Case No.: Honorable Judge Commissioner. COMES NOW, the Plaintiff, LORIE JEAN KENDALL RICKS, individually and as

Size: px
Start display at page:

Download "Case No.: Honorable Judge Commissioner. COMES NOW, the Plaintiff, LORIE JEAN KENDALL RICKS, individually and as"

Transcription

1 D. BRIAN BOGGESS, No N. University Ave., Suite 275 Provo, Utah Telephone: (385) Fax: (855) Attorney for Plaintiffs IN THE DISTRICT COURT OF THE THIRD JUDICIAL DISTRICT IN AND FOR SALT LAKE COUNTY, STATE OF UTAH LORIE JEAN KENDALL RICKS, individually and as authorized representative of THE ESTATE OF KAY COMPLAINT and JURY DEMAND PORTER RICKS, v. Plaintiff, Case No.: UTAH TRANSIT AUTHORITY, a political subdivision of the State of Utah, by and through its Board of Trustees; THE ESTATE OF FLINT WAYNE HARRISON, an individual; DERECK JAMES HARRISON; and JOHN DOES I- XXX and DOE ENTITIES I-XXX, Honorable Judge Commissioner Defendants. COMES NOW, the Plaintiff, LORIE JEAN KENDALL RICKS, individually and as authorized representative of THE ESTATE OF KAY PORTER RICKS, by and through her attorneys, D. Brian Boggess and Boggess Law Group, and for causes of action against UTAH TRANSIT AUTHORITY, a political subdivision of the State of Utah, by and through its Board of Trustees, hereby complains, alleges, avers as follows: PARTIES AND JURISDICTION 1. Plaintiff LORIE JEAN KENDELL RICKS (hereinafter Mrs. Ricks or Plaintiff ) was and is, at all times material, a resident of County of Utah, State of Utah. 2. Defendant UTAH TRANSIT AUTHORITY (hereinafter UTA or Defendant ) was Complaint Page 1

2 created pursuant to the Utah Limited Purpose Local Government Entities - Local Districts Act, Title 17B, Chapter One and the Utah Public Transit District Act, Chapter 2(a), Part 8 of the Utah Code Annotated 1953, as amended (the Act ), and is a public transit district organized under the laws of the State of Utah. 3. UTA, comprised of its Board of Trustees (the Board ), officers, management and employees, is a political subdivision of the State of Utah; with those powers specifically granted in the Act and with implied powers necessary to carry out the objectives and purposes of a public transit district. 4. At all times relevant hereto, UTA conducted its business within the State of Utah. 5. Upon information and belief, Defendant THE ESTATE OF FLINT WAYNE HARRISON is based in Utah and Wyoming. Flint Wayne Harrison died of an apparent suicide while in David County Jail in July, Upon information and belief, Defendant Dereck James Harrison is a resident of Utah currently serving a life sentence in the Wyoming State Prison System. 7. All events giving rise to this Complaint occurred in Salt Lake County, Utah, and venue in this Court is proper. 8. The true names and capacities, whether partnership, individual, corporate, associate or otherwise of Defendants John Does I through XXX and Doe Entities I through XXX, inclusive, are unknown to Plaintiff at this date; that said Defendants are named herein by fictitious names, but may be responsible or liable to the Plaintiff by virtue of the actions hereinafter described and Plaintiff reserves the right to amend her Complaint to insert any additional charging allegations, together with their true identities and capacities, when the same have been ascertained. 9. Plaintiff is informed, believes and therefore alleges that at all times herein mentioned, Complaint Page 2

3 Defendants and each of them, were the agent, partner, employee and/or alter-ego of each other, and in doing the things herein alleged, were acting within the course and scope of said agency, partnership, or relation, with the permission and consent of their codefendants, and that each of them were working as a single entity and enterprise. FACTS COMMON TO ALL CAUSES OF ACTION 10. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 9 above 11. Kay Porter Ricks ( Mr. Ricks ) was hired as a full-time employee by UTA on or about October 11, He was hired as a maintenance worker, and assigned to the swing shift, during which he would perform maintenance services at various UTA bus and train stops and other assigned locations during or after normal operating hours. 13. Mr. Ricks assigned shift often required him to be alone at UTA locations in downtown Salt Lake City. 14. The UTA Board has the power and responsibility to promulgate any and all resolutions, orders and ordinances as it deems necessary for the operation and administration of UTA, including the health, welfare and protection of UTA employees. 15. Upon information and belief, on numerous occasions, UTA employees performing maintenance similar to Mr. Ricks, in locations similar to those serviced by Mr. Ricks, were threatened, assaulted or harmed by vagrants and other individuals in the area of the UTA work sites. 16. Upon information and belief, UTA employees had repeatedly made UTA management aware of the dangers posed to UTA maintenance employees by their working alone in unsafe areas. Complaint Page 3

4 17. Upon information and belief, various Union representatives raised concerns to UTA management before the events which gave rise to this Complaint about the danger of UTA maintenance employees working alone in certain locations, including those locations serviced by Mr. Ricks. 18. Notwithstanding UTA s knowledge of the risks of its employees working alone in unsafe locations, UTA failed or refused to assign a second employee or apprentice trainee to work with its maintenance employees. 19. Further, although global positioning system ( GPS ) units are inexpensive and common, and their placement in corporate vehicles is now standard across the country, UTA failed or refused to place a GPS receiver in its maintenance trucks. 20. What UTA did offer its employees, during swing or overnight shifts and otherwise, was a panic button on UTA-issued communication devices. Unfortunately, the panic buttons are only as good as the support staff monitoring those communications. 21. Upon information and belief, UTA failed to provide adequate training, supervision or attention to the receiving end of panic button communications, such that a distress signal sent via a panic button by Mr. Ricks was not received or acknowledged in anything close to a timely, reasonable manner. 22. These failures on the part of UTA and its Board, to implement a policy requiring a second employee to be with maintenance employees, to install GPS receivers in UTA maintenance vehicles and to monitor and respond to a distress signal, would prove to have deadly consequences. 23. On May 12, 2016, Kay Porter Ricks was working his usual swing shift performing maintenance at the UTA Ballpark TRAX Station located at 1300 S. 200 West in Salt Lake City, Utah. Complaint Page 4

5 24. He was working out of his UTA Maintenance Vehicle, number 12659, a white 2013 F- 150 with a truck bed mounted equipment rack, UTA markings and bearing Utah license plate number EX. His UTA Maintenance Vehicle was not equipped with a GPS unit. 25. At some time around 5:00 p.m., May 12, 2016, Mr. Ricks was approached by Flint Wayne Harrison and Defendant Dereck James Harrison (the Harrisons ), a father and son who were the subject of a statewide manhunt for unrelated crimes. 26. The Harrisons had been staying at a hotel two (2) miles from the Ballpark TRAX Station, where Ricks was working. 27. Mr. Ricks attempted to make a distress transmission on his UTA-issued radio, and sounds of commotion were transmitted before it was turned off about 5 p.m. Mr. Rick s voice sounded hurried and higher pitched, as if he were stressed. 28. UTA failed to respond to the distress signal. 29. Mr. Ricks assailants kidnaped him, forcing him into his UTA Maintenance Vehicle and driving east along I-80 until they crossed the Wyoming border sometime around 6:30 p.m. 30. While it is unknown how the Harrisons kidnaped Mr. Ricks, crime scene investigators have noted that Ricks suffered an injury to his right temple well-prior to his death. 31. Less than an hour after entering Wyoming, Mr. Ricks and the Harrisons arrived in the Little Muddy Creek area, the Harrisons assaulted Ricks for eighteen (18) minutes, savagely beat him in the face and head, slashed his throat, dragged him behind sagebrush and left him to die. 32. Afterward, the Harrisons used fluorescent green spray paint to hide the UTA logo on Mr. Ricks' work truck, then drove about 15 miles north to Diamondville, Wyoming, where Complaint Page 5

