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IN THE CIRCUIT COURT FOR RUTHERFORD COUNTY, TENNESSEE SCOTT WALKER on beat ofhiseesed) Soo, NOEL WAL, ; Revie an ; ttchalfefeminreh OLIVIA} WALKER, } vo, Stee . ; } SD RALPH BAXTER CONSTRUCTION 1, wl } we RALPH BAXTER, “ ; 3 Defendants ? i es COMPLAINT his stats tothe Cour: 1. Plainiff Scot Walker is a citizen and resident of Rutherford County, Tennessee. Soott Walkers the surviving spouse of lune Angela Walker, deceased 2 Scott and Angela Walker were the natural parents of Reed Walker and Olivia Walker 4 Defendant Ralph Baxter Constetion, LLC (Baxter Constution’) is limited. liability company organized under Tennesse la. 4. Defendant Ralph Baxter (*M. Bax" is an agent of Banter Construction 5. Ie 2017, Baxter Construction bil a residential home at 7812 Midland Road in ‘Ruther County, Tennesse. 6 Baxter Constrtion laid the foundation forthe home, 7. Baxter Construction built the Fame ofthe home. & A home needs anchor bolts embedded into the foundation 9. Anchor bolts are embedded into the foundation using concrete footings. 10, Anchor bots are there to ensure shame doesnot shift, move orhave an uplift with forces lke stong winds 11, Ifthe anchor bots are not properly embedded ito concrete footings, the home cannot safely withstand forees like song winds 12, Baxter Constrton didnot properly embed the hom’ anchor bolts ito conerate footings. 15, The Walker family moved into the home ia November 2017, 14, The Walker farily bad no reason o belive that Baxter Constuction constructed the home witout properly anchoring it 15, On thenight of November 6, 2018, tornado pasted bythe home. 16. Angela and Oliva Walker were inside the home 17, ‘The winds uplifted and completly flipped the home, 18, The eventkilled Angela Walker 19, If Baxter Constvction had properly embedded the home's anchor bolts into concrete footing, Angela Walker would have survived. 20, Olivia Walker sufered minor physical injures and was able to escape the upside down home. She was stinding outside the home when she frst leamed her mother was dead. Besides the rlatively minor physical injuries, Olivia Walker has suffered devastating emotional harm as result of her mother's death 21, Seott Walker was standing outside the home when he first leamed his wife was dead, Me. Waker suffered devastating emotional harm asa result of his wife's death 22, Baxter Consttion built th home without adequately securing the anchor bot 23. Baxter Construction built the home without securing the frameto the foundation. 28, Baxter Coosttion opened the home fora family to live in when the home was dangerous and unsafe 25. Oninformation and belie, Mr. Banter personally worked on the home on Midland Read, and was personally involved in each negligent act andor omission by Baxter Construction. 26, Defendants ets and omiasions were npligent 27. Defendants artful forthe deat of Angela Walker, the physical and emotional injies to Olivia Walker, an the emotional injuries to Scot Walker. 28. Angela Walker endured her home being lipped around her. 29. On infomation and belie, Angela Walker endured tevor, womying where her minor daughter wa in the home during the even 30. Angela Walker suffered taumatic injures because ofthe event Si. For the time period between the home fist uplifting from the foundation ui Angela Walker's death, Scott Walker seeks to recover for Angela Walker’s pun and suffering, emotional dares, and all ther damages allowed under Tennessee lw. 32, For the death of Angela Walker, Scot Walker seks to recover on behalf of Reed ‘Walker, Olivia Walker, nd himself for funeral bills andthe pecuniary value of the ie of Angela ‘Wolke, including ost earning capacity and the loss of love society, affection, and companionship “berween Angela Waker and her family. 33. On behalfof Olivia Walker, Scot Walker alo seaks to recover for the emotional isuess Olivia Walker has suffered asa result of her mother's death 34. Scot Walker alo sesks to recover forthe emotional distress Be has suffered a a seslt of is wife's death WHEREFORE, Plaintiff prays forthe following relief