IN THE CIRCUIT COURT FOR

BALTIMORE COUNTY

 

Rhanda P. Gaines,

Personal Representative of the
Estate of Korryn Shadawn Gaines
816 Crimson Ave,

Baltimore, MD 21229

Plaintiff,

Rhanda P. Gaines,

on behalf of herself and as
Guardian on behalf of her
minor grandchild, K. Gaines
816 Crimson Ave,
Baltimore, MD 21229

Plaintiff,

Kareem K. Courtney,

the father and legal custodian
of said child, K. Gaines

2800 Clifton Avenue
Baltimore, Maryland 21216

Plaintiff,

To the use of Corey Cunningham,

father of minor child Kodi Gaines,

unrepresented by instant counsel
711 St. Paul St.

Baltimore, MD 21202

Use-Plaintiff,

To the use of Ryan Gaines, Sr.,
father of decedent, Korryn Gaines
unrepresented by instant counsel

300 South Herring Court
Baltimore, MD 21231

Use-Plaintiff

Case No.

JURY DEMAND

Baltimore County Maryland

400 Washington Avenue, Mailstop 2M01A
Old Courthouse Mezzanine

Towson, Maryland 21204

And

Of?cer First Class Ruby

(Of?cial and Individual Capacity)
Baltimore County Police Department
Support Operations Division

700 E. Joppa Road

Towson, Maryland 21286

Defendants.

 

1.

COMPLAINT

The Plaintiff, Rhanda P. Gaines, Personal Representative of the Estate of Korryn
Shadawn Gaines, deceased; Rhanda P. Gaines on behalf of herself and as Guardian on
behalf of her minor grandchild, K. Gaines, and Plaintiff Kareem K. Courtney, the father
and legal custodian of said child, K. Gaines; (to the use of Plaintiff Corey Cunningham, the
father of minor child Kodi Gaines ?unrepresented by instant counsel) by and through their
attorneys, J. Wyndal Gordon, Esq. and The Law Of?ce of J. Wyndal Gordon, RA, and
Jimmy A. Bell, Esq. and the Law Of?ce of Jimmy Bell, L.L.C., present this Complaint
for Wrongful Death and Survival Action; (for violation of Maryland Declaration of
Rights Articles 10, 24, 26 (Suppression of Speech; Excessive Force; Gross Negligence
(failure to train and failure to supervise) against Defendant Baltimore County, Maryland,
Defendant Of?cer Rudy. The last known address of each use-plaintiff is listed above in
the caption and the party bringing the action, Rhanda P. Gaines, Personal Representative
of the Estate of Korryn Shadawn Gaines, conducted a good faith and reasonably diligent
effort to identify, locate, and name, as use plaintiffs, all individuals who might qualify as
such. The Plaintiff states as follows:

JURISDICTION AND VENUE
Plaintiffs brings before this Circuit Court a civil action with an amount in controversy that

exceeds $75,000 as re?ected in Maryland Rule 2-305(b) and consistent with MD.
COURTS AND JUDICIAL PROCEEDINGS CODE ANN. 1? 501.

. Defendant Baltimore County, Maryland is a chartered county established under MD.

ANN. CODE ART. 25A and, as such, is a person or entity sut' juris organized under the
laws of the State of Maryland over whom this Court may exercise personal jurisdiction.
See, MD. ANN. CODE ART. MD. COURTS AND JUDICIAL PROCEEDINGS
CODE ANN. 6-102.

Venue is properly laid as the acts herein complained of occurred in Baltimore County,
Maryland where the physical injuries and death occurred.

10.

11

12.

STATEMENT OF FACTS

The Plaintiff, Rhanda P. Gaines, Personal Representative of the Estate of Korryn
Shadawn Gaines, deceased.

Plaintiff, Rhanda P. Gaines brings this lawsuit on behalf of herself and as Guardian on
behalf of her minor grandchild, K. Gaines.

Plaintiff Kareem K. Courtney, the father and legal custodian of said child, K. Gaines brings
this lawsuit on behalf of K. Gaines.

This claim is being brought to the use of Plaintiff Corey Cunningham, the father of minor
child Kodi Gaines, who is also decedent Korryn Gaines? biological son. They are not
represented by undersigned counsel; they are represented by Kenneth Ravenell, Esq.,
Baltimore, Maryland; and to the use of Plaintiff Ryan Gaines, Sr., who is the biological
father of Korryn Gaines. Ryan Gaines is not represented by undersigned counsel; he is
represented by Landon White, Esq., Baltimore, Maryland.

Defendant Baltimore County, Maryland is a chartered county established under Maryland
law. The Baltimore County Police Department is an agency of Defendant Baltimore
County, Maryland.

Defendant Of?cer Ruby is a Baltimore County Police Of?cer who on August 1, 2016,
illegally and unconstitutionally shot and killed Korryn Shadawn Gaines in her own
apartment while he was on duty and/or acting within the scope of his employment.
Defendant Of?cer Rudy shooting and killing of Korryn Shadawn Gaines was done with
malice and constituted excessive force. Therefore, his conduct is not subject to public
of?cial immunity.

. At all times mentioned herein, Defendant Of?cer Rudy was a sworn Baltimore County

Police Of?cer for Defendant Baltimore County, Maryland. He was in full uniform, was
an agent/employee for the Baltimore County Government, and his conduct was in
furtherance of Baltimore County Government?s interests of security and law
enforcement. At all times mentioned herein, Defendant Rudy was acting, under color of
law and with malice as his actions were motivated by ill will, and an improper motive
exclusively driven by frustration rather than any perceived threat of injury, for the
purpose of deliberately and willfully injuring Gaines.

Korryn Gaines, a 23 year old African?American woman and mother of two children, was
illegally shot and killed by Of?cer Rudy, who is Caucasian, of the Baltimore County
Police on August 1, 2016. Korryn was the daughter of Rhanda P. Gaines, who serves as
the Personal Representative of Korryn?s Estate, and Guardian of Korryn?s one-year old
child. Kareem Courtney is the father and legal custodian of said one-year old child.
Courtney is employed as a HVAC Apprentice and is a graduate of TESST College
HVAC. Korryn?s mother is a retired nurse formerly employed by Harbor
HOSpital and Bon Secours, and her biological father is a former dispatcher for the

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16.

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18.

19.

20.

Baltimore City Housing Police.

Korryn Gaines, graduated from Baltimore City College High School in 2010, which was
founded in 1839 and is the third oldest public high school in the United States. It remains
one of Baltimore?s most highly regarded educational institutions. It was listed as one of
Top High Schools in 2010, which was the same year Korryn Gaines graduated, as
published in Baltimore Magazine; it was awarded a certi?cate of
outstanding achievement on the 2010 Maryland High School Assessment from Baltimore
City Public Schools; and listed in 2006, 2007, and 2008 as one of America?s Top Public
High Schools featured in Newsweek.com.

After graduating from high school Gaines enrolled at historic Morgan State University in
the fall of semester of 2010 where she majored in political science. When Gaines learned
she was pregnant with her ?rst child, she began working as a to support herself
with hopes of one day returning to school and completing her degree.

On August 1, 2016, Korryn Gaines was illegally shot and killed in front of one of her two
children by Of?cer Ruby not because he was fearful or perceived her as a threat but
because he grew frustrated with the amount of time it was taking for Korryn to surrender
to authorities and had had enough of County of?cers attempting to negotiate her
surrender after a 7hr standoff as more fully described below.

Korryn Gaines was at her apartment located in Baltimore County Maryland, when she
was gunned down by Of?cer Ruby, and incidentally, Gaines was not his ?rst kill. Of?cer
Ruby has shot and killed two people in less than 10 years while on duty as a Baltimore
County of?cer acting under color of law. Unfortunately, in this instance, Of?cer Ruby
acted with malice and had no legal justi?cation for killing Korryn Gaines in light of the
particular facts attendant to this case.

Fortunately, there were witnesses to the events that led to Gaines illegal and untimely
death. In fact, an witness named Ramone Coleman, Korryn?s next door neighbor,
was home during the entire incident on August 1, 2016, and recalls the of?cers
expression of frustration immediately prior to shots ringing out by police.

Coleman?s apartment, directly adjacent to Gaines?, was illegally commandeered and
thereby seized by the Baltimore County Police SWAT Unit and used without Coleman?s
voluntary consent as a command post. Coleman was present during the entire incident as
he was con?ned to his unit against his will while County of?cers con?gured his
apartment to set up their systems and operation.

