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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS


)
COUNTY OF HORRY ) Civil Action No.: ___________

______________________________________________________________________________

SELECTIVE WAY INSURANCE : SUMMONS


COMPANY a/s/o/ Smith & Courtney, Inc. :
d/b/a Rivertown Bistro :
40 Wantage Avenue :
Branchville, NJ 07890 :
Plaintiff :
:
v. :
:
ASHLEY, INC. :
11109 Highway 707 :
Murrells Inlet, SC 29576 :
:
ASHLEY, INC. d/b/a A&A Hood Systems :
Fabrication and Repair :
11109 Highway 707 :
Murrells Inlet, SC 29576 :
:
Christopher A. Saylors :
rd
1002 3 Avenue South :
Myrtle Beach SC 29577 :
:
ABC Corporations 1-10 (unidentified fire :
suppression system installation companies) :
:
ABC Corporations 1-10 (unidentified fire :
suppression system repair companies) :
:
John Does 1-10 (unidentified fire :
suppression system installation :
individuals) :
:
John Does 1-10 (unidentified fire :
suppression system inspection, :
maintenance and repair individuals) :
:
Defendants :
______________________________________________________________________________
ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
TO THE ABOVE-NAMED DEFENDANTS:

YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy

of which is herewith served upon you, and to serve a copy of your Answer to this Complaint

upon the subscriber, at the address shown below, within thirty (30) days after service hereof,

exclusive of the day of such service, and if you fail to answer the Complaint, judgment by

default will be rendered against you for the relief demanded in the Complaint.

May _28_____, 2019 _s/Paul E. Hammack____________________


Paul E. Hammack, SC Bar #68501
Hammack Law Firm, P.A.
223 West Stone Avenue
Greenville, SC 29609
Telephone: 864-326-3333
paul@hammacklawfirm.com
Attorney for Plaintiff

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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
)
COUNTY OF HORRY ) Civil Action No.: ___________

______________________________________________________________________________

SELECTIVE WAY INSURANCE : COMPLAINT


COMPANY a/s/o/ Smith & Courtney, Inc. :
d/b/a Rivertown Bistro : (Jury Trial Demanded)
40 Wantage Avenue :
Branchville, NJ 07890 :
Plaintiff :
:
v. :
:
ASHLEY, INC. :
11109 Highway 707 :
Murrells Inlet, SC 29576 :
:
ASHLEY, INC. d/b/a A&A Hood Systems :
Fabrication and Repair :
11109 Highway 707 :
Murrells Inlet, SC 29576 :
:
Christopher A. Saylors :
1002 3rd Avenue South :
Myrtle Beach SC 29577 :
:
ABC Corporations 1-10 (unidentified fire :
suppression system installation companies) :
:
ABC Corporations 1-10 (unidentified fire :
suppression system repair companies) :
:
John Does 1-10 (unidentified fire :
suppression system installation :
individuals) :
:
John Does 1-10 (unidentified fire :
suppression system inspection, :
maintenance and repair individuals) :
:
Defendants :
______________________________________________________________________________

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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
CIVIL ACTION COMPLAINT

Plaintiff, Selective Way Insurance Company, by and through its undersigned counsel,

hereby brings this Complaint against Defendants, Ashley, Inc., Ashley, Inc. d/b/a A&A Hood

Systems and Fabrication and Repair and Christopher A. Saylors and upon information and belief

avers as follows:

PARTIES

1. Selective Way Insurance Company a/s/o Smith & Courtney, Inc. d/b/a Rivertown

Bistro (hereinafter, “Selective”) is a corporation organized and existing under and by virtue of

the laws of the State of New Jersey with its principal place of business located at 40 Wantage

Avenue, Branchville, NJ 07890. At all times material hereto, Selective was licensed to issue

insurance policies in the state of South Carolina.

2. Defendant, Ashley, Inc. (hereinafter, “Ashley”) is a business entity organized and

existing under and by virtue of the laws of the state of South Carolina with its principal place of

business located at 11109 Highway 707, Murrells Inlet, SC 29576.

3. Defendant, Ashley, Inc. d/b/a A&A Hood Systems Fabrication and Repair

(hereinafter, “A&A Hood”) is a business entity organized and existing under and by virtue of the

laws of the state of South Carolina with its principal place of business located at 11109 Highway

707, Murrells Inlet, SC 29576.

