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Blackmon's Suit

Blackmon's Suit

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IN THE CIRCUIT COURT TWENTIETH JUDICIAL CIRCUIT ST.

CLAIR COUNTY, ILLINOIS TERRA JENKINS, ELMER SMITH, CARTESLIA MCGEE, HENRY CARPENTER, and WILLIE SPRATT, Plaintiffs,
) ) ) ) )

v.
BLACKMON'S, INC. d/b/a BLACKMON'S PLAZA, TRILL ENTERTAINMENT, INC., and VARNER RICHARDSON
"

) ) ) ) )
) ) ) )

d-O(~ Case No.:~-L-

(){)

'J ~

ST. CLAIR COTJNTY

FILED

JAN 1 9 2012

JR.
Defendants. ) COMPLAINT COUNT I (Terra Jenkins v. Blackmon's Inc. d/b/a Blackmon's Plaza - Dramshop Act) Comes now Plaintiff Terra Jenkins, by her attorneys, Crowder & Scoggins, Ltd., and for Count I of her Complaint against Defendant Blackmon's, Inc. d/b/a Blackmon's Plaza, states as follows: 1. 2. Plaintiff, Terra Jenkins, is a resident of the County of St. Clair, State of Illinois. Defendant, Blackmon's, Inc., is an Illinois corporation, which owns, operates, Plaza, located at 127

manages, does business as and is the' liquor licensee for Blackmon's

Collinsville Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members of the public.

1

3.

On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises. 4. On these dates, a rap concert was taking place at Blackmon's were performing, Plaza in which

several entertainers extremely intoxicated. 5. premises. 6.

and many patrons drank alcoholic liquor and became

At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

At approximately 4:00 a.m. on April 3, 2011, many patrons, because of their

intoxicated condition, broke out in a brawl, punching, striking, and otherwise battering each other causing a chaotic environment. resulting in serious injuries to Plaintiffs 7. Plaintiff was then and there stampeded by other patrons, back, left foot, and left ankle. actions causing its patrons'

As a direct and proximate result of Defendant's

intoxication, Plaintiff sustained serious and personal injuries. Plaintiff was and will be hindered and prevented from attending to her usual and customary affairs, duties and occupation, and has lost, and will continue to -lose, wages, profits, and the value of that time. Plaintiff has also

suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further spent and become liable, and will continue to spend and become liable for large sums of money for medical care and services attempting to heal and cure her mjunes. 8. Dramshop Act. This action is brought pursuant to 235 ILCS 5/6-21, commonly known as the

2

WHEREFORE, Plaintiff Terra Jenkins prays this Court enter judgment against Defendant Blackmon's Inc. d/b/a Blackmon's Plaza for the sum of Sixty One Thousand One Hundred Fifty One Dollars and 39/100 Cents ($61,151.39), for Plaintiffs costs of suit, for any additional

recoveries permitted under the Illinois Dramshop Act, and for such additional relief as this Court deems just and proper under the circumstances. COUNT II (Elmer Smith v. Blackmon's Inc. d/b/a Blackmon's Plaza-

Dramshop Act)

Comes now Plaintiff Elmer Smith, by his attorneys, Crowder & Scoggins, Ltd., and for Count II of his Complaint against Defendant Blackmon's Inc. d/b/a Blackmon's follows: 1. 2. Plaintiff, Elmer Smith, is a resident of the County of St. Clair, State of Illinois. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza located at 127 Collinsville liquor is sold to Plaza, states as

does business as and is the liquor licensee for Blackmon's

Avenue, in the City of East St. Louis, St. Clair County, Illinois, whereaIcoholic members of the public. 3.

On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises. 4. On these dates, a rap concert was taking place at Blackmon's Plaza in which

several entertainers were performing, extremely intoxicated. 5. premises.

and many patrons drank alcoholic liquor and became

At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

3

6.