Around 8:30am 8:45am Monday, August I, 2016, Coleman heard several men yelling
outside of the front door to his apartment unit. He went to the door to determine the
source of the commotion, when he opened it, he observed several police of?cers in the
hallway yelling at the top of their lungs.

Baltimore County police conceded that at least three of?cers went to Gaines? apartment
unit to serve a bench warrant (not a search warrant) for failure to appear in court on July
13, 2016, for traf?c violations and related misdemeanors. County police claimed they
were present to serve Korryn Gaines, and Gaines? ?anc? and father of her daughter,
Kareem Courtney (who?s address and drivers license show that he lives in Baltimore City

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21.

22.

23.

24.

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27.

28.

and has never lived with Korryn in Baltimore County), with an arrest warrant (again, not
a search warrant) for an unrelated misdemeanor offense from June 18, 2016, involving
Gaines.

Police knocked on the door but no one answered, even though the police station was right
across the street from the Carriage Hill Apartment complex in which they lived, police
didn?t leave and come back a different day, but stayed to ratchet up the encounter. They
did this in spite of not knowing whether Korryn or Kareem were in the home despite
hearing the sounds of voices coming from inside. It was not con?rmed who?s voices were
heard or whether they were the voices of Gaines, Courtney, or arti?cially produced by a
television set.

Despite not having any further information about whether the subjects of the arrest
warrant were inside the apartment unit, County of?cers, without a search warrant,
obtained a key from building management and illegally opened the front door to search
for who was inside in violation of Gaines? and Courtney?s constitutional rights at the
time.

Police failed to articulate any exigent circumstance, consent, nor any reasonable belief
that Gaines and Courtney were in the apartment unit, and they further failed to obtain a
search warrant to law?illy gain entry into Gaines? home.

The Baltimore County Police Department stated that police of?cers tried to open the door
fully but it was secured by a chain-link lock. However, through the partially opened door,
the of?cers observed Gaines sitting on the floor holding her lawfully purchased and
possessed shotgun, and her ?ve-year-old milling about nearby. Police concede that
Gaines was the lawful owner of the gun that she purchased in 2015.

. Meanwhile, Ramone Coleman, who lived next door was able to hear everything taking

place between Gaines and County police because police had his door open for operational
purposes and logistics. Coleman heard Gaines request to inspect a copy of the warrant
and he also heard the police refuse to comply with this reasonable request. Coleman also
heard Gaines inquire about the physical location of the warrant; none of the of?cers
responded to her inquisition.

At about 9:00 am. County police seized Ramone Coleman?s apartment unit and set up
surveillance equipment in his home; they brought in four (4) big black boxes. These
of?cers were identi?ed as Baltimore County Special-forces. They didn?t have regular
Baltimore County Police uniforms. Their uniforms were dark green, and they carried AR-
15 assault ri?es and 9mm handguns strapped near their knees.

The Baltimore County Special Forces team the tactical unit drilled holes in Coleman?s
living room, bedroom and bathroom walls to monitor the movements of his next door
neighbor, Korryn Gaines, with surveillance equipment connected to TV-like monitors.
County special-forces used this equipment to watch what was going on in Gaines?
apartment from different angles. Coleman observed one of the tactical unit of?cers
wearing a body camera mounted on his helmet.

About 25 minutes after police set up their command post, Kareem Courtney, and
Courtney and Gaines? child, K. Gaines, exited the apartment unit, Courtney surrendered

5

29police. He was arrested on the spot then later released within hours on his own
recognizance.

Between 10am and 10:30am, Korryn Gaines said to the police, ?if you put your guns
down and back up from my apartment, I will come out.? However, none of the police
backed up from the apartment door.

At that time, at least eight (8) Baltimore County Police Of?cers were in the hallway right
outside of Gaines? door; six - eight Baltimore County Tactical Unit Police were in
Coleman?s unit. The Tactical Unit police made sure Coleman?s front door remained wide
open at all times during the stand-off.

. When the of?cers failed or refused to produce the arrest warrants and leave from in front

of Gaines? unit after Gaines? demand, Gaines said ?leave me alone and get the hell away
from my house.? In response, Baltimore County Police escalated the confrontation into a
full-blown standoff refusing all options to deescalate the situation beyond any point
where police were committed to resolving it peacefully.

