332 / 370 100% 1. Plaintiff is, and all times hereafter was, a citizen and resident of the Town of PLACID CITY, County of LONDON, State of Placid. 2. Plaintiff alleges upon information and belief that the defendant Great Goody Grocery Store, Inc., is, and at all times hereafter was, a corporation organized and existing un- der the laws of the State of Placid, licensed to do business, and in fact doing business, in the State of Placid and having a registered agent for the service of process by the name of Paula Purple, located at 2156 Alder Circle, Suite 12 B, Placid City, Placid, 27562. 3. Plaintiff alleges upon information and belief that the defendant Steve W. DOE is a citi- zen and resident of the County of London, State of Placid. Defendant Great Goody Grocery Store, Inc. (hereafter referred to as "Defendant Goody"), did, at the time of the incident complained of, own, maintain, and manage a retail establishment ("store") within the city limits of Placid City, Placid, and located at 123 Greengrocer's Lane, Placid City. 5. On May 12, 2005, plaintiff was a customer at the store located at 123 Greengrocer's Lane. 6. After making her purchases inside the store, plaintiff exited the premises and proceeded to her automobile, parked in the customer parking area in front of the store. 7. As plaintiff was loading her groceries into her car, she was attacked by defendant Steve W. Doe. 8. Plaintiff was dragged from her car, in full view of security cameras set atop light poles in the parking lot by Defendant Goody. 9. Security agents, employed by Defendant Goody, noted the abduction and contacted po- lice after witnessing the assault on the plaintiff. 309ous and that he had attempted to assault other customers. f. Defendant Goody breached its duty to plaintiff by failing to notify plaintiff that De- fendant Doe had a history of violence toward women. g. Defendant Goody did not prevent Defendant Doe from repeatedly returning to its premises and harassing its customers. 12. The negligence of Defendant Goody was a proximate cause of the injuries sustained by plaintiff and joined and concurred in the intentional acts of Defendant Doe bringing about the plaintiff's serious, painful, and permanent injuries and damages, all of which exceed the sum of Ten Thousand Dollars ($10,000.00), and which include, without limitation, the following: 1) bodily injury and resulting pain and suffering; 2) medical expenses, including the costs of therapy: 3) loss of earnings and earning capacity; 4) punitive damages as a result of the defendants" reckless and wanton conduct. WHEREFORE, the plaintiff prays the Court as follows: 1. That the plaintiff have and recover from the defendants, jointly and severally, a sum in excess of Ten Thousand Dollars ($10,000.00) for compensatory and punitive dam- ages as alleged above. 2. That the plaintiff have and recover the costs of this action. 3. For a trial by jury. 4. For such other and further relief as the Court may deem just and proper. This the 6th day of April, 2006. Rhonda Roe Attorney for Plaintiff 2121 Elm Lane Placid City, PL 06254 IN THE GENERAL COURT OF JUSTICE COUNTY OF LONDON STATE OF PLACID CIVIL ACTION FILE NO: 07-x-8974-6 Mary Alice Baker, ANSWER OF DEFENDANT335 / 370 100% pervisors, corporate personnel, private investigators, of histrance adjusters, skate men maine(s) and address(es), and state whether such investigation was reduced to writing. If said investigator obtained any signed statements or recorded statements, identify the person who gave the state- ment and attach to your Answers a copy of any said statement. Answer: If you know of the existence of any pictures, photographs, charts, diagrams, recorded images, videotapes, digital media, or objects relative to the attack on the Plaintiff on the day and time alleged in the Complaint, the Plaintiff's physical condition, or the scene of the occurrence, identify the substance of such recording and the present custodian of each such item. Answer: Please list all insurance agreements you have regarding the store location, the corporation or other policy that may, in any way, have any bearing on the occurrence, including the name of the insurance company, the name of the policy owner, the policy number, the type of cover- age, the amount of coverage (specifying its upper and lower limits), and the effective dates of said policy for the past five (5) years. (a) In answering this interrogatory, take into consideration all policies possibly affording coverage, including any excess or umbrella policies which might afford coverage to you; (b) if there is any questionable liability insurance coverage, state the basis for denying or questioning the coverage that might otherwise be afforded. Answer:Facts in baker Case IN THE GENERAL COURT OF JUSTICE COUNTY OF LONDON STATE OF PLACID CIVIL ACTION FILE NO: 07-x-8974-6 Mary Alice Baker, COMPLAINT CONTAINING Plaintiff JURY TRIAL DEMAND Great Goody Grocery Store, Inc. & Steve Doe Defendants Plaintiff, by and through his attorneys, complains of the defendants as follows: 1. Plaintiff is, and all times hereafter was, a citizen and resident of the Town of PLACID CITY, County of LONDON, State of Placid. 2. Plaintiff alleges upon information and belief that the defendant Great Goody Grocery Store, Inc., is, and at all times hereafter was, a corporation organized and existing un- der the laws of the State of Placid, licensed to do business, and in fact doing business, in the State of Placid and having a registered agent for the service of process by the name of Paula Purple, located at 2156 Alder Circle, Suite 12 B. Placid City, Placid, 27562. 3. Plaintiff alleges upon information and belief that the defendant Steve W. DOE is a citi- zen and resident of the County of London, State of Placid. 4. Defendant Great Goody Grocery Store, Inc. (hereafter referred to as "Defendant Goody") did, at the time of the incident complained of, own, maintain, and manage a retail establishment ("store") within the city limits of Placid City, Placid, and located at 123 Greengrocer's Lane, Placid City. 5. On May 12, 2005, plaintiff was a customer at the store located at 123 Greengrocer's