6 they stopped at an Arctic Circle drive-thru before continuing north to Pinedale, Wyoming. 33. Police officers found the body of Mr. Ricks near a dirt road five days later, on May 17. He had somehow survived the beating, and had crawled or dragged himself out of the sagebrush in hopes of being found. 34. An autopsy reported that Mr. Ricks ultimately died from "crushing wounds" to his face and head, ostensibly from the Harrisons repeatedly hitting him in the face and head with a blunt object, "which was swung with great accuracy and control." 35. It has since been learned that the object was one of the tools from Mr. Ricks UTA Maintenance Vehicle. 36. The UTA truck was found near Half Moon Lake, near Pinedale, Wyoming, and the Harrisons were arrested a few days after Mr. Ricks' body was found. FIRST CAUSE OF ACTION (Negligence as to UTA) 37. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 36 above 38. Defendant UTA owed Kay Ricks a duty of care to ensure that he could perform his maintenance services in a safe manner, protected from injury or death from kidnaping or other assaults from others. 39. Defendant UTA breached this duty to Mr. Ricks by failing to assign a second employee or apprentice trainee to work with him in locations that UTA knew or should have known could be dangerous to Ricks and its other employees. 40. Defendant UTA breached this duty to Mr. Ricks by failing to install GPS equipment on his UTA Maintenance Vehicle, which could have pinpointed the location of the truck and Complaint Page 6

7 Mr. Ricks long before he suffered the injuries which ultimately caused his death. 41. Defendant UTA breached this duty to Mr. Ricks by failing to adequately respond to the distress signals sent by Mr. Ricks as he was being accosted by the Harrisons, and by failing to have systems in place to rapidly respond to such situations. 42. As a direct and proximate result of the negligence and carelessness of UTA s decisions and conduct, Mr. Ricks suffered immensely at the hands of the Harrisons, and ultimately lost his life. 43. As a direct and proximate result of the negligence and carelessness of UTA s decisions and conduct, Mrs. Ricks has suffered significant damages, including loss of consortium, loss of financial and emotional support and emotional distress. 44. Mr. Ricks injuries and death have prevented him from engaging in his usual activities and have prevented him from being part of the lives of his family and friends. 45. Therefore, Mrs. Ricks has been damaged as a direct and proximate result of UTA s conduct as more fully set forth below. 46. Plaintiff has been required to secure the services of an attorney to prosecute this action and is entitled to an award for her reasonable attorneys fees and costs of court incurred herein. SECOND CAUSE OF ACTION (Willful Misconduct as to all Defendants) 47. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 46 above 48. Defendants Flint Wayne Harrison and Dereck James Harrison willfully and wantonly kidnaped, assaulted, savagely beat and murdered Kay Porter Ricks. 49. As a direct and proximate result of their willful and wrongful acts, Kay Ricks suffered Complaint Page 7

8 needless death and Mrs. Ricks suffered needless damages, as more fully set forth below. 50. Despite actual knowledge of the risks to UTA employees in working alone in dangerous areas, UTA, knowingly and with the knowledge that it was potentially harmful, sent Kay Ricks, without adequate warning or protection, to perform his maintenance services at the Ballpark TRAX Station alone, without the benefit of a GPS system in his UTA Maintenance Vehicle. 51. Once Mr. Ricks was in distress, and utilized his UTA-issued communication device to send out a call for help, UTA, knowingly and with the knowledge that said failure to respond would result in harm to Mr. Ricks, failed to take adequate action to protect or save Mr. Ricks from his assailants. 52. UTA knew or should have known, to a substantial certainty, that Kay Ricks and/or other employees would be assaulted, kidnaped, injured or killed so long as those employees were working alone, their UTA vehicles did not have GPS capabilities, and UTA failed to properly monitor its communications from employees to ascertain and respond to distress calls. 53. As a direct and proximate result of UTA s knowing and willful acts, Kay Ricks suffered needless death and Mrs. Ricks suffered needless damages, as more fully set forth below. 54. Plaintiff has been required to secure the services of an attorney to prosecute this action and is entitled to an award for her reasonable attorneys fees and costs of court incurred herein. THIRD CAUSE OF ACTION (Intentional Non-Feasance as to UTA) 55. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 55 above Complaint Page 8

9 56. UTA, as the employer of Kay Ricks, as the entity or individual who created the risk and caused the harm to Kay Ricks, as the controller of the information concerning the danger to UTA employees from persons at various UTA work sites, and as a result of the promises and commitments made in UTA s contract and policy documentation owed a duty of care to Kay Ricks to warn him or the dangers and hazards of working alone, to minimize the dangers and hazards, and to take reasonable and prompt steps to assist Kay Ricks and its other employees in the event of assault or threat from other individuals. 57. UTA willfully and knowingly failed to warn Kay Ricks of the dangers and hazards, failed to minimize the damages and hazards, and failed to take reasonable and prompt steps to assist Kay Ricks when he was faced with assault or other threat. 58. As a direct and proximate result of UTA s knowing and willful breach of its duties to him, Kay Ricks suffered needless death and Mrs. Ricks suffered needless damages, as more fully set forth below. 59. Plaintiff has been required to secure the services of an attorney to prosecute this action and is entitled to an award for her reasonable attorneys fees and costs of court incurred herein. FOURTH CAUSE OF ACTION (Wrongful Death as to all Defendants) 60. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 59 above 61. As more fully set forth above, Defendants engaged in wrongful, intentional and/or negligent acts or omissions which resulted in the death of Kay Ricks. 62. Mrs. Ricks, as the surviving spouse and personal representative of Kay Ricks, is the proper person to seek redress under UCA 78B Complaint Page 9

10 63. As a direct and proximate result of Defendants wrongful, intentional and/or negligent acts, Kay Ricks suffered needless death and Mrs. Ricks suffered needless damages, as more fully set forth below. 64. Plaintiff has been required to secure the services of an attorney to prosecute this action and is entitled to an award for her reasonable attorneys fees and costs of court incurred herein. FIFTH CAUSE OF ACTION (Loss of Spousal Consortium) 65. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 64 above 66. Defendant UTA s conduct as set forth herein resulted in the death of Kay Ricks. 67. The death of Kay Ricks has resulted in a loss of spousal consortium to Mrs. Ricks, his wife. 68. As a result of Kay Ricks death, Mrs. Ricks has been deprived of the love, companionship, society, solace and other attributes that make for the traditional marriage to Kay Ricks which she enjoyed prior to the events of May 12, Mrs. Ricks has endured the shock, sadness and anguish of losing her husband, partner, best friend and provider. 70. Mrs. Ricks is entitled to recover an award for her loss of spousal consortium, in an amount to be proved at trial. 71. Plaintiff has been required to secure the services of an attorney to prosecute this action and they are entitled to an award for their reasonable attorneys fees and costs of court incurred herein. Complaint Page 10

