IN THE CIRCUIT COURT OF HAMILTON COUNTY, TENNESSE! and ERMC II] PROPERTY MANAGEMENT COMPANY, LLC, TERIANCE COPELAND and CAROL * COPELAND, both individually and anf = * TECARA COPELAND, * . a Plaintiffs, 7 NO. jEC Ie Ws vs. * DIVISION, CBL & ASSOCIATES PROPERTIES, INC. * JURY DEMAND Defendants. COMPLAINT ‘The Plaintiffs, Teriance Copeland and Carol Copeland, both individually and a/n/f TeCara Copeland (“Plaintiffs”), hereby files their Complaint against the Defendants, CBL & Associates Properties, Inc. (“Defendant CBL”) and ERMC Ill Property Management Company, LLC (“Defendant ERMC”), and shows the Court the following: 1. The Plaintiffs are residents and citizens of Hamilton County, Harrison, Tennessee. 2. Defendant CBL is a foreign for-profit corporation licensed to do business in the state of Tennessee. 3. Defendant ERMC is a domestic limited liability company licensed to do business in the state of Tennessee. 4, The facts giving rise to this Complaint occurred in Hamilton County, Chattanooga, Tennessee, therefore this Court has both subject matter and personal jurisdiction. 6. On December 26, 2016, the busiest shopping day of the year, the Plaintiffs were customers of premises owned by Defendant CBL. 7. ‘The Plaintiffs were shopping at the mall where they were injured by human stampedecaused by the incident in the food court, 8. The Plaintiffs were trampled and injured as a result of this human stampede. 9. The Defendants had an obligation to provide a safe environment in which the Plaintiffs could shop, 10, The Defendants had a duty to have policies and procedures in effect that would prevent! the human stampede from happening. 11. Upon information and belief, a group of individuals inside the mall set off fireworks in the food court area of the mall causing panic and the human stampede that caused injuries to the Plaintiffs, 12, The Defendants were under an obligation to provide adequate security to prevent the human stampede from occurring. 13, The Defendants were negligent by failing to have adequate policies and procedures and by failing to provide adequate security during the busiest shopping day of the year. 14. Asa result of the Defendants’ negligence, the Plaintiffs sustained personal injuries. WHEREFORE, Plaintiff prays as follows: (1) That summons and process issue and be served in the time and manner prescribed by Tennessee law; (2) That a jury of twelve be empaneled to hear this cause; (3) That Plaintiff Teriance Copeland be awarded damages in the amount of $50,000.00; (4) That Plaintiff Carol Copeland be awarded damages in the amount of $50,000.00; (8) That Plaintiff TeCara Copeland be awarded damages in the amount of $50,000.00; and (6) Any and all other general and equitable relief the Court may deem just.Respectfully submitted, WARREN & GRIFFIN, P, BY: C. Midrk Warren John Mark Griffin (BPR #14105) “Attorneys for Plaintiff Suite 600, Dome Building 736 Georgia Avenue Chattanooga, TN 37402 (423) 265-4878 (BPR #013992)IN THE CIRCUIT COURT OF HAMILTON COUNTY, TENNESSEE TERIANCE COPELAND and CAROL COPELAND, both individually and a/n/f TECARA COPELAND, Plaintiffs, NO. [GC 14Gb 40 vs. DIVISION CBL & ASSOCIATES PROPERTIES, INC. JURY DEMAND > and ERMC Ill PROPERTY MANAGEMENT COMPANY, LLC, Defendants. COST BOND The undersigned acknowledges and hereby binds the undersigned for the payment of all costs in this Court which may at any time be adjudged against Teriance Copeland and Carol Copeland, both individually and a/n/f TeCara Copeland, the principal herein, in the event said principal shall not pay the same if so ordered by this Court. my hand nisl ay of Wttvalatr— 2016. Respectfully submitted, WITNI WARREN & GRIFFIN, P.C- C. Mark Warren: (BPR #013992) John Mark Griffin (BPR #014105) Attomeys for Plaintiff Suite 600, Dome Building 736 Georgia Avenue Chattanooga, TN 37402 (423) 265-4878 BY: