National Coalition For School Bus Safety
National Coalition For School Bus Safety
 

THE LIABILITY ASPECT

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WASHTENAW

DOUGLAS STOTLAR, as Personal Representative of the Estate of Lauren Stotlar, deceased, Plaintiff,

v.

Case No. 00- 

 -NO   

JANICE MAE MCCULLOUGH,
HEATHER DENISE ARMBRUSTER,
and DEXTER COMMUNITY SCHOOL DISTRICT,
Defendants.

George A. Googasian  (P14185)
Thomas H. Howlett  (P57346)
The Googasian Firm, P.C.
Attorneys for Plaintiff
6895 Telegraph Road
Bloomfield Hills, Michigan 48301-3138
248/540-3333

                                        COMPLAINT AND JURY DEMAND

 There is no other pending or resolved civil action arising out of the transaction or occurrence alleged in the complaint.

 Plaintiff, Douglas Stotlar, as personal representative of the Estate of Lauren Stotlar and by and through his attorneys The Googasian Firm, P.C., alleges as follows:

                                                               Nature of Action

1.            This is a wrongful death action brought on behalf of the Estate of Lauren Stotlar pursuant to MCLA 600.2922(1).  Lauren Stotlar, at the tender age of six, was killed on March 21, 2000 when she was run over by a Dexter Community Schools District school bus in front of her home in Webster Township in Washtenaw County, Michigan.

                                                                       Parties

2.            Plaintiff is the duly appointed personal representative of the Estate of Lauren Stotlar in a pending probate action, styled In the Matter of Lauren Stotlar, Deceased, File No. 00-595-DE, in Washtenaw County Probate Court.

3.            Defendant Janice Mae McCullough (“McCullough”) is, upon information and belief, a resident of Washtenaw County, Michigan, and she currently is employed in the Village of Dexter in Washtenaw County as the Director of Transportation for Dexter Community Schools.

4.            Defendant Heather Denise Armbruster (“Armbruster”) is, upon information and belief, a resident of Washtenaw County, Michigan, and she currently is employed in the Village of Dexter in Washtenaw County as a bus driver for Dexter Community Schools.

5.            Defendant Dexter Community School District (“Dexter Community Schools”) is a governmental entity organized and existing in accordance with Michigan law and based in the village of Dexter in Washtenaw County, Michigan.  Its principal place of business is 7714 Ann Arbor Street, Dexter, Michigan, 48130.

                                                          Jurisdiction and Venue

6.            The wrongful death giving rise to this action occurred on Cedar Hills Drive in Webster Township, Washtenaw County, Michigan.

7.            This Court has jurisdiction over this wrongful death action pursuant to Mich. Const. Art. 6, § 13 and MCLA 600.605.  Venue is proper under MCLA 600.1629.

8.            The amount in controversy exceeds $25,000, exclusive of costs, interest and attorney fees.

                          Janice McCullough’s Tenure with Dexter Community Schools

9.            Dexter Community Schools has employed McCullough for more than 22 years.

10.        From approximately 1977 to 1988, McCullough worked for Dexter Community Schools as a bus driver.

11.        Since at least 1989, McCullough has served in the supervisory position of Transportation Director (also known as Transportation Supervisor) of Dexter Community Schools.

In this capacity, McCullough has had supervisory responsibility for the transportation department of Dexter Community Schools, including oversight of its bus drivers, bus routes and bus safety.

12.        During her tenure as Transportation Director, McCullough’s salary has steadily increased, nearly doubling from about $25,000 to more than $49,000.

13.        Throughout her tenure as Transportation Director, McCullough has reported directly to Ross Stephenson, who is Dexter Community Schools’ Deputy Superintendent.  Stephenson, in turn, reports directly to Bill Spargur, Superintendent of Dexter Community Schools.

14.        According to her written job description, McCullough, as Transportation Director, “plans, directs and coordinates activities of the Transportation Department to provide students with efficient and safe transportation” through a series of duties performed by McCullough personally or through her staff.

15.        McCullough’s job duties include processing complaints and initiating corrective action; completing performance appraisals on bus drivers and other transportation staff; and carrying the personnel responsibilities for hiring and firing of all transportation employees, including bus drivers.

16.        In her position as Transportation Director, McCullough has been directly responsible for Dexter Community Schools’ hiring, evaluation and retention of Armbruster as a bus driver at all times relevant to this action.

