IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF INDIANAjp
BANKERS STANDARD INSURANCE
as subrogee of Jerry andNorma Ferguson,
COPLEN CONSTRUCTION, INC., ELITECONTRACTING SERVICES, INC.,TRADESMEN INTERNATIONAL, INC.,HEISLER CONSTRUCTION, LLC andDOMOTECK FLOOR WARMINGSYSTEMS, INC.,Defendants.
NOW COMES the
BANKERS STANDARD INSURANCE COMPANY assubrogee of
and Norma Ferguson, by and through its attorneys, COZEN O'CONNOR, andfor its Complaint against Defendants, Coplen Construction, Inc., Elite Contracting Services, Inc.,Tradesmen International, Inc., Heisler Construction, LLC and Domoteck Floor WarmingSystems, Inc., states as follows:
Bankers Standard Insurance Company ("Bankers"), is a Pennsylvaniacorporation duly licensed to do business in the State of Indiana with a principal place of businesslocated at 436 Walnut Street, P. O. Box 1000, Philadelphia, Pennsylvania 19105.
insured, Jerry and Norma Ferguson ("the Fergusons"), are residents ofthe State of Indiana and the owners of the real and personal property located at 5 Ems T-35 Lane,Leesburg, Indiana ("subject residence'*). At all times relevant and material hereto, Bankers had