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General Civil and Domestic Relations Case Filing Information Form
☐ Superior or ☐ State Court of ______________________________ County
For Clerk Use Only
Date Filed _________________________ Case Number _________________________
MM-DD-YYYY
Plaintiff(s) Defendant(s)
__________________________________________________ __________________________________________________ Last First Middle I. Suffix Prefix Last First Middle I. Suffix Prefix
__________________________________________________ __________________________________________________ Last First Middle I. Suffix Prefix Last First Middle I. Suffix Prefix
__________________________________________________ __________________________________________________ Last First Middle I. Suffix Prefix Last First Middle I. Suffix Prefix
__________________________________________________ __________________________________________________ Last First Middle I. Suffix Prefix Last First Middle I. Suffix Prefix
Plaintiff’s Attorney ________________________________________ Bar Number __________________ Self-Represented ☐
Check One Case Type in One Box
General Civil Cases
☐ Automobile Tort
☐ Civil Appeal
☐ Contract
☐ Garnishment
☐ General Tort
☐ Habeas Corpus
☐ Injunction/Mandamus/Other Writ
☐ Landlord/Tenant
☐ Medical Malpractice Tort
☐ Product Liability Tort
☐ Real Property
☐ Restraining Petition
☐ Other General Civil
Domestic Relations Cases
☐ Adoption
☐ Dissolution/Divorce/Separate
Maintenance
☐ Family Violence Petition
☐ Paternity/Legitimation
☐ Support – IV-D
☐ Support – Private (non-IV-D)
☐ Other Domestic Relations
Post-Judgment – Check One Case Type
☐ Contempt
☐ Non-payment of child support,
medical support, or alimony
☐ Modification
☐ Other/Administrative
☐ Check if the action is related to another action(s) pending or previously pending in this court involving some or all
of the same parties, subject matter, or factual issues. If so, provide a case number for each.
____________________________________________ ____________________________________________
Case Number Case Number
☐ I hereby certify that the documents in this filing, including attachments and exhibits, satisfy the requirements for
redaction of personal or confidential information in O.C.G.A. § 9-11-7.1.
☐ Is an interpreter needed in this case? If so, provide the language(s) required. ________________________________ Language(s) Required
☐ Do you or your client need any disability accommodations? If so, please describe the accommodation request.
_________________________________________________________________________________________________________________________
_________________________________________________________________________________________________________________________
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-0087406-01-2020
1
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
2
SUMMONS—HOUSING AUTHORITY OF SAVANNAH
TO THE ABOVE-NAMED DEFENDANT: Housing Authority of Savannah (“HAS”) operates a
principal place of business at 1407 Wheaton St. Savannah, GA. HAS can be served via personal
service on its executive director Earline W. Davis. The Housing Authority of Savannah is hereby
summoned, required to file with the clerk of said Court, and serve upon Plaintiff’s attorney, whose
name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
3
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
4
SUMMONS—ENVOLVE COMMUNITY MANAGEMENT, LLC
TO THE ABOVE-NAMED DEFENDANT: Envolve Community Management, LLC (Formerly
LEDIC Management Group, LLC) operates a principal place of business at 555 Perkins Ext., Floor
2 Memphis, TN 38117. Envolve can be served via personal service on its registered agent
Corporate Service Company, 40 Technology Parkway South, Suite 300 Norcross, Gwinnett
County, GA 30092. Envolve Community Management, LLC is hereby summoned, required to file
with the clerk of said Court, and serve upon Plaintiff’s attorney, whose name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
5
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
6
SUMMONS—HUNT COMPANIES, INC.
TO THE ABOVE-NAMED DEFENDANT: Hunt Companies, Inc. is the foreign limited liability
corporation who operates a principal place of business at 4401 North Mesa El Paso, TX 79902-
1107. She also resides in Savannah, GA. Hunt can be served via personal service on its registered
agent for service Capitol Corporate Services, Inc., located at 3675 Crestwood Parkway, N.W.,
Suite 350, Duluth, Gwinnett County, Ga 30096. Hunt Companies, Inc. is hereby summoned,
required to file with the clerk of said Court, and serve upon Plaintiff’s attorney, whose name and
address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
7
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
8
SUMMONS—HITCH PHASE II, L.P.
TO THE ABOVE-NAMED DEFENDANT: Hitch Phase II, L.P., operates a principal place of
business at 4401 North Mesa, Attn: Legal Department, El Paso, TX 79902-1107. HAS can be
served via personal service on its registered agent Capitol Corporate Services, Inc., located at 3675
Crestwood Parkway, N.W., Suite 350, Duluth, Gwinnett County, Ga 30096. Hitch Phase II, L.P.
is hereby summoned, required to file with the clerk of said Court, and serve upon Plaintiff’s
attorney, whose name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
9
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
10
SUMMONS—NO PUNCHES PULLED SECURITY
TO THE ABOVE-NAMED DEFENDANT: No Punches Pulled Security operates a principal place
of business at 1715 Derry Avenue Atlanta, GA 30377/PO Box 94181 ATL, GA 30377. It can be
served via personal service on its owner, Hassan Rashid at 1715 Derry Avenue Atlanta, GA 30377.