County police were observed turning away Gaines? family members who desperately
seeking to offer help to the situation fearing that police would kill her because everyone
was extremely hyped. Family members pleaded with of?cers to allow them to help
deescalate the situation as they remained present in an additional command post during
the standoff. However, they were never asked to assist police in bringing the standoff to a
peaceful resolution. In fact, family members were told by County police Of?cers, early as
10 am, less than an hour into the standoff, that the situation was past the point where
they could be useful. However, this was untrue because Gaines had a great relationship
with her family present on the scene, and knowing Korryn Gaines, they could have
spoken to her to get her to surrender. This was not a suicide, or hostage situation nor was
it a barricade as County top brass publicly conceded because none of the negotiations
between Gaines and police were recorded according to departmental policy, --it was
indeed a standoff.

The Baltimore County Police admitted that they did not use their Crisis Team during the
standoff but was unclear as to why. Incidentally, this ?Mobile Crisis Team,? according to
the county website, can be dispatched for ?suicidal subjects, mentally ill subjects,
situational crisis, emergency petitions and other acute situations.? Gaines? matter

constituted a situational crisis or other acute situation for which the Crisis Team was
established.

After the standoff extended into close to three hours, at 12:30 pm, Baltimore County
police applied for arrest warrant from a Baltimore County District Court Commissioner
alleging that Gaines pointed a gun at them. No reason was given for the of?cers? request
for the court to issue another arrest warrant if they truly already had valid arrest warrants
for both Gaines and Courtney in their possession before their unlawful forced entry into
Gaines? apartment unit with a key they obtained from Carriage Hill Apartments? rental
of?ce.

Incidentally, while the standoff was in full swing, Korryn Gaines was live-streaming it
through social media to capture what the of?cers were doing to her in real time. When
County police learned of her live-stream it had the social media outlets block her

6

36.

37.

38.

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40.

41.

42.

43.

streaming coverage. By blocking her live streaming, the Baltimore County Police
Department not only suppressed her speech under the Maryland Constitution but also
stopped the only independent audio-visual record of what was taking place before Of?cer
Ruby killed her.

Police did not fear Gaines as they had indulged her for several hours even up to the point
where they alleged that she handled her weapon. Police grew frustrated with Gaines
because she would not submit to their authority, after 6?7 hours the wait had taken a toll
on the of?cers, namely Ruby, because Gaines would not come out of the apartment.
Upon information and belief, the of?cer closest to Gaines did not ?re his weapon; it was
of?cer Ruby, who was furthest away from Gaines who shot multiple times and killed her,
and injured her son. As it were, shortly after Korryn Gaines? door was kicked in Of?cer
Ruby entered her unit with his partner and killed her.

Indeed, the next thing heard was a male police of?cers voice utter, ?m sick of this shit.?
From that point forward multiple shots were ?red, a multiple expletives were hurled in a
male?s voice, then there was a brief period of silence, and ultimately chaos.

County of?cers shot ?rst, killing Gaines with multiple shots to her torso area in an utter
disregard of Gaines? life, and the life of her ?ve-year old son who was shot in the face
and elbow requiring several surgeries to repair. Of?cer Ruby did not act reasonably in his
decision to shoot and kill Korryn Gaines out of his own personal frustration rather than
any true fear of a threat to him or others. In fact, his actions of shooting Plaintiff were
malicious, sadistic, and done under color of law and within the sc0pe of his mployment.

Defendant Baltimore County, Maryland failed to properly train, supervise and and/or
adequately monitor Defendant Of?cer Ruby actions toward decedent Korryn Gaines
while acting in the course of his duties, and speci?cally failed to supervise the Defendant
Of?cer Ruby as he illegally shot and killed decedent Korryn Gaines.

Defendant Of?cer Ruby?s gross negligence and illegal actions are responsible for the
natural injuries suffered by Korryn Gaines. Defendant Of?cer Ruby?s intentional illegal
actions were committed while he was acting under color of state law. Defendant Ruby
intentional illegal actions constituted a state-created danger which deprived decedent
Korryn Gaines of life and liberty in violation of the Maryland Constitution.

Defendant Baltimore County, Maryland with deliberate indifference to the Maryland
Constitutional rights of decedent Korryn Gaines created a dangerous situation, thereby
directly causing the death of decedent Korryn Gaines.

