, marketing, testing, selling, installing, warning, and/or

maintaining the carbon dioxide and beer distribution system in Cooler 331, and placed the

subject product(s) into the Georgia and national stream of commerce when it was neither

merchantable nor reasonably suited for the use for which it was intended and was otherwise

defective and dangerous.

120.

As the designer, manufacturer, assembler, and installer of the carbon dioxide and beer

distribution system, Defendants owed a duty to exercise reasonable care to design, test,

manufacture, inspect, assemble, and install a carbon dioxide and beer distribution system that is

merchantable, reasonably suited to the use intended, and free of unreasonable risk of harm to

users, including Marvin Todd Keeling. Defendants also owed a duty to the general public and

26
users, including Marvin Todd Keeling, to warn and adequately communicate warnings about

foreseeable dangers from normal use of its product.

121.

The carbon dioxide and beer distribution system was in its defective and dangerous

condition when it left the manufacturer’s possession, and the defective nature of the product was

a direct and proximate cause of the catastrophic injuries and death at issue in this case. At the

time of the subject incident, the carbon dioxide and beer distribution system was in the same or

substantially same condition in which it was sold and was not altered or misused by Marvin

Todd Keeling in any way. Defendants knew or should have known prior to its production and

sale that the carbon dioxide and beer distribution system was defective and prone to leaks.

Marvin Todd Keeling had no knowledge of the defects identified herein and was a foreseeable

user of the carbon dioxide and beer distribution system.

122.

Defendants are strictly liable to Plaintiffs under Georgia law, including as set forth in

O.C.G.A. § 51-1-11, as well as Georgia’s interpretive case law regarding strict product liability.

The carbon dioxide/beer distribution system was defectively designed and manufactured and not

reasonably suited for its intended use because its inherent risks outweighed its utility. In

particular, the carbon dioxide and beer distribution system was defectively designed,

manufactured, inspected, assembled, and installed in the following ways, among others:

(a) Defendants designed and manufactured the carbon dioxide and beer distribution system

such that it was prone to and experienced leaks;

(b) Defendants failed to use or install proper devices to prevent leaks in the carbon dioxide

and beer distribution system;

27
(c) Defendants failed to follow common and accepted specifications for the carbon dioxide

and beer distribution system;

(d) Defendants failed to use reliable and proper materials for the design and manufacturing

of the carbon dioxide and beer distribution system;

(e) Defendants employed a defective design and manufacturing process in making,

marketing, and distributing the carbon dioxide and beer distribution system at issue;

(f) The product and components were defective due to Defendants’ failure to test or

adequately test the components’ foreseeable use to ensure they were reasonably safe and

suitable for their intended purpose and use;

(g) The product and its component parts were defective due to inadequate or absent warnings

and/or proper notice to alert users regarding the hazardous condition as described herein;

(h) At the time the product left Defendants’ control, it could have adopted safer, practical,

feasible, and otherwise reasonable alternative designs and/or manufacturing process that

would have eliminated or minimized the defects without compromising the part’s

usefulness, practicality, and desirability;

(i) Defendants’ product was further defective for improper marketing/packaging defects,

failure to warn, defective labeling, and breaches of the implied warranties and warranties

of merchantability;

(j) In the event Defendants repaired or refurbished the carbon dioxide/beer distribution

system, Defendants failed to properly repair and refurbish, and negligently failed to

recall, the Flojet beer pump, ventilation system, and other component parts that were

leaking carbon dioxide;

(k) Pursuant to O.C.G.A. § 51-1-11, et seq., the product at issue was not merchantable and

28
 reasonably suited to the use intended and its condition when sold was the proximate

cause of the injury to Plaintiffs’ decedent, and Defendants were negligent per se; and

(l) All other defects identified and disclosed as the case and discovery proceeds.

123.

The defects in the subject product were not known to Marvin Todd Keeling and were not

discoverable through reasonable inspection. The risk of the subject product in its design and

manufacture greatly outweighed the utility of the carbon dioxide and beer distribution system’s

design, and at the time of the occurrence that makes the basis of this lawsuit, the product was

being used for its ordinary, intended, and foreseeable purpose and in an ordinary, intended, and

foreseeable manner by foreseeable users, including Marvin Todd Keeling.

124.

Defendants knew or should have known at the time of sale and installation up through the

time of the subject incident that the carbon dioxide and beer distribution system was defective

and leaked carbon dioxide into Cooler 331.

125.