At approximately 4:00 a.m. on April 3, 2011, many patrons, because of their

intoxicated condition, broke out in a brawl, punching, striking, and otherwise battering each other causing a chaotic environment. Plaintiff was then and there hit on the head with a stool,

resulting in serious injuries and seven to eight staples in his head. 7. As a direct and proximate result of Defendant's actions causing its patrons'

intoxication, Plaintiff sustained serious and personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also

suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further spent and become liable, and will continue to spend and become liable for large sums of money for medical care and services attempting to heal and cure his injuries. 8. Dramshop Act. WHEREFORE, Plaintiff Elmer Smith prays this Court enter judgment against Defendant Blackmon's Inc. d/b/a Blackmon's Plaza for the sum of Sixty One Thousand One Hundred Fifty One Dollars and 39/100 Cents ($61,151.39), for Plaintiffs costs of suit, for any additional This action is brought pursuant to 235 ILCS 5/6-21, commonly known as the

recoveries permitted under the Illinois Dramshop Act, and for such additional relief as this Court deems just and proper under the circumstances.

4

COUNT III (Carteslia McGee v. Blackmon's Inc. d/b/a Blackmon's Plaza - Dramshop Act) Comes now Plaintiff Carteslia McGee, by her attorneys, Crowder & Scoggins, Ltd., and for Count III of her Complaint against Defendant Blackmon's states as follows: 1. 2. Plaintiff, Carteslia McGee, is a resident of Madison County, State of Illinois. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza located at 127 Collinsville Inc. d/b/a Blackmon's Plaza,

does business as and is the liquor licensee for Blackmon's

Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members of the public. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises. 4. On these dates, a rap concert was taking place at Blackmon's Plaza in which

several entertainers were performing, and many patrons drank alcoholic liquor and became extremely intoxicated. 5. premises. 6. At approximately 4:00 a.m. on April 3, 2011, many patrons, because of their At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

intoxicated condition, broke out in a brawl, punching, striking, and otherwise battering each other causing a chaotic environment. Plaintiff was then and there stampeded by other patrons

trying to leave, punched in the head and also thrown down by security officers, all causing her senous mjunes. 5

7.

As a direct and proximate result of Defendant's

actions causmg its patrons'

intoxication, Plaintiff sustained serious and personal injuries. Plaintiff was and will be hindered and prevented from attending to her usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also

suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further spent and become liable, and will continue to spend and become liable for large sums of money for medical care and services attempting to heal and cure her injuries. 8. Dramshop Act. WHEREFORE, Defendant Blackmon's Plaintiff Carteslia McGee prays this Court enter judgment against This action is brought pursuant to 235 ILCS 5/6-21, commonly known as the

Inc. d/b/a Blackmon's Plaza for the sum of Sixty One Thousand One costs of suit, for any

Hundred Fifty One Dollars and 39/100 Cents ($61,151.39), for Plaintiff's

additional recoveries permitted under the Illinois Dramshop Act, and for such additional relief as this Court deems just and proper under the circumstances.

(Henry Carpenter v. Blackmon's Inc. d/b/a Blackmon's Plaza - Dramshop Act) Comes now Plaintiff Henry Carpenter, by his attorneys, Crowder & Scoggins, Ltd., and for Count IV of his Complaint against Defendant Blackmon's Inc. d/b/a Blaclanon's as follows: 1. Illinois. Plaintiff, Henry Carpenter,
IS

COUNT IV

Plaza, states

a resident of the County of St. Clair, State of

6

~y'

-,

2.

Defendant, Blackmon's

Inc., an Illinois corporation, owns, operates, manages,

does business as and is the liquor licensee for Blackmon's Plaza located at 127 Collinsville Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members of the public. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises. 4. On these dates, a rap concert was taking place at Blackmon's Plaza in which

several entertainers were performing, and many patrons drank alcoholic liquor and became extremely intoxicated. 5. premises. 6. At approximately 4:00 a.m. on April 3, 2011, many patrons, because of their At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

intoxicated condition, broke out in a brawl, punching, striking, and otherwise battering each other causing a chaotic environment. Plaintiff was then and there stampeded by other patrons _

trying to leave, resulting in serious injuries to his neck and right arm. 7. As a direct and proximate result of Defendant's actions causing its patrons'

intoxication, Plaintiff sustained serious and personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also

suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further spent and become liable, and will continue to spend and become

