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VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF NORFOLK. JAWOSKI LOTT, Administrator for the Estate of KISHA LATRICE MARROW-LOTT, Deceased, Plaintiff, v. case nox AUG SASS MICHAEL WHEELER, Serve at: oS ‘Newport News, VA 23606 and SHANNON FRAZIER-WHEELER, | | 53 5 Serve at: {Oss & Newport News, VA 23606 ac 2 Defendants. b 2 4 COMPLAINT COMES NOW, the Plaintiff, Jawoski Lott, in his official capacity as Administrator of the Estate of Kisha Latrice Marrow-Lott, deceased, by counsel, and moves the Court for a judgment and an award of ‘execution against the Defendants, Michael Wheeler and Shannon Frazier Wheeler, in the amount of tly and severally, for damages together with TWENTY-FIVE MILLION DOLLARS ($25,000,000.00),. pre-judgment interest thereon from October 27, 2018, until paid, for this, to-wit: PARTIES Ll Plaintiff, Jawoski Lott, is the duly appointed, qualified, and acting administrator of the Estate of Kisha Latrice Marrow-Lott, the deceased, who died in the manner alleged below on October 27, 2018, leaving as survivors those persons listed below for whose benefit Plaintiff ‘Administrator is bringing this action. Page 1 of7 qa 2. Kisha Latrice Marrow-Lott (hereinafter also referred to as the “Decedent”) was thirty-seven (37) years old at the time of her death, and was the spouse of the Plaintiff Administrator, Jawoski Lott. 3. ‘The only surviving heirs and statutory beneficiaries of Kisha Latrice Marrow- Lott, are: her husband, Jawoski Lott, and her children, S00» born \qgua@iiay and qn”) EE 4, The Plaintiff Administrator represents the interests of all such statutory beneficiaries identified as such under Virginia Code §8.01-50, et seq, to recover compensation for such beneficiaries. 5. Defendant Michael Wheeler (hereinafter referred to as “Wheeler”) is now, and was at all times mengioned in this complaint was, a resident of CIE Newport ‘News, Virginia. 6. Defendant Shannon Frazier-Wheeler (hereinafter refered to as “Frazier Wheeler”) is now, and at all times mentioned in this complaint was, a resident of [8 WEED. Newport News, Virginia. At all relevant times mentioned herein, the Defendants owned and/or operated a business trading as “Rolling With The Wheelers,” and did each engage in the business of a common carrier of passengers for hire, including in the City of Norfolk, Virginia, and were so engaged in such business at all times pertinent hereto, GENERAL FACTS 8. In October of 2018, Defendants Wheeler and Frazier-Wheeler owned and were operating a 1998 Ford Super Duty RV that had been modified into a bus for the purpose of Page 2 of 7 transporting groups of people for events such as bachelor and bachelorette parties (the “Party Bus”). 9. On or about October 27, 2018, the Decedent was riding in the Party Bus as a participant in a bachelorette party while it was being operated by Defendants Wheeler and Frazier-Wheeler in Norfolk, Virginia, including at and near the Waterside Drive ramp to 1-264, 10. At the aforementioned time and place, the Decedent was thrown and/or fell out of the Party Bus through the open and/or unsecured side door. 11, Decedent was run over by the Party Bus. 12. Decedent suffered severe injuries as a result of being run over by the Party Bus. 13. The injuries so inflicted on the Decedent resulted in the Decedent's death on October 27, 2018, COUNT I~ NEGLIGENCE (Against Defendants Wheeler Wheeler) 14, Plaintiff herein incorporates the allegations set forth above as if they were fully incorporated herein, 15, As the operators of the Party Bus on October 27, 2018, Defendants Wheeler and Frazier-Wheeler had a duty to exercise a high duty of care, and in the alternative a reasonable duty of care, for the safety of its passengers and others using the roadway and Party Bus, including the Decedent, and had a duty to act free of negligence in the use, maintenance, and operation of the Party Bus. 16. Defendants Wheeler and Frazier-Wheeler failed to operate the Party Bus in a reasonably safe manner and were thereby negligent in that: a. They operated the Party Bus, including but not limited to its side door, in such a manner to cause or permit it to open while the Bus was traveling; Page 3 of 7