11 SIXTH CAUSE OF ACTION (Damages) 72. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 71 above 73. As a direct and proximate cause of the acts and omissions of the Defendants complained of herein, the Plaintiff has suffered special damages and general damages in a sum subject to proof at trial. 74. As a direct and proximate result of the acts and omissions of Defendants, Kay Ricks lost his life and the Plaintiff has incurred the following damages: a. Funeral and burial expenses for Kay Ricks; b. Past and future physical pain and suffering for the loss of Kay Ricks; c. Past and future emotional pain and suffering for the loss of Kay Ricks; d. Past and future loss of enjoyment of life; e. Past and future lost household services which would otherwise have been provided by Kay Ricks; f. Loss of earnings and earning capacity which would otherwise have been provided by Kay Ricks; g. Loss of spousal consortium from the loss of Kay Ricks; h. Loss of care, companionship and guidance from the loss of Kay Ricks; i. Past and future special damages; j. Past and future general damages; and k. Punitive damages. /// Complaint Page 11

12 WHEREFORE, Plaintiff respectfully requests judgment as follows: 1. For special damages in an amount to be proven at trial; 2. For general damages in an amount to be proven at trial; 3. For exemplary and punitive damages in an amount to be proven at trial; 4. For Plaintiff's attorneys fees and costs of suit incurred herein; and 5. For such other and further relief as to the Court may appear just and equitable. th DATED this 11 day of May, /s/ D. Brian Boggess D. BRIAN BOGGESS Attorney for Plaintiff Complaint Page 12

13 DEMAND FOR JURY TRIAL Plaintiff demands that all of the above issues and allegations be tried by jury. th Dated this 11 day of May, /s/ D. Brian Boggess D. Brian Boggess, Esq. Complaint Page 13

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

IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH Richard D. Burbidge (#0492) rburbidge@bmgtrial.com Jefferson W. Gross (#8339) jwgross@bmgtrial.com Aida Neimarlija (#12181) aneimarlija@bmgtrial.com BURBIDGE MITCHELL & GROSS 215 South State Street, Suite

More information

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

IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH. Civil No.: Judge Michael A. Worel (12741) Alan W. Mortensen (6616) Lance L. Milne (14879) DEWSNUP KING OLSEN WOREL HAVAS MORTENSEN 36 South State Street, Suite 2400 Salt Lake City, Utah 84111 Telephone: (801) 533-0400

More information

Case 3:16-cv RLY-MPB Document 1 Filed 04/25/16 Page 1 of 13 PageID #: 1

Case 3:16-cv RLY-MPB Document 1 Filed 04/25/16 Page 1 of 13 PageID #: 1 Case 3:16-cv-00054-RLY-MPB Document 1 Filed 04/25/16 Page 1 of 13 PageID #: 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA EVANSVILLE DIVISION KIMBALL INTERNATIONAL, INC., ) ) Plaintiff, )

More information

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO SAM DOE 1, SAM DOE 2, (A MINOR BY AND THROUGH HER PARENT AND NEXT FRIEND,) AND SAM DOE 3, C/O ACLU OF OHIO 4506 CHESTER AVENUE CLEVELAND, OHIO

More information

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

IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH Michael A. Worel (12741) Alan W. Mortensen (6616) Lance L. Milne (14879) DEWSNUP KING OLSEN WOREL HAVAS MORTENSEN 36 South State Street, Suite 2400 Salt Lake City, Utah 84111 Telephone: (801) 533-0400

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA COMPLAINT. I. Preliminary Statement

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA COMPLAINT. I. Preliminary Statement IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA JAMES W. GREEN, an individual, and AMERICAN CIVIL LIBERTIES UNION OF OKLAHOMA, a non-profit corporation, Plaintiffs, v. Case No.:

More information

IN THE CIRCUIT COURT OF COOK COUNTY, LAW DIVISION COOK COUNTY, ILLINOIS

IN THE CIRCUIT COURT OF COOK COUNTY, LAW DIVISION COOK COUNTY, ILLINOIS STATE OF ILLINOIS ) ) SS COUNTY OF COOK ) IN THE CIRCUIT COURT OF COOK COUNTY, LAW DIVISION COOK COUNTY, ILLINOIS DARYL VAN SCHOUWEN, ) Individually and as Father and next ) friend of the minor child,

More information

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA. Plaintiff, for his complaint, states and alleges the following:

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA. Plaintiff, for his complaint, states and alleges the following: 1 1 1 1 1 1 1 Robert E. Pastor, SBN 0 MONTOYA, L UCERO & P ASTOR, P.A. 0 North Central A venue, Suite 0 Phoenix, Arizona 01 Phone: (0) - Fax: (0) - repastor@mjpattomeys.com Attorneys for Plaintiff COPY

More information

FILED: KINGS COUNTY CLERK 05/09/ :30 PM INDEX NO /2016 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 05/09/2016

FILED: KINGS COUNTY CLERK 05/09/ :30 PM INDEX NO /2016 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 05/09/2016 FILED: KINGS COUNTY CLERK 05/09/2016 08:30 PM INDEX NO. 501142/2016 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 05/09/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X

More information

IN THE SEVENTH JUDICIAL DISTRICT COURT IN AND FOR SAN JUAN COUNTY, STATE OF UTAH. Case No. v. Judge WILLIE GRAYEYES,

IN THE SEVENTH JUDICIAL DISTRICT COURT IN AND FOR SAN JUAN COUNTY, STATE OF UTAH. Case No. v. Judge WILLIE GRAYEYES, PETER STIRBA (Bar No. 3118) MATTHEW STROUT (Bar No. 16732) STIRBA, P.C. 215 South State Street, Suite 750 P.O. Box 810 Salt Lake City, UT 84110-0810 Telephone: (801) 364-8300 Fax: (801) 364-8355 Email:

More information

Case 1:12-cv RJS Document 8 Filed 01/29/13 Page 1 of 8

Case 1:12-cv RJS Document 8 Filed 01/29/13 Page 1 of 8 Case 112-cv-08170-RJS Document 8 Filed 01/29/13 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------- X U.S. COMMODITY FUTURES TRADING COMMISSION,

More information

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY OF COOK, LAW DIVISION COMPLAINT AT LAW

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY OF COOK, LAW DIVISION COMPLAINT AT LAW HENRY VAUGHN, Plaintiff, IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY OF COOK, LAW DIVISION vs. ROBERT KELLY Case No. JURY DEMAND Defendant. COMPLAINT AT LAW NOW COMES the Plaintiff, HENRY VAUGHN,

More information

Case: 1:11-cv DCN Doc #: 2 Filed: 11/03/11 1 of 12. PageID #: 13

Case: 1:11-cv DCN Doc #: 2 Filed: 11/03/11 1 of 12. PageID #: 13 Case: 1:11-cv-02374-DCN Doc #: 2 Filed: 11/03/11 1 of 12. PageID #: 13 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION WILLIAM T. PHELPS, 464 Chestnut Drive Berea,

More information

John M. O Connor, Esq. ANDERSON KILL & OLICK, P.C.

John M. O Connor, Esq. ANDERSON KILL & OLICK, P.C. John M. O Connor, Esq. ANDERSON KILL & OLICK, P.C. Edward Barocas, Legal Director American Civil Liberties Union of New Jersey Foundation P.O. Box 750 Newark, NJ 07101 973-642-2084 Attorneys for Plaintiffs

More information

IN THE FIFTH JUDICIAL DISTRICT COURT WASHINGTON COUNTY, STATE OF UTAH

IN THE FIFTH JUDICIAL DISTRICT COURT WASHINGTON COUNTY, STATE OF UTAH Roger H. Hoole (5089) Gregory N. Hoole (7894) HOOLE & KING, L.C. 4276 South Highland Drive Salt Lake City, UT 84124 Telephone: (801) 272-7556 Facsimile: (801) 272-7557 Attorneys for Plaintiff Wallace Jeffs

More information

IN THE SECOND JUDICIAL DISTRICT COURT IN AND FOR WEBER COUNTY, STATE OF UTAH

IN THE SECOND JUDICIAL DISTRICT COURT IN AND FOR WEBER COUNTY, STATE OF UTAH William B. Ingram, #10803 Alan R. Houston, #14206 STRONG & HANNI 102 South 200 East, Suite 800 Salt Lake City, Utah 84111 Telephone: (801) 532-7080 Facsimile: (801) 596-1508 bthomas@strongandhanni.com

More information

Case 3:18-cv SB Document 1 Filed 08/22/18 Page 1 of 16

Case 3:18-cv SB Document 1 Filed 08/22/18 Page 1 of 16 Case 3:18-cv-01546-SB Document 1 Filed 08/22/18 Page 1 of 16 Kristian Roggendorf, OSB #013990 ksr@vf-law.com 17355 SW Boones Ferry Rd., Suite A Tel. (503) 684-4111 Of Attorneys for Plaintiff Doe 550 IN

More information

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION COMPLAINT

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION COMPLAINT UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION FERNANDO MORALES, Plaintiff, v. SQUARE, INC. Defendant. CIVIL ACTION NO. 5:13-CV-1092 JURY TRIAL REQUESTED COMPLAINT

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. SEAN SHIELDS; and ASHLEE SHIELDS, by and through her father and next friend, SEAN SHIELDS, v. Plaintiffs, KIOWA COUNTY

More information

AN ORDINANCE AMENDING AND SUPPLEMENTING CHAPTER 93 ( CRIMINAL HISTORY BACKGROUND CHECKS ) OF THE MANALAPAN TOWNSHIP CODE Ordinance No.

AN ORDINANCE AMENDING AND SUPPLEMENTING CHAPTER 93 ( CRIMINAL HISTORY BACKGROUND CHECKS ) OF THE MANALAPAN TOWNSHIP CODE Ordinance No. AN ORDINANCE AMENDING AND SUPPLEMENTING CHAPTER 93 ( CRIMINAL HISTORY BACKGROUND CHECKS ) OF THE MANALAPAN TOWNSHIP CODE Ordinance No. 2008-02 Adopted February 27, 2008 WHEREAS, the Township of Manalapan

More information

SIM GILL DISTRICT ATTORNEY

SIM GILL DISTRICT ATTORNEY Ralph Chamness Civil Division SIM GILL DISTRICT ATTORNEY Jeffrey William Hall Lisa Ashman Administrative Operations FOR IMMEDIATE RELEASE: Feb. 18, 2014 Contact Sim Gill: (801) 230-1209 or sgill@slco.org

More information

Case 2:11-cv GP Document 12 Filed 09/29/11 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 2:11-cv GP Document 12 Filed 09/29/11 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Case 2:11-cv-05827-GP Document 12 Filed 09/29/11 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA WEBMD HEALTH CORP. ) ) Plaintiff, ) ) v. ) C.A. No. 11-5827 ) ANTHONY

More information

Case 1:18-cv Document 1 Filed 10/06/18 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Case 1:18-cv Document 1 Filed 10/06/18 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION Case 1:18-cv-00849 Document 1 Filed 10/06/18 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION U.S. Pastor Council, Plaintiff, v. City of Austin; Steve Adler, in

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA BLUEFIELD DIVISION : : : : : : : : : : : : : : : : : : : : : COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA BLUEFIELD DIVISION : : : : : : : : : : : : : : : : : : : : : COMPLAINT IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA BLUEFIELD DIVISION FREEDOM FROM RELIGION FOUNDATION, INC., and JANE DOE, individually, and on behalf of JAMIE DOE Plaintiffs,

More information

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT 1 1 1 Hector O. Villagra (Bar No. ) ACLU FOUNDATION OF SOUTHERN CALIFORNIA 0 W. Chapman Avenue, Suite Orange, CA (Additional Counsel Listed On Following Page) Attorneys for Plaintiff JAMEELAH MEDINA, v.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO. CIVIL No.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO. CIVIL No. Case 1:12-cv-00125-JAP-WDS Document 1 Filed 02/08/12 Page 1 of 19 JANE FELIX, and B.N. COONE, Plaintiffs, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO vs. CIVIL No. THE CITY OF BLOOMFIELD,

More information

INTERNATIONAL CHURCHES OF CHRIST A California Nonprofit Religious Corporation An Affiliation of Churches. Charter Affiliation Agreement

INTERNATIONAL CHURCHES OF CHRIST A California Nonprofit Religious Corporation An Affiliation of Churches. Charter Affiliation Agreement INTERNATIONAL CHURCHES OF CHRIST A California Nonprofit Religious Corporation An Affiliation of Churches Charter Affiliation Agreement I PARTIES This Charter Affiliation Agreement dated June 1, 2003 (the

More information

Case 2:18-cr RJS Document 1 Filed 01/03/18 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT DISTICT OF UTAH, CENTRAL DIVISION

Case 2:18-cr RJS Document 1 Filed 01/03/18 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT DISTICT OF UTAH, CENTRAL DIVISION Case 2:18-cr-00009-RJS Document 1 Filed 01/03/18 Page 1 of 6 JOHN W. HUBER, United States Attorney (#7226) MARK K. VINCENT, Assistant United States Attorney (#5357) Attorneys for the United States of America

More information

The State of West Virginia, by and through its duly elected Attorney General, Patrick

The State of West Virginia, by and through its duly elected Attorney General, Patrick IN THE CIRCUIT COURT OF WOOD COUNTY, WEST VIRGINIA STATE OF WEST VIRGINIA ex rel. PATRICK MORRISEY, ATTORNEY GENERAL, Plaintiff, v. Civil Action No. Judge DIOCESE OF WHEELING- CHARLESTON and MICHAEL J.

