NOTICE OF ELECTRONIC FILING - Frankly Incftpcontent.worldnow.com/wbma/misc/gate-city-lawsuit.pdf ·...

AlaFile E-Notice

To: GLENDA GALE COCHRAN

[email protected]

01-CV-2013-905049.00

NOTICE OF ELECTRONIC FILING

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA

The following complaint was FILED on 12/23/2013 1:01:01 PM

DARRYLE JEROME BROWN ET AL V. ALABAMA GAS CORPORATION ET AL

01-CV-2013-905049.00

Notice Date: 12/23/2013 1:01:01 PM

ANNE-MARIE ADAMS

CIRCUIT COURT CLERK

JEFFERSON COUNTY, ALABAMA

716 N. RICHARD ARRINGTON BLVD.

BIRMINGHAM, AL 35203

205-325-5355

[email protected]

JEFFERSON COUNTY, ALABAMA

State of Alabama

Unified Judicial System

Form ARCiv-93 Rev.5/99

COVER SHEETCIRCUIT COURT - CIVIL CASE

(Not For Domestic Relations Cases)

Case Number:

Date of Filing:

01-CV-2013-905049.00

12/23/2013

Judge Code:

GENERAL INFORMATION

IN THE CIRCUIT OF JEFFERSON COUNTY, ALABAMA

First Plaintiff:

DARRYLE JEROME BROWN ET AL v. ALABAMA GAS CORPORATION ET AL

Business

Government

Individual

Other

BusinessFirst Defendant:

Government

Individual

Other

NATURE OF SUIT:

TORTS: PERSONAL INJURY

WDEA - Wrongful Death

TONG - Negligence: General

TOMV - Negligence: Motor Vehicle

TOMM - Malpractice-Medical

TOPL - Product Liability/AEMLD

TOWA - Wantonnes

TOLM - Malpractice-Legal

TOOM - Malpractice-Other

TBFM - Fraud/Bad Faith/Misrepresentation

TOXX - Other:

TORTS: PERSONAL INJURY

TOPE - Personal Property

TORE - Real Property

OTHER CIVIL FILINGS

ABAN - Abandoned Automobile

ACCT - Account & Nonmortgage

APAA - Administrative Agency Appeal

ADPA - Administrative Procedure Act

ANPS - Adults in Need of Protective Services

OTHER CIVIL FILINGS (cont'd)

MSXX -

CVRT - Civil Rights

COND - Condemnation/Eminent Domain/Right-of-Way

CTMP-Contempt of Court

CONT-Contract/Ejectment/Writ of Seizure

Birth/Death Certificate Modification/Bond ForfeitureAppeal/Enforcement of Agency Subpoena/Petition toPreserve

TOCN - Conversion

EQND- Equity Non-Damages Actions/DeclaratoryJudgment/Injunction Election Contest/Quiet Title/Sale ForDivision

CVUD-Eviction Appeal/Unlawfyul Detainer

FORJ-Foreign Judgment

FORF-Fruits of Crime Forfeiture

MSHC-Habeas Corpus/Extraordinary Writ/Mandamus/Prohibition

PFAB-Protection From Abuse

FELA-Railroad/Seaman (FELA)

RPRO-Real Property

WTEG-Will/Trust/Estate/Guardianship/Conservatorship

COMP-Workers' Compensation

CVXX-Miscellaneous Circuit Civil Case

ORIGIN: F

R

A

T

INITIAL FILING

REMANDED

APPEAL FROMDISTRICT COURT

TRANSFERRED FROMOTHER CIRCUIT COURT

O OTHER

HAS JURY TRIAL BEEN DEMANDED? Yes No

RELIEF REQUESTED: MONETARY AWARD REQUESTED NO MONETARY AWARD REQUESTED

MEDIATION REQUESTED: Yes No Undecided

ATTORNEY CODE: COC001 12/23/2013 1:01:01 PM /s/ GLENDA GALE COCHRAN

ELECTRONICALLY FILED12/23/2013 1:01 PM

01-CV-2013-905049.00CIRCUIT COURT OF

JEFFERSON COUNTY, ALABAMAANNE-MARIE ADAMS, CLERK

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA

DARRYLE JEROME BROWN, by and through

his mother and next friend BEVERLY

JOHNSON,

Plaintiff,

v.

