COUNTY OF GREENVILLE ) FOR THE THIRTEENTH JUDICIAL CIRCUIT )
Carl Ameche, ) ) C.A. NO.: 2016-CP-23-999999 Plaintiff, ) ) vs. ) ) COMPLAINT
Margie Congden, Leroy Congden, ) (JURY TRIAL DEMANDED) and Maple Meadows Campground, ) ) Defendants. ) ) The Plaintiff, Carl Ameche (hereinafter “Ameche”), complaining of the Defendants, Margie Congdon (hereinafter “Congden”) and Maple Meadows Campground
(hereinafter “Maple”) would show unto this Honorable Court as follows:
1. Ameche is a citizen and …show more content…
Causing or allowing to exist a dangerous condition on the grounds;
c. Failing to warn of a dangerous condition for which Congden and Maple knew or should have known existed on the grounds;
d. Failing to use the care and caution that a reasonably prudent person would in the circumstances then and there existing.
As a direct and proximate result of the Defendants’ acts and/or omissions, the Plaintiff has suffered injuries and damages as set forth above, all of which are in direct violation of the common law and Statutes of the State of South Carolina.
15. Ameche is therefore informed and believes that he is entitled to judgment against Congden and Maple for actual and general damages as well as punitive damages.
WHEREFORE, the Plaintiff, Carl Ameche, prays for judgment against the Defendants, Margie Congden, Leroy Congden, and Maple Meadows Campground, for actual, consequential, special, and punitive damages in an amount to be determined by a jury, and for such other relief as the Court may deem just and proper.
Respectfully submitted, _________________________________________ John R. Bell, Jr. (SC Bar No. 72599) John Bell Law