More information

Case 3:18-cv BRM-TJB Document 1 Filed 01/23/18 Page 1 of 10 PageID: 11 IN THE UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

Case 3:18-cv BRM-TJB Document 1 Filed 01/23/18 Page 1 of 10 PageID: 11 IN THE UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY Case 3:18-cv-00941-BRM-TJB Document 1 Filed 01/23/18 Page 1 of 10 PageID: 11 IN THE UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY OHEL YIS HAK SEPHARDIC SYNAGOGUE OF ALLENHURST, and RABBI MOSHE SHAMAH,

More information

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

IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE SALT LAKE COUNTY, STATE OF UTAH Jerry Salcido (11956) jerry@salcidolaw.com Spencer Benny Salcido (14490) benny@salcidolaw.com SALCIDO LAW FIRM PLLC 43 W 9000 S Ste B Sandy UT 84070 801.413.1753 Phone 801.618.1380 Fax Attorneys for Plaintiff

More information

ABBEY ROAD AND WILDWOOD DRIVE PROJECTS REIMBURSEMENT AGREEMENT BY AND BETWEEN THE NORTHEAST OHIO REGIONAL SEWER DISTRICT AND

ABBEY ROAD AND WILDWOOD DRIVE PROJECTS REIMBURSEMENT AGREEMENT BY AND BETWEEN THE NORTHEAST OHIO REGIONAL SEWER DISTRICT AND ABBEY ROAD AND WILDWOOD DRIVE PROJECTS REIMBURSEMENT AGREEMENT BY AND BETWEEN THE NORTHEAST OHIO REGIONAL SEWER DISTRICT AND THE CITY OF NORTH ROYALTON This Agreement is made and entered into this day

More information

PROPOSALS MUST BE RECEIVED NO LATER THAN: 5:00 p.m., April 30, Proposals received after this time will not be evaluated.

PROPOSALS MUST BE RECEIVED NO LATER THAN: 5:00 p.m., April 30, Proposals received after this time will not be evaluated. BRIGHAM CITY CORPORATION (www.brighamcity.utah.gov) REQUEST FOR PROPOSALS 1100 W. Highway 91 Intersection Design PROPOSALS MUST BE RECEIVED NO LATER THAN: 5:00 p.m., April 30, 2012. Proposals received

More information

County of Kane Office of County Board Kane County Government Center. DOCUMENT VET SHEET for Karen McConnaughay Chairman, Kane County Board (1J I6 A

County of Kane Office of County Board Kane County Government Center. DOCUMENT VET SHEET for Karen McConnaughay Chairman, Kane County Board (1J I6 A County of Kane Office of County Board Kane County Government Center Karen McConnaughay Chairman 630-232-5930 KANE coui:ff\t -.. --- -~---~!... ~< p 0 '-~:t-~,1"1 (~ 0 719 Batavia Avenue Geneva, Illinois

More information

Case 1:05-cv RMU Document 1 Filed 01/31/2005 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:05-cv RMU Document 1 Filed 01/31/2005 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Case 1:05-cv-00220-RMU Document 1 Filed 01/31/2005 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ESTATE OF YAEL BOTVIN by and through its Administrator Russell Ellis, Esq.

More information

Plaintiff, Defendants. Plaintiff, The Port Authority of New York and New Jersey (hereinafter the "Port

Plaintiff, Defendants. Plaintiff, The Port Authority of New York and New Jersey (hereinafter the Port MARGARET TAYLOR FmUCANE One PATH Plaza Jersey City, New Jersey 07306 (201) 216-6370 (212) 435-7000 By: David Kromm, Esq. and Benjamin Noren, Esq. Attorney for Plaintiff The Port Authority ofnew York and

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION AT THE CROSS FELLOWSHIP BAPTIST CHURCH INC ) ) ) Plaintiff, ) ) v. ) Case No. ) CITY OF MONROE, NORTH CAROLINA,

More information

STATEMENT OF BISHOP EMERITUS DONALD TRAUTMAN As he has done his entire career, Bishop Trautman sends his prayerful support to all victims of clergy

STATEMENT OF BISHOP EMERITUS DONALD TRAUTMAN As he has done his entire career, Bishop Trautman sends his prayerful support to all victims of clergy STATEMENT OF BISHOP EMERITUS DONALD TRAUTMAN As he has done his entire career, Bishop Trautman sends his prayerful support to all victims of clergy sexual abuse. Bishop Trautman shares the Grand Jury s

More information

INTERLOCAL AGREEMENT FOR FIRE PROTECTION SERVICES

INTERLOCAL AGREEMENT FOR FIRE PROTECTION SERVICES INTERLOCAL AGREEMENT FOR FIRE PROTECTION SERVICES THIS AGREEMENT, made and entered into as of the 1 st day of July, 2010, by and between HYRUM CITY, a municipal corporation of the State of Utah, hereinafter

More information

Case 2:18-cv BCW Document 2 Filed 04/04/18 Page 1 of 20

Case 2:18-cv BCW Document 2 Filed 04/04/18 Page 1 of 20 Case 2:18-cv-00284-BCW Document 2 Filed 04/04/18 Page 1 of 20 Jeffrey R. Oritt (2478) Cohne Kinghorn 111 East Broadway, 11 th Floor Salt Lake City, UT 84111 Phone: (801) 363-4300 joritt@cohnekinghorn.com

More information

EXHIBIT 4 FILED: ONONDAGA COUNTY CLERK 11/07/ :40 PM. the. Affirmation of Laurel J. Eveleigh

EXHIBIT 4 FILED: ONONDAGA COUNTY CLERK 11/07/ :40 PM. the. Affirmation of Laurel J. Eveleigh EXHIBIT 4 to the Affirmation of Laurel J. Eveleigh SUPREME COURT STATE OF NEW YORK COUNTY OF ONONDAGA INTEGRATED CONSTRUCTION & POWER SYSTEMS, INC., PLAINTIFF'S FIRST SET Plaintiff, OF INTERROGATORIES

More information

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION E. Kwan Choi, individually and on behalf of Urantia Foundation, Urantia Corporation, Urantia Brotherhood Association,

More information

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. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO KATHRYN CHRISTIAN, JILL HAVENS, JEFF BASINGER, CLARE BOULANGER, SARAH SWEDBERG, AMERICAN CIVIL LIBERTIES UNION OF COLORADO,

More information

and sexuality, a local church or annual conference may indicate its desire to form or join a self-governing

and sexuality, a local church or annual conference may indicate its desire to form or join a self-governing Total Number of Pages: 14 Suggested Title: Modified Traditional Plan - Traditional Plan Implementation Process Discipline Paragraph or Resolution Number, if applicable: Discipline New 2801 General Church

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION NO.

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION NO. IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION NO. NIKKI IACONO, in her individual ) capacity, and on behalf of her minor child, ) ARIANA IACONO, ) ) Plaintiffs,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE Lt. Commander KENNETH J. WHITWELL, : U.S. Navy, : : Plaintiff, : : C.A. No. v. : : ARCHMERE ACADEMY, INC., a Delaware : corporation; CATHOLIC

More information

Opening Ceremonies 1. Welcome/Introductions Ray dewolfe 2. Serious Moment of Reflection/Pledge of Allegiance Corey Thomas

Opening Ceremonies 1. Welcome/Introductions Ray dewolfe 2. Serious Moment of Reflection/Pledge of Allegiance Corey Thomas See Page Two for Continuation of Agenda South Salt Lake City Council REGULAR MEETING AGENDA Public notice is hereby given that the South Salt Lake City Council will hold a Regular Meeting on Wednesday,

More information

FILED: ONONDAGA COUNTY CLERK 11/16/ :25 AM

FILED: ONONDAGA COUNTY CLERK 11/16/ :25 AM FILED: ONONDAGA COUNTY CLERK 11/16/2016 09:25 AM STATE OF NEW YORK CICERO TOWN COURT COUNTY OF ONONDAGA INDEX NO. 2016EF4347 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 11/16/2016 TOWN OF CICERO, Petitioner, MOTIONS

More information

IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA

IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA JAMAL MIFTAH, IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA Plaintiff, vs. CASE NO. CJ 2007-04083 Judge Gordon McAllister ISLAMIC SOCIETY OF TULSA, an Oklahoma non profit corporation,

More information

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) ) ) ) ) ) ) ) No.