ALABAMA GAS CORPORATION; HOUSING

AUTHORITY OF THE BIRMINGHAM

DISTRICT; FICTITIOUS DEFENDANTS, A, B,

C, and D, whether singular or plural, being those

persons, corporations, partnerships, or other legal

entities whose negligent and/or wanton acts

caused or contributed to the explosion and events

that caused the injuries to the Plaintiff;

FICTITIOUS DEFENDANTS E, F, G, and H,

whether singular or plural, being those persons,

corporations, partnerships, or other legal entities

who owned or were responsible for maintaining

or ensuring the safety of the property and/or any

equipment in and around the Marks Village

Apartments in Birmingham, Alabama, connected

to or related to the events and explosion that

caused the injuries to the Plaintiff; FICTITIOUS

DEFENDANTS I, J, K, and L, whether singular

or plural, being those persons, corporations,

partnerships, or other legal entities who designed,

manufactured, and/or sold equipment and other

products that caused or contributed to the injuries

to the Plaintiff; FICTITIOUS DEFENDANTS M,

N, O, and P, whether singular or plural, being

those persons, corporations, partnerships, or other

legal entities who by statute, agreement, contract,

undertaking or otherwise were responsible for the

maintenance and/or safety of the natural gas

distribution lines and equipment in and around the

Marks Village Apartments in Birmingham,

Alabama, including but not limited to inspecting,

maintaining, correcting hazardous or dangerous

conditions in, repairing, and/or replacing said

natural gas distribution lines and equipment, and

whose failure to properly inspect, maintain,

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JURY TRIAL DEMANDED

ELECTRONICALLY FILED12/23/2013 1:01 PM

01-CV-2013-905049.00CIRCUIT COURT OF

JEFFERSON COUNTY, ALABAMAANNE-MARIE ADAMS, CLERK

2

repair, and/or replace said natural gas lines and

equipment caused injuries to Plaintiff;

FICTITIOUS DEFENDANTS Q, R, S, and T

being those persons, corporations, partnerships, or

other legal entities, other than those entities

described above, who are the predecessors or

successors in interest of those entities described

above. Plaintiff avers that the identity of the

fictitious party defendants is otherwise unknown

to Plaintiff at this time, or, if their names are

known to Plaintiff at this time their identities as

proper party defendants is not known to Plaintiff

at this time; but their true names will be

substituted by amendment when the aforesaid

lacking knowledge is ascertained,

Defendants.

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COMPLAINT

COMES NOW, the Plaintiff, Darryle Jerome Brown, by and through his mother and

next friend Beverly Johnson, in the above-styled cause and for his Complaint states as follows:

PARTIES

1. The Plaintiff, Darryle Jerome Brown, is a resident of the Jefferson County, Alabama.

Darryle Jerome Brown brings this action by and through his next friend and mother

Beverly Johnson.

2. The Defendant, Alabama Gas Corporation (hereinafter “Alagasco”), upon information

and belief, is an Alabama corporation with its principal place of business in Birmingham,

Alabama.

3. Defendant Housing Authority of the Birmingham District (hereinafter “HABD”), upon

information and belief, is a housing authority organized pursuant to Alabama Code § 24 -

1-1 (1975) et seq. operating in Jefferson County, Alabama.

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4. Fictitious Defendants A, B, C, and D, whether singular or plural, being those persons,

corporations, partnerships, or other legal entities whose negligent and/or wanton acts

caused or contributed to the explosion and events that caused the injuries to the Plaintiff.

5. Fictitious Defendants E, F, G, and H, whether singular or plural, being those persons,

corporations, partnerships, or other legal entities who owned or were responsible for

maintaining or ensuring the safety of the property and/or any equipment in and around

the Marks Village Apartments in Birmingham, Alabama, connected to or related to the

events and fire that caused the injuries to the Plaintiff.

6. Fictitious Defendants I, J, K, and L, whether singular or plural, being those persons,

corporations, partnerships, or other legal entities who designed, manufactured, and/or

sold equipment and other products that caused or contributed to the injuries to the

Plaintiff.

