Case 2:12-cv-00060-RWS Document 4

Filed 03/26/12 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION
ANNA K. MARTIN, Plaintiff, v. GAINEY TRANSPORTATION SERVICES, INC. and ACE AMERICAN INSURANCE COMPANY, Defendants. CIVIL ACTION FILE NO.: 2:12-CV-0060

AMENDMENT TO COMPLAINT
COMES NOW the plaintiff ANNA K. MARTIN, by and through her undersigned counsel of record, and hereby amends her complaint for damages for the purpose of correcting misnomer and respectfully shows the Court as follows : 1. Defendant Gainey Transportation Services, Inc., who is referred to in plaintiff's complaint as defendant Gainey, has amended its articles of incorporation to change its name to Old GTS, Inc. and has been determined to be doing business under the assumed names Gainey Transportation Services Inc., GTS, Inc.,

Gainey Transportation Services and Gainey Specialized Transport.

Case 2:12-cv-00060-RWS Document 4

Filed 03/26/12 Page 2 of 3

2. Plaintiff hereby amends the caption of the complaint in this action so as to substitute defendant Gainey Transportation Services, Inc. with Old GTS, Inc.

d/b/a Gainey Transportation Services Inc. d/b/a GTS, Inc. d/b/a Gainey Transportation Services d/b/a Gainey Specialized Transport.
3. Plaintiff hereby amends every paragraph of her complaint in this action that contains any reference to defendant Gainey Transportation Services, Inc. (referred to throughout the complaint as defendant Gainey) so as to substitute defendant Gainey Transportation Services, Inc. (referred to throughout the complaint as defendant Gainey) with Old GTS, Inc. d/b/a Gainey Transportation Services

Inc. d/b/a GTS, Inc. d/b/a Gainey Transportation Services d/b/a Gainey Specialized Transport.
4.

Old GTS, Inc. d/b/a Gainey Transportation Services Inc. d/b/a GTS, Inc. d/b/a Gainey Transportation Services d/b/a Gainey Specialized Transport
may be served with a copy of the complaint and summons through its registered agent, The Corporation Company at 30600 Telegraph Road, Suite 2345, Bingham Farms, MI 48025-5720.

Case 2:12-cv-00060-RWS Document 4

Filed 03/26/12 Page 3 of 3

Respectfully submitted, this 26th day of March, 2012.

LA W OFFICES OF R. SHANE SMITH,

P.C.

By: /s/ R. Shane Smith R. SHANE SMITH Georgia Bar No. 663357 /s/ Jason N. Slate JASONN. SLATE Georgia Bar No. 846650 Attorneys for Plaintiff 263 Highway 74 North Post Office Box 2474 Peachtree City, Georgia 30269 P: (770) 487-8999 F: (770) 631-7667 www.shanesmithlaw.com

Case 2:12-cv-00060-RWS Document 4-1

Local F onn 440 ( 12/09) Summons in a Civil Action

Filed 03/26/12 Page 1 of 2

UNITED STATES D ISTRICT COURT

for the
-----

Northe rn

District of Georgia

Anna K. Martin
Plaintiff

v.
Gainey Transportation Services , Inc. and Ace American Insurance Company

Defendant

) ) ) ) ) ) )

Civil Action No.

2: 12-CV-0060

SUMMONS IN A CIVIL ACTION

To : (Defendant 's name and address)

Old GTS , Inc. d/b/a Gainey Transportation Services, Inc. d/b/a GTS , Inc. d/b/a Gainey Transportation Services d/b/a Gainey Specialized Transport c/o Th e Corporation Company 30600 Telegraph Rd. , Suite 2345 Bingham Farm s, MI 48025-5720
A lawsuit has been filed against you. Within 21 days after service of this summons on you (not counting the day you received it) - or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) - you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney, whose name and address are: R. Shane Smith, Esq. Jason N. Slate, Esq . Law Offices of R. Shane Smith, P.C. P.O. Box 2474 Peachtree City, GA 30269 If you fail to respond, judgment by default will be entered against you for the reI ief demanded in the complaint. You also must file your answer or motion with the court.

CLERK OF CO URT

Date: _ _ _ _ _ __ _ __
Signature of Clerk or Deputy Clerk

Case 2:12-cv-00060-RWS Document 4-1

Local Fonn 440 (12/09) Summons in a Civil Action (page 2)

Filed 03/26/12 Page 2 of 2

Civil Action No. ~~ 1 - cV- C060 2..

PROOF OF SERVICE (This section must be filed with the court unless exempted by Fed. R. Civ. P. 4 (I).)
This summons for (name a/individual and title, if any) was received by me on (date)

D I personally served the summons on the individual at (place)

------------------------------------------------on (date)
--------- - - - - - (name)

; or

D I left the summons at the individual ' s residence or usual place of abode with
---------------------------------on (date)
---------------

, a person of suitable age and discretion who resides there,

, and mailed a copy to the individual ' s last known address; or , who is

D I served the summons on (name a/individual)

designated by law to accept service of process on behalf of (name 0/ organization) on (date) ; or

-------------------------------------------------

I returned the summons unexecuted because

-------------------------------------------

; or

D Other (specify):

My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server 's signature

Printed name and title

Server 's address

Additional information regarding attempted service, etc :