Defendants failed to warn users, including Marvin Todd Keeling, that the carbon dioxide

and beer distribution system was defectively designed and not suitable or safe for foreseeable

users, including Marvin Todd Keeling. This duty was breached at the time of the sale and

installation of the carbon dioxide and beer distribution system, and the continuing duty to warn

was breached through the time of the subject incident.

126.

Defendants owed a duty to exercise ordinary care in selling, marketing, distributing,

assembling, manufacturing, designing, installing, and, if necessary, recalling the carbon dioxide

29
and beer distribution system and any failed component parts, and owed a duty to warn and

adequately communicate warnings to users of the carbon dioxide system and beer distribution

system, including Marvin Todd Keeling, of its known and foreseeable dangers. Defendants

breached these duties to Marvin Todd Keeling.

127.

Defendants negligently employed, retained, trained, and supervised their agents and

employees who designed, manufactured, assembled, installed, marketed, and sold the carbon

dioxide and beer distribution system, and are liable under theories of agency, respondeat

superior, and vicarious liability.

128.

As a direct and proximate cause of the negligence and failure to warn of Defendants,

Marvin Todd Keeling endured pain and suffering and ultimately death. Defendants are liable for

Plaintiffs’ damages, including but not limited to, pain and suffering, wrongful death, the

expenses of medical treatment, lost wages and other economic losses, and all other elements of

damages allowed under the laws of the State of Georgia, including all special, compensatory,

incidental, consequential, economic, and punitive damages.

129.

Defendants’ defective design, manufacture, assembly, inspection, distribution, marketing,

and sale of the carbon dioxide and beer distribution system was a proximate cause of the June 26,

2018 incident, and as a result, Defendants are strictly liable to Plaintiffs.

130.

The product sold by the Defendants was sold in a manner not reasonably safe, suited, and

fit for the use intended, but rather was defective and was unreasonably hazardous and dangerous

30
for normal use and, thereby, the Defendants breached their implied warranties of fitness,

merchantability, and all other warranties under Georgia Law.

131.

Plaintiffs maintain that all of the allegations herein constitute simple and ordinary

negligence and strict liability and that no malpractice or standard of care affidavit is needed.

Moreover, Plaintiffs have not directly sued a professional engineer but rather the corporate

Defendants responsible for designing, manufacturing, and placing the product in the stream of

commerce, which does not require an expert affidavit. However, since Plaintiffs have

extensively consulted with experts in this case and out of abundance of caution,

contemporaneous with the filing of this Complaint and in full compliance with the requirements

of O.C.G.A. §§ 9-11-9.1 and 24-7-702, Plaintiffs file the Affidavit of Mark L. Elrod, P.E. Said

Affidavit sets forth at least one negligent act or omission committed by the Defendants and the

factual basis for such claim, and is not intended to list all acts of negligence. Defendants are

liable to Plaintiffs for their breach of the applicable professional standards of care, and otherwise

negligent acts and omissions to include, but are not limited to, negligent engineering and design

defects with the carbon dioxide and beer distribution system at issue, as alleged above.

PROXIMATE CAUSE AND DAMAGES COMMON TO ALL COUNTS AND

DEFENDANTS

132.

Plaintiffs incorporate by reference Paragraphs 1 through 138 as if fully restated herein.

133.

As a proximate and foreseeable result of the negligence of Defendants, decedent Marvin

Todd Keeling received serious injuries and died, endured pain and suffering, mental anguish,

became aware of his impending death, loss of the enjoyment of life, lost wages, wrongful death,

31
and suffered other damages as will be proven at trial and as are permitted under Georgia law.

Plaintiff Angela Keeling, as the wrongful death Plaintiff, is entitled to recover for the full value

of the life of Marvin Todd Keeling, for his wrongful death, and all other elements of damages

allowed under Georgia law. Plaintiffs state their intention to seek all compensatory, special,

economic, consequential, general, punitive, and all other damages permissible under Georgia

Law, including, but not limited to:

a) Personal injuries;

b) Pain and suffering;

c) Mental anguish;

d) Loss of the enjoyment of life;

e) Wrongful death;

f) Funeral expenses of at least $4,070.00;

g) Incidental expenses;

h) Loss of earnings;

i) Medical expenses;

j) Consequential damages to be proven at trial;

k) All estate-based and wrongful death damages permitted under Georgia law; and

l) All permissible special, compensatory, economic, punitive, and allowable damages.

134.

Plaintiff Angela Keeling, as the Administratrix of the Estate of Marvin Todd Keeling,

claims general damages for all the elements of the personal injuries, conscious physical and

mental pain and suffering, mental anguish, medical expenses, and all other injuries and damages

endured by Marvin Todd Keeling prior to his death proximately caused by the incident at issue.