                                Hiring of Heather Armbruster as a School Bus Driver

17.        On or about August 26, 1996, McCullough, acting on behalf of Dexter Community Schools, hired Armbruster as a Dexter Community Schools bus driver at the age of 21.

18.        Prior to her hiring as a school bus driver for Dexter Community Schools, Armbruster had caused an accident in Dexter Township.  On August 31, 1994, at the age of 19, Armbruster was cited for failing to yield when making a left turn onto Newman Road while driving south on Baker Road, thereby causing an oncoming northbound driver on Baker Road to swerve and strike another car.

19.        Prior to her hiring as a school bus driver for Dexter Community Schools, Armbruster also had been cited at least once for speeding and at least once for lack of vehicle registration.  In 1993, Armbruster received a ticket for driving 10 miles over the speed limit in Livingston County at the age of 18.  In 1995, Armbruster received a ticket for lack of proof of registration in Washtenaw County at the age of 20.

                                 Armbruster’s Repeated Misconduct as a Bus Driver                                                     and McCullough’s Notice of It

20.        From the Fall of 1996 to the months preceding the death of Lauren Stotlar on March 21, 2000, upon information and belief, Armbruster engaged in numerous illegal and improper activities while operating a Dexter Community Schools bus, all of which McCullough had notice, including, but not limited to the following:

                      a. repeatedly driving in excess of speed limits;

b. repeatedly engaging in erratic and dangerous driving practices, including skidding to stops and screeching away from stops;

c. repeatedly engaging in inappropriate behavior on the bus, including speaking abusively and profanely to schoolchildren;

d. repeatedly failing to perform and record required pre-trip inspections on her bus;

e. operating a personal stereo music box while on bus routes;

                      f. striking at least one car with a school bus;

                      g. driving into a ditch with a school bus on at least two separate occasions requiring evacuation of schoolchildren; and

h. hitting curbs and mailboxes.

21.        Throughout Armbruster’s tenure as a Dexter Community Schools bus driver, concerned parents and other persons made repeated complaints to McCullough and the Dexter Community Schools Transportation Department regarding Armbruster’s illegal and improper driving activities, specifically including numerous calls to and meetings with McCullough during every school year in which Armbruster has been employed.

22.        Notwithstanding Armbruster’s illegal and improper activities and McCullough’s notice of such activities, Armbruster was not fired, suspended, issued any formal written warnings or otherwise disciplined in any manner by McCullough or Dexter Community Schools at any time prior to March 21, 2000, when Lauren Stotlar was killed.

                             Armbruster’s Misconduct During the 1996-97 School Year                                                     and McCullough’s Notice of It

23.        During the 1996-97 school year at Dexter Community Schools, Armbruster repeatedly drove her bus in excess of speed limits and in a dangerous and illegal manner.

24.        Less than two months after commencing her first route as a bus driver for Dexter Community Schools, numerous parents and others along the route complained to Armbruster, McCullough and the Transportation Department regarding Armbruster’s driving, specifically including complaints about Armbruster driving too fast, arriving at and departing from bus stops in a dangerous manner and engaging in inappropriate behavior.

25.        In the Fall of 1997, Armbruster’s driving was the subject of a special meeting attended by parents, Armbruster, McCullough, and Deputy Superintendent Ross Stephenson, among others.

26.        During the 1996-97 school year, Armbruster drove her bus into a ditch, requiring evacuation of schoolchildren.

27.        Following a series of complaints regarding Armbruster from parents along the first route to which she was assigned, McCullough transferred Armbruster to a different route within the Dexter Community School District in February 1997.

28.        During the first month of Armbruster’s transfer to the second route, numerous parents and others along the route complained to Armbruster, McCullough and the Transportation Department regarding Armbruster’s driving, specifically including complaints about Armbruster driving too fast, arriving at and departing from bus stops in a dangerous manner and engaging inappropriate behavior.

29.        Notwithstanding numerous complaints about Armbruster received during the 1996-97 school year, McCullough did not attempt to remove Armbruster from her position as a school bus driver or take any adverse employment action against her.

                             Armbruster’s Misconduct During the 1997-98 School Year                                                     and McCullough’s Notice of It

30.        During the 1997-98 school year at Dexter Community Schools, Armbruster repeatedly drove her bus in excess of speed limits and in a dangerous and illegal manner.

31.        Following a series of complaints regarding Armbruster from parents along the second route to which she was assigned during the 1996-97 school year, McCullough transferred Armbruster to a different route within the Dexter Community School District at the beginning of the 1997-98 school year.