No Punches Pulled Security is hereby summoned, required to file with the clerk of said Court, and
serve upon Plaintiff’s attorney, whose name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
11
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
12
SUMMONS—EARLINE W. DAVIS
TO THE ABOVE-NAMED DEFENDANT: Earline W. Davis is the Executive Director of The
Housing Authority of Savannah who operates a principal place of business at 1407 Wheaton St.
Savannah, GA. She also resides in Savannah, GA. She can be served via personal service at either
her residence or The Housing Authority’s place of business. Earline W. Davis is hereby
summoned, required to file with the clerk of said Court, and serve upon Plaintiff’s attorney, whose
name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
13
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
14
SUMMONS—YOLANDA FONTAINE
TO THE ABOVE-NAMED DEFENDANT: Yolanda Fontaine is the Director of Property
Management of The Housing Authority of Savannah who operates a principal place of business at
1407 Wheaton St. Savannah, GA. She also resides in Savannah, GA. She can be served via
personal service at either her residence or The Housing Authority’s place of business. Yolanda
Fontaine is hereby summoned, required to file with the clerk of said Court, and serve upon
Plaintiff’s attorney, whose name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
15
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
16
SUMMONS—IRVENIA BROOKS
TO THE ABOVE-NAMED DEFENDANT: Irvenia Brooks is the Property Manager of The View
at Oglethorpe which operates a principal place of business at 280 Randolph St.. Savannah, GA.
She also resides in Savannah, GA. She can be served via personal service at either her residence
or The View’s place of business. Irvenia Brooks is hereby summoned, required to file with the
clerk of said Court, and serve upon Plaintiff’s attorney, whose name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
17
IN STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
18
SUMMONS—ROBERT MARSHALL
TO THE ABOVE-NAMED DEFENDANT: Robert Marshall is the Director of Facilities
Management for The Housing Authority of Savannah who operates a principal place of business
at 1407 Wheaton St. Savannah, GA. He also resides in Savannah, GA. He can be served via
personal service at either his residence or The Housing Authority’s place of business. Robert
Marshall is hereby summoned, required to file with the clerk of said Court, and serve upon
Plaintiff’s attorney, whose name and address is:
The Mance Law Firm, LLC
Chadrick A. Mance
24 Commerce Place, Suite C
Savannah, GA 31406
Tel: (912)574-4529
an answer to the complaint that is herewith served upon you, within 30 days after the service of
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default
will be taken against you for the relief demanded in the complaint.
This 1st day of June, 2020.
Clerk of Chatham County State Court
Deputy Clerk
By:
To Defendant upon whom this petition is served:
This copy of complaint and summons was served upon you ____________________, 2020.
____________________________________________, Deputy Sheriff
I
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
/s/ Joann Darden
19
N STATE COURT OF CHATHAM COUNTY
STATE OF GEORGIA
Deontray Grant, individually as the
surviving next of kin of Shawntray Grant,
deceased, and as the Administrator of the
estate of Shawntray Grant,
Plaintiff,
v.
Housing Authority of Savannah,
Hitch Phase II, L.P.,
Envolve Community Management, LLC,
Hunt Companies, Inc.,
No Punches Pulled Security,
Earline W. Davis,
Yolanda Fontaine,
Irvenia Brooks,
Robert Marshall,
ABC Corporations 1-3, and
John Does 1-3.
Defendants.
CIVIL ACTION
FILE NO.:
JURY TRIAL DEMANDED
COMPLAINT
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
STCV20-00874
20
Deontray Grant, individually, as surviving next of kin of Shawntray Grant, and as Administrator
of Shawntray Grant’s estate, (“Plaintiff”) files this Complaint and shows the following:
I. INTRODUCTION
1. Dangerous low-income housing is a big business in which corporations receive hundreds of
millions in governmental assistance to provide safe housing to vulnerable populations.
2. Defendants are part of the big business of low-income housing in America.
3. Defendants valued profits over the safety of The View at Oglethorpe (“The View”), a
property owned, managed, funded or controlled by them.
4. The View is a Housing Authority of Savannah (“HAS”) apartment complex located in an
area plagued by violent crime.
5. The View’s inadequate security created an ideal incubator for violent crimes.
6. For decades, HAS tolerated a vicious cycle of violence and crime in its neighborhoods.
7. For decades, based upon information and belief, HAS, Hitch Phase II (“Hitch”), Envolve
Community Management, LLC (“Envolve”), and Hunt Companies, Inc., (“Hunt”),
collectively received hundreds of millions in governmental assistance from similar housing
arrangements but allowed The View to become an epicenter for crime harming generations
of innocent people.
8. To comply with safety requirements, Defendants took minimal steps to keep The View
reasonably safe from preventable crime, despite their multitude of resources.
9. Based on age, sex, location, race, and weapon, Shawntray Grant’s death in a dangerous
neighborhood with minimal security was foreseeable and avoidable according to
governmental statistics
10. On June 15, 2018, three opportunistic criminals tragically and horrifically robbed and
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
21
gunned-down anti-violence activist Shawntray Grant in The View’s parking lot.
11. Plaintiff sues Defendants for Shawntray Grant’s preventable, foreseeable, wrongful death
claiming damages in excess of $100,000,000.00.
II. PARTIES, JURISDICTION, AND VENUE1
12. Shawntray Grant died without a will on June 15, 2018. He left no surviving spouse, children,
or parent. Plaintiff is entitled, under O.C.G.A. § 51-4-5, to bring this action for Shawntray’s
next of kin, namely, Deontray Grant, Angela Grant Mack, Kaiisha Simmons Williams,
Clarence Singleton, Terry Grant, Erika Jenkins, Robert A. Grant, Clarence Grant Jr., Willie
Earl Simmons Jr., Terry K. Grant, and Tara E. Grant (siblings).
13. A citizen and resident of Chatham County, Georgia, Plaintiff is the Administrator under The
Temporary Letters of Administrator and Order Appointing him as administrator, executed by
the Chatham County Probate Court. (See Exhibit A-Temporary Letters of Administration and
Order, May 19, 2020.) As the next of kin and Administrator, Plaintiff is the proper party to
bring an action for, recover, and hold the amount recovered for the benefit of Shawntray’s
next of kin.
14. The Housing Authority of Savannah (“HAS”), is an owner, occupier, and landlord of The
View (formerly Robert Hitch Village) and other dangerous housing within a 2-mile radius of
The View. HAS is a public housing authority and body politic organized under Title 8 of the
Official Code of Georgia. HAS may be served with a copy of the Summons, Complaint and
1 All foreign Corporate Defendants, should they have no registered agent or their registered
agents cannot be served with reasonable diligence, can be served by registered or certified mail
or statutory overnight delivery, return receipt requested, addressed to the chief executive officer,
chief financial officer, or secretary of the foreign corporation, or a person holding a position
comparable to any of the foregoing, at their principal office shown in the later of their
applications for a certificate of authority or their most recent annual registration.
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
22
discovery by leaving a copy with its Executive Director, Earline W. Davis, at 1407 Wheaton
St. Savannah, GA 31404.
15. Envolve Communities2 (“Envolve”) (Formerly “LEDIC Management Group, LLC”) was
hired/retained by Hunt Companies, Inc. and HAS, as the “management agent” of The View.
It is a foreign limited liability company whose principal office address is located at 555
Perkins Ext., Floor 2 Memphis, TN 38117. It may be served by leaving a copy of the
Summons, Complaint, and discovery with its registered agent, Corporate Service Company,
40 Technology Parkway South, Suite 300 Norcross, Gwinnett County, GA 30092.
16. Hunt Companies, Inc. served as The Housing Authority of Savannah’s development partner
for The View. Hunt Companies, Inc. is a foreign limited liability corporation. Hunt may be
served by leaving a copy of the Summons and Complaint with its registered agent Capitol
Corporate Services, Inc. located at 3675 Crestwood Parkway, N.W., Suite 350 Duluth,
Gwinnett County, GA 30096.
17. Hitch served as the tenant at The View, pursuant to Ground Lease Agreement. Hitch
subleased the premises to tenants such as Shawntray Grant. It is a Georgia domestic limited
partnership. Its principal office address is 4401 North Mesa, Attn: Legal Department, El
Paso, TX 79902-1107. It may be served through leaving a copy of the Summons, Complaint,
and discovery with its registered agent, Capitol Corporate Services, Inc., located at 3675
Crestwood Parkway, N.W., Suite 350, Duluth, Gwinnett County GA 30096.
18. No Punches Pulled Security is a private detective and security agency. It is a domestic
limited liability company owned by Hassan Abdul Rashid. Its principal office address is P.O.
Box 94181 ATL, GA 30377. It may be served by leaving a copy of the Summons, Complaint
2 Envolve is also owned by Hunt.
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
23
and discovery with its registered agent, Hassan Rashid, whose address is 1715 Derry Avenue,
Atlanta, GA 30310.
19. Earline W. Davis is the Executive Director of the Housing Authority of Savannah. She is a
resident of Savannah, Chatham County, GA. Davis may be personally served by hand-
delivering a copy of the Summons, Complaint, and discovery to her.
20. Yolanda Fontaine is the Director of Property Management for the Housing Authority of
Savannah. She is a resident of Savannah, Chatham County, GA. She may be personally
served by hand-delivering a copy of the Summons, Complaint, and discovery to her.