32
This Plaintiff seeks all estate-based damages permitted under Georgia law in an amount to be

determined by the enlightened conscious of a fair and impartial jury.

135.

Plaintiffs are entitled to an award of punitive damages, without limitation or cap, because

the actions of Defendants, their agents and employees showed willful misconduct, malice, fraud,

wantonness, oppression, and an entire want of care which would raise the presumption of

conscious indifference to consequences and/or a specific intent to cause harm.

136.

Defendants’ actions evidence a species of bad faith, were and are stubbornly litigious,

and have caused Plaintiffs undue expense. Thus, Plaintiffs are entitled to recover necessary

expenses of litigation, including an award of reasonable attorneys’ fees and expenses required by

this action, pursuant to O.C.G.A. § 13-6-11 and/or O.C.G.A. § 9-11-68(e), as well as any other

statutory or common law basis.

WHEREFORE, Plaintiffs respectfully pray that:

1) Process issue as provided by law;

2) Plaintiffs be awarded actual damages in amounts to be shown at trial from the

Defendants;

3) Plaintiffs be awarded all medical, doctor, and funeral expenses in an amount to be

proven through the evidence at the time of trial;

4) Plaintiff Angela Keeling, individually and as surviving spouse of Marvin Todd

Keeling, be awarded all damages for the wrongful death of Marvin Todd Keeling, and

all general, special, compensatory, economic and other allowable damages in

accordance with the enlightened conscience of an impartial jury from the Defendants

33
 and as permitted under Georgia law;

5) Plaintiff Angela Keeling, as Administratrix of the Estate of Marvin Todd Keeling,

recover any and all damages allowed by law, including for conscious pain and

suffering, as well as all general, special, compensatory, and economic damages from

Defendants, and punitive damages from Defendants, in accordance with the

enlightened conscience of an impartial jury;

6) Plaintiffs recover damages sufficient to compensate Plaintiffs fully, fairly, and

completely for all losses compensable under Georgia law as set forth above;

7) Plaintiffs have a trial by jury; and

8) Plaintiffs have such other relief as this Court deems just and proper.

TRIAL BY JURY IS HEREBY DEMANDED.

This 21st day of June, 2019.

Respectfully submitted,

LAW & MORAN

/s/ Peter A. Law

Peter A. Law
Georgia Bar No. 439655
E. Michael Moran
Georgia Bar No. 521602
Elizabeth A. Rose
Georgia Bar No. 940275
Attorneys for Plaintiffs
563 Spring Street, NW
Atlanta, Georgia 30308
(404) 814-3700

34
 THE FINDLING LAW FIRM, P.C.

/s/ Drew Findling

Drew Findling
Georgia Bar No. 260425
(signed with express permission by PAL)
Attorney for Plaintiffs
THE FINDLING LAW FIRM, P.C.
One Securities Centre
3490 Piedmont Road, Suite 600
Atlanta, GA 30305
(404) 460-4500

35
Exhibit A
Exhibit A
 Resume of
Mark L. Elrod, P.E.

Applied Technical Services, Inc.

1049 Triad Court
Marietta, Georgia 30062
(770) 423-1400

Capabilities

Mechanical engineering, inspection and evaluation services for various clients from individuals to major
industry. Industrial systems evaluation, field failure analysis, boiler systems analysis and operational/remedial
recommendations. Mechanical systems evaluation, maintenance, and repair. Piping and pressure vessel system
design and failure analysis. Vehicular inspection and analysis, including individual systems, in passenger
vehicles, medium and heavy trucks and heavy industrial equipment. Extensive testing capabilities, test plan
development, design and construction of test fixtures and implementation of actual testing. Capabilities include
evaluation of equipment to performance specifications based on actual performance.

ATS Responsibilities

Manager of the Material Testing Department, Senior Engineer. Duties include failure analysis, operational
analysis, project coordination and execution of testing for analysis, customer contact, preparation and review of
technical reports, training and mentoring of engineers in training, design and inspection oversight, continual
personnel development and quality control. Day to day operations of the department business, capital and
personnel asset management, adherence to quality control requirements. General consulting support for other
ATS departments.