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN The ESTATE of SYLVILLE K. SMITH, by Personal Representative Mildred Haynes, Patrick Smith, and Mildred Haynes, on her own behalf. Plaintiffs,

More information

IN THE CIRCUIT COURT OF MONTGOMERY, COUNTY, ALABAMA

IN THE CIRCUIT COURT OF MONTGOMERY, COUNTY, ALABAMA IN THE CIRCUIT COURT OF MONTGOMERY, COUNTY, ALABAMA BOARD OF DEACONS OF THE SHILOH MISSIONARY BAPTIST CHURCH AND THE BOARD OF TRUSTEES OF SHILOH MISSIONARY BAPTIST CHURCH CV: Plaintiffs vs. JUAN D. MCFARLAND,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION ) JOHN DOE, ) Civil Action ) Plaintiff, ) File No. ) v. ) ) Complaint for Declaratory BARROW COUNTY, GEORGIA;

More information

IN THE CIRCUIT COURT FOR ST. LOUIS COUNTY STATE OF MISSOURI VERIFIED PETITION

IN THE CIRCUIT COURT FOR ST. LOUIS COUNTY STATE OF MISSOURI VERIFIED PETITION IN THE CIRCUIT COURT FOR ST. LOUIS COUNTY STATE OF MISSOURI STEVE WINGFIELD AND FIRST CHRISTIAN CHURCH OF FLORISSANT Plaintiffs, v. Cause No. DOUGLAS LAY Serve: 2409 Lavin Court Florissant, MO 63033 TITUS

More information

In The Court of Appeals For The First District of Texas NO CV

In The Court of Appeals For The First District of Texas NO CV Opinion issued November 30, 2009 In The Court of Appeals For The First District of Texas NO. 01-07-00572-CV CORY WAYNE MAGEE, INDIVIDUALLY, AND TRACEY D ANN MAYO, INDIVIDUALLY AND AS LEGAL REPRESENTATIVE

More information

Background Packet. Name: I have done my observations and I am applying for:

Background Packet. Name: I have done my observations and I am applying for: Background Packet Name: I have done my observations and I am applying for: Church office Monday-Friday 9a-5p -Administrative Office address: 14418 K Miller Ave. Fontana, CA 92336 The following questions

More information

DANIEL F. MONAHAN, ESQUIRE Attorney I.D. No North Pottstown Pike, Suite 210 Exton, PA

DANIEL F. MONAHAN, ESQUIRE Attorney I.D. No North Pottstown Pike, Suite 210 Exton, PA DANIEL F. MONAHAN, ESQUIRE Attorney I.D. No. 28557 300 North Pottstown Pike, Suite 210 Exton, PA 19341 610-363-3888 dmonahan@jdllm.com MARCI A. HAMILTON, ESQUIRE Attorney I.D. No. 54820 36 Timber Knoll

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA BLUEFIELD DIVISION : : : : : : : : : : : : : : : : : : : : :

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA BLUEFIELD DIVISION : : : : : : : : : : : : : : : : : : : : : Case 117-cv-00642 Document 21 Filed 03/28/17 Page 1 of 22 PageID # 201 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA BLUEFIELD DIVISION FREEDOM FROM RELIGION FOUNDATION,

More information

ESSAY [60 Minutes] UNIVERSITY OF MISSOURI-COLUMBIA School of Law Torts 2. Mid-Term Examination SAMPLE ANSWERS

ESSAY [60 Minutes] UNIVERSITY OF MISSOURI-COLUMBIA School of Law Torts 2. Mid-Term Examination SAMPLE ANSWERS UNIVERSITY OF MISSOURI-COLUMBIA School of Law Torts 2 Mid-Term Examination SAMPLE ANSWERS Mr. Fischer October 14, 2005 8:30 a.m. 9:30 a.m. ESSAY [60 Minutes] On December 29, 2004, Nancy Smith, the mother

More information

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN. JOSEPH CASIAS, Case No CK Hon. Plaintiff,

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN. JOSEPH CASIAS, Case No CK Hon. Plaintiff, STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN JOSEPH CASIAS, Case No. 10- -CK Hon. Plaintiff, v. WAL-MART STORES, INC.; and TROY ESTILL, Defendants. DANIEL W. GROW, PLLC AMERICAN CIVIL

More information

STATE OF VERMONT PROFESSIONAL RESPONSIBILITY BOARD. Decision No. 35

STATE OF VERMONT PROFESSIONAL RESPONSIBILITY BOARD. Decision No. 35 35 PRB [17-May-2002] PROFESSIONAL RESPONSIBILITY BOARD In re: Thomas A. Bailey, Esq. - Respondent PRB Docket No. 2002-118 Decision No. 35 Upon receipt of the Affidavit of Resignation submitted to the Board

More information

LAKE VALLEY FIRE PROTECTION DISTRICT

LAKE VALLEY FIRE PROTECTION DISTRICT LAKE VALLEY FIRE PROTECTION DISTRICT RESPONSE TO EL DORADO COUNTY GRAND JURY REPORT NUMBER GJ-13-12 The Lake Valley Fire Protection District s responses to each finding and recommendation are embedded

More information

The Halachic Medical Directive

The Halachic Medical Directive The Halachic Medical Directive PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE AND POST-MORTEM DECISIONS FOR USE IN THE STATE OF DELAWARE The Halachic Medical Directive is designed to help ensure that

More information

Case: 4:15-cv Doc. #: 1 Filed: 06/25/15 Page: 1 of 32 PageID #: 1

Case: 4:15-cv Doc. #: 1 Filed: 06/25/15 Page: 1 of 32 PageID #: 1 Case: 4:15-cv-01008 Doc. #: 1 Filed: 06/25/15 Page: 1 of 32 PageID #: 1 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION REV. XIU HUI JOSEPH JIANG, ) ) Plaintiff, ) ) v.

More information

F I L E II. IN THE DISTRICT COURT, FIRST JUDICIAL DISTRICT IN AND FOR LARAMIE COUNTY, STATE OF WYOMING Docket No. I( \ COMPLAINT

F I L E II. IN THE DISTRICT COURT, FIRST JUDICIAL DISTRICT IN AND FOR LARAMIE COUNTY, STATE OF WYOMING Docket No. I( \ COMPLAINT IN THE DISTRICT COURT, FIRST JUDICIAL DISTRICT IN AND FOR LARAMIE COUNTY, STATE OF WYOMING Docket No. I( \ JONMICHAEL GUY and ) AMERICAN HUMANIST ASSOCIATION, ) ) Plaintiffs, ) ) vs. ) ) ROBERTO. LAMPERT,

More information

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO KA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO KA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE E-Filed Document May 1 2018 16:12:56 2017-KA-01170-COA Pages: 10 IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI RODNEY WAYNE SMITH APPELLANT VS. NO. 2017-KA-01170 STATE OF MISSISSIPPI APPELLEE BRIEF