32.        After Armbruster’s transfer to her third route within the span of one year, numerous parents and others along the third route complained to Armbruster, McCullough and the Transportation Department regarding Armbruster’s driving, specifically including complaints about Armbruster driving too fast, arriving at and departing from bus stops in a dangerous manner and engaging in inappropriate behavior.

33.        Notwithstanding numerous complaints about Armbruster received during the 1997-98 school year, McCullough did not attempt to remove Armbruster from her position as a school bus driver or take any adverse employment action against her.

                             Armbruster’s Misconduct During the 1998-99 School Year                                                     and McCullough’s Notice of It

34.        Prior to the commencement of the 1998-99 school year, one or more parents met with McCullough to discuss concerns about Armbruster’s driving, specifically including complaints about Armbruster driving too fast and arriving at and departing from bus stops in a dangerous manner.  Notwithstanding the continued receipt of complaints about Armbruster’s driving, McCullough did not attempt to remove Armbruster from her position as a school bus driver or take any adverse employment action against her

35.        During the 1998-99 school year, Armbruster repeatedly drove her bus in excess of speed limits and in a dangerous and illegal manner.

36.        During the Fall of 1998, numerous parents and others again complained to Armbruster, McCullough and the Transportation Department regarding Armbruster’s driving, specifically including complaints about Armbruster driving too fast, arriving at and departing from bus stops in a dangerous manner and engaging in inappropriate behavior.

37.        In the Fall of 1998, Armbruster’s driving was a subject of a special meeting attended by parents, Armbruster, McCullough, and Deputy Superintendent Ross Stephenson, among others.

38.        During the 1998-99 school year, Armbruster drove her bus into a ditch on Chamberlin Road on a clear day without inclement weather, requiring the evacuation of schoolchildren.

39.        On or about April 22, 1999, Armbruster backed her school bus into a car stopped behind her at the intersection of Dan Hoey Road and Baker Road in Dexter.

40.        In at least one instance during the 1998-99 school year, McCullough instructed another bus driver to take over a segment of Armbruster’s route following a complaint regarding Armbruster from a parent along that segment of Armbruster route.   McCullough did not otherwise remove Armbruster from the route she had been driving.

41.        Notwithstanding numerous complaints about Armbruster received during the 1998-99 school year and at least two incidents in which Armbruster’s bus was involved in an accident, McCullough did not attempt to remove Armbruster from her position as a school bus driver or take any adverse employment action against her.

                           Armbruster’s Misconduct During the 1999-2000 School Year                                                     and McCullough’s Notice of It

42.        During the 1999-2000 school year, numerous parents and others again complained to Armbruster, McCullough and the Transportation Department regarding Armbruster’s driving, specifically including complaints about Armbruster driving too fast, arriving at and departing from bus stops in a dangerous manner and engaging in inappropriate behavior.

43.        In the late Fall of 1999, following the resignation of another bus driver, McCullough expanded Armbruster’s bus route to include the Cedar Hills subdivision off of Mast Road, where a number of schoolchildren resided, including Lauren Stotlar.

44.        During the few short months in which Armbruster’s route included Lauren Stotlar’s neighborhood, McCullough received additional complaints regarding Armbruster’s driving, specifically including one parent who complained that Armbruster was driving “way too fast” into a bus stop and exceeding the speed limit on Mast Road.

45.        Notwithstanding the series of complaints about Armbruster received from the commencement of her job as a bus driver in the Fall of 1996 up to and including the months preceding Lauren Stotlar’s death, McCullough did not attempt to remove Armbruster from her position as a school bus driver or take any adverse employment action against her.

                                                     The Death of Lauren Stotlar

46.        On March 21, 2000, Armbruster drove Lauren Stotlar and other schoolchildren on Dexter School Bus #1 into the Cedar Hills subdivision off of Mast Road in Webster Township.

47.        At all relevant times, Dexter School Bus #1, bearing Michigan registration number 460X31 and Vehicle Identification Number 1HVBBAAP9VH479381, was owned and operated by Dexter Community Schools and driven by Armbruster, an employee of Dexter Community Schools, with the express consent of Dexter Community Schools.

48.        On March 21, 2000, Armbruster stopped the bus in front of Lauren Stotlar’s home on Cedar Hills Drive.

49.        On March 21, 2000, Lauren Stotlar exited the bus and proceeded to cross Cedar Hills Drive in front of the bus, as required by state law and as she had been instructed to do.  Section 55(3) of Michigan’s Pupil Transportation Act, Public Act No. 187, states that school bus “[p]assengers crossing the road upon being discharged from a school bus shall cross in front of the stopped school bus.”  MCL 257.1855(3).