7

liable for large sums of money for medical care and services attempting to heal and cure his injuries. 8. Dramshop Act. WHEREFORE, Defendant Blackmon's Plaintiff Henry Carpenter prays this Court enter judgment Inc. d/b/a Blaclanon's against This action is brought pursuant to 235 ILCS 5/6-21, commonly known as the

Plaza for the sum of Sixty One Thousand One costs of suit, for any

Hundred Fifty One Dollars and 391100 Cents ($61,151.39), for Plaintiffs

additional recoveries permitted under the Illinois Dramshop Act, and for such additional relief as this Court deems just and proper under the circumstances. COUNT V (Willie Spratt v. Blaclanon's Inc. d/b/a Blaclanon's Plaza - Drarnshop Act) Comes now Plaintiff Willie Spratt, by his attorneys, Crowder & Scoggins, Ltd., and for Count V of his Complaint against Defendant Blaclanon's follows: 1. 2. Plaintiff, Willie Spratt, is a resident of St. Louis County, State of Missouri. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza located at 127 Collinsville Inc. d/b/a Blackmon's Plaza, states as

does business as and is the liquor licensee for Blackmon's

Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members of the public. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises.

8

4.

On these dates, a rap concert was taking place at Blackmon's

Plaza in which

several entertainers were performing, extremely intoxicated. 5. premises. 6.

and many patrons drank alcoholic liquor and became

At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

At approximately 4:00 a.m. on April 3, 2011, many patrons, because of their

intoxicated condition, broke out in a brawl, punching, striking, and otherwise battering each other causing a chaotic environment. Plaintiff was then and there stampeded by patrons trying to

leave, suffered a "blow to the head and was also attacked by security officers, all causing serious mjunes. 7. As a direct and proximate result of Defendant's actions causmg its patrons'

intoxication, Plaintiff sustained serious and personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also

suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further spent and become liable, and will continue to spend and become liable for large sums of money for medical care and services attempting to heal and cure his mjunes. 8. This action is brought pursuant to 235 ILCS 5/6-21, commonly known as the

Dramshop Act. WHEREFORE, Plaintiff Willie Spratt prays this Court enter judgment against Defendant Blackmon's Inc. d/b/a Blackmon's Plaza for the sum of Sixty One Thousand One Hundred Fifty

9

One Dollars and 391100 Cents ($61,151.39), for Plaintiffs

costs of suit, for any additional

recoveries permitted under the Illinois Dramshop Act, and for such additional relief as this Court deems just and proper under the circumstances. COUNT VI Inc. d/b/a Blaclanon's Plaza - Premises Liability)

(Terra Jenkins v. Blaclanon's

Comes now Plaintiff Terra Jenkins, by her attorneys, Crowder & Scoggins, Ltd., and for Count VI of her Complaint against Defendant Blackmon's Inc. d/b/a Blackmon's follows: 1. 2. Plaintiff, Terra Jenkins, is a resident of the County of St. Clair, State of Illinois. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza located at 127 Collinsville Plaza, states as

does business as and is the liquor licensee for Blaclanon's

Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members of the public. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises, and provided security for a rap music event. 4. premises. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl, At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was stampeded by other patrons, resulting in serious injuries to Plaintiffs left foot, and left ankle. 10 back,

6.

At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition. for Plaintiff and other persons lawfully in and about Defendant's premises and, further, not to create or allow any dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises .. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant attacked failed to exercise reasonable by other patrons care to protect Plaintiff from being when these actions were

and security officers,

foreseeable and Defendant knew or should have: known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that she might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of its premises.

11

9.

