Professional Documents
Culture Documents
Zachary Barnes
LDSBC Law Firm
2345 E 1800 S
SLC, UT 84101
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STATE OF UTAH
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Plaintiff,
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vs.
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Congden,
Defendant
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Amache,
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NATURE OF CASE
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recover more than $200,000 of damages caused by Congdens failure to act. Amache
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suffered sever injuries due to Congdens actions and inactions and therefore we are
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seeking to recover for medical bills, loss of wages from work absence, and pain and
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suffering damages.
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2. The Second Judicial District Court in and for Summit County, State of Utah,
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has jurisdiction of the claims asserted below pursuant to the provisions of 78A-5-
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3. Venue is properly laid before the Fourth Judicial District Court in and for
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Wasatch County, State of Utah, pursuant to the provisions of 78B-3-307, Utah Code
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Ann, in that the causes of action alleged below arose within Wasatch County, State of
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Utah.
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Amache v. Congden - 1
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FACTS
4. Leroy Cogden and his wife Margie are the owners and managers of Maple Meadows
Campground. It was the busiest time of the year for them and they were informed that
some of the electrical outlets in the camp sites were not functioning properly. The
repairs were going to require the Cogdens to close sites 30 through 39 until repairs
could be made. They did not want to cancel those reservations for those sites so they
postponed the repairs until Sept 7, 2016 and scheduled that with an electrician.
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5. For the mean time Mr. Cogden ran an extension cord from the outlet at site 40
to the sites with faulty electrical outlets. The extension chord was broken in several
places, which Mr. Cogden knew, and he still place the chord.
6. The Amaches arrived in camp site 36 and their six-year-old son Zach went off
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to play around the site. He stumbled across the broken chord and pulled it away into a
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grassy area. The Amaches then noticed a flickering behind their camper and upon
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inspection found their son Zach trapped in the grass surrounded by fire. Mr. Amache
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saved their son from the fire but was burned severely in the process.
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NEGLIGENCE
7. Cogden was required as a business owner and manager of a campsite to exercise
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reasonable care and diligence to ensure that they site was safe for all ages. The
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defendant breached their duty of care by failure to notify the Amache family of the
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electrical malfunction and danger at the camp site they were directed to.
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Plaintiffs have suffered, continue to suffer, and will suffer in the future, injuries,
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including pain of body and mind, medical treatment, lost wages, disability,
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Amache v. Congden - 2
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9. Plaintiffs hereby request that this matter be tried to a jury and Plaintiffs
have submitted their jury fee herewith
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at trial
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$25,000.00
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currently are and are not limited to, severe burns on both legs,
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e. Costs of suit and such further relief as the court deems just and
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proper.
II.
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LDSBC
Zachary Barnes
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Amache v. Congden - 3