50.        Before Lauren Stotlar had cleared the front of the bus on March 21, 2000, Armbruster suddenly accelerated the bus, fatally striking the little girl.

51.        Armbruster accelerated the bus on March 21, 2000 without waiting for Lauren Stotlar to cross the street safely, as she was legally required to do.

52.        Armbruster accelerated the bus on March 21, 2000, instead of placing the bus in neutral or park and applying the parking brake until Lauren Stotlar had crossed the street safely, as she was legally required to do.

53.        Armbruster continued to drive the bus approximately 30 feet along Cedar Hills Drive before stopping on March 21, 2000, according to the traffic crash report prepared by the Washtenaw County Sheriff Department.

54.        Armbruster was driven away from the scene of the accident on March 21, 2000 by another bus driver and employee of Dexter Community Schools.

                              McCullough’s Concealment of Armbruster’s Misconduct

55.        From 1996 to 2000, McCullough repeatedly and knowingly concealed and withheld information from the Deputy Superintendent, Superintendent and Board of Education of Dexter Community Schools regarding Armbruster’s misconduct, the numerous complaints received regarding Armbruster and Armbruster’s threat to the safety of schoolchildren.

56.        From 1996 to 2000, McCullough repeatedly failed to act upon and ignored evidence of Armbruster’s misconduct as a bus driver, the numerous complaints received regarding Armbruster and Armbruster’s threat to the safety of schoolchildren.

57.        From 1996 to 2000, McCullough repeatedly failed to preserve information regarding Armbruster’s misconduct, the numerous complaints received regarding Armbruster and Armbruster’s threat to the safety of schoolchildren.

58.        As a result of McCullough’s concealment of information and failure to act upon and preserve information regarding Armbruster, the Dexter Community Schools’ Superintendent and Board of Education were not provided with information regarding Armbruster necessary to discharge their duties with respect to Armbruster.

59.        Dexter Community Schools Policy No. 1312 provides in relevant part that: “The Superintendent shall keep a file of all written citizen complaints and actions taken to address them.  The Superintendent shall make available to the Board of Education an annual report detailing the kind and number of complaints received and the actions taken to resolve them.”

                                                                     COUNT I

                                            (Gross Negligence against McCullough)

60.        Plaintiff repeats and realleges paragraphs 1 through 59 as if fully set forth herein.

61.        At all relevant times, McCullough acted or believed she was acting within the scope of her authority as Transportation Director for Dexter Community Schools.

62.        At all relevant times, McCullough was engaged in the exercise or discharge of a governmental function, namely the provision of transportation services to students in the Dexter Community School District.

63.        At all relevant times, McCullough’s acts and omissions with respect to Armbruster’s misconduct as a bus driver, the numerous complaints received regarding Armbruster and Armbruster’s threat to the safety of schoolchildren prior to the death of Lauren Stotlar constituted gross negligence.  McCullough’s acts and omissions constitute conduct so reckless as to demonstrate a substantial lack of concern for whether injury would result from Armbruster’s continued transportation of schoolchildren.

64.        As a direct and proximate result of McCullough’s gross negligence, Lauren Stotlar died from injuries sustained when she was struck on March 21, 2000 by the front of the school bus driven by Armbruster.

65.        Plaintiff, on behalf of the estate and all individuals entitled to damages under MCLA 600.2922, requests all damages that are fair and just under the circumstances, including, without limitation, the following: reasonable funeral and burial expenses; reasonable compensation for the pain and suffering Lauren Stotlar experienced as a result of her injuries prior to her death; and losses suffered by Lauren Stotlar’s surviving family members as a result of her death, including, but not limited to, loss of society and companionship and other miscellaneous losses.

                                                                    COUNT II

                                (Willful and Wanton Misconduct against McCullough)

66.        Plaintiff repeats and realleges paragraphs 1 through 65 as if set forth below.

67.        Prior to the death of Lauren Stotlar, McCullough had actual or constructive notice of problems regarding Armbruster’s driving of a school bus that required the exercise of ordinary care and diligence to avert future injury to schoolchildren and other persons.

68.        Prior to the death of Lauren Stotlar, McCullough had the ability to avoid future harm to other persons from Armbruster’s driving by exercising ordinary care and diligence in the use of means available to her.