7. Fictitious Defendants M, N, O, and P, whether singular or plural, being those persons,

corporations, partnerships, or other legal entities who by statute, agreement, contract,

undertaking or otherwise were responsible for the maintenance and/or safety of the

natural gas distribution lines and equipment in and around the Marks Village Apartments

in Birmingham, Alabama, including but not limited to inspecting, maintaining, correcting

hazardous or dangerous conditions in, repairing, and/or replacing said natural gas

distribution lines and equipment, and whose failure to properly inspect, maintain, repair,

and/or replace said natural gas lines and equipment caused injuries to Plaintiff.

8. Fictitious Defendants Q, R, S, and T, whether singular or plural, being those persons,

corporations, partnerships, or other legal entities, other than those entities described

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above, who are the predecessors or successors in interest of to the named and fictitious

defendants described herein.

JURISDICTION

9. This Court has jurisdiction pursuant to § 12-11-30, Alabama Code 1975, as the amount in

controversy in this action exceeds $10,000, exclusive of interest and costs.

VENUE

10. Pursuant to § 6-3-7, Ala. Code 1975, venue is proper in Jefferson County as said county

is where the acts and omissions which constitute or form the basis of this action.

FACTS

11. In the early morning hours of December 17, 2013, an explosion occurred in or near the

Marks Village Apartments in the Gate City neighborhood of Birmingham, Alabama.

12. At the time of the subject explosion, Darryle Jerome Brown was inside one of the Mark

Village Apartment buildings with his fiancé, Tyrennis Laval Mabry.

13. The subject explosion severely damaged the building where Darryle Jerome Brown was

located, causing him extensive injuries, and ultimately killing Tyrennis Laval Mabry.

14. Upon information and belief, the subject explosion was caused by a natural gas leak.

15. Defendant Alagasco was the natural gas provider in the Gate City neighborhood. Prior to

the subject explosion, Defendant Alagasco had received notice through numerous

complaints of natural gas leaks in the Gate City area, including but not limited to leaks in

and around the Marks Village Apartments. As the natural gas provider, Defendant

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Alagasco was responsible for the maintenance and safety of natural gas distribution lines

and equipment in the area.

16. The subject explosion was the result of the negligence and/or wantonness of Defendant

Alagasco, including but not limited to: (1) its failure to adequately investigate reports of

natural gas leaks in the Gate City area, including but not limited to leaks in natural gas

distribution lines and equipment in and around the Marks Village Apartments; (2) its

failure to correct natural gas leaks and other hazardous conditions in said natural gas lines

and equipment; (3) its failure to properly inspect, maintain, repair, and/or replace the

natural gas distribution lines and equipment in the Gate City area, including but not

limited to leaks in natural gas distribution lines and equipment in and around the Marks

Village Apartments; (4) its failure to take adequate and/or necessary steps and actions to

properly warn and protect the public, including but not limited to occupants of the Marks

Village Apartments, from danger; and (5) its failure to take adequate and/or necessary

steps to reduce the hazards to which the occupants of the Marks Village Apartments were

subjected by reason of its equipment and facilities.

17. The negligence and/or wantonness of Defendant Alagasco was a proximate cause of the

subject explosion and Plaintiff Darryle Jerome Brown’s injuries.

18. The subject explosion was also the result of the negligence and/or wantonness of

Defendant HADB, which had a duty to inspect, warn, and/or make safe any dangerous

conditions at the Marks Village Apartments as the owner/lessor/manager of said

premises.

19. The subject explosion was also caused by the negligent and wanton acts of Fictitious

Defendants A-P as described hereinabove.

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20. Fictitious Defendants Q-T, as the predecessors or successors in interest to the named and

fictitious defendants described herein, are liable for the conduct of said defendants.

COUNT I

NEGLIGENCE—DEFENDANT ALAGASCO

21. Plaintiff hereby incorporates by reference all preceding allegations as if fully set forth

herein.

