AFTAB PUREVAL

HAMILTON COUNTY CLERK OF COURTS

COMMON PLEAS DIVISION

ELECTRONICALLY FILED
October 9, 2020 02:51 PM
AFTAB PUREVAL
Clerk of Courts
Hamilton County, Ohio
CONFIRMATION 993907

COURT STREET EXECUTIVE A 2003578

SUITES LLC
vs.
HOWARD FROELICHER IV

FILING TYPE: INITIAL FILING (IN COUNTY) WITH JURY

DEMAND
PAGES FILED: 14

EFR200

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 William H. Blessing (0006848)
Attorney for Plaintiff

IN THE COURT OF COMMON PLEAS

HAMILTON COUNTY OHIO
______________________________________________________________________________

COURT STREET EXECUTIVE SUITES Case No. _____________________

LLC, on behalf of itself and other
similarly situated class members
c/o William H. Blessing
119 East Court Street Suite 500
Cincinnati OH 45202

-vs-

HOWARD FROELICHER IV
23 SOUTHVIEW AVENUE
FT THOMAS KY 41075,

WILLIAM BOGGS
3123 MOZART AVENUE #4
CINCINNATI OH 45211

JACOB CASON
1310 YOUNG STREET
BROUSSARD LA 70518

DARVON ANTON GREEN

745 WOODLAWN AVENUE
CINCINNATI OH 45205

WILLIAM KAMHOLTZ
3287 MORRISON #7
CINCINNATI OH 45220

SARA ABBOUD
2334 VICTOR STREET
CINCINNATI OH 45219

ROWAN M. GRISEZ
483 STONE CREEK WAY
CINCINNATI OH 45103

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 BRENNON THOMAS
4201 BRIARWOOD DRIVE
INDEPENDENCE KY 45051

DENZEL CORTEZ PARKS

2507 LANGDON FARM ROAD
CINCINNATI OH 45212

ILLYA IBBOTT
2205 READING ROAD
CINCINNATI OH 45206

CHORD HILL
1577 ELIZABETH PLACE
CINCINNATI OH 45237

EVAN ACKNER
12081 CARRINGTON LANE #102
LOVELAND OH 45140

TERRY BECKHAM
36 APPLEWOOD DRIVE
FAIRFIELD OH 45014

BRIAN DICKENS
5535 WINCHESTER MEADOWS DRIVE
CANAL WINCHESTER, OH 43110

JODY CUNNINGHAM
134 GLENRIDGE PLACE #4
CINCINNATI OH 45217

RANDY CONYERS
353 ROCKDALE
CINCINNATI OH 45229

JOHN COMPTON
122 E. FIFTH STREET
COVINGTON KY 41011

ANTWAN CAMPBELL
7817 NARRWON
CINCINNATI OH 45231

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 CHASE BUTLER
1309 WALNUT STREET #304
CINCINNATI OH 45202

PARKER BUSCHELMAN
3303 WATSON
CINCINNATI OH 45231

KATHLEEN BERBERICH
2334 KEMPER LANE
CINCINNATI OH 45206

BETHANY BENNET
6700 JENNIFER LYN DRIVE
CINCINNATI OH 45248

ROBERT EDWARDS
2859 PRESIDENTIAL DRIVE
HEBRON KY 41048

ZOLA BOGGS
6094 BELMONT
CINCINNATI OH 45202

TAYLOR EGGERS
3871 VINE STREET
CINCINNATI OH 45202

THEODORE FLAHERTY
3559 MOONEY AVENUE
CINCINNATI OH 45208

KEERSTEN FELTNER
3009 LAYHIGH ROAD
HAMILTON OH 45013

TYLER GAMBILL
403 N. SECTION EXTENSION
SOUTH LEBANON OH 45065

JARED GAUSLIN
6842 HOME CITY AVENUE
CINCINNATI OH 45233

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 BRIDGET DENMAN
3606 W. EIGHTH STREET
CINCINNATI OH 45241

COREY FREEMAN
6362 SIMPSON AVENUE
CINCINNATI OH 45229

YVONNE GASTON
4125 BELL STREET
NORWOOD OH 45212

JARROD GEARY
4125 BELL STREET
NORWOOD OH 45212

ZACHARY GRAY
406 E. FIFTH STREET
NEWPORT KY 42071

TEVIN GREEN
708 GLENWOOD AVENUE
CINCINNATI OH 45229

WILLIAM HANSEN
2362 RAVINE STREET
CINCINNATI OH 45219

HANNAH HARDMAN
5462 MONTGOMERY ROAD
NORWOOD OH 45212

ALEXANDER HARTUNG
7652 CAROLE LANE
FLORENCE KY 42042

EUGENE HASKAMP
324 FAIRFIELD AVENUE
BELLEVUE KENTUCKY 41073

DANIEL HAYNES
1053 OAK GROVE COURT #1
INDEPENDENCE KY 41051

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 JOSHUA HEDGES
700 RIDDLE ROAD #503
CINCINNATI OH 45220

NATALIE HAMPFLING
889 SANDSTONE RIDGE
COLD SPRING KY 41076

NICOLE HENNET
3053 MARSHALL AVENUE #9
CINCINNATI OH 45220

CODY HOLBERT
3357 CEDAR TREE LANE
ERLANGER KY 41018

JAYSON HOWARD
2659 WENDLE DRIVE #2028
CINCINNATI OH 45238

JACQUIL ROYAL VOULTEZ HUDSON

1533 MADISON ROAD APT 22
CINCINNATI OH 45206

MARQUISE HUGHES
5400 NEWFIELD AVENUE
CINCINNATI OH 45237

KIYAH JETT
1743 GARDEN LANE
CINCINNATI OH 45237

DAULTON KING
4134 ST. WILLIAMS AVENUE
CINCINNATI OH 45205

DAKOTA LANGHALS
10854 RIDDLES RUN ROAD
UNION KY 41091

ANTHONY LE
335 WEST EIGHTEENTH STREET
NEWPORT KY 41071

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 JAGGER LOUDEN
14 UTZ
FLORENCE KY 41042

TANNER MCDOLE
2343 PENNINGTON LANE
CINCINNATI OH 45244

MAXWELL MCDONALD
7505 MONTGOMERY ROAD #15
CINCINNATI OH 45236

JESSICA MORGAN
107 DUDLEY PIKE
EDGEWOOD KY 41022

VANESSA MOSER
3817 EASTERN AVENUE #1
CINCINNATI OH 45226

MELISSA MYRICK
993 SEMINOLE TRAIL
MILFORD OH 45150

RODNEY MYRICK
993 SEMINOLD TRAIL
MILFORD OH 45150

LEWIS MYSZKOWSKI
65 DEERHAVEN COURT
FLORENCE KY 41042

MADISON NUSS
2732 EAST TOWER DRIVE #427
CINCINNATI OH 45238

TYLER O’CONNELL
449 GENERAL DRIVE
FT. WRIGHT KY 41011

JESSICA PARTIN
335 WEST TENTH STREET
NEWPORT KY 41071

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 DAVID PALLICASTRO
1942 MAPLE AVENUE
NORWOOD OH 45212

CHRIS PHIFFER
1820 SUNSET AVENUE
CINCINNATI OH 45238

BRYCE PHILLIPS
117 E. TWELFTH STREET
CINCINNATI OH 45202

ALISA POWLEY
3275 BASSWOOD LANE
CINCINNATI OH 45239

MILES ROAT
8551 RATHMAN PLACE
CINCINNATI OH 45255

PAULINE PROKHOROVA
1309 WALNUT STREET
CINCINNATI OH 45202

MICHELLE RICE
4425 HAMILTON AVENUE #1
CINCINNATI OH 45223

KEISHAWN ROBINSON
8779 DESOTO
CINCINNATI OH 45231

IAN SCHEFFLER
1901 MILLS AVENUE #2
NORWOOD OH 45212

SEAN SLACK
213 KLOTTER AVENUE
CINCINNATI OH 45219

HUGH SMITH
1335 MAIN STREET
CINCINNATI OH 45202

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 AIDEN SMOCK
1550 TEAKWOOD AVENUE
CINCINNATI OH 45224

DEVIN DARRELL SHAFER

2314 IOWA AVENUE APT #408
CINCINNATI OH 45206

THADDEUS STEWART STEELE

9320 MARKER DRIVE #12
CINCINNATI OH 45251

SIERRA THOMAS
1126 CHAMBERLAIN AVENUE
CINCINNATI OH 45215

DRAKE TURLEY
2770 RUNNING TREE DRIVE
FLORENCE KENTUCKY 41042

IMANI BRAZILLE
8232 W. GALBRAITH ROAD
CINCINNATI OH 45231

JOE VENDITTI
24 CONKLIN STREET
CINCINNATI OH 45219

CALEB VOLLING
8377 MACE AVENUE
CINCINNATI OH 45216

MICHAEL WARDEN
2417 PARK AVENUE
NORWOOD OH 45212

JAMISON WALKER
4401 VIRGINIA AVENUE
CINCINNATI OH 45223

AUSTIN WEINHEIMER
5327 MOELLER AVENUE
NORWOOD OH 45212

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 BRANDONLYN WILSON
1302 RESERVOIR STREET
CINCINNATI OH 45211

DREW WITT
448 MORRVUE DRIVE
CINCINNATI OH 45238

COREY WOLFE
290 SALMON PASS
COLD SPRING KY 41010

MARY ZEISER
5064 BEND STREET
CINCINNATI OH 45202

ROBERT ZIEZULKA
401 MARSHAL AVENUE #1013
GEORGETOWN OH 45121

ZACHARY LIPO ZOVIC

135 LYON STREET
CINCINNATI OH 45219

Defendants.

CLASS ACTION COMPLAINT WITH JURY DEMAND

______________________________________________________________________________

Plaintiff Court Street Executive Suites LLC (“CSES”), by its attorneys, brings this class

action complaint for money damages and for equitable relief on behalf of itself and

similarly-situated members of the class described below. To those ends CSES alleges as

follows.

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 PRELIMINARY STATEMENT

In 1884, an assembly of protesters marched on the Hamilton County Courthouse. They

were angered by systemic corruption in the county’s criminal justice system and specifically

outraged by a jury’s lenient verdict in a high-profile murder trial. The protest turned into

riot. Shots came from the crowd. Exactly who fired could not be determined. Three days of

pitched battles between law enforcement authorities and rioters ensued. In the end, there

was widespread property damage. Our courthouse was burned. And more than 50 persons

lay dead, including James Desmond whose statue now stands on the first floor of the

current courthouse edifice. Each member of the rioting crowd was civilly and criminally

responsible, because each encouraged, aided, or participated in the riot.

In 2020, from May 29 through 31, protests against the perceived unfairness of criminal

justice in the United States took place in Cincinnati. Late on the evening of May 29, the

assembly turned into riot, which continued for three nights: a concerted course of arson,

assaults, damage to public property and business establishments, as well as extensive looting

in downtown and in the Clifton area. Unlike 1884 and despite a police officer’s being shot in

the head, the 2020 riot did not result in loss of life. However, just as in 1884, those who

participated, connived, conspired, tacitly consented to, aided, abetted, ratified, or

encouraged the rioting are just as responsible for the injuries and damages as are the specific

perpetrators.

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 THE PARTIES

1. Plaintiff is an Ohio limited liability company and the owner of certain real property

on Court Street in downtown Cincinnati. Plaintiff brings this action on behalf of the class of

proprietors and real property owners whose properties in downtown Cincinnati, Over-the-

Rhine, West End, Clifton Heights, University Heights, and Fairview were broken into,

looted, vandalized, damaged, defaced, or destroyed by the conduct described below.

2. Each of the Defendants is an individual who has reached age of majority. The

Defendants reside in various states, as indicated in the caption of this Complaint, primarily

in Ohio and Kentucky.

FACTS

3. At various times commencing around 10:00 PM on the evening of May 29, 2020 and

continuing through early June 1, 2020, the named Defendants participated, aided and

abetted, ratified, tacitly consented, and promoted a pattern of riotous conduct in the

downtown, Over-the-Rhine, West End, and Clifton Heights, University Heights, and

Fairview areas of Cincinnati.

4. The unlawful conduct included arson, shooting a Cincinnati police officer in the

head, breaking into, looting, and burglarizing business properties, vandalism, defacing and

otherwise damaging public and private property, theft of property, assaults on law

enforcement officers with firearms, rocks, and bottles, as well as efforts to impede law

enforcement officials from performing their duty to protect persons and property.

5. Each of the Defendants connived and acted to encourage, sponsor, ratify, and

promote the violence and destruction of property that was perpetrated.

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 CLASS ALLEGATIONS

6. Pursuant to Ohio Civil Rule 23, Plaintiff proposes to represent a class of persons in

its claims against the Defendants, defined as follows:

All property owners, lessors, tenants, and proprietors of businesses or real

estate in downtown Cincinnati, Over-the-Rhine, West End, Clifton Heights,
University Heights, and East Walnut Hills whose properties or businesses
were vandalized, damaged, destroyed, defaced, or otherwise impaired by the
rioting that occurred from late May 29, 2020 through June 1, 2020.

FIRST CAUSE OF ACTION

CONCERT OF ACTION AND CONSPIRACY

7. Plaintiff, on behalf of itself and the class described above, brings this claim against

each of the named defendants based upon their participation, concerted action and

conspiracy in the rioting and incorporate by reference the allegations stated in Paragraphs 1-

5, above.

8. Each defendant engaged in a malicious combination, conspiracy, and concerted

behavior to perpetrate, promote, ratify, and execute the riotous conduct described in

Paragraph 4, above.

9. Plaintiff and the named class members suffered various damages to their respective

properties or businesses as a direct and proximate result of the rioting and Defendants’

unlawful conduct.

10. Each of the Defendants is jointly and severally liable for the damages, including

economic damages and loss of goodwill, proximately caused by the concerted action and

conspiracy described above and is liable for punitive damages, costs, and attorney fees under

the law of Ohio.

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 SECOND CAUSE OF ACTION
STATUTORY LIABILITY UNDER RC 2307.60

11. Plaintiff, on behalf of itself and the class described above, brings this claim against

each of the named Defendants as authorized by RC 2307.60. Plaintiff incorporates the

allegations stated in Paragraphs 1-9, above.

12. The named Defendants and others acting in concert with are jointly and severally

liable for all damages, including economic damages and loss of good will, proximately or

directly caused by the acts described in Paragraphs 4-5, above.

13. The named Defendants are liable for punitive damages, costs, and attorney fees per

RC 2307.60.

THIRD CAUSE OF ACTION: RIOT

14. Plaintiff, on behalf of itself and the class described above, brings this claim against

each of the named Defendants for their engaging in a riot, defined by RC 2917.02. Plaintiff

incorporates the allegations stated in Paragraphs 1-12, above.

15. Each of the named Defendants joined together in promoting, encouraging, and

participating in rioting conduct as defined in RC 2917.02, and each Defendant is liable,

jointly and severally, for all damages, including economic damages and loss of good will,

proximately or directly caused by the rioting.

16. The named Defendants are also liable for punitive damages, costs, and attorney fees

per the law of Ohio.

WHEREFORE, Plaintiff demands that money judgment be entered in favor of it and all

members of the class, jointly and severally against each Defendant as follows:

A. Joint and several judgment for money damages for personal property loss, damages

to real estate, and loss of good will against each Defendant;

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 B. An award of punitive damages against each Defendant in an amount sufficient to

punish them for their wrongful conduct and to deter each such Defendant from engaging in

that conduct in the future;

C. An award to Plaintiff of its costs of suit, including attorney fees, as provided by the

common law of Ohio and by statute; and such other relief as may be just and proper.

Respectfully submitted,

/s/ William H Blessing

________________________
William H Blessing (0006848)
Trial Attorney for Plaintiff
BLESSING & WALLACE LAW
119 East Court Street, Suite 500
Cincinnati OH 45202
(513) 621-9191
bill@blessing-attorneys.com

JURY DEMAND

Plaintiff hereby demands its right to trial by jury.

/s/ William H Blessing

___________________________
William H Blessing

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