4. Defendant, Christopher A. Saylors, is an adult individual who is a citizen and

resident of South Carolina with a personal and/or business address at 1002 3rd Avenue South,

Myrtle Beach, SC 29577.

5. It is believed and averred that Defendant, Christopher A. Saylors, is the principal

owner of and does business as Ashley and A&A Hood.

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6. Defendant, ABC Corporations 1-10 (unidentified fire suppression system

installation companies) are corporations, partnerships, sole proprietorships, unknown at this time,

which were responsible for the installation of the fire suppression system.

7. Defendant, ABC Corporations 1-10 (unidentified fire suppression system

inspection, maintenance and/or repair companies) are corporations, partnerships, sole

proprietorships, unknown at this time, which were responsible for the inspection, maintenance

and repair of the fire suppression system.

8. Defendants, John Does 1-10 (unidentified installers) are sole proprietors or

individuals, unknown at this time, which were responsible for installing the fire suppression

system.

9. Defendants, John Does 1-10 (unidentified fire suppression system inspection,

maintenance and repair individuals) are sole proprietors or individuals, unknown at this time,

which were responsible for inspecting, maintaining, and repairing the fire suppression system.

FACTUAL BACKGROUND

10. Selective’s insured, Smith and Courtney, Inc. d/b/a Rivertown Bistro (hereinafter,

“Rivertown Bistro”) owned and operated the Bonfire Smokin’ Taqueria restaurant (hereinafter,

“Bonfire Restaurant”) located at 110 Main Street, Conway, SC (hereinafter, “the Property”).

11. At all times material hereto, Selective insured the Bonfire Restaurant and its

contents and the business operated therein under policy number S-1901920 (hereinafter, “the

Policy”).

12. At all times material hereto, Ashley, A&A Hood and/or Chris Saylor were in the

business of designing, installing, servicing, testing, repairing, maintaining, inspecting and

cleaning commercial kitchen fire suppression systems.

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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
13. At all times material hereto, Ashley, A&A Hood and/or Chris Saylor were in the

business of cleaning restaurant equipment, including equipment and components relating to

commercial kitchen fire suppression systems, such as exhaust hoods and duct work.

14. Rivertown Bistro retained Ashley, A&A Hood and/or Christopher Saylor to

design and install a commercial kitchen fire suppression system for a 48” Swig and Swine solid

fuel smoker (hereinafter, “the Smoker”) located at the Property.

15. In December of 2015, Ashley, A&A Hood and/or Christopher Saylor designed

and installed a Pyro Chem Kitchen Knight I commercial kitchen fire suppression system

(hereinafter, “the Suppression System”) for the Smoker at the Bonfire Restaurant.

16. After the initial installation of the Suppression System, Ashley, A&A Hood

and/or Christopher Saylors were responsible for inspecting, cleaning and maintaining the

Suppression System.

17. Additionally, Ashley, A&A Hood and/or Christopher Saylors were responsible

for inspecting and cleaning the exhaust and duct work for the Smoker.

18. On May 9, 2016, Ashley, A&A Hood and/or Christopher Saylors certified to

Rivertown Bistro that it cleaned the exhaust system for the Smoker.

19. On May 28, 2016, a fire (hereinafter, “the Fire”) originated at the Smoker and was

allowed to spread into the duct work above it and to other areas of the Property.

20. The Fire spread from the Smoker because of an accumulation of grease and

combustible materials inside the duct work.

21. The Suppression System did not operate because it was deficient, unsafe and not

compliant with NFPA 96, Standard for Ventilation control and Fire Protection of Commercial

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Kitchen Operation (hereinafter, “NFPA 96”) or the Pyro Chem’s listing at the time of its

installation, its inspection and at the time of the Fire.

22. At the time the Suppression System was sold and installed Ashley, A&A Hood

and/or Christopher Saylors, defendants knew or should have known that it was inappropriate for

protection of the Smoker and its use for that application was a violation of the Pyro Chem UL

listing and NFPA 96.

23. As a result of the failure of the Suppression System to activate and the

accumulation of grease and combustible materials inside the exhaust and duct work for the

Smoker, the Fire was able to spread to and damage the Bonfire Restaurant and its contents.

