Page
1
of
10
VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF VIRGINIA BEACHINENA TATEM, as Administrator of theEstate of MICHAEL MARMON KNOCKETT, deceased,Plaintiff,v. Case No.:THE CITY OF VIRGINIA BEACH, A municipal corporation,Serve: Mark D. Stiles, Esquire, City AttorneyCity of Virginia BeachCity Attorney¶s OfficeMunicipal Center, Bldg 1Virginia Beach, VA 23456 ANDHEATHER M. BOYD, as an employeeof the City of Virginia Beach, and individually,Serve: Mark D. Stiles, Esquire, City AttorneyCity of Virginia BeachCity Attorney¶s OfficeMunicipal Center, Bldg 1Virginia Beach, VA 23456 ANDJOHN DOE #1, as an employee of theCity of Virginia Beach, and individually, ANDJOHN DOE #2, as an employee of theCity of Virginia Beach, and individually,Defendants.
Page
2
of
10
COMPLAINT
Plaintiff, INENA TATEM, as Administrator of the Estate of MICHEAL MARMONKNOCKETT, deceased, moves for judgment against the defendants, CITY OFVRIGINIA BEACH (³VIRGINIA BEACH´), HEATHER M. BOYD (³BOYD´), JOHN DOE#1 (³DOE #1´), JOHN DOE #2 (³DOE #2´), pursuant to Sections 8.01-50 and 64.1-75 of the Code of Virginia, 1950, as amended, both jointly and severally, on the grounds andin the amount set forth as follows:1. Plaintiff qualified and was duly appointed administrator of the estate of Michael Marmon Knockett, deceased, by the Circuit Court Clerk of the City of Virginia Beach on the 29
th
day of July 2010.2. Plaintiff duly filed and served Notice of Claim pursuant to Virginia CodeSection 15.2-209, 1950, as amended, upon VIRGINIA BEACH on August 13,2010, as required by statute.3. VIRGINIA BEACH is a municipal corporation, who is responsible for theoperation and management of the Department of Public Works, to include thehiring, supervision, and training of its personnel, and the establishment of thepolicies and procedures under which the personnel perform their functions.VIRGINIA BEACH is vicariously liable for the conduct of its personnel whileacting in the scope of their employment.
Page
3
of
10
4. BOYD was a Virginia Beach Public Works employee, employed by VIRGINIABEACH and acting in the scope of her employment at all times during theevents described in this Complaint.5. DOE #1 was a Virginia Beach Public Works employee, employed byVIRGINIA BEACH and acting in the scope of his employment at all timesduring the events described in this Complaint.6. DOE #2 was a Virginia Beach Public Works employee, employed byVIRGINIA BEACH and acting in the scope of his employment at all timesduring the events described in this Complaint.7. Venue is proper pursuant to 8.01-262(4), 1950, as amended, where thecause of action arose.8. Defendants VIRGINIA BEACH, BOYD, DOE #1, and DOE #2 had a duty, atthe time of this incident complained of, to use reasonable care to conduct theoperation of beach waste disposal according to the laws of the City of VirginiaBeach and the Commonwealth of Virginia within the policies and proceduresestablished by the City of Virginia Beach.9. Defendant VIRGINIA BEACH had a duty, prior to and at the time of theincident complained of, to use reasonable care to properly hire, maintain andreview, and to terminate employees of VIRGINIA BEACH according to thelaws of the City of Virginia Beach and the Commonwealth of Virginia withinthe policies and procedures established by the City of Virginia Beach.
Search History:
Result 00 of 00
00 results for result for
p.
More From This User
Notes
Load more