Education

Bachelor of Science, Mechanical Engineering Technology, 1987 Southern College of Technology

Associate of Mechanical Engineering Technology, 1978 Southern Tech
Chevrolet Certified Technician, 1980 General Motors Tech

Registrations

Registered Professional Engineer, Georgia No. 27443, Alabama No. 26167, Virginia No. 40399, South Carolina
No. 26703, Mississippi No. 20673, NCEES Engineering Certification, No. 22302 (National Council of
Examiners for Engineering and Surveying), American Welding Service, Certified Welding Inspector No.
5030531, OSHA Safety Training No. 1393702, Highway Watch Professional No. GA421711, Commercial
Driver, Class A No. 56745166, DOT Design Certifying Engineer No. CT-5446.

Experience

(March 2016 to Present) Department Manager, Materials Testing, Applied Technical Services, Inc. Responsible
for the materials testing groups, consisting of metallurgy, polymers, failure analysis, mechanical, special, and
weld testing. Failure analysis, forensic and fire investigations. Duties include professional engineering oversight,
evaluations, and analysis for clients. Expansion of markets and coordination of services. Direct interface with
the quality assurance program and safety.

(January 2008 to February 2016) Senior Engineer - Forensics, Applied Technical Services, Inc. Responsible
for professional engineering evaluations, testing and document review for the forensics department. Engaged in
inspections, failure analysis, testing and evaluations for clients. Duties include mentoring and development of
new markets for inspection/evaluation/testing. Professional witness testimony, based on article and system
testing, design, and experience.

(November 2002 to December 2007) Senior Consulting Engineer, Applied Technical Services, Inc. Responsible
for professional engineering document review for the consulting engineering department. Engaged in
Mark L. Elrod Resume, July 2016

inspections, on-site recommendations, and consultation with clients for improved system operations. Duties
include mentoring and development of new markets for inspection/evaluation. Duties include providing
professional engineering services to other departments within ATS including Metallurgy, Forensics Engineering,
and Fire Investigation. Operations analysis, failure analysis, component and product testing.

(June 2002 to November 2002) Principal-Mechanical Engineer, John Ware & Associates, 1951 Airport Road,
Atlanta, Georgia. Responsible for all mechanical functions within the architectural engineering firm. Principal
and co-owner of the firm. Engaged in industrial mechanical engineering, system design, equipment
specifications, and consultation for industrial mechanical systems and instructor for mechanical systems
operation and maintenance classes.

(January 2001 to May 2002) Vice President – Engineering, National Linen Service, Responsible for all
engineering functions, capital management, maintenance operations (both equipment and fleet), maintenance
staffing requirements, machinery and equipment design, and operating specifications. Project management, and
coordination of design professionals, inspections and due diligence for acquisitions and mergers. Equipment,
boilers, pressure vessel inspections, design and operation.

(March 1995 to December 2000) Manager of Engineering, Project Engineering. National Linen Service,
Responsible for all formal engineering, systems design, equipment design and operating specifications,
engineering interface and project management of major capital projects. Duties include working in conjunction
with the industrial engineers and operations in equipment selection, plant operations and execution. Additional
functions extend to assembling and maintaining status of the annual capital budget. As engineering interface, to
conduct training classes in specialized and general engineering concepts for corporate and plant personnel.

(June 1991 to February 1995) Director of Engineering, Linen Supply Division, National Linen Service.
Responsible for approval of all capital expenditures, maintenance supervision, process and fleet specifications
and all engineering operations division wide. Maintained direct control over plant engineering functions for 63
operating facilities across the U.S. Design of and implementation of boiler, water, air and related process
systems.

(February 1988 to June 1991) Manager of Project Engineering, National Linen Service. In charge of all capital
engineering projects for the corporation. All research and development, as well as project mechanical
responsibility and equipment specifications. During this time period, 18 months was devoted to being the
project manager for the new corporate offices of National Service Industries. (Managed the largest corporate
relocation over a single weekend in Atlanta history.)

(June 1986 to February 1988) Senior Project Engineer, National Linen Service. Engineer in charge of R&D
and major capital projects manager. Design responsibility for all mechanical systems, and Maintained
responsibility Over all drafting functions.

(December 1984 to June 1986) Project Engineer, National Linen Service. Engineer in charge of specific
process equipment troubleshooting, failure analysis, equipment specifications, general and capital project
management. Responsible for implementation of AutoCAD system for NLS and training of engineering
personnel.

(February 1982 to December 1984) Engineering Draftsman, National Linen Service.

(June 1978 to February 1982) Chevrolet Certified Technician, General Motors Corporation, Anderson
Chevrolet, Inc., 900 Roswell Street, Marietta, Georgia 30060.

Professional Memberships

Georgia Society of Professional Engineers

American Society of Mechanical Engineers
American Welding Society