Complaint Essay

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IN THE SUPERIOR COURT OF ATHENS- CLARKE COUNTY STATE OF GEORGIA Carl Ameche (individually & guardian), Zoe Ameche (individually & guardian), And Zachary Ameche, ) (A minor by his parents and guardians) Plaintiffs, ) ) ) v. ) CIVIL ACTION FILE NO. 015496893 ) ) Margie Congden and ) Leroy Congden d/b/a ) Maple Meadows Campground ) Defendants. ) Plaintiff Demand Trial by Jury. COMPLAINT FOR NEGELIGENCE Plaintiff alleges that: 1. Plaintiff Carl Ameche resides at 2222 2nd St. Thorp, Ohio 10000, Meade County. 2. Plaintiff Zoe Ameche is the wife of Carl Ameche. Zachery Ameche is the minor child of Zoe and Carl Ameche. Both Zoe and Zachery reside with Plaintiff Carl Ameche. 3. Defendants Margie and Leroy Congden are the owners of Maple Meadows Campground. The campground is located at 810 HWY 29 N Athens, Ga. 30601. 4. On August 21, 2009, the plaintiff did begin a two week vacation at Maple Meadows Campground on campsite 36. 5. On the plaintiff’s campsite there was a black electrical cord that was worn and broken in several spots. It was allegedly placed there by the owners of the campground. 6. As a consequence of the defendant’s negligence action to pace the cord there, a fire was started surrounding the plaintiff’s son, Zachery. Plaintiff Carl sustained injury in order to rescue his son Zachery. 7. As a result of the negligent act, Plaintiff Carl received severe burns to his face, hands, and legs that has caused him great pain, suffering, permanent scarring, and physical disability. 8. Because of this action Plaintiff Carl has accumulated expensive hospital bills and

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