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY Case 2:18-cv-00966 Document 1 Filed 01/23/18 Page 1 of 30 PageID: 1 Michael P. Hrycak NJ Attorney ID # 2011990 316 Lenox Avenue Westfield, NJ 07090 michaelhrycak@yahoo.com Counsel for Plaintiff IN THE

More information

SIM GILL DISTRICT ATTORNEY

SIM GILL DISTRICT ATTORNEY Ralph Chamness Chief Deputy Civil Division SIM GILL DISTRICT ATTORNEY Jeffrey William Hall Chief Deputy Justice Division Lisa Ashman Administrative Operations FOR IMMEDIATE RELEASE: March 7, 2014 Blake

More information

Investigative Report Automotive Repair Discount November 10, 2015

Investigative Report Automotive Repair Discount November 10, 2015 OFFICE OF INSPECTOR GENERAL PALM BEACH COUNTY John A. Carey Inspector General Inspector General Accredited Enhancing Public Trust in Government Investigative Report 2015-0008 Automotive Repair Discount

More information

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

IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH Roger H. Hoole (5089) HOOLE & KING, L.C. 4276 South Highland Drive Salt Lake City, UT 84124 Telephone: (801) 272-7556 Facsimile: (801) 272-7557 Attorneys for Plaintiff Richard Holm IN THE THIRD JUDICIAL

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 POLICE NO. : 19-000697 PROSECUTOR NO. : 095451472 OCN: STATE OF MISSOURI, ) PLAINTIFF, ) vs. ) ) CLIFTON L. JACK ) 1404 NE Ivory Lane )

More information

CAMP DAVID FATHER AND SON CAMP

CAMP DAVID FATHER AND SON CAMP www.campdavidnam.com windhoek@campdavidnam.com Tel: 061 300 650 Fax: 061 300 654 P O Box 31116, Pionierspark, Windhoek Namibia CAMP DAVID FATHER AND SON CAMP Malachi 4:5-6: Behold, I will send you Elijah

More information

DURABLE POWER OF ATTORNEY/DECLARATION WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS FOR USE IN CALIFORNIA

DURABLE POWER OF ATTORNEY/DECLARATION WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS FOR USE IN CALIFORNIA The Halachic Living Will DURABLE POWER OF ATTORNEY/DECLARATION WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS FOR USE IN CALIFORNIA The Halachic Living Will is designed to help ensure

More information

MEDICAL DURABLE POWER OF ATTORNEY FOR HEALTH CARE AND DECLARATION FOR USE IN COLORADO

MEDICAL DURABLE POWER OF ATTORNEY FOR HEALTH CARE AND DECLARATION FOR USE IN COLORADO The Halachic Living Will MEDICAL DURABLE POWER OF ATTORNEY FOR HEALTH CARE AND DECLARATION FOR USE IN COLORADO The Halachic Living Will is designed to help ensure that all medical and post-death decisions

More information

IN THE CIRCUIT COURT CRITTENDEN COUNTY APPELLEES SECOND MOTION AND BRIEF FOR RECONSIDERATION

IN THE CIRCUIT COURT CRITTENDEN COUNTY APPELLEES SECOND MOTION AND BRIEF FOR RECONSIDERATION IN THE CIRCUIT COURT CRITTENDEN COUNTY PAM HICKS and JOHN MARK BYERS APPELLANTS v. CV-2012-290-6 THE CITY OF WEST MEMPHIS, ARKANSAS, and SCOTT ELLINGTON, in his Official Capacities as Prosecuting Attorney

More information

IN THE THIRD DISTRICT COURT, WEST JORDAN DEPARTMENT IN AND FOR THE COUNTY OF SALT LAKE, STATE OF UTAH DAO #

IN THE THIRD DISTRICT COURT, WEST JORDAN DEPARTMENT IN AND FOR THE COUNTY OF SALT LAKE, STATE OF UTAH DAO # SIM GILL, Bar No. 6389 District Attorney for Salt Lake County R. JOSH PLAYER, Bar No. 7768 Deputy District Attorney 8080 South Redwood Road, Suite 1100 West Jordan, UT 84084 Telephone: (801)233-9900 IN

More information

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT INDEPENDENCE COMPLAINT. Count I. Murder 2nd Degree ( Y )

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT INDEPENDENCE COMPLAINT. Count I. Murder 2nd Degree ( Y ) IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT INDEPENDENCE POLICE NO. : 17-058838 PROSECUTOR NO. : 095440950 STATE OF MISSOURI, ) PLAINTIFF, ) vs. ) PATRICK L. BARKWELL ) 11409 E. Anderson, ) Sugar

More information

PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS FOR USE IN CONNECTICUT INSTRUCTIONS

PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS FOR USE IN CONNECTICUT INSTRUCTIONS The Halachic Living Will PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS FOR USE IN CONNECTICUT The Halachic Living Will is designed to help ensure that all medical

More information

BOARD OF BISHOPS GRIEVANCE COMMITTEE

BOARD OF BISHOPS GRIEVANCE COMMITTEE BOARD OF BISHOPS GRIEVANCE COMMITTEE Of the CHURCH OF GOD IN CHRIST, INC DEACON TIMOTHY JONES Complainant, vs. Bishop ALBERT GALBRAITH, Respondent Case Number: Pursuant to the Official Manual; Article

More information

=======================================X In the Matter of the Proceeding Pursuant to Section 44, subdivision 4, ofthe Judiciary Law, in Relation to

=======================================X In the Matter of the Proceeding Pursuant to Section 44, subdivision 4, ofthe Judiciary Law, in Relation to STATE OF NEW YORK COMMISSION ON JUDICIAL CONDUCT =======================================X In the Matter of the Proceeding Pursuant to Section 44, subdivision 4, ofthe Judiciary Law, in Relation to Lawrence

More information

PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS

PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM DECISIONS Developed and published by: Agudath Israel of America 42 Broadway, 14 th Floor New York, NY 10004 212-797-9000 The Halachic Living Will PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE DECISIONS AND POST-MORTEM

More information

Pullenvale QLD The Woman, Julia-Eileen: Gillard., acting as The Honourable JULIA EILEEN GILLARD FIAT JUSTITIA, RUAT COELUM

Pullenvale QLD The Woman, Julia-Eileen: Gillard., acting as The Honourable JULIA EILEEN GILLARD FIAT JUSTITIA, RUAT COELUM Friday, 23 rd September, 2011 Malcolm-Ieuan: Roberts. Beneficiary, Administrator for MALCOM IEUAN ROBERTS 180 Haven Road, Pullenvale QLD 4069 The Woman, Julia-Eileen: Gillard., acting as The Honourable

More information

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF VIRGINIA Roanoke Division ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT.

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF VIRGINIA Roanoke Division ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT. IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF VIRGINIA Roanoke Division DOE 1, by Doe 1 s next friend and parent, DOE 2, who also sues on Doe 2 s own behalf, v. Plaintiffs, SCHOOL BOARD OF GILES

More information

MOTION TO SUPPRESS STATEMENTS

MOTION TO SUPPRESS STATEMENTS IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA. CASE NO.: 16-2013-CF-005781-AXXX-MA DIVISION: CR-D STATE OF FLORIDA vs. DONALD SMITH MOTION TO SUPPRESS STATEMENTS

More information

The Halachic Medical Directive

The Halachic Medical Directive The Halachic Medical Directive PROXY AND DIRECTIVE WITH RESPECT TO HEALTH CARE AND POST-MORTEM DECISIONS FOR USE IN THE STATE OF MISSOURI The Halachic Medical Directive is designed to help ensure that

More information

IN THE SECOND JUDICIAL DISTRICT COURT IN AND FOR DAVIS COUNTY, STATE OF UTAH COMPLAINT. Tier III. Civil No. The Honorable

IN THE SECOND JUDICIAL DISTRICT COURT IN AND FOR DAVIS COUNTY, STATE OF UTAH COMPLAINT. Tier III. Civil No. The Honorable D. Matthew Moscon (6947) matt.moscon@stoel.com Andrew T. Wojciechowski (15286) andrew.wojciechowski@stoel.com STOEL RIVES LLP 201 S Main Street, Suite 1100 Salt Lake City, UT 84111 Telephone: (801) 328-3131

More information

State of New York Supreme Court, Appellate Division Third Judicial Department

State of New York Supreme Court, Appellate Division Third Judicial Department State of New York Supreme Court, Appellate Division Third Judicial Department Decided and Entered: June 1, 2006 98719 ERNEST L. et al., Individually and as Parents and Guardians of NATASHA L., an Infant,

More information

YOUTH TRIP Diocese of Palm Beach

YOUTH TRIP Diocese of Palm Beach YOUTH TRIP Diocese of Palm Beach Section 20 February 2017 Page 1 of 8 YOUTH TRIP POLICY Updated April 2, 2009 CONCERNING SUPERVISION FOR TRIPS & OTHER FUNCTIONS Page 1 of 4 I. Introduction The following

More information

6:13-cv GRA Date Filed 09/11/13 Entry Number 1 Page 1 of 25. UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA Greenville Division

6:13-cv GRA Date Filed 09/11/13 Entry Number 1 Page 1 of 25. UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA Greenville Division 6:13-cv-02471-GRA Date Filed 09/11/13 Entry Number 1 Page 1 of 25 UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA Greenville Division American Humanist Association, CA No. John Doe and Jane Doe,

More information

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 SAN JOSE DIVISION 4 UNITED STATES OF AMERICA, ) CR-0-2027-JF ) 5 Plaintiff, ) ) San Jose, CA 6 vs. ) October 2, 200 ) 7 ROGER VER, ) ) 8

More information

FAITH EVANGELICAL LUTHERAN CHURCH MEMORIAL PRAYER GARDEN 886 North Shore Drive Forest Lake, Minnesota RULES AND PROCEDURES

FAITH EVANGELICAL LUTHERAN CHURCH MEMORIAL PRAYER GARDEN 886 North Shore Drive Forest Lake, Minnesota RULES AND PROCEDURES FAITH EVANGELICAL LUTHERAN CHURCH MEMORIAL PRAYER GARDEN 886 North Shore Drive Forest Lake, Minnesota 55025 RULES AND PROCEDURES Effective: March, 2008 I -ESTABLISHMENT AND ADMINISTRATION A. Establishment.

More information

The Halachic Medical Directive

The Halachic Medical Directive The Halachic Medical Directive ADVANCE DIRECTIVE WITH RESPECT TO HEALTH CARE DECISIONS AND POST- MORTEM DECISIONS FOR USE IN NEW JERSEY The Halachic Medical Directive is designed to help ensure that all

More information

2014 REDSKINS TRAINING CAMP TICKET LOTTERY OFFICIAL RULES

2014 REDSKINS TRAINING CAMP TICKET LOTTERY OFFICIAL RULES 2014 REDSKINS TRAINING CAMP TICKET LOTTERY OFFICIAL RULES NO PURCHASE NECESSARY TO ENTER OR WIN. A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. Open only to legal residents of the United States

More information

THE POWERS OF A PARISH MEETING IN A PARISH WITHOUT A SEPARATE PARISH COUNCIL

THE POWERS OF A PARISH MEETING IN A PARISH WITHOUT A SEPARATE PARISH COUNCIL Legal Topic Note LTN 3 September 2014 THE POWERS OF A PARISH MEETING IN A PARISH WITHOUT A SEPARATE PARISH COUNCIL Purpose, name, style, constitution and governance 1. Unless indicated otherwise, references

More information

lo) [E ~ [E ~ \Yl [E rr\ lru JUN 2 I 2012 ty

lo) [E ~ [E ~ \Yl [E rr\ lru JUN 2 I 2012 ty Karen McConnaughay Chairman 630-232-5930 County of Kane Office of County Board Kane County Government Center lo) [E ~ [E ~ \Yl [E rr\ lru JUN 2 I 2012 ty 719 Batavia Avenue Geneva, Illinois 60134 Fax 630-232-9188

More information

Revision: DRAFT 0622 BYLAWS. Revision Bylaws: Vancouver First Church of God Page 1

Revision: DRAFT 0622 BYLAWS. Revision Bylaws: Vancouver First Church of God Page 1 BYLAWS Revision 2017 Bylaws: Vancouver First Church of God Page 1 Table of Contents ARTICLE 1 NAME... 3 ARTICLE 2 PURPOSE & MISSION... 3 ARTICLE 3 MEMBERSHIP... 4 ARTICLE 4 OFFICERS... 5 ARTICLE 5 SENIOR

More information

LONG ISLAND ABUNDANT LIFE CHURCH HICKSVILLE, NEW YORK. This church shall be known as the Long Island Abundant Life Church.

LONG ISLAND ABUNDANT LIFE CHURCH HICKSVILLE, NEW YORK. This church shall be known as the Long Island Abundant Life Church. LONG ISLAND ABUNDANT LIFE CHURCH HICKSVILLE, NEW YORK "Grace be to you, and peace, from God our Father, and the Lord Jesus Christ." I Corinthians 1:3 We, the members of the Body of Christ, desiring that

More information

Oneida County Title VI Policy Statement

Oneida County Title VI Policy Statement Oneida County Title VI Policy Statement As a recipient of federal and state funds, Oneida County is subject to the requirements and provisions of the Title VI of the Civil Rights Act of 1964, as amended.

More information

Kosher Quality Caterers, Inc. v. Kalman Goodman & Menachem Moskowitz

Kosher Quality Caterers, Inc. v. Kalman Goodman & Menachem Moskowitz Beth Din of America Reported Decision 6 Kosher Quality Caterers, Inc. v. Kalman Goodman & Menachem Moskowitz January 19, 2005 The Beth Din of America, having been chosen as arbitrators pursuant to an arbitration

More information

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT C/W SAFEWAY INSURANCE COMPANY OF LOUISIANA, ET AL. ************

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT C/W SAFEWAY INSURANCE COMPANY OF LOUISIANA, ET AL. ************ DAVID CHAPMAN, ET AL. VERSUS STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT 06-0529 C/W 06-0530 SAFEWAY INSURANCE COMPANY OF LOUISIANA, ET AL. ************ APPEAL FROM THE TWENTY-SEVENTH JUDICIAL DISTRICT

More information

Lutheran CORE Constitution Adopted February 23, 2015

Lutheran CORE Constitution Adopted February 23, 2015 Chapter 1. Name and Incorporation Lutheran CORE Constitution Adopted February 23, 2015 1.01. The name of this ministry shall be Lutheran Coalition for Renewal, dba Lutheran CORE, a community of confessing

More information