As a direct and proximate result of Defendant's

negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to her usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure her injuries. WHEREFORE, Plaintiff Terra Jenkins prays this COUli award judgment against

Defendant Blackmon's Inc. d/b/a Blackmon's Plaza for compensatory damages in excess of Fifty Thousand Dollars and 00/100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such

additional relief as this Court deems just and proper under the circumstances. COUNTvrr (Elmer Smith v. Blackmon's Inc. d/b/a Blackmon's Plaza - Premises Liability) Comes now Plaintiff Elmer Smith, by his attorneys, Crowder & Scoggins, Ltd., and for Count VII of his Complaint against Defendant Blackmon's Inc. d/b/a Blackmon's Plaza, states as follows: 1. 2. Plaintiff, Elmer Smith, is a resident of the County of St. Clair, State of Illinois. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza located at 127 Collinsville

does business as and is the liquor licensee for Blackmon's

Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members ofthe public.

12

3.

On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises, and provided security for a rap music event. 4. premises. 5. At approximately 4:00 a.m. on April 3,2011, many patrons broke out in a brawl, At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was hit on the head with a stool, resulting in serious injuries and seven to eight staples in his head. 6: At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Defendant's premises and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions:

13

(a)

Defendant attacked

failed to exercise reasonable by other patrons and security

care to protect Plaintiff from being officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of its premises. 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Plaintiff Elmer Smith prays this Court award judgment against

Defendant Blackmon's Inc. d/b/a Blackmon's Plaza for compensatory damages in excess of Fifty Thousand Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such

additional relief as this Court deems just and proper under the circumstances.

14

COUNT VIII (Carteslia McGee v. Blackmon's Inc. d/b/a Blackmon's Plaza - Premises Liability) Comes now Plaintiff Carteslia McGee, by her attorneys, Crowder & Scoggins, Ltd., and for Count VIII of her Complaint against Defendant Blackmon's Inc. d/b/a Blackmon's states as follows: 1. 2. Plaintiff, Carteslia McGee, is a resident of Madison County, State of Illinois. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza,

does business as and is the liquor licensee for Blackmon's Plaza located at 127 Collinsville Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members of the public. 3. employees On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and acting within the scope of their duties, sold alcoholic liquor to many patrons, all

invitees on Defendant's premises, and provided security for a rap music event. 4. premises. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl, At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's exiting. security officers chained the exit doors, preventing Plaintiff and other patrons from

Plaintiff was thrown down by security officers, suffered a blow to the head and was

stampeded by patrons trying to leave, all causing serious injuries. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other

15

persons lawfully in and about Defendant's

premises and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant attacked failed to exercise reasonable by other patrons and security care to protect Plaintiff from being officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that she might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of its premises. 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to her usual and customary affairs, duties and occupation, and has lost, and will continue to lose,

16

wages, profits, and the value of that time.

Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure her injuries. WHEREFORE, Plaintiff Carteslia McGee prays this Court award judgment against

Defendant Blackmon's Inc. d/b/a Blackmon's Plaza for compensatory damages in excess of Fifty Thousand Dollars and 0011 00 Cents ($50,000.00) for Plaintiffs costs of suit, and for such

additional relief as this Court deems just and proper under the circumstances.

(Henry Carpenter v. Blackmon's Inc. d/b/a Blackmon's Plaza - Premises Liability) Comes now Plaintiff Henry Carpenter, by his attorneys, Crowder & Scoggins, Ltd., and for Count IX of his Complaint against Defendant Blackmon's Inc. d/b/a Blackmon's Plaza, states as follows: 1. Illinois. 2. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza located at 127 Collinsville Plaintiff, Henry Carpenter,
IS

COUNT IX

a resident of the County of St. Clair, State of

does business as and is the liquor licensee for Blackmon's

Avenue, in the City of East St. Louis, St.. Clair County, Illinois, where alcoholic liquor is sold to members of the public. 3. Oil April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises, and provided security for a rap music event.

17

4. premises. 5.