24. As a direct and proximate result of the failures and deficiencies identified in the

preceding paragraphs, Rivertown Bistro sustained damage to its business and property in an

amount in excess of $835,000.00.

25. In accordance with the terms & conditions of the Policy issued to its insured,

Selective has made payments to, or on behalf of, Rivertown Bistro for damage incurred to its

business and property in an amount in excess of $835,000.00.

26. By virtue of its payments made to or on behalf of Rivertown Bistro, Selective is

now subrogated to Rivertown’s rights of recovery against Ashley, A&A Hood and/or

Christopher Saylors to the extent of payments made.

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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
FIRST CAUSE OF ACTION

Plaintiff v. Ashley, Inc., Ashley Inc. d/b/a A&A Hood Systems Fabrication and Repair,
Christopher Saylor, ABC Corporations 1-10 (fire suppression system installation
companies) ABC Corporations 1-10 (fire suppression system inspection, maintenance
and/or repair companies), John Does 1-10 (fire suppression system installers) and John
Does 1-10 (fire suppression system inspection, repair and/or maintenance)

27. The foregoing averments of this Complaint are hereby incorporated by reference

as though fully set forth hereinafter.

28. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

had a duty to exercise reasonable care, control and supervision over its agents, employees, sub-

contractors and/or servants during the design, installation, inspection, testing, repair,

maintenance and service of the Suppression System protecting the Smoker.

29. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

had a duty to exercise reasonable care, control and supervision over its agents, employees, sub-

contractors and/or servants during the inspection and cleaning of the duct work associated with

the Smoker.

30. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

also had a duty to exercise reasonable care in connection with the installation, testing, inspection,

repair and maintenance of the Suppression System and the inspection and cleaning of the duct

work for the Smoker at the Bonfire Restaurant so as to protect against the risk of fire.

31. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

breached their duties of care and caused Plaintiff’s damages by:

a) failing to properly design the Suppression System at the Property;

b) failing to properly install the Suppression System at the Property;

c) failing to advise the Plaintiff’s insured that the Suppression System installed at the
Property was not listed for use as fire protection for natural fuel smokers;

d) failing to install an appropriate fire protection system for the natural fuel smoker;

e) failing to design, install, test, inspect, maintain and service the Suppression
System in accordance with NFPA 96, UL 300 and other industry standards;

f) failing to design, install, repair, test, inspect, maintain, service and repair the
Suppression System in accordance with state and local code;

g) improperly certifying that the Suppression System was safe, code compliant
and/or operational despite the fact that it could not adequately contain or suppress
a foreseeable fire originating within the Smoker;

h) failing to warn Rivertown Bistro and/or the Bonfire Restaurant that the
Suppression System was unsafe, inoperable and not compliant with the applicable
codes and NFPA standards;

i) improperly cleaning the exhaust duct work for the Smoker;

j) failing to remove a build-up of combustible grease and other materials from


within the Smoker and its duct work when it was cleaned in May 9, 2016;

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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
k) failing to advise the Plaintiff’s insured that there was a build-up of combustible
grease and other materials within the duct work for the Smoker; and

l) failing to advise the Plaintiff that the Smoker and its duct work constituted an
unacceptable risk of fire to the Property.

32. The acts and omissions of actions described in the preceding paragraphs were

committed by the duly authorized agents, servants and/or employees of Ashley, A&A Hood,

Christopher Saylors, ABC Corporations 1-10 (fire suppression system installation companies)

ABC Corporations 1-10 (fire suppression system inspection, maintenance and/or repair

companies), John Does 1-10 (fire suppression system installers) and/or John Does 1-10 (fire

suppression system inspection, repair and/or maintenance), acting within the course and scope of

their agency and/or employment.

33. As a direct and proximate result of Ashley, A&A Hood, Christopher Saylors,

ABC Corporations 1-10 (fire suppression system installation companies) ABC Corporations 1-10

(fire suppression system inspection, maintenance and/or repair companies), John Does 1-10 (fire

suppression system installers) and/or John Does 1-10’s (fire suppression system inspection,

repair and/or maintenance) breaches of duty, Plaintiff’s insured, Rivertown Bistro, sustained

extensive damage to the Bonfire Restaurant and related property.

34. In accordance with the terms and conditions of the Policy issued to Rivertown

Bistro, Selective has made payments to, or on behalf of, Rivertown Bistro for the damages

incurred to its business and property in an amount in excess of $835,000.00.