22. Defendant Alagasco breached a duty of due care to Plaintiff in multiple respects,

including, but not limited to: (1) its failure to adequately investigate reports of natural gas

leaks in the Gate City area, including but not limited to leaks in natural gas distribution

lines and equipment in and around the Marks Village Apartments; (2) its failure to correct

natural gas leaks and other hazardous conditions in said natural gas lines and equipment;

(3) its failure to properly inspect, maintain, repair, and/or replace the natural gas

distribution lines and equipment in the Gate City area, including but not limited to leaks

in natural gas distribution lines and equipment in and around the Marks Village

Apartments; (4) its failure to take adequate and/or necessary steps and actions to properly

warn and/or protect occupants of the Marks Village Apartments from danger; (5) its

failure to take adequate and/or necessary steps to reduce the hazards to which the

occupants of the Marks Village Apartments were subjected by reason of its equipment

and facilities.

23. Defendant Alagasco’s failure to comply with its duties constitutes negligence.

24. Defendant Alagasco’s breaches of duty combined and concurred with other wrongful

conduct to proximately cause Plaintiff’s injuries.

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WHEREFORE Plaintiff claims compensatory and punitive damages for his injuries resulting

from said incident, including, but not limited to, past and future medical expenses, past and

future physical pain and suffering, present and future mental anguish, permanent injuries and

disabilities, disfigurement, loss of enjoyment of life and other hedonic damages, damages

resulting from the exacerbation of prior medical conditions and/or injuries, loss of personal

property, loss of use and enjoyment of personal property, and such other compensatory damages

as may be shown, in an amount to be determined by a jury, and costs, expenses and fees, and

such other equitable relief as may be allowed by law.

COUNT II

WANTONNESS—DEFENDANT ALAGASCO


herein.

26. Prior to the subject explosion on December 17, 2013, Defendant Alagasco had superior

knowledge of the dangers, defects, hazards and/or risks associated with natural gas

distribution lines and equipment in the Gate City area, including but not limited to natural

gas distribution lines and equipment in and around the Marks Village Apartments, as well

as hazards and/or risks associated with natural gas.

27. Prior to the subject explosion on December 17, 2013, Defendant Alagasco received

notice in the form of numerous complaints and knew that there were natural gas leaks in

the Gate City area, including but not limited to leaks in and around the Marks Village

Apartments.

28. Defendant Alagasco knew or should have known, before the date of the incident that

injured the Plaintiff, that this type of explosion could occur.

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29. Defendant Alagasco, despite this knowledge, consciously and recklessly disregarded the

rights and safety of others, including Plaintiff, through its actions, including but not

limited to: (1) its failure to adequately investigate reports of natural gas leaks in the Gate

City area, including but not limited to leaks in natural gas distribution lines and

equipment in and around the Marks Village Apartments; (2) its failure to correct natural

gas leaks and other hazardous conditions in said natural gas lines and equipment; (3) its

failure to properly inspect, maintain, repair, and/or replace the natural gas distribution

lines and equipment in the Gate City area, including but not limited to leaks in natural gas

distribution lines and equipment in and around the Marks Village Apartments; (4) its

failure to take adequate and/or necessary steps and actions to properly warn and/or

protect occupants of the Marks Village Apartments from danger; (5) its failure to take

adequate and/or necessary steps to reduce the hazards to which the occupants of the

Marks Village Apartments were subjected by reason of its equipment and facilities.

30. Defendant Alagasco’s wanton conduct combined and concurred with other wrongful










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COUNT III

NEGLIGENCE PER SE—DEFENDANT ALAGASCO


herein.

32. Defendant Alagasco’s negligent and wanton conduct described herein also breached a

duty of care to Plaintiff by violation of local, state, and national laws, regulations,

ordinances, fire codes, industry standards, and/or safety codes.

33. Plaintiff is within the class of persons intended to be protected by said laws, regulations,

ordinances, industry standards and/or safety codes, and is among the class of persons to

whom such duty ran.

34. Plaintiff’s injuries are the type of harm intended to be prevented by such laws,

regulations, ordinances, industry standards and/or safety codes.

35. The negligent and/or wanton breach of duty by Defendant Alagasco constitutes

negligence per se.

36. The negligent and/or wanton breach of duty by Defendant Alagasco combined and

concurred with other wrongful conduct to proximately cause injuries and damages to

Plaintiff as previously described.