At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

At approximately 4:00 a.m. on April 3,2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was stampeded by other patrons trying to leave, resulting in serious injuries to his neck and right ann. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Defendant's premises and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons care to protect Plaintiff from being were

and security officers, when these actions

foreseeable and Defendant knew or should have known of the existing danger;

18

(b)

Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; . (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of its premises. 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his .usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, a.nd the value of that time. Plaintiff has also suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Plaintiff Henry Carpenter prays this Court award judgment against

Defendant Blackmon's Inc. d/b/a Blackmon's Plaza for compensatory damages in excess of Fifty Thousand Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit,. and for such

additional relief as this Court deems just and proper under the circumstances.

19

COUNT X (Willie Spratt v. Blackmon's Inc. d/b/a Blackmon's Plaza - Premises Liability) Comes now Plaintiff Willie Spratt, by his attorneys, Crowder & Scoggins, Ltd., and for Count X of his Complaint against Defendant Blackmon's Inc. d/b/a Blackmon's Plaza, states as follows: 1. 2. Plaintiff, Willie Spratt, is a resident of St. Louis County, State of Missouri. Defendant, Blackmon's Inc., an Illinois corporation, owns, operates, manages, Plaza located at 127 Collinsville

does business as and is the liquor licensee for Blackmon's

Avenue, in the City of East St. Louis, St. Clair County, Illinois, where alcoholic liquor is sold to members of the public. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and

employees acting within the scope of their duties, sold alcoholic liquor to many patrons, all invitees on Defendant's premises, and provided security for a rap music event. 4. premises. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl, At all times relevant to this Complaint, Plaintiff was an invitee on Defendant's

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was attacked by security officers, suffered a head injury and was stampeded by patrons trying to leave, all causing serious injuries. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other

20

persons lawfully in and about Defendant's

premises and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant attacked failed to exercise reasonable by other patrons and security care to protect Plaintiff from being officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of its premises. 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose,

21

wages, profits, and the value of that time.

Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Plaintiff Willie Spratt prays this Court award judgment against

Defendant Black ... men's Inc. d/b/a Blackmon's Plaza for compensatory damages in excess of Fifty Thousand Dollars and 00/100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such

additional relief as this Court deems just and proper under the circumstances. COUNT XI (Terra Jenkins v. Trill Entertainment, Inc. - Premises Liability) Comes now Plaintiff Terra Jenkins, by her attorneys, Crowder & Scoggins, Ltd., and for Count XI of her Complaint against Defendant Trill Entertainment, Inc., states as follows: 1. 2. Plaintiff, Terra Jenkins , is a resident of the County of St. Clair, State of Illinois. Defendant, Trill Entertainment, Inc., is a dissolved Georgia corporation, which located at 718

operates as a record label that promotes and manages several rap musicians, Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. employees

On April 2, 2011 and April 3,2011, Defendant, through its members, agents, and acting within the scope of their duties, shared the possession and control of

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event.

22

5.

At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from

exiting. Plaintiff was stampeded by other patrons, resulting in serious injuries to Plaintiff s back, left foot, and left ankle. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons care to protect Plaintiff from being

and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that she might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger;

23

(c)

Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and

(d)

Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza.

9.

As a direct and proximate result of Defendant's

negligence, Plaintiff sustained

serious personal injuries.

Plaintiff was and will be hindered and prevented from attending to her

usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure her injuries. WHEREFORE, Plaintiff Terra Jenkins prays this Court award judgment against

Defendant Trill Entertainment,

Inc. for compensatory

damages in excess of Fifty Thousand

Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XII (Elmer Smith v. Trill Entertainment, Inc. - Premises Liability) Comes now Plaintiff Elmer Smith, by his attorneys, Crowder & Scoggins, Ltd., and for Count XII of his Complaint against Defendant Trill Entertainment, Inc., states as follows: 1. Plaintiff, Elmer Smith, is a resident of the County of St. Clair, State of Illinois.

24

2.

Defendant,

Trill Entertainment,

Inc., a dissolved Georgia corporation,

which

operates as a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. employees On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and acting within the scope of their duties, shared the possession and control of

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was hit on the head with a stool, resulting in serious injuries and seven to eight staples in his head. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises: 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises.

25

8.

