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    Energy Companies Lawsuit

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    3K views18 pages

    Energy Companies Lawsuit

    Uploaded by

    David Mark
    Energy Companies Lawsuit

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
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    Tos eo sot CLASSEN CURVE RESIDENCES OWNER LLC, CERTAIN UNDERWRITERS AT LLOYDS SUBSCRIBING TO POLICY ‘NUMBERS CSN009675; 20-SBR-0214; and AMR-70971, INDIAN HARBOR INSURANCE, COMPANY, QBE SPECIALTY INSURANCE COMPANY, STEADFAST INSURANCE COMPANY, GENERAL SECURITY INDEMNITY COMPANY OF ARIZONA, UNITED SPECIALTY INSURANCE COMPANY, LEXINGTON INSURANCE COMPANY, SAFETY SPECIALTY INSURANCE COMPANY, HDI GLOBAL SPECIALTY SE, OLD REPUBLIC UNION INSURANCE COMPANY, ILLINOIS UNION INSURANCE COMPANY, LANDMARK AMERICAN INSURANCE COMPANY, and AXIS SPECIALTY EUROPE SE, as subrogees of Classen Curve Residences Owner LLC, Plaintiffs vs, OKLAHOMA GAS AND ELECTRIC COMPANY, and RED DIRT ELECTRIC, LLC, Defendants Wann Ue | iv THE DIsTRICT COURT OF OKLAHOMA COUNTY ie STATE OF OKLAHOMA ) ) ) ) ) ) ) ) ) ) ) ) | ) ) Q ) ) ) ) ) ) ) ) ) ) ) ) ) CTY AWG- Song FILED IN DISTRICT Col OKLAHOMA COUNTY JUL 12 2023 RI TARRE) ASP AEERY CASE NO. CJ_ 2023-3885 PLAINTIFFS’ PETITI Plaintiffs, Classen Curve Residences Owner LLC (‘Classen Curve” or “Insured”), Certain Underwriters at Lloyds subscribing to policy numbers CSN009675; 20-SBR-0214 and AMR- 70971, Indian Harbor Insurance Company, QBE Specialty Insurance Company, Steadfast Insurance Company, General Security Indemnity Company of Arizona, United Specialty Insurance Company, Lexington Insurance Company, Safety Specialty Insurance Company, HDI Global Specialty SE, Old Republic Union Insurance Company, Illinois Union Insurance Company, Landmark American Insurance Company, and Axis Specialty Europe SE, as subrogees of Classen Curve Residences Owner LLC (hereinafter “Insurers”) (collectively “Plaintiffs”) for their claims against Defendants, Oklahoma Gas and Electric Company and Red Dirt Electric, LLC (collectively “Defendants”), allege and state as follows: ‘TIES 1. Plaintiff, Classen Curve is a limited liability corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois, At all material times, Classen Curve owned the property located at 1150 NW 63 Street, ‘Oklahoma City, Oklahoma 73118, commonly referred to as The Canton at Classen Curve (the “Property”). 2. Plaintiff, Certain Underwriters at Lloyd’s, London subscribing to policies CSN009675; 20-SBR-0214 and AMR-70971, are unincorporated associations of participating syndicates, incorporated or primarily organized under the laws of and having their principal places of business in the United Kingdom. They are authorized to transact business and have transacted business in the State of Oklahoma, They are real parties in interest having made payments to their Insured, Classen Curve, pursuant to their policies of insurance. Plaintiffs’ subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 3. Plaintiff, Indian Harbor Insurance Company (“Indian Harbor”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of the State of Pennsylvania with its principal place of business located at 505 Eagleview Blvd., Ste. 100, Exton, PA 19341. It is authorized to transact business and has transacted business in the State of Oklahoma. Indian Harbor is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation ‘organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 4, Plaintiff, QBE Specialty Insurance Company (“QBE”) is a foreign surplus lines insurance company engaged in the insurance business organized and existing under the laws of ‘Australia, with its principal place of business located at One QBE Way, Sun Prairie, WI 53596. Its authorized to transact business and has transacted business in the State of Oklahoma. QBE is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 5, Plaintiff, Steadfast Insurance Company (“Steadfast”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of the State of Delaware, with its principal place of business located at 1299 Zurich Way, Schaumburg, IL 60196- 1056. Itis authorized to transact business and has transacted business in the State of Oklahoma. Steadfast is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Ilinois. At all material times, Classen Curve owned the Property. 6. Plaintiff, General Security Indemnity Company of Arizona (“General Security”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of the State of Arizona, with its principal place of business located at 28 Liberty Street, Suite 3400, New York, NY 10005-1445. It is authorized to transact business and has transacted business in the State of Oklahoma, General Security is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 7. Plaintiff, United Specialty Insurance Company (“United Specialty”) is a foreign insurance company organized and existing under the laws of the State of Texas, with its principal place of business located at 1900 L. Don Dodson Dr., Bedford, TX 76021. It is authorized to transact business and has transacted business in the State of Oklahoma. United Specialty is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 8. Plaintiff, Lexington Insurance Company (“Lexington”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of the State of Delaware, with its principal place of business located at 99 High Street, 23rd Floor, Boston, MA 02110. Itis authorized to transact business and has transacted business in the State of Oklahoma. Lexington is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 9. Plaintiff, Safety Specialty Insurance Company (“‘Safety Specialty”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of the State of Delaware with its principal place of business located at 1832 Schuetz Road, St. Louis, MO 63146-3540, It is authorized to transact business and has transacted business in the State of Oklahoma. Safety Specialty isa real party in interest having made payments to its Insured, Classen, Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois At all material times, Classen Curve owned the Property. 10. Plaintiff, HDI Global Specialty SE (“HDI”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of Germany, with its principal place of business located at HDI-Platz 1, 30659 Hannover, Germany. It is authorized to transact business and has transacted business in the State of Oklahoma. HDI is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property 11, Plaintiff, Old Republic Union Insurance Company (“ORIC”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of the State of Pennsylvania with its principal place of business located at 307 North Michigan Avenue, Chicago, IL 60601. It is authorized to transact business and has transacted business in the State of Oklahoma, ORIC is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois, At all material times, Classen Curve owned the Property. 12. Plaintiff, Ilinois Union Insurance Company (“Illinois Union”) is a foreign insurance company engaged in the insurance business organized and existing under the laws of the State of Illinois, with its principal place of business located at 436 Walnut Street, Philadelphia, PA 19106. It is authorized to transact business and has transacted business in the State of Oklahoma. Illinois Union is a real party in interest having made payments to its Insured, Classen Curve, pursuant to their policies of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 13, Plaintiff; Landmark American Insurance Company (“Landmark”) is a surplus lines carrier engaged in the insurance business organized and existing under the laws of the State of Oklahoma, with its principal place of business located at 945 E. Paces Ferry Rd, Suite 1800, Atlanta, GA. 30326-1160. It is authorized to transact business and has transacted business in the State of Oklahoma. Landmark is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policy of insurance. Plaintiff's subrogor, Classen Curve, is a corporation organized and existing under the laws of the State of Delaware, with its principal place of business located in Chicago, Illinois. At all material times, Classen Curve owned the Property. 14, Plaintiff, Axis Specialty Europe SE (“Axis”) is a foreign surplus lines insurance company engaged in the insurance business organized and existing under the laws of Australia, with its principal place of business located at L 2.70 Hindmarsh Square Adelaide, South Australia, 5000 Australia. It is authorized to transact business and has transacted business in the State of Oklahoma. Axis is a real party in interest having made payments to its Insured, Classen Curve, pursuant to its policies of insurance. Plaintiff's subrogor, Classen Curve, is a corporation ing under the laws of the State of Delaware, with its principal place of business organized and exi located in Chicago, Illinois, At all material times, Classen Curve owned the Property. 15, Defendant, Oklahoma Gas and Electric Company (“Defendant” or “OG&E”), is a regulated electric utility company organized and existing under the laws of the State of Oklahoma, with its principal office located at 321 N. Harvey Ave., Oklahoma City, OK 73101. OG&E can be served with process by serving its registered agent: Oklahoma Gas and Electric Company Patricia Horn, Registered Agent 321 N. Harvey Avenue Oklahoma City, OK 73101 16. Defendant, Red Dirt Electric, LLC (“Defendant” or “Red Dirt”), is an Oklahoma corporation who is authorized to and is conducting business in the State of Oklahoma, Red Dirt may be served through its Registered Agent at the following address: Red Dirt Electric, LLC Spencer Evan Struck, Registered Agent 19906 N. 2840 Rd Kingfisher, OK 73750 JURISDICTION AND VENUE 17, The Court has subject-matter jurisdiction over this lawsuit because the amount in controversy exceeds this Court’s minimum jurisdictional requirements. The Court has jurisdiction over the Defendants because the Defendants reside in and/or conduct business in the State of Oklahoma. 18. Venue is proper in this Court pursuant to 12 Okla. Stat. § 131(2) because the property damaged by Defendants is situated here, Further, venue is proper in this Court pursuant to 12 Okla, Stat. § 134 because OG&E is a domestic corporation and has its principal place of business in this county. FACTS 19, Atall relevant times, the Property, was owned by Classen Curve. 20. The Property was designed to include a five-story multi-family project with 325 for-rent units, consisting of 374,507 square feet, a parking garage and two interior courtyard areas. 21. The Property was scheduled to be completed in early 2022, with phased in ‘occupancy beginning in March, 2022. 22. Onor about February 8, 2022, at approximately 6:33 p.m., the Oklahoma City Fire Department received a 911 call reporting that smoke was coming from the top of the Property. The fire burned for several days. 23, A post-fire investigation identified that the fire originated (started) at several areas inside the Property's attic space. 24, The fires in the attic space ignited as the result ofan electrical fault, The electrical fault occurred when the Property's neutral conductors became energized by the incoming phased power. 25. During a post-fire inspection of a transformer that supplied electrical power to the Property, it was determined that a phased power (hot) conductor was connected to the building's neutral conductors. 26. OG&E was the electric utility company that owned the electrical transmission lines up to the point-of-service at the Property. OG&E contracted, subcontracted or otherwise retained Red Dirt to install the electrical transmission lines to the point-of-service at the Property. 27. At all times relevant hereto, OG&E and Red Dirt were required to perform all electrical installation work in accordance and conformance with the requirements of the National Electric Safety Code (NESC); National Electric Code (NEC); all applicable OSHA codes ordinances; and all local power company guidelines and specifications. 28. Furthermore, at all times relevant hereto, OG&E and Red Dirt were required to comply with the Federal Energy Regulatory Commission (FERC) regulations and applicable (Oklahoma Gas and Electric Company FERC Electric Tariff, and take action consistent with Good Utility Practice, including but not limited to curtailing service for purposes of making adjustments to, changes in or repairs in cases where service would endanger persons or property. 29. OG&E and Red Dirt’s improper connection of phased power to the neutral conductors was a proximate cause of the fire and total loss of the Property. 30. As a result of the improper connection made by OG&E and Red Dirt, Plaintiffs suffered damages in excess of $60,000,000. ‘AUSES OF ACTION AGAINST OKLAHOMA GAS AND ELECTRIC COMPANY A. NEGLIGENCE 31. Atall relevant times, OG&E had or should have had specialized knowledge of the electric utility business, including the proper, safe, and accepted methods for making all final electrical connections at the point of delivery. 32. OGRE, as operator of the electric utility that provided electricity to the Property, owed Plaintiffs a duty to exercise reasonable care to avoid a foreseeable risk of injury to others, to perform its work with the same care as a reasonably prudent electrical service utility and to provide safe and continuous electrical service. OG&E breached its duties in one or more of the following ways: i, Failing to perform its scope of work in a safe and competent manner, and in compliance with all codes, regulations and industry standards; Failing to ensure there was no objectionable flow of current over the grounding conductor (NESC, §9(D)); Failing to comply with the Federal Energy Regulatory Commission (“FERC”) regulations and applicable Oklahoma Gas and Electric Company FERC Electric Tariff, and failing to take action consistent with Good Utility Practices, including but not limited to curtailing service for purposes of making adjustments to, changes in or repairs in cases where service would ‘endanger persons or property; Failing to comply with and adhere to the National Electric Code, consistent with Good Utility Practice, including §110.7, which provides that “wiring installations shall be free from short circuits, ground faults, or any connections to ground other than as required or permitted elsewhere” in NEC Code; Failing to exercise reasonable care in connecting power to the Property; Improperly communicating to its electrical subcontractor regarding which switchgear was ready to accept power; Failing to inspect and test the connections made at the switchgear to ensure that all connections were proper, safe and ready to receive power; Failing to make proper connections at the point of delivery (transformer secondary bushing) and/or to ensure that its contractors made the proper connections at the point of delivery; Failing to ensure that wiring installations shall be free from short circuits, ground faults, or any connections to ground; Failing to use an ohm meter, Megger, or continuity tester to check the connections for short circuits, ground faults, or any connections to ground which would have immediately revealed the existence of a defective condition that could have been remedied without damage to the property; Performing work in such a manner as to unreasonably subject the Property to risk of electrical damage; Failing to wam Plaintiffs of the dangerous and/or hazardous condition Defendant created at the Property; 10 m. Failing to hire a competent and qualified electrical contractor to perform services on behalf of and at the request of OG&E; n. Failing to properly train and supervise its personnel, employees, contractors and independent contractors to ensure that all work was performed safely and correctly; ©. Failing to properly communicate with its electrician regarding the color scheme utilized by OG&E which is in contradiction to commonly used color schemes related to neutral/ground wires so they are not inadvertently energized; p. Failing to act as a reasonably prudent electrical utility would have acted under the same or similar circumstances; and q. Otherwise failing to use due care under the circumstances. 33, Each of the above-referenced acts and omissions, separately and/or in combination with others, constitutes negligence, including gross negligence, on the part of OG&E and is a direct and proximate cause of the Incident and damages suffered by Plaintiffs, which are in excess of the ‘minimum jurisdictional limits of this Court. 34. Plaintiffs are entitled to recover reasonable attorney's fees, court costs and interest to be set by the Court. B, GROSS NEGLIGENCE 35. OG&E’s acts, errors and/or omissions described herein constitute gross negligence, willful and wanton conduet, and reckless disregard of Plaintiffs’ safety and property. Such actions, which involved high-voltage electricity, constituted conduct life-threatening to humans. 36. The nature of the gross negligence and/or willful conduct is such as to entitle Plaintiffs to an award of punitive damages sufficient to deter like conduct in the future. 37. Plaintiffs are entitled to recover reasonable attomey’s fees, court costs and interest to be set by the Court. u = NEGLIGENCE PER SE 38, The work performed by OG@&E at the Property was inherently dangerous. 39. OG&E was required to perform work in accordance with and in conformance with the National Electric Safety Code, National Electric Code, and all applicable OSHA codes and ordinances, which were established to protect persons and property, including Classen Curve and the Property, and to promote public safety. 40. OG&E’s failure to provide safe electrical service at the Property violated safety laws that were in place to prevent the very thing that occurred on the day of the Incident. 41, The Incident and Plaintiffs’ resultant damages were caused by OG&E’s violation of safety regulations. 42. Plaintiffs are entitled to recover reasonable attomey’s fees, court costs, and interest to be set by the Court. D. H_OF_IMPLIED WARRANTY OF )D_AND_Wi PERFORMANCE, 43. Asan operator of an electric utility servicing thousands of customers in Oklahoma, OG&E expressly and/or impliedly purported to be specially qualified in the methods and standards associated with installing, maintaining and servicing equipment used to supply electrical power to its customers’ property. 44. OG@&E failed to properly and safely connect power to the Property. 45. OGRE failed to perform work at the Property in accordance with applicable codes, regulations and industry standards. 46. OG&E failed to comply with the Federal Energy Regulatory Commission (“FERC”) regulations and applicable Oklahoma Gas and Electric Company FERC Electric Tariff, and take action consistent with Good Utility Practices, including but not limited to curtailing 12 service for purposes of making adjustment to, changes in or repairs in cases where service would ‘endanger persons or property. 47, OG&E failed to make proper connections at the point of delivery and/or verify that its contractor made the proper connections at the point of delivery. 48. OG&E failed to ensure that completed wiring installations were free from short circuits, ground faults, or any connections to ground. 49. OG&E failed to use an ohm meter, Megger, or continuity tester to check the connections for short circuits, ground faults, or any connections to ground which would have immediately revealed the existence of a defective condition that could have been remedied without damage to the property. 50. OG&E’s work at the Property was not performed in a manner consistent with the industry standard of care. 51. OGRE breached its nondelegable duty to ensure the safe delivery of power. 52. OG&E’s acts and omissions constitute a breach of the express and/or implied ‘warranty that Defendants would perform their scope of work in a good and workmanlike manner. 53. OG&E’s breach of its express and/or implied warranties was a proximate cause of Plaintiffs’ damages as set forth herein. E. VICARIOUS LIABILITY 54. OG&E’s duties to Plaintiffs were nondelegable because, inter alia, the activities described herein were inherently dangerous. 55, _ Inaddition to liability for its own direct negligence, OG&E is vicariously liable for the acts, errors and omissions of Red Dirt, including, without limitation, for its acts, errors and 1B omissions constituting actionable negligence and is vicariously liable for any punitive damages assessed against Red Dirt. CAUSES OF ACTI :AINST RED DIRT ELECTRIC, LL A. NEGLIGENCE 56. Electrical construction and maintenance services are recognized as involving dangerous and hazardous conditions, which require a higher standard of care for persons working in the industry. 57, Asthe chosen subcontractor of OGRE, Red Dirt had or should have had specialized knowledge of electrical construction, overhead and underground power distribution, as well as the proper, safe, and accepted methods for making proper connections at the point of delivery at new construction projects. 58. Red Dirt owed a duty to exercise reasonable care to avoid a foreseeable risk of injury to others, to perform its work with reasonable care and skill, and to act with reasonable skill and diligence in performing its services so as not to injure persons or property. Red Dirt breached these duties in one or more of the following ways: a, Failing to perform its scope of work in a safe and competent manner, and in compliance with all codes, regulations and industry standards; b. Failing to exercise reasonable care in connecting power to the Property; c. Failing to ensure there was no objectionable flow of current over the grounding conductor (NESC, §9(D)); d. Failing to comply with and adhere to the National Electric Code, consistent with Good Utility Practices, including §110.7, which provides that “wiring installations shall be free from short circuits, ground faults, or any connections to ground other than as required or permitted elsewhere” in NEC Code; ¢. Failing to inspect and test the connections it made at the point of delivery to ensure that all connections were proper and safe; 14 P. Failing to make proper connections at the point of delivery (transformer secondary bushing); Failing to ensure that completed wiring installations shall be free from short circuits, ground faults, or any connections to ground; Failing to use an ohm meter, Megger, or continuity tester to check the connections for short circuits, ground faults, or any connections to ground which would have immediately revealed the existence of a defective condition that could have been remedied without damage to the property; Failing to conduct a proper inspection of the Property to ensure that no dangerous conditions existed on and within the Property before leaving the Property; Performing work in such a manner as to unreasonably subject the Property to risk of electrical damage; Failing to warn Plaintiff of the dangerous and/or hazardous condition Defendants created at the Property as a result of the work they performed; Failing to hire competent employees with the requisite knowledge, training and experience to perform electrical work at the Property; Failing to properly train and supervise its personnel, employees, contractors and independent contractors to ensure that all work was performed safely and correctly; Failing to consider, appreciate and take appropriate precautionary action to avoid dangerous conditions that present an unreasonable risk of injury, harm or damage to persons or the Property; Failing to act as a reasonably prudent electrical contractor would have acted under the same or similar circumstances; and Otherwise failing to use due care under the circumstances. 59. Each of the above-referenced acts and omissions, separately and/or in combination with others, constitutes negligence including gross negligence, on the part of Red Dirt, and are a direct and proximate cause of the Incident and damages suffered by Plaintiffs. 15 60. Plaintiffs are entitled to recover reasonable attorney’s fees, court costs and interest to be set by the Court. B. GROSS NEGLIGENCE 61. Red Dirt’s acts, errors, and/or omissions described herein constitute gross negligence, willful and wanton conduct, and reckless disregard of Plaintiffs’ safety and property. Such actions also constituted conduct life-threatening to humans. 62, The nature of the gross negligence and/or willful conduct is such as to entitle Plaintifis to an award of punitive damages sufficient to deter like conduct in the future. 63, Plaintiffs are entitled to recover reasonable attorney's fees, court costs, and interest to be set by the Court. . NEGLIGENCE PER SE 64. The work performed by Red Dirt at the Property was inherently dangerous. 65. Red Dirt was required to perform work in accordance with and in conformance to the National Electric Safety Code, National Electric Code, and all applicable OSHA codes and ordinances, which were established to protect persons and property, and to promote public safety. 66. Red Dirt’s improper connection of a phased conductor to a neutral at the Property violated safety laws that were in place to prevent the very thing that occurred on the day of the Incident. 67. The fire and Plaintiffs’ resultant damages were caused by Red Dirt’s violation of safety regulations. 68, Plaintiffs are entitled to recover reasonable attorney's fees, court costs and interest to be set by the Court. 16 JURY DEMAND 69. Plaintiffs respectfully request that this Court empanel a lawful jury to try this cause. RESERVATION OF RIGHTS 70. Plaintiffs specifically reserve the right to bring additional causes of action against Defendants and to amend this Petition as necessary. PRAYER WHEREFORE, Plaintiffs seek judgment against Defendants for damages in excess of the minimum jurisdictional limits of this Court; punitive damages; costs of this action; reasonable attorneys’ fees; prejudgment interest at the highest legal rate; post-judgment interest at the highest legal rate; Court costs; and for such other and further relief, general or special, both at law and in equity, to which Plaintiffs may show they are justly entitled. ATTORNEY LIEN CLAIMED Respectfully submitted,

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