69.        Prior to the death of Lauren Stotlar, McCullough failed to use ordinary care and diligence to avert danger to others from Armbruster’s driving, when it was apparent that the result of such inaction was likely to prove disastrous.

70.        As a direct and proximate result of McCullough’s wanton and willful misconduct, Lauren Stotlar died from injuries sustained when she was struck on March 21, 2000 by the front of the school bus driven by Armbruster.

71.        Plaintiff, on behalf of the estate and all individuals entitled to damages under MCLA 600.2922, requests all damages that are fair and just under the circumstances, including, without limitation, the following: reasonable funeral and burial expenses; reasonable compensation for the pain and suffering Lauren Stotlar experienced as a result of her injuries prior to her death; and losses suffered by Lauren Stotlar’s surviving family members as a result of her death, including, but not limited to, loss of society and companionship and other miscellaneous losses.

                                                                   COUNT III

                                            (Gross Negligence against Armbruster)

72.        Plaintiff repeats and realleges paragraphs 1 through 71 as if fully set forth herein.

73.        At all relevant times, Armbruster acted or believed she was acting within the scope of her authority as a school bus driver for Dexter Community Schools.

74.        At all relevant times, Armbruster was engaged in the exercise or discharge of a governmental function, namely the provision of transportation services to students in the Dexter Community School District.

75.        At all relevant times, Armbruster’s acts and omissions with respect to her driving of a school bus constituted gross negligence in that it was conduct so reckless as to demonstrate a substantial lack of concern for whether injury would result from her continued transportation of schoolchildren.

76.        As a direct and proximate result of Armbruster’s gross negligence, Lauren Stotlar died from injuries sustained when she was struck on March 21, 2000 by the front of the school bus driven by Armbruster.

77.        Plaintiff, on behalf of the estate and all individuals entitled to damages under MCLA 600.2922, requests all damages that are fair and just under the circumstances, including, without limitation, the following: reasonable funeral and burial expenses; reasonable compensation for the pain and suffering Lauren Stotlar experienced as a result of her injuries prior to her death; and losses suffered by Lauren Stotlar’s surviving family members as a result of her death, including, but not limited to, loss of society and companionship and other miscellaneous losses.

                                                                   COUNT IV

                                 (Willful and Wanton Misconduct against Armbruster)

78.        Plaintiff repeats and realleges paragraphs 1 through 77 as if set forth below.

79.        Prior to the death of Lauren Stotlar, Armbruster had actual notice of problems regarding her driving of a school bus that required the exercise of ordinary care and diligence to avert future injury to schoolchildren and other persons.

80.        Prior to the death of Lauren Stotlar, Armbruster had the ability to avoid future harm to other persons from her driving by exercising ordinary care and diligence in the use of means available to her.

81.        Prior to the death of Lauren Stotlar, Armbruster failed to use ordinary care and diligence to avert danger to others from her driving, when it was apparent that the result of such inaction was likely to prove disastrous.

82.        As a direct and proximate result of Armbruster’s wanton and willful misconduct, Lauren Stotlar died from injuries sustained when she was struck on March 21, 2000 by the front of the school bus driven by Armbruster.

83.        Plaintiff, on behalf of the estate and all individuals entitled to damages under MCLA 600.2922, requests all damages that are fair and just under the circumstances, including, without limitation, the following: reasonable funeral and burial expenses; reasonable compensation for the pain and suffering Lauren Stotlar experienced as a result of her injuries prior to her death; and losses suffered by Lauren Stotlar’s surviving family members as a result of her death, including, but not limited to, loss of society and companionship and other miscellaneous losses.

                                                                    COUNT V

                                (Negligent Operation of a Government Owned Vehicle

                                               against Dexter Community Schools)

84.        Plaintiff repeats and realleges paragraphs 1 through 83 as if set forth below.

85.        Dexter Community Schools owned and operated the school bus driven by Armbruster on March 21, 2000 when she fatally struck Lauren Stotlar.

86.        When Armbruster fatally struck Lauren Stotlar on March 21, 2000, she was operating the school bus with the express consent and permission of Dexter Community Schools and was acting within the scope of her employment with Dexter Community Schools.

87.        Armbruster and Dexter Community Schools owed a duty to Lauren Stotlar, other schoolchildren, their parents and the general public to operate the school bus in a safe, prudent and reasonable manner and to comply with all state and other laws regarding its operation.

88.        Armbruster and Dexter Community Schools, by and through its agent/servant/employee Armbruster, breached the duty to Lauren Stotlar in one or more ways on March 21, 2000, including by:

                      a. Failing to operate a school bus in a safe, prudent, and reasonable manner;

                      b. Failing to operate a school bus in compliance with the motor vehicle codes of the State of Michigan and the rules of common law;

                      c. Failing to remain stopped at the bus stop until Lauren Stotlar was safely across the street, as required by law;

                      d. Failing to place the school bus in park or neutral and apply the parking brake until Lauren Stotlar was safely across the street, as required by law;

                      e. Driving a school bus in wilful and wanton disregard of the safety of persons, in violation of MCL 257.626;

                      f. Negligently and recklessly operating a school bus.

89.        As a direct and proximate result of the negligence of Dexter Community Schools and Armbruster, Lauren Stotlar died from injuries sustained when she was struck on March 21, 2000 by the front of the school bus driven by Armbruster.

90.        Dexter Community Schools is liable for Plaintiff’s damages under MCLA 691.1405.

91.        Plaintiff, on behalf of the estate and all individuals entitled to damages under MCLA 600.2922, requests all damages that are fair and just under the circumstances, including, without limitation, the following: reasonable funeral and burial expenses; reasonable compensation for the pain and suffering Lauren Stotlar experienced as a result of her injuries prior to her death; and losses suffered by Lauren Stotlar’s surviving family members as a result of her death, including, but not limited to, loss of society and companionship and other miscellaneous losses.

                                                                   COUNT VI

                              (Negligent Entrustment of a Government Owned Vehicle                                                against Dexter Community Schools)

           92 .      Plaintiff repeats and realleges paragraphs 1 through 91 as if set forth below.

           93 .      Dexter Community Schools owned and operated the school bus driven by Armbruster on March 21, 2000 when she fatally struck Lauren Stotlar.

           94 .      When Armbruster fatally struck Lauren Stotlar on March 21, 2000, she was operating the school bus with the express consent and permission of Dexter Community Schools and was acting within the scope of her employment with Dexter Community Schools.

           95 .      Dexter Community Schools owed a duty to Lauren Stotlar, other schoolchildren, their parents and the general public not to negligently allow its school bus to be driven by Armbruster without due care and caution and not to allow the vehicle to be operated in such a manner as to endanger the life of others and in violation of the motor vehicle codes of the State of Michigan and the rules of common law.

           96 .      Dexter Community Schools allowed its school bus to be entrusted to Armbruster with its express consent and knowledge.

           97 .      Contrary to the duties owed to Lauren Stotlar, Dexter Community Schools negligently breached these duties by allowing its vehicle to be operated by a person whom Dexter Community Schools knew or should have known would operate the vehicle in a careless, reckless, or incompetent manner, in violation of the motor vehicle codes of the State of Michigan and the rules of common law.

           98 .      As a direct and proximate result of Dexter Community Schools’s negligent entrustment of the school bus to Armbruster, Lauren Stotlar died from injuries sustained when she was struck on March 21, 2000 by the front of the school bus driven by Armbruster.

           99 .      Dexter Community Schools is liable for Plaintiff’s damages under MCLA 691.1405.

         100 .      Plaintiff, on behalf of the estate and all individuals entitled to damages under MCLA 600.2922, requests all damages that are fair and just under the circumstances, including, without limitation, the following: reasonable funeral and burial expenses; reasonable compensation for the pain and suffering Lauren Stotlar experienced as a result of her injuries prior to her death; and losses suffered by Lauren Stotlar’s surviving family members as a result of her death, including, but not limited to, loss of society and companionship and other miscellaneous losses.

PLAINTIFF REQUESTS that this Court award fair and just compensation in an amount exceeding $25,000, plus all interest, costs, and attorney fees allowable by law.

THE GOOGASIAN FIRM, P.C.

 

By___________________________________

George A. Googasian (P14185)

Thomas H. Howlett (P57346)

Attorneys for Plaintiff

6895 Telegraph Road

Bloomfield Hills, MI 48301-3138

248/540-3333

Dated:  June 19, 2000

 

JURY DEMAND

Plaintiff, Douglas Stotlar, as personal representative of the Estate of Lauren Stotlar and by and through his attorneys, The Googasian Firm, P.C., hereby demands a trial by jury in the above entitled cause.

THE GOOGASIAN FIRM, P.C.

By___________________________________

George A. Googasian (P14185)

Thomas H. Howlett (P57346)

Attorneys for Plaintiff

6895 Telegraph Road

Bloomfield Hills, MI 48301-3138

248/540-3333

Dated:  June 19, 2000

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