At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant attacked failed to exercise reasonable by other patrons and security care to protect Plaintiff from being officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza. 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Plaintiff Elmer Smith prays this Court award judgment against

Defendant Trill Entertainment,

Inc. for compensatory

damages in excess of Fifty Thousand

26

Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XIII (Carteslia McGee v. Trill Entertainment, Inc. - Premises Liability) Comes now Plaintiff Carteslia McGee, by her attorneys, Crowder & Scoggins, Ltd., and for Count XIII of her Complaint against Defendant Trill Entertainment, Inc., states as follows: 1. 2. Plaintiff, Carteslia McGee is a resident of Madison County, State of Illinois. Defendant, Trill Entertainment, Inc., a dissolved Georgia corporation, which

operates as a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and and control of

employees acting within the scope of their duties, shared the possession

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was thrown down by security officers, suffered a blow to the head and was

stampeded by patrons trying to leave, all causing serious injuries. 6. At that time and place, Defendant had a duty, by and through its members, agents, safe condition for Plaintiff and other

and employees, to keep the premises in a reasonably 27

persons lawfully in and about Blackmon's

Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons and security care to protect Plaintiff from being officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that she might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza. 9. A$ a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to her usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages,

28

profits, and the value of that time. Plaintiff has also suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further spent and

become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure her injuries. WHEREFORE, Plaintiff Carteslia McGee prays this Court award judgment against

Defendant Trill Entertainment,

Inc., for compensatory damages in excess of Fifty Thousand

Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XIV (Henry Carpenter v. Trill Entertainment Inc. - Premises Liability) Comes now Plaintiff Henry Carpenter, by his attorneys, Crowder & Scoggins, Ltd., and for Count XIV of his Complaint against Defendant Trill Entertainment, Inc., states as follows: 1. Illinois. 2. Defendant, Trill Entertainment, Inc., a dissolved Georgia corporation, which Plaintiff, Henry Carpenter, is a resident of the County of S1. Clair, State of

operates as a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. employees On April 2, 2011 and April 3, 2011, Defendant,through its members, agents, and and control of

acting within the scope of their duties, shared the possession

Blackmon's Plaza, located in the City of East S1. Louis, S1. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event.

29

5.

At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from

exiting. Plaintiff was stampeded by other patrons trying to leave, resulting in serious injuries to his neck and right arm. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons care to protect Plaintiff from being

and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by' other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger;

30

(c)

Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and

(d)

Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza.

9.

As a direct and proximate result of Defendant's

negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Plaintiff Henry Carpenter prays this Court award judgment Inc. for compensatory against

Defendant Trill Entertainment,

damages in excess of Fifty Thousand

Dollars and 00/100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XV (Willie Spratt v. Trill Entertainment, Inc. - Premises Liability) Comes now Plaintiff Willie Spratt, by his attorneys, Crowder & 'Scoggins, Ltd., and for Count XV of his Complaint against Defendant Trill Entertainment, Inc., states as follows: 1. Plaintiff, Willie Spratt, is a resident of S1.Louis County, State of Missouri.

31

2.

Defendant, Trill Entertainment,

Inc., a dissolved Georgia corporation, which

operates as a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and and control of

employees acting within the scope of their duties, shared the possession

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was attacked by security officers, suffered a head injury and was stampeded by patrons trying to leave, all causing serious injuries. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew of several patrons

or, in the exercise of reasonable care, should have known that thousands

combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises.

32

8.

At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons and security care to protect Plaintiff from being officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries .. WHEREFORE, Plaintiff Willie Spratt prays Inc. for compensatory this Court award judgment against

Defendant Trill Entertainment,

damages in excess of Fifty Thousand

33

Dollars and 0011 00 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XVI (Terra Jenkins v. Varner Richardson Jr. - Premises Liability) Comes now Plaintiff Terra Jenkins, by her attorneys, Crowder & Scoggins, Ltd., and for Count XVI of her Complaint against Defendant Varner Richardson Jr. states as follows: 1. 2. Plaintiff, Terra Jenkins, is a resident of the County of St. Clair, State of Illinois. Defendant, Varner Richardson Jr., is the last known chief executive officer of

Trill Entertainment Inc., a dissolved Georgia corporation that is a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. employees On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and acting within the scope of their duties, shared the possession and control of

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which itpromoted, 4. advertised and provided security for the premises.