35. By virtue of its payments made to or on behalf of its insured, Selective is now

subrogated to Rivertown Bistro’s rights of recover against Ashley, A&A Hood, Christopher

Saylors, ABC Corporations 1-10 (fire suppression system installation companies) ABC

Corporations 1-10 (fire suppression system inspection, maintenance and/or repair companies),

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ELECTRONICALLY FILED - 2019 May 28 4:20 PM - HORRY - COMMON PLEAS - CASE#2019CP2603344
John Does 1-10 (fire suppression system installers) and/or John Does 1-10 (fire suppression

system inspection, repair and/or maintenance) to the extent of payments made.

WHEREFORE, Plaintiff demands judgment against Ashley, A&A Hood, Christopher

Saylors, ABC Corporations 1-10 (fire suppression system installation companies) ABC

Corporations 1-10 (fire suppression system inspection, maintenance and/or repair companies),

John Does 1-10 (fire suppression system installers) and/or John Does 1-10 (fire suppression

system inspection, repair and/or maintenance) in an amount in excess of $835,000.00, together

with interest, costs and such other relief as this Honorable Court deems just and proper under the

circumstances.

SECOND CAUSE OF ACTION

Plaintiff v. Ashley, Inc., Ashley Inc. d/b/a A&A Hood Systems Fabrication and Repair,
Christopher Saylor, ABC Corporations 1-10 (fire suppression system installation
companies) ABC Corporations 1-10 (fire suppression system inspection, maintenance
and/or repair companies), John Does 1-10 (fire suppression system installers) and John
Does 1-10 (fire suppression system inspection, repair and/or maintenance) (Breach of
Warranty)

36. Plaintiff hereby incorporates all preceding paragraphs of this Complaint the same

as if fully set forth hereinafter.

37. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

held themselves out and represented to Rivertown Bistro and/or the Bonfire Restaurant as being

competent and qualified to design, install, inspect, service, test and maintain the Suppression

System for the Smoker.

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38. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

held themselves out and represented to Rivertown Bistro and/or the Bonfire Restaurant as being

competent and qualified to inspect and clean the exhaust system and duct work for the Smoker.

39. Based on Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10’s (fire suppression system inspection, repair and/or

maintenance) representations, Rivertown Bistro and/or the Bonfire Restaurant retained the

services of Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire suppression

system installation companies) ABC Corporations 1-10 (fire suppression system inspection,

maintenance and/or repair companies), John Does 1-10 (fire suppression system installers)

and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance) to design,

install, inspect, service, test and maintain the Suppression System and to clean the exhaust

system and duct work for the Smoker.

40. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

through their individual or respective representations of competency, made certain implied

warranties that its services would be performed in a fit, workmanlike and competent manner.

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41. Plaintiff’s insured, Rivertown Bistro and the Bonfire Restaurant justifiably relied

on the defendants’ representation of competency.

42. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

also expressly warranted that the Suppression System was tested and inspected in accordance

with NFPA 96.

43. At all times material hereto, Rivertown Bistro and/or the Bonfire Restaurant

performed all of the obligations and conditions present under the contractual agreement with

Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire suppression system

installation companies) ABC Corporations 1-10 (fire suppression system inspection,

maintenance and/or repair companies), John Does 1-10 (fire suppression system installers)

and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance).

44. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

breached thier agreement with Rivertown Bistro and/or the Bonfire Restaurant and the expressed

and implied warranties related thereto by performing work under the contract without exercising

reasonable care, skill and ability under similar conditions and like surrounding circumstances as

would ordinarily be employed by others in the same profession.

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45. Ashley, A&A Hood, Christopher Saylors, ABC Corporations 1-10 (fire

suppression system installation companies) ABC Corporations 1-10 (fire suppression system

inspection, maintenance and/or repair companies), John Does 1-10 (fire suppression system

installers) and/or John Does 1-10 (fire suppression system inspection, repair and/or maintenance)

further breached the agreement with Rivertown Bistro and/or the Bonfire Restaurant and the

expressed and implied warranties related thereto by failing to design, install, inspect, test and

maintain the Suppression System in accordance with the procedures outlined in NFPA 96.

46. The damages sustained by Rivertown Bistro and the Bonfire Restaurant were a

natural and foreseeable consequence of Ashley, A&A Hood, Christopher Saylors, ABC

Corporations 1-10 (fire suppression system installation companies) ABC Corporations 1-10 (fire

suppression system inspection, maintenance and/or repair companies), John Does 1-10 (fire

suppression system installers) and/or John Does 1-10 (fire suppression system inspection, repair

and/or maintenance) breach of contract and related warranties.

47. In accordance with the terms and conditions of the Policy, Selective has made

payments to, or on behalf of, Rivertown Bistro for damage incurred to its business and property

in an amount in excess of $835,000.00.

48. By virtue of its payments made to or on behalf of its insured, Selective is now

subrogated to Rivertown Bistro’s rights of recovery against Ashley, A&A Hood, Christopher

Saylors, ABC Corporations 1-10 (fire suppression system installation companies) ABC

Corporations 1-10 (fire suppression system inspection, maintenance and/or repair companies),

John Does 1-10 (fire suppression system installers) and/or John Does 1-10 (fire suppression

system inspection, repair and/or maintenance) to the extent of payments made.

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WHEREFORE, Plaintiff demands judgement against Defendants, Ashley, Inc., A&A

Hood, Christopher Saylors, ABC Corporations 1-10 (fire suppression system installation

companies) ABC Corporations 1-10 (fire suppression system inspection, maintenance and/or

repair companies), John Does 1-10 (fire suppression system installers) and/or John Does 1-10

(fire suppression system inspection, repair and/or maintenance) in an amount in excess of

$835,000.00 together with interest, costs and other such relief as this Honorable Court deems just

and proper under the circumstances.

THIRD CAUSE OF ACTION

Plaintiff v. Ashley, Inc., Ashley Inc. d/b/a A&A Hood Systems Fabrication and Repair,
Christopher Saylor, ABC Corporations 1-10 (fire suppression system installation
companies) John Does 1-10 (fire suppression system installers)
(Violation of South Carolina Code of Laws 39-5-10 et. Seq. (SCUTPA))

49. Plaintiff incorporates herein by reference all preceding paragraphs of this

Complaint the same as if set forth fully hereinafter.

50. Defendants, Ashley, A&A Hood, Christopher Saylor, ABC Corporations 1-10

(fire suppression system installation companies) John Does 1-10’s (fire suppression system

installers) actions described herein are unfair and deceptive acts or practices in violation of South

Carolina Code of Laws 39-5-10, et. eq. by designing and installing a Suppression System for the

Smoker that was not listed by the manufacturer for that application.

51. Defendants, Ashley, A&A Hood, Christopher Saylor, ABC Corporations 1-10

(fire suppression system installation companies) John Does 1-10’s (fire suppression system

installers) unfair and deceptive acts or practices affect commerce.

52. The public has an interest in insuring that fire suppression systems installed by

licensed contractors are safe and adequate for the protection of people and property.

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53. Defendants, Ashley, A&A Hood, Christopher Saylor, ABC Corporations 1-10

(fire suppression system installation companies) John Does 1-10’s (fire suppression system

installers), unfair and deceptive acts or practices described herein impact the public interest

because those acts and practices involve the installation of fire protection systems which are

inadequate to suppress a foreseeable fire which endangers people and property.

54. Defendants, Ashley, A&A Hood, Christopher Saylor, ABC Corporations 1-10

(fire suppression system installation companies) John Does 1-10’s (fire suppression system

installers) actions described herein have damaged the Plaintiff’s insured in an amount in excess

of $835,000.00.

55. Plaintiff is entitled to recover treble its actual damages and attorney’s fees

resulting from Defendants’ unfair and deceptive trade practices pursuant to South Carolina Code

of Laws 39-5-10, et. eq.

WHEREFORE, Plaintiff demands judgment against the Defendants, Ashley, A&A Hood,

Christopher Saylor, ABC Corporations 1-10 (fire suppression system installation companies)

John Does 1-10’s (fire suppression system installers), in an amount in excess of $835,000.00 and

other relief as this Honorable Court deems just and proper.

May _28_____, 2019 _s/Paul E. Hammack____________________


Paul E. Hammack, SC Bar #68501
Hammack Law Firm, P.A.
223 West Stone Avenue
Greenville, SC 29609
Telephone: 864-326-3333
paul@hammacklawfirm.com
Attorney for Plaintiff

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