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IN THE STATE COURT OF FULTON COUNTY

STATE OF GEORGIA
Patrick Blake, individually as the surviving
Parent of Jerome Blake, deceased, and as the CIVIL ACTION
Administrator of the Estate of Jerome Blake, FILE NO.:
Plaintiff,
v.
Candler Warehouses, LLC, Eagle Eye
Protection, Inc, and John Does 1-10,
Defendants.
JURY TRIAL DEMANDED
COMPLAINT

COMES NOW Patrick Blake individually as the surviving parent of Jerome Blake,
deceased, and as the Administrator of the Estate of Jerome Blake, plaintiff, and makes and files
this complaint against defendants Candler Warehouses, LLC, Eagle Eye Protection, Inc., and
John Does 1-10 as follows:
PARTIES AND JURISDICTION
1.
Defendant Candler Warehouses, LLC is a domestic limited liability company and can be
served by process of service upon its registered agent, Margot E. Smith, 675 Metropolitan
Parkway #4000, Fulton, Atlanta, GA, 30310.
2.
Defendant Eagle Eye Protection, Inc. is a domestic profit corporation and can be served
by process of service upon its registered agent, Lacy E. Wright, III, 3330 Cumberland Bvld.,
Suite 500, Fulton, Atlanta, GA, 30339.
3.
Defendants John Does 1-10 are as yet unknown and unidentifiable but whose negligence
harmed Plaintiff. Defendants John Does 1-10 include managers, maintenance workers, and
security personnel. These persons will be served upon identification.
4.
Plaintiff Patrick Blake, individually and in his capacity as Administrator of Jerome
Blakes estate resides in Fulton County.
5.
Jurisdiction and venue are appropriate in this Court.
BACKGROUND
6.
Defendant Candler Warehouses, LLC owns, operates, and manages The Metropolitan, a
complex of residential and commercial spaces that spans over 38 acres.
7.
Defendant Eagle Eye Protection, Inc. was responsible for providing security and patrols
for the premises of The Metropolitan on and around April 20, 2016.
8.
On April 20, 2016, Jerome Blake, now deceased, was either a guest or an invitee upon the
premises of The Metropolitan. He was visiting at the request of and for the benefit of one of the
commercial tenants, a recording studio. While he was there, Mr. Blake was assaulted and killed
by gunmen.
9.
Ingress and egress to The Metropolitan is only possible by vehicle through two gates.
One of these entrances is regularly locked and chained closed, but the other entrance has a code
box, a closing gate, a security booth, and surveillance cameras. At least some of this equipment
failed to function on and before April 20, 2016.
NEGLIGENCE COUNTS
10.
Defendants, owners or occupiers of these premises, who by express or implied invitation

induce and lead invitees upon their premises, failed to exercise ordinary care in keeping these

premises and approaches safe.


11.

The Defendants failed to protect Jerome Blake from injury caused by the misconduct of

third persons.

12.

The Defendants breached their duty owed to Jerome Blake by their failure to exercise

ordinary care in keeping the premises and approaches safe:

(a) Defendants knew or should have known of prior, substantially similar criminal

activity.

(b) Defendants failed to warn of criminal hazards known to them.

(c) Defendants failed to guard Jerome Blake against injury from dangerous characters

since the Defendants had reason to anticipate criminal acts from prior experience

with substantially similar types of crimes.

(d) Defendants failed to adequately maintain or repair the limited access gate.

(e) Defendants failed to provide uniformed roaming security guards to patrol

randomly the common areas.

13.

As a result of the negligence of the Defendants, Jerome Blake suffered mortal injuries.

14.
Patrick Blake is the Administrator of the Estate of Jerome Blake, deceased, and is the
proper party to bring the claims for Jerome Blakes pre-death pain and suffering, his funeral
expenses and his medical expenses.
3.
Defendants are liable to plaintiff for the pre-death pain and suffering of Jerome Blake, his
funeral expenses and his medical expenses.
15.
Patrick Blake as surviving parent of Jerome Blake is the proper party to bring a claim for
the wrongful death of Jerome Blake.
16.
Defendant is liable to plaintiff for the full value of the life of Jerome Blake.
WHEREFORE, plaintiff prays that he have a trial on all issues and judgment against
defendant as follows:
(a) That plaintiff recover the full value of the life of the decedent;
(b) That plaintiff recover for the decedents pre-death mental and physical pain and
suffering, funeral expenses and medical expenses;
(c) That plaintiff recover such other and further relief as is just and proper;
(d) That all issues be tried before a jury.
This 30th day of January, 2017.
DURHAM LAW GROUP

By: /Stephen A. Shea/


STEPHEN A. SHEA
Georgia Bar No. 102908
Attorney for Plaintiff

Durham Law Group


191 Peachtree St. NE, Suite 2600
Atlanta, GA 30303
Fax: 404-419-7838
E-mail: SShea@DurhamLawGroupPC.com

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