At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3,2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was stampeded by other patrons, resulting in serious injuries to Plaintiff s back, left foot, and left ankle.

34

6.

At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons care to protect Plaintiff from being when these actions were

and security officers,

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that she might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza.

35

9.

As a direct and proximate result of Defendant's

negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to her usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure her injuries. WHEREFORE, Plaintiff Terra Jenkins prays this Court award judgment against

Defendant Varner Richardson Jr. for compensatory damages in excess of Fifty Thousand Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XVII (Elmer Smith v. Varner Richardson Jr. - Premises Liability) Comes now Plaintiff Elmer Smith, by his attorneys, Crowder & Scoggins, Ltd., and for Count XVII of his Complaint against Defendant Varner Richardson Jr. states as follows: 1. 2. Plaintiff, Elmer Smith, is a resident of the County of St. Clair, State of Illinois. Defendant, Varner Richardson Jr., is the last known chief executive officer of

Trill Entertainment Inc., a dissolved Georgia corporation that is a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and and control of

employees acting within the scope of their duties, shared the possession

36

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was hit on the head with a stool, resulting in serious injuries and seven to eight staples in his head. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place; Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons care to protect Plaintiff from being

and security ,officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger;

37

(b)

Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza. 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Plaintiff Elmer Smith prays this Court award judgment against

Defendant Varner Richardson Jr. for compensatory damages in excess of Fifty Thousand Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XVIII (Catieslia McGee v. Varner Richardson Jr. - Premises Liability) Comes now Plaintiff Carteslia McGee, by her attorneys, Crowder & Scoggins, Ltd., and for Count XVIII of her Complaint against Defendant Varner Richardson Jr., states as follows: 38

1. 2.

Plaintiff, Carteslia McGee is a resident of Madison County, State of Illinois. Defendant, Varner Richardson Jr., is the last known chief executive officer of

Trill Entertainment Inc., a dissolved Georgia corporation that is a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. employees On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and acting within the scope of their duties, shared the possession and control of

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's exiting. security officers chained the exit doors, preventing Plaintiff and other patrons from

Plaintiff was thrown down by security officers, suffered a blow to the head and was

stampeded by patrons trying to leave, all causing serious injuries. 6. At that time and place, Defendant had a duty, by and through its members, agents, safe condition for Plaintiff and other

and employees, to keep the premises in a reasonably persons lawfully in and about Blackmon's

Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined

39

with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant failed to exercise reasonable attacked by other patrons care to protect Plaintiff from being when these actions were

and security officers,

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that she might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza. 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to her usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure her injuries.

40

WHEREFORE,

Plaintiff Carteslia McGee prays this Court award judgment

against

Defendant Varner Richardson Jr. for compensatory damages in excess of Fifty Thousand Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XIX (Henry Carpenter v. Varner Richardson Jr. - Premises Liability) Comes now Plaintiff Henry Carpenter, by his attorneys, Crowder & Scoggins, Ltd., and for Count XIX of his Complaint against Defendant Varner Richardson Jr. states as follows:
1.

Plaintiff, Henry Carpenter, is a resident of the County of St. Clair, State of

Illinois. 2. Defendant, Varner Richardson Jr., is the last known chief executive officer of

Trill Entertainment Inc., a dissolved Georgia corporation that is a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia. 3. On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and and control of

employees acting within the scope of their duties, shared the possession

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from 41

exiting. Plaintiff was stampeded by other patrons trying to leave, resulting in serious injuries to his neck and right arm. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew

or, in the exercise of reasonable care, should have known that thousands of patrons combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions: (a) Defendant attacked failed to exercrse reasonable care to protect Plaintiff from being by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and

42

(d)

Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza.

9.

As a direct and proximate result of Defendant's

negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and Plaintiff has further

anguish, in both mind and body, and will continue to suffer in the future.

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Plaintiff Henry Carpenter prays this Court award judgment against

Defendant Varner Richardson Jr. for compensatory damages in excess of Fifty Thousand Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances. COUNT XX (Willie Spratt v. Varner Richardson Jr. - Premises Liability) Comes now Plaintiff Willie Spratt, by his attorneys, Crowder & Scoggins, Ltd., and for Count XX of his Complaint against Defendant Varner Richardson Jr., states as follows: 1. 2. Plaintiff, Willie Spratt, is a resident of St. Louis County, State of Missouri. Defendant, Varner Richardson Jr., is the last known chief executive officer of

Trill Entertainment Inc., a dissolved Georgia corporation that is a record label that promotes and manages several rap musicians, located at 718 Hunter Ridge Drive, in the City of Jonesboro, Clayton County, Georgia.

43

3. employees

On April 2, 2011 and April 3, 2011, Defendant, through its members, agents, and acting within the scope of their duties, shared the possession and control of

Blackmon's Plaza, located in the City of East St. Louis, St. Clair County, Illinois for a rap music event in which it promoted, advertised and provided security for the premises. 4. At all times relevant to this Complaint, Plaintiff was an invitee at Blackmon's

Plaza, the location where Defendant was promoting a rap event. 5. At approximately 4:00 a.m. on April 3, 2011, many patrons broke out in a brawl,

punching, striking, and otherwise battering each other causing a chaotic environment, in which Defendant's security officers chained the exit doors, preventing Plaintiff and other patrons from exiting. Plaintiff was attacked by security officers, suffered a head injury and was stampeded by patrons trying to leave, all causing serious injuries. 6. At that time and place, Defendant had a duty, by and through its members, agents,

and employees, to keep the premises in a reasonably safe condition for Plaintiff and other persons lawfully in and about Blackmon's Plaza and, further, not to create or allow any

dangerous conditions to exist on or about the premises. 7. At that time and place, Defendant and its members, agents, and employees knew of several patrons

or, in the exercise of reasonable care, should have known that thousands

combined with an inadequate amount of security officers on the premises, were a threat to the safety of the persons on Defendant's premises. 8. At the time and place, Defendant became guilty of the following negligent acts,

failures, and omissions:

44

,

,.

(a)

Defendant attacked

failed to exercise reasonable care to protect Plaintiff from being by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (b) Defendant failed to exercise reasonable care to warn Plaintiff that he might be attacked by other patrons and security officers, when these actions were

foreseeable and Defendant knew or should have known of the existing danger; (c) Defendant failed to provide adequate security in order to protect Plaintiff from dangers known or dangers which should have been known to Defendant existing on the premises; and (d) Defendant was otherwise negligent in the maintenance, operation, and control of Blackmon's Plaza 9. As a direct and proximate result of Defendant's negligence, Plaintiff sustained

serious personal injuries. Plaintiff was and will be hindered and prevented from attending to his usual and customary affairs, duties and occupation, and has lost, and will continue to lose, wages, profits, and the value of that time. Plaintiff has also suffered a great deal of pain and anguish, in both mind and body, and will continue to suffer in the future. Plaintiff has further

spent and become liable, and will continue to spend and become liable, for large sums of money for medical care and services attempting to heal and cure his injuries. WHEREFORE, Defendant Plaintiff Willie Spratt prays this Court award judgment against

Vamer Richardson

Jr., for compensatory

damages in excess of Fifty Thousand

Dollars and 001100 Cents ($50,000.00) for Plaintiffs costs of suit, and for such additional relief as this Court deems just and proper under the circumstances.

45

S, LTD.

Mark C. Scoggins #02530384 Attorney for Plaintiff CROWDER & SCOGGINS, LTD. Attorneys at Law 121 West Legion Avenue P.O. Box 167 Columbia,· Illinois 62236 Telephone:618/281-7111

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