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COUNT IV

NEGLIGENCE, WANTONNESS, and NEGLIGENCE PER SE—

DEFENDANT HABD


herein.

38. Defendant HABD owned, leased, managed and/or was otherwise responsible for the

Marks Village Apartments.

39. Prior to the subject explosion on December 17, 2013, Defendant HABD had superior

knowledge of the dangers, defects, and hazards in and around the Marks Village

Apartments.

40. Despite its knowledge, Defendant HABD consciously and recklessly disregarded the

rights and safety of others, and negligently and wantonly breached a duty of due care to

Plaintiff in multiple respects, including, but not limited to, failing to properly inspect,

maintain, repair, and or warn regarding hazards within the Marks Village Apartments.

41. Defendant HABD’s negligent and wanton conduct described herein also breached a duty

of care to Plaintiff by violation of local, state, and national laws, regulations, ordinances,

fire codes, industry standards, and/or safety codes. Plaintiff is within the class of persons

intended to be protected by said laws, regulations, ordinances, industry standards and/or

safety codes, and is among the class of persons to whom such duty ran. Plaintiff’s

injuries are the type of harm intended to be prevented by such laws, regulations,

ordinances, industry standards and/or safety codes.

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42. Defendant HABD’s negligent and wanton conduct described herein combined and

concurred with other wrongful conduct to proximately cause Plaintiff’s injuries.

WHEREFORE Plaintiff claims compensatory and punitive damages for his injuries

resulting from said incident, including, but not limited to, past and future medical expenses, past

and future physical pain and suffering, present and future mental anguish, permanent injuries and






COUNT V

PREMISES LIABILITY—

DEFENDANT HABD


herein.

44. Defendant HABD had a duty to inspect, warn, and/or make safe any dangerous

conditions on the Marks Village Apartments premises.

45. Defendant HABD breached that duty by failing to investigate, inspect, warn or make safe

the dangerous conditions.

46. Defendant HABD’s breach of its duties combined and concurred with other wrongful




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COUNT VI


FICTITIOUS DEFENDANTS A-D


herein.

48. Fictitious Defendants A, B, C, and D committed negligent and/or wanton acts which

caused or contributed to the explosion and events that caused the injuries to the Plaintiff.

49. Prior to the subject explosion on December 17, 2013, Fictitious Defendants A, B, C, and

D had superior knowledge of the dangers, defects, and hazards in and around the Marks

Village Apartments.

50. Despite its knowledge, Fictitious Defendants A, B, C, and D consciously and recklessly

disregarded the rights and safety of others, and negligently and wantonly breached a duty

of due care to Plaintiff in multiple respects.

51. Fictitious Defendants A, B, C, and D’s negligent and wanton conduct described herein

also breached a duty of care to Plaintiff by violation of local, state, and national laws,

regulations, ordinances, fire codes, industry standards, and/or safety codes. Plaintiff is

within the class of persons intended to be protected by said laws, regulations, ordinances,

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industry standards and/or safety codes, and is among the class of persons to whom such

duty ran. Plaintiff’s injuries are the type of harm intended to be prevented by such laws,


52. Fictitious Defendants A, B, C, and D’s negligent and wanton conduct described herein

combined and concurred with other wrongful conduct to proximately cause Plaintiff’s

injuries.









COUNT VII


FICTITIOUS DEFENDANTS E-H


herein.

54. Fictitious Defendants E, F, G, and H owned or were otherwise responsible for

maintaining or ensuring the safety of the property and/or any equipment in and around

the Marks Village Apartments in Birmingham, Alabama.

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55. Prior to the subject explosion on December 17, 2013, Fictitious Defendants E, F, G, and

H had superior knowledge of the dangers, defects, and hazards in and around the Marks

Village Apartments.

56. Despite its knowledge, Fictitious Defendants E, F, G, and H consciously and recklessly

disregarded the rights and safety of others, and negligently and wantonly breached a duty

of due care to Plaintiff in multiple respects, including, but not limited to, failing to

properly inspect, maintain, repair, and or warn regarding hazards within the Marks

Village Apartments.

57. Fictitious Defendants E, F, G, and H’s negligent and wanton conduct described herein







58. Fictitious Defendants E, F, G, and H’s negligent and wanton conduct described herein


injuries.






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COUNT VIII

AEMLD and NEGLIGENT DESIGN, MANUFACTURE, AND/OR WARNING--

FICTITIOUS DEFENDANTS I-L


herein.

60. Fictitious Defendants I, J, K, and L designed, manufactured, and/or sold equipment and

other products that caused or contributed to the injuries to the Plaintiff.

61. The subject equipment and related and component parts were without substantial change

in their condition from the time of their design, manufacture, and sale to the time of the

incident which is the subject of this action.

62. The subject equipment and/or its component and related parts were defective in that they

were unreasonably dangerous when put to their intended use as a result of defective

design, manufacturing defect and/or failure in warnings and instructions.

63. The defective condition of the subject equipment and/or its component and related parts

combined and concurred with the other wrongful conduct alleged herein to proximately

cause Plaintiff’s injuries; thus, Fictitious Defendants I, J, K, and L are liable to the

Plaintiff pursuant to the Alabama Extended Manufacturer’s Liability Doctrine.

64. Fictitious Defendants I, J, K, and L failed to exercise reasonable care to eliminate the

danger or otherwise prohibit Plaintiff from encountering the condition in their design,

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manufacture, and/or sale of the equipment, including but not limited to their failure to

issue adequate warnings regarding the equipment.

65. Fictitious Defendants I, J, K, and L’s breaches of duty combined and concurred with the

other wrongful conduct alleged herein to proximately cause Plaintiff’s injuries.









COUNT IX


FICTITIOUS DEFENDANTS M-P


herein.

67. Fictitious Defendants M, N, O, and P, by statute, agreement, contract, undertaking or

otherwise were responsible for the maintenance and/or safety of the natural gas

distribution lines and equipment in and around the Marks Village Apartments in

Birmingham, Alabama.

68. Prior to the subject explosion on December 17, 2013, Fictitious Defendants M, N, O, and

P had superior knowledge of the dangers, defects, hazards and/or risks associated with

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natural gas distribution lines and equipment in and around the Marks Village Apartments,

as well as hazards and/or risks associated with natural gas.

69. Prior to the subject explosion on December 17, 2013, Fictitious Defendants M, N, O, and

P were aware of complaints regarding natural gas leaks in and around the Marks Village

Apartments.

70. Fictitious Defendants M, N, O, and P knew or should have known, before the date of the

incident that injured the Plaintiff, that this type of explosion could occur.

71. Despite their knowledge, Fictitious Defendants M, N, O, and P consciously and

recklessly disregarded the rights and safety of others, and negligently and wantonly

breached a duty of due care to Plaintiff in multiple respects, including, but not limited to,

failing to properly inspect, maintain, correct hazardous or dangerous conditions in, repair,

and/or replace the natural gas distribution lines and equipment in and around the Marks

Village Apartments.

72. Fictitious Defendants M, N, O, and P’s negligent and wanton conduct described herein







73. Fictitious Defendants M, N, O, and P’s negligent and wanton conduct described herein


injuries.

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COUNT X

FICTITIOUS DEFENDANTS Q-T


herein.

75. Fictitious Defendants Q, R, S, and T, as predecessors or successors in interest to the

named and fictitious defendants herein, are liable for the conduct of said defendants

described herein.







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PLAINTIFF DEMANDS A TRIAL BY STRUCK JURY ON ALL ISSUES.

Respectfully submitted,

/s/ Glenda G. Cochran

Glenda G. Cochran (ASB-5150-C66G)

COCHRAN & ASSOCIATES

310 Richard Arrington Jr. Blvd. North, Suite 500

Birmingham, Alabama 35203

Telephone: (205) 328-5050

Facsimile: (205) 320-1659

E-mail: [email protected]

Attorney for Plaintiff

Please serve the Defendants via certified mail at the following addresses:

Alabama Gas Corporation

c/o David J. Woodruff

605 Richard Arrington Jr. Blvd. North

Birmingham, AL 35203-2707

Housing Authority of the Birmingham District

c/o Naomi H. Truman

1826 3rd

Avenue South

Birmingham, AL 35255

mailto:[email protected]

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