Defendant Baltimore County, Maryland with deliberate indifference to the Maryland
Constitutional rights of decedent Korryn Gaines failed to properly train, supervise and
and/or adequately monitor Baltimore County police of?cer Ruby and others on the
clearly established constitutional rights of citizens that prohibit unlawful searches and
seizures in the home of Korryn Gaines.

Baltimore County, Maryland further failed to instruct its of?cers not to interfere with
Gaines? rights as a private citizen to video record police in the performance of their
public duties via live-stream or in any other way, and to train its of?cers not to illegally
suppress Gaines? clearly established fundamental right to freedom of Speech under the

7

44.

45.

46.

47.

48.

49.

50.

51.

52.

53.

Maryland Constitution.

Defendant Baltimore County, Maryland with deliberate indifference to the Maryland
Constitutional rights of decedent Korryn Gaines created a dangerous situation by
engaging in all of the conduct contained in paragraphs 16 - 46, thereby directly causing
the death of decedent Korryn Gaines and there is no suf?cient intervening cause of
injuries and death suffered by Korryn Gaines.

As a result of all of the Defendants? conduct and actions/inactions, Korryn Gaines
suffered sudden impact fright, severe physical and conscious pain and suffering after she
was shot multiple times by of?cer Ruby.

On September 12, 2016, Plaintiffs satis?ed the notice provision for suing a local
government under the Maryland Local Government Tort Claims Act.

COUNT I Wrongful Death Act
(Against All Defendants)

The Plaintiff repeats and realleges Paragraphs 1 46 of this Complaint with full force
and effect as if pleaded here in full.

It was the duty of the Defendants to exercise reasonable care under the circumstances to
protect and preserve the life of the decedent, Korryn Shadawn Gaines, and respect her
rights to be free from unlawful searches and seizures, excessive force resulting from an
arrest for traf?c violations and misdemeanor criminal offenses, manslaughter due to
negligence or murder; yet, notwithstanding these duties, the Defendants, through its
agents, servants, or employees acting within the course and scope of their employment
failed to exercise reasonable care under the circumstances that would have placed their
conduct in consonant with the law.

Defendant Of?cer Ruby shooting and killing of Korryn Shadawn Gaines constituted an
unlawful seizure and unconstitutional use of excessive force.

Defendant Of?cer Ruby committed these acts with ill will, gross negligence,
recklessness, wantonness, oppressiveness, a willful disregard of the Plaintiff?s Rights,
and actual malice.

Defendant Of?cer Rudys? intentional illegal actions were committed while he was acting
under color of state law. Defendant Rubys? intentional illegal actions constituted a state-
created danger which ultimately resulted in the shooting death of Korryn Gaines.

Defendant Of?cer Ruby?s intentional illegal actions were foreseeable, and his actions
causing potential kill Korryn Gaines were foreseeable. Defendant Ruby intentionally
used his authority to create a danger for Korryn Gaines and rendered her more vulnerable
to the death than if Defendant Ruby had not acted at all.

Defendant Baltimore County, Maryland with deliberate indifference to the Maryland
Constitutional rights of decedent Korryn Gaines created a dangerous situation, thereby
directly and/or proximately causing the death of decedent Korryn Gaines.

54.

55.

56.

57.

58.

59.

60.

61.

62.

Defendant Baltimore County, Maryland with deliberate indifference to the Maryland
Constitutional rights of decedent Korryn Gaines by failing to properly train, supervise
and and/or adequately monitor the Baltimore County police not to illegally enter Korryn
Gaines? apartment and not to illegally suppress her freedom of speech under the
Maryland Constitution.

Defendant Baltimore County, Maryland with deliberate indifference to the Maryland
Constitutional rights of decedent Korryn Gaines created a dangerous situation, thereby
directly causing the death of decedent Korryn Gaines and there is no suf?cient
intervening cause that resulted in the injuries and death to Korryn Gaines.

As a direct and proximate result of one or more of the aforementioned acts or omissions
of the Defendants, the Plaintiffs? decedent suffered serious injuries that resulted in death.
Defendants? aforementioned acts or omissions constituted gross negligence and a
violation of decedent, Korryn Shadawn Gaines constitutional rights under the Maryland
Constitution.

Pursuant to the Annotated Code of Maryland, Courts Judicial Proceedings 
Plaintiffs bring an action based upon the death of Korryn Ganