Just A Complaint On Wrongful Death

These are a rare sort as wrongful death attorneys have to work too hard. A wrongful death attorney fights all odds. They cry. The wrongful death attorney spends his families money to fight for a conclusion to a wrongful death. It is not cheap, but families are devastated and they have to stand up. Wrongful death attorneys stand for families and the dead.

Do not take these wrongful death attorneys as regular. They have a heart and soul to do these things and it is really hard, even on their own families.

1. The only living heirs of ----‘’’’’’ the deceased in this complaint are ------

2. Plaintiffs are the surviving heirs at law of the decedent plaintiff ------ is the surviving spouse of the decedent and plaintiffs ----- were dependents.

3. Perhaps 3 for dependent grandchildren.

4. Each and every plaintiff are joined in this action. Pursuant to California Code of Civil Procedure section 382. There are no other heirs that are known at this time.

5. Plaintiffs do not know the true names of defendants named a DOES 1 through 20 inclusive and thereby sue them by these named DOES. Plaintiffs are informed and believe, and on the basis of that information and belief allege, that each of those defendants was in some manner were negligent and proximately responsible for the events and happenings allege in this complaint and the damages suffered by plaintiffs and each of them.

6. Plaintiffs are informed and believe, and on that basis of information allege that during all times mentioned herein each defendant named as a doe were the employees or agents of the other named defendants and at all time mentioned were acting and the control and direction of the named defendants. They were acting in the course and scope of either that employment or agency.

7. Defendant GEO---- is now and at all times mentioned herein was a corporation listed and incorporated in the State of California and maintained a business and enterprise in San Diego County in the downtown of the city of San Diego.

8. Defendant GEO --- was and is now in the business of running a private jail/prison for the state of California and the county of San Diego. And at the place of business is where the death of decedent did occur. Defendant GEO did act negligently in running that jail which in fact caused the death of decendent ‘’’’’.

9. To be clear, for jurisdictional purposes defendant did run their business at ----- st in San Diego.

10. Defendant did in fact house and confine prisoners for the state of California and it’s municipalities. Further they confined prisoners for the Federal government and must be held to the standards set forth thereby which they did not do at the time of death of the decedent.

11. Sometime prior to decedents death the standard of care for such private detention facilities fell below acceptable standards lead to the death of decedent “”.

12. At all times mentioned herein defendants and each of them so negligently and carelessly maintained their facility that it rises to the degree of gross negligence and intentional misconduct for the purpose of profits that fits the standard for punitive damages. It was dangerous and unsafe for inmates not yet convicted of crimes and created a public danger.

13. As a direct and proximate result of defendants above referenced negligent and careless and willful conduct decedent died, while in their care and custody.

14. The above resulted in decedent’s death on---- while in defendants care.

15. As the direct and proximate cause and result of the foregoing and the resulting death of the decedent, Plaintiffs and all of them have been deprived and will deprived of the loving and caring comfort of the spouse and father and ------. Society, comfort, care, companionship, guidance, affection, marital consortium, physical assistance and love have been lost forever. The home cannot be maintained anymore without this participation. Hope is lost forever. There is no replacement for the decedents guiding hand. Financial support is gone. Years of contribution lost forever.

(I combined some stuff to show a joint loss) I may rethink that/////

16. As a further and direct result and proximate cause as alleged every and each plaintiff financially to be proven at trial, pursuant to California Codes of Civil Procedure sections 425. Punitive damages must be included as the motive for such negligence was clearly corporate profit without a care.

17. Further as a direct and proximate cause, attorney fees have been incurred as have the costs of funeral and other expenses to lay the body to rest. These will be proven at the time of trial pursuant to proper compliance with rules and procedure.

I do figure that folks need to do some soul searching. Most the time I say stand and fight but maybe for you and yours you just need to roll over. I get but I fight for people who cannot fight for themselves. Just my blood. I work with the finest moral men I know and they fight for others. Damn good men and women. So maybe if something went wrong and your loved one went down wrong call one.