21. Irvenia Brooks is Property Manager at The View. She is a resident and citizen of Chatham
County, GA. She may be personally served by hand-delivering a copy of the Summons,
Complaint, and discovery to her.
22. Robert Marshall is the Director of Facilities Management for the Housing Authority of
Savannah. He is a resident and citizen of Chatham County, GA. He may be personally served
by hand-delivering a copy of the Summons, Complaint, and discovery to him.
23. ABC Corporations 1-3 are corporations serving as agents, contractors or employees who
oversaw or administered the maintenance, repair, inspection or security for The View and
Defendants on or before the date of Grant’s death. Their identities are presently unknown to
Plaintiff but are known to Defendants. They may be served by hand-delivering a copy of the
Summons, Complaint, and discovery to their registered agents.
24. John Does 1-3 are employees, agents or contractors of corporations named as Defendants
(“Corporate Defendants”) in this case. These employees were responsible for maintenance,
repair, inspection, or security at The View. Their names are presently unknown to Plaintiff
RECEIVED FOR FILING, STATE COURT CLERK CHATHAM CO. GA, 6/1/2020 5:04 PM
24
but known to Defendants. They may be served by hand delivering a copy of the Summons,
Complaint, and discovery to them.
25. This action is based upon tortious acts or omissions in Savannah, Chatham County, Georgia.
26. Venue and jurisdiction are proper in this Court.
III. FACTS
A. HISTORY, LOCATION, AND VIOLENCE AT THE VIEW
27. Since the 1930s, business leaders, politicos, and citizens have gathered to provide safe,
secure housing to citizens earning lower income in Savannah, GA by forming HAS.
28. Furthering that mission, HAS constructed Robert Hitch Village (“Hitch Village”).
29. Over the years, Hitch Village devolved into a hotbed of violence, crime, and dangerous
conditions for its residents.
30. To reverse the vicious cycle of crime and poverty in Hitch Village, HAS, Hunt, and Hitch
built The View located where Hitch Village once stood3.
31. HAS, Hitch, Hunt, and Envolve maintained an ownership interest in The View and received
millions4 in government assistance to create safe housing.
32. Envolve managed The View’s property.
33. Envolve and HAS created a lease for residents at The View.
34. Although The View’s lease disclaims any responsibility for the security of residents, HAS
historically assumed responsibility for its residents’ safety.
❖ HAS was formed to address the shortage of safe housing in Savannah, GA.
❖ HAS’s First Cooperation Agreement with the City of Savannah assures that
residents receive police protection.
❖ HAS was required to collaborate with Savannah Police to create a specific safety
plan under 24 CFR 903.7(m).
3 Demolished in 2010, Hitch Village3 was one of the most crime-ridden neighborhoods in Savannah, GA.
4 Upon information and belief, Plaintiff believes HAS received as much as 51 million dollars per
year in government assistance to operate its low income housing.
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❖ HAS received federal funds5 to improve safety at The View.
35. Many of the most dangerous public housing complexes in Savannah are within less than a 2-
mile radius of The View: Herbert Kayton Homes (1.7 miles away), Simon Frazier Homes
(1.7 miles away), Yamacraw Village (1.4 miles away), River Point I and II (formerly Fred
Wessels Homes) (0.5 miles away).
36. Over 3 years before Grant’s death, a plethora of violent crimes occurred at The View:
❖ 9/4/15, aggravated assault, man was struck and pummeled during an altercation.
❖ 5/30/16, aggravated assault, victim found with blood on his shirt and the back of
his head.
❖ 7/30/16, aggravated assault, man choked until he suffered subconjunctival
hemorrhaging in his eyes and urinated on himself.
❖ 12/17/17 (parking lot crime), vehicle damaged and broken into. Items stolen, rear-
view mirror on the ground, damage to windshield that was hit with an object in 2
spots.
❖ 4/14/18, simple battery, two women (1 with a knife) attacked a woman holding a
baby in her home.
❖ 5/22/18 (Less than 1 month before Grant’s death), woman jumped by 15-20 other
women, 6 gunshots fired, car damaged with passenger door shot and window
shattered. (parking lot crime)
37. Although many more crimes occurred, these provide an illustration of the violent
environment that desperately commanded more security.
38. Directly across the street from The View crime persisted.
39. For example, on 6/9/18 (6 days before Grant’s death), 8 rounds were fired from a .45 caliber
in middle of the street in front of Apts 220A and B at Fred Wessels Homes (now River
Point).
40. The same patterns of crime persisted at other HAS properties located within a 2-mile radius
of The View.
5 In 2012, HAS was awarded the Choice Neighborhood Initiative Grant. This grant was used to
“transform” the old Robert Hitch Village (now “The View”) into a neighborhood of opportunity. The
grant required HAS, in large part, to re-engineer Hitch Village into a multi-income neighborhood that
would be safe.
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41. These patterns of crime made it reasonably foreseeable that Grant’s death would occur at the
time, place, and location that it did.
B. INADEQUATE SECURITY AND PROPERTY MANAGEMENT
42. On or before June 15, 2018, The View and Corporate Defendants failed to:
❖ Hire enough active or qualified security to patrol, detect, inspect, warn of and
remove unreasonably violent crime and safety threats.
❖ Install adequate surveillance systems6.
❖ Implement adequate crime deterrents.
❖ Disseminate security notices informing residents of crime.
❖ Track, measure, and assess crime.
43. The View’s property management company, Envolve7 presented an equally troubling safety
history for its workers and residents throughout Georgia:
6 Upon information and belief, the only visible camera at The View on the date of Grant’s death
was located on the inside of a stairwell, making it barely visible to potentially dangerous criminal
assailant targeting innocent residents. 7 Recently, LEDIC rebranded itself as “Envolve” presumably to avoid the stigma associated with
its unsafe history.
Source: https://www.peopleclaim.com/complaint-history/ledic-management-group---headquarters-memphis-tn-283892
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44.
45. Envolve was previously sued for poor security which should have also placed Corporate
Defendants on notice that Envolve would unsafely manage The View:
❖ Ross v. Nations Bank Community and LEDIC Mgmt Group, et. al.,
94VS0093683, Fulton County, Filed on 12/5/1994
❖ Brown v. Atlanta Affordable Housing and LEDIC Mgmt Group, et. al.,
99VS0154307, Fulton County, Filed on 6/15/1999.
❖ Johnson v. LEDIC Mgmt Group et. al., 01VS020571, Fulton County, Filed on
7/23/2001
❖ James v. LEDIC Mgmt Group et. al., 16EV002828, Filed on June 16, 2016
46. Envolve’s unsafe property management and lawsuits in Atlanta, GA---years before Grant’s
death--- made it reasonably foreseeable to HAS, Hitch, and other Corporate Defendants that
Envolve would unsafely manage The View.
C. STATISTICAL FORESEEABILITY OF GRANT’S DEATH
47. Based on the sex, age, race, location, and murder weapon used in Grant’s death, Shawntray
Grant’s death was statistically foreseeable and preventable.
48. The Georgia Department of Public Health (DPH) concluded that murder victims are
disproportionately male (Shawntray’s sex):
Source: https://www.indeed.com/cmp/Ledic-Management-Group/reviews?start=40
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49. Shawntray’s age made him more vulnerable to homicide; DPH also concluded that the
overall age-specific death rate was highest among Shawntray’s age group (25-34):
50. Shawntray Grant was highly vulnerable to dying from gun violence in Savannah ,which had
the second highest number of violent deaths in Georgia in 2012:
Source: Fitzgerald, O’Neal, Drenzek, Bayakly, and Ryan, Georgia Department of Public Health, “Violent Deaths in Georgia, 2008-2012:
Georgia Violent Death Reporting System, 2014”
Source: Fitzgerald, O’Neal, Drenzek, Bayakly, and Ryan, Georgia Department of Public Health, “Violent Deaths in Georgia, 2008-2012:
Georgia Violent Death Reporting System, 2014”
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51. HUD reports that violent crime is geographically concentrated in certain neighborhoods and
in more localized areas known as hotspots8 (The View is surrounded by 5 of the most
dangerous housing complexes in its 2-mile radius).
52. It was highly likely that Shawntray could die a violent death in a parking lot; DPH concluded
that parking lots had the 5th most frequent number of violent deaths between 2008 and 2012:
53. HUD, via FBI statistics, also concludes that African Americans (Shawntray’s race) are more
likely to be victims of murder:
8 See https://www.huduser.gov/portal/periodicals/em/summer16/highlight2.html
Source: Fitzgerald, O’Neal, Drenzek, Bayakly, and Ryan, Georgia Department of Public Health, “Violent Deaths in Georgia, 2008-2012:
Georgia Violent Death Reporting System, 2014”
Source: Fitzgerald, O’Neal, Drenzek, Bayakly, and Ryan, Georgia Department of Public Health, “Violent Deaths in Georgia, 2008-2012:
Georgia Violent Death Reporting System, 2014”
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54. It was highly probable that Shawntray would die from a firearm:
55. These governmental statistics were published as of 2014 (4 years before Grant’s death) and
freely available to Corporate Defendants.
56. Since HAS’s own governing agency and The State of Georgia predicted that persons
similarly situated to Shawntray were disproportionately predisposed to violent deaths like
Source: Federal Bureau of Investigation. “Murder Victims by Race, Ethnicity, and Sex, 2014” (ucr.fbi.gov/crime-
in-the-u.s/2014/crime-in-the-u.s.-2014/tables/expanded-homicide-
data/expanded_homicide_data_table_1_murder_victims_by_race_ethnicity_and_sex_2014.xls).
Accessed 7 August 2016.
Source: Fitzgerald, O’Neal, Drenzek, Bayakly, and Ryan, Georgia Department of Public Health, “Violent Deaths in Georgia, 2008-2012:
Georgia Violent Death Reporting System, 2014”
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Shawntray’s, Corporate Defendants reasonably should have known that Shawntray’s murder
was foreseeable and should have implemented reasonable security measures at The View
before Grant’s death.
D. GRANT’S DEATH, JUNE 15, 2018
57. As of June 15, 2018, Grant resided in his apartment at The View for a mere 7 days.
58. Grant won proceeds from The Emerald Princess Casino Boat earlier in the evening while
celebrating with several associates.
59. Around 2:10 AM, Grant dropped off his associates at their homes, the last of which lived in a
nearby apartment at The View.
60. After saying goodbye to his associate, Grant walked to his vehicle located in The View’s
parking lot.
61. Within a short time, loud, cannon-like gun shots were fired.
62. Police later found 33-year-old Grant lying motionless, unresponsive, with multiple gunshot
wounds, and no sign of life in The View’s parking lot, only a few doors away from where he
grew-up.
63. Authorities pronounced Grant dead on arrival.
64. The Chatham County District Attorney later indicted and tried several bad actors for Grant’s
murder.
65. The View was under re-development at the time of Grant’s killing.
66. A security guard from “No Punches Pulled Security,” presumably Hasan Rashid, guarded
“the developer’s (presumably Hitch’s) building supplies,” at or near the time of Grant’s
murder.
67. Upon information and belief, Rashid heard the gunshots but he refrained from calling the
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police.
68. Upon information and belief, Rashid frequently heard gunshots in this area prior to Grant’s
death.
69. Defendants prioritized the protection of property and profits over the protection of people by
facilitating generational a cycle of violence culminating in Shawntray Grant’s wrongful
death.
E. GRANT’S LIFE
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70. Grant’s vision was to end gun-violence a problem that has cost governmental entities,
corporations, and citizens billions in lost human and economic potential.
71. Fighting vigorously to save the youth and create safe zones of opportunity in impoverished
neighborhoods, Grant dreamed of a community in which violence was an after-thought and
opportunity was overflowing, even for the most unfortunate.
72. He was a deacon in his church, former drum major of Savannah High School, and left behind
thousands of admirers in Savannah.
73. His potential contribution to the world was limitless.
F. THE BIG BUSINESS OF LOW-INCOME HOUSING
74. As early as 1937, Corporate Defendants have profited greatly in size and wealth from
dangerous low -income housing.
75. HAS was the 4th largest public housing authority in GA.
76. HAS serves 4,700 families, primarily through public housing and housing choice voucher
(Section 8) programs.
77. Hunt, an international company, is a diversified, family-owned holding company that invests
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in operating businesses, real estate assets, and infrastructure assets.
78. Its scope and size grew substantially while gaining considerable expertise across multiple
real asset sectors.
79. Hunt is the 5th largest multifamily housing owner.
80. Hunt is the 10th largest U.S. Apartment syndicator.
81. Hunt and its affiliates have more than $13 billion in assets under management, including
144,583 multi-family housing units and 8.3 million square feet of office, retail and industrial
properties.
82. Hunts project costs have totaled more than $6.3 billion with more than $8.2 billion in
construction costs.
83. Hunt owns Envolve, the 8th largest affordable multifamily property management company.
84. Under the name LEDIC, Envolve was one of the top 50 largest management companies in
America.
85. Envolve is a vertically integrated owner and operator of multi-family housing.
86. Envolve’s portfolio consists of affordable, tax credit, conventional, layered, and HOME
communities.
87. Envolve touts the following accomplishments in industry leadership:
Source: https://www.envolve-csg.com/
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88. Envolve owns the properties that it manages.
89. Under the name LEDIC, Envolve was ranked No. 9 on the 2013 National Affordable
Housing Management Association Affordable 100 list.
90. Envolve’s ownership interests reach far and wide throughout the United States as indicated
by the states in blue:
91. The scope of dangers posed by Defendants’ unsafe housing ventures have numerous, lasting
effects on generations of low-income housing residents throughout the United States that
extend beyond the violence’s direct impact on a particular victim and associates.
92. As HUD emphatically states:
❖ In dangerous neighborhoods people may avoid going outside, and a strong
relationship exists between perceived neighborhood safety and obesity rates … In
general, exposure to violence puts youth at significant risk for psychological,
social, academic, and physical challenges and also makes them more likely to
commit violence themselves. Exposure to gun violence can desensitize children,
increasing the likelihood that they act violently in the future.
Source: https://www.envolve-csg.com/
Source: https://www.huduser.gov/portal/periodicals/em/summer16/highlight2.html
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IV. LAW
COUNT I NUISANCE
93. Plaintiff incorporates by reference the preceding paragraphs as if fully restated here.
94. The View, plagued with excessive crime, constituted a nuisance.
95. The nuisance caused Shawntray Grant’s hurt, inconvenience, and death.
96. This nuisance’s inconvenience is not fanciful, but it is the type that affects an ordinary,
reasonable tenant.
97. Further, the nuisance produced actual, tangible, and substantial injury, in addition to special
damage to Grant.
COUNT II NEGLIGENCE PER SE
98. Plaintiff incorporates by reference the preceding paragraphs as if fully restated here.
99. Defendants violated laws, principally, O.C.G.A. § 51-3-1 and 24 CFR 903.7(m) by failing to
use ordinary care to keep the premises and approaches reasonably safe and failing to
implement a reasonable safety plan in accordance with federal guidelines, among other
things.
100. These violations caused Grant’s death.
101. Such violations are negligence per se.
COUNT III NEGLIGENCE
102. Plaintiff incorporates the preceding paragraphs as if fully restated here.
103. HAS, Hitch, Hunt, Envolve, and their agents, were negligent. Their negligence actually
and proximately caused Grant’s death by:
❖ Violating O.C.G.A. § 51-3-1 when failing to use ordinary care to keep the
premises and approaches reasonably safe.
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❖ Failing to properly inspect and maintain the premises.
❖ Failing to warn of latent dangers on the premises.
❖ Failing to properly retain, entrust, hire, train and supervise their employees,
contractors, and agents.
❖ Failing to ensure business policies, systems, and security measures were
adequately followed and implemented concerning the following areas, among
others: investigating crime, reporting crime, warning of crime and maintaining
The View and its other properties in The View’s vicinity in a reasonably safe
manner.
❖ Failing to act to remove loiterers in the parking lot and premises.
❖ Failing to inspect, patrol, or appropriately monitor the parking lot and premises.
104. Defendants had actual and constructive knowledge of these dangers through the direct
knowledge of their employees or agents.
105. Defendants should have known that The View (and similarly situated HAS Complexes in
the 2-mile radius) were in a high-crime area.
106. Defendants should have known that their residents and others were victims of violent
crimes such as the ones mentioned above in the area at The View and other HAS Complexes
nearby.
107. Defendants should have known of a foreseeable risk of harm to their residents who
entered and exited their parking lot.
108. Defendants should have known that persons of Shawntray’s demographic profile were
extraordinarily vulnerable to death by violent crime, given the overwhelming statistical data
published years before Grant’s death.
109. Yet, Defendants negligently provided security (primarily near the developer’s supplies).
110. Security was negligently understaffed and inadequate in type, quantity, and measures9.
9 The U.S. Department of Housing and Urban Development recently stated: “Where crime and
vandalism are serious problems, security should be recognized as a significant element of
the capital and operating expenses of HUD-assisted multifamily housing. Where new
construction or rehabilitation is contemplated, financial feasibility analysis must take realistic
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COUNT IV GROSS NEGLIGENCE
111. Plaintiff incorporates by reference the preceding paragraphs as if fully restated.
112. Defendants were grossly negligent under O.C.G.A. § 51-1-4.
113. Defendants failed to exercise the slightest diligence.
114. This gross negligence caused Grant’s death.
COUNT V JOINT VENTURE/ENTERPRISE LIABILITY
115. Plaintiff incorporates by reference the preceding paragraphs as if fully restated here.
116. Defendants HAS, Hitch, Hunt, and Envolve combined their property or labor in a joint
undertaking for profit.
117. Similarly, No Punches Pulled Security combined its property and labor with at least 1 of
the defendants to guard the developer’s property.
118. These defendants each had a right of mutual control over the enterprise which operated,
managed, maintained, or otherwise controlled The View.
119. Accordingly, these defendants are liable for their tortious conduct and their agents, which
is imputed to them as principals.
COUNT VI AGENCY AND RESPONDEAT SUPERIOR
120. Plaintiff incorporates by reference the preceding allegations as if fully restated herein.
121. Earnestine Davis, Irvenia Brooks, Yolanda Fontaine, Robert Marshall, John Does 1-3,
and ABC Corporations 1-3 committed acts or omissions causing Grant’s death.
account of the level of operating expense.”
https://www.hud.gov/sites/documents/74604C9PIHH.PDF (emphasis supplied)
Defendants should have known of this recommendation before Grant’s death.
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122. These defendants acted within the course and scope of their agency and employment with
Corporate Defendants such as HAS, Hunt, Hitch, and Envolve.
123. They were staff members or contractors of Corporate Defendants.
124. They negligently, inspected, maintained, and managed The View.
125. Their acts and omissions as Corporate Defendants’ agents, contractors, or employees are
imputed to Corporate Defendants.
COUNT VII PERSONAL LIABILITY OF EMPLOYEES
126. Plaintiff incorporates by reference the preceding allegations as if fully restated herein.
127. Ernestine Davis (HAS Executive Director), Yolanda Fontaine (HAS Director of Property
Management), Irvenia Brooks (The View’s Property Manager), and Robert Marshall (HAS
Facilities Manager) are responsible for the management, maintenance, and inspection of The
View or nearby HAS complexes.
128. These employees are also responsible for warning residents of unreasonable dangers
posed by violent crime.
129. They are further responsible for removing any unreasonable dangers of crime.
130. They breached their duties to ensure that The View and its approaches were in a
reasonably safe condition.
131. They breached their duties by violating their employer’s internal policies and industry
standards.
132. These breaches constituted active negligence.
133. These employees, upon information and belief, further ratified tortious conduct leading to
Grant’s death.
134. Their conduct actually and proximately caused or contributed to Grant’s death.
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COUNT VIII NEGLIGENT HIRING, RETENTION, AND SUPERVISION
135. Plaintiff incorporates the preceding allegations as if fully restated here.
136. Corporate Defendants negligently hired, trained, supervised, entrusted, and retained their
employees and contractors of The View10.
137. Under O.C.G.A. § 51-1-4, all Corporate Defendants identified as employers are liable for
their contractors’ negligence because:
❖ The wrongful acts of the contractors violate statutory duties.
❖ Defendants retained the right to direct or control the time and manner of
executing the work or interefers and assumed control, creating the relation of
employer and employee.
❖ Defendants ratified and approved the unauthorized wrong leading to Grant’s
death.
138. Corporate Defendants’ combined negligence is the actual and proximate cause of Mr.
Grant’s death.
DAMAGES
139. Plaintiff is entitled to recover from Defendants for the intangible value of Shawntray
Grant’s life (from Shawntray’s perspective) in the sum of $100,000,000.00 under O.C.G.A. §
51-4-5.
140. Plaintiff is entitled to recover for the full value of Grant’s life.
141. Shawntray died at 33 years old, and his reasonable life expectancy was 41.75 years.
142. On the date of his death, Shawntray earned at least $2,000.00 per month from his
occupation.
10 HAS is also responsible for negligently leasing the premises to Hitch Phase II. Among the agents of
Hitch Phase II are Envolve entrusted with the management of the property, John Doe Construction
Company No Punches Pulled Security and its owner Hasaan Rashid (entrusted with the security of the
construction site). Envolve is responsible for the negligent hiring, training, supervision and retention of its
employees, contractors and entrustment of The View to its agents and employees.
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143. Plaintiff is entitled to a minimum of $1,002,000.00 in lost earnings.
144. Plaintiff is entitled to recover for Shawntray Grant’s pre-death mental and physical pain
and suffering and funeral expenses in an amount to be determined at trial.
PRAYER FOR RELEIF
WHEREFORE Plaintiff prays that he has a trial on all issues and judgment against
Defendants:
(a) Defendants are liable for the full value of the life of Shawntray Grant, especially its
intangible element (valued at $100,000,000.00).
(b) Defendants are liable for Grant’s minimum of $1,002,000.00 in lost earnings.
(c) Defendants are liable to Plaintiff for Grant’s funeral expenses.
(d) Defendants are liable to Plaintiff for Grant’s pre-death pain and suffering.
(e) Defendants are liable for punitive damages under O.C.G.A. § 51-12-5.1 in an amount to
be determined by the enlightened conscience of the jury for Defendants’ actions showing
willful misconduct, malice, fraud, wantonness, oppression, or that entire want of care
which would raise the presumption of conscious indifference to consequences.
(f) Plaintiffs have a trial by jury.
(g) Defendants are liable for Plaintiff’s attorney’s fees and expenses for Defendants’ bad
faith, stubborn litigiousness, or unnecessary trouble and expense under O.C.G.A. § 13-
16-11.
(h) Defendants are liable for Plaintiff’s attorney’s fees for asserting a claim, defense, or other
position having a complete absence of justiciable law or fact under O.C.G.A. § 9-15-1411.
11 HAS and Envolve’s lease states that HAS is not responsible for their resident’s security, which
contravenes the duty of landlords under GA Law to provide reasonably safe premises and
approaches.
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(i) Defendants are liable for all general, special, compensatory, economic, punitive and other
permissible damages in accordance with the enlightened conscience of an impartial jury.
(j) Defendants are liable for such other relief as this Court deems just and appropriate.
This 1st day of June 2020.
THE MANCE LAW FIRM
__________________________________
Chadrick A. Mance
State Bar No. 703877
Attorney for Plaintiff
The Mance Law Firm, LLC
24 Commerce Place, Suite C
Savannah, GA 31406
Phone: 912-574-4529
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