District Court, Denver County, Colorado1437 Bannock Street, Room 256Denver, CO 80202
COURT USE ONLY
Plaintiff:
ROBIN LOHRE
v. Defendant(s):
POSH MAIDS, LLC,MIRANDA PALLONE,and DOES 1-5, inclusive.Attorneys for Plaintiff:
Jay Wayne Swearingen, Reg. #4842Jennifer Reba Edwards, Reg. #38349The Animal Law Center, LLC4465 Kipling Street, Suite 108Wheat Ridge, CO 80033Phone Number: 303-322-4355Fax Number: 303-322-4354E-mail: jws@theanimallawcenter.com jre@theanimallawccenter.com Case No:Division:Courtroom:
COMPLAINT
COMES NOW, the Plaintiff, by and through her attorneys, The Animal Law Center, and for her Complaint against Defendants, states and alleges as follows:
I. GENERAL ALLEGATIONS
1.
At all times material hereto, Plaintiff Robin Lohre (hereinafter “Plaintiff”) was a resident of Colorado, County of Denver, residing at 2256 Franklin Street, Denver, CO 80205.
2.
At all times material hereto, Defendant Posh Maids, LLC (hereinafter “Posh Maids”) was acorporation incorporated in Colorado, County of Denver, with a principal place of business at1742 Champa Street, #3D, Denver, CO 80202 and a mailing address of P.O. Box 3216, Denver,CO 80201. According to the Colorado Secretary of State Business Division Website, Posh Maidshas held a delinquent status since May 1, 2010.
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3.
At all times material hereto, Defendant Miranda Pallone was the owner and Registered Agent of Posh Maids, LLC and was a resident of Colorado, County of Denver, with a Registered AgentStreet address of 1742 Champa Street, #3D, Denver, CO 80202 and a mailing address of P.O.Box 3216, Denver, CO 80201.
4.
At all times material hereto, Defendant Does were unknown agents and/or employees of PoshMaids, LLC.
5.
All of the events alleged herein occurred within the State of Colorado, and all the parties areresidents in the state of Colorado or operate a business in the State of Colorado.
6.
Venue is proper in the District Court for Denver County, as all acts complained of occurredherein, Plaintiff resides in Denver County, and Defendants operate a business in Denver County.
III. FACTUAL ALLEGATIONS
7.
Plaintiff hereby incorporates by reference as though fully set forth herein the allegationscontained in the General Allegations of the Complaint.
8.
Plaintiff was the owner of Ruthie, an 18-month-old dog of
mixed
breed.
9.
In 2011, Plaintiff engaged the services of Defendant Posh Maids after purchasing a “LivingSocial” coupon, which entitled her to three hours of housecleaning for $49.00. Plaintiff scheduled the housecleaning appointment for August 17, 2011.
10.
On August 17, 2011, Defendant Posh Maids arrived at Plaintiff’s house at approximately 10:00AM.
11.
Upon the arrival of Defendant Posh Maids, Plaintiff asked one of the maids, named “Tina,” if she could leave the dog Ruthie at the home while Plaintiff ran errands. “Tina” stated thatleaving Ruthie at the house would be fine.
12.
Plaintiff instructed “Tina” that if she needed to leave the house for any reason, she must only usethe back door because it was the only door to the house could be locked without a key. The back door was attached to a mudroom, which was enclosed by a second door that led to the kitchen.The presence of the second door prevented Ruthie from leaving the house.
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13.
On August 17, 2011, Plaintiff left the dog Ruthie in the care of Posh Maids.
14.
At 12:22 PM, Plaintiff received a phone call from Defendant Pallone advising her that thecleaners were finished. Plaintiff inquired as to the time frame for the cleaning because the“Living Social” coupon entitled her to three hours of cleaning. Defendant Pallone assuredPlaintiff that she received over three hours of cleaning, as additional staff had arrived at thehouse and assisted “Tina” in completing the work. The phone conversation ended without anyfurther discussion.
15.
Approximately 40 minutes later, Plaintiff and her six-year-old daughter arrived home to findtheir dog Ruthie lying dead under the dining room table.
16.
After about twenty minutes, as Plaintiff tried to overcome the shock and anguish of findingRuthie dead, Plaintiff called Defendant Posh Maids. Defendant Posh Maids informed Plaintiff that the maids had left Plaintiff’s house only five minutes prior, that the dog Ruthie had been hit by a car, and that when the maids left Plaintiff’s home, Ruthie was alive and was “whimpering alittle.”
17.
Defendant Posh Maids did not contact Plaintiff to advise her that something had happened to thedog Ruthie, nor did Defendant Posh Maids attempt to seek veterinary treatment for Ruthie if Ruthie had been hit by a car, as Defendant Posh Maids represented.
18.
Posh Maids states on their website that “You will be worry free with Posh Maids Home cleaningService because you can trust that your home is cleaned by our classy, professional staff that payvery close attention to detail.”
19.
Posh Maids states on their website that “we will take great care in being cautious with your possessions…”
20.
Plaintiff’s counsel sent Defendants a demand letter outlining Plaintiff’s position on September 14, 2010 asking for a response by September 23, 2010. To date, Defendants have notcommunicated with Plaintiff or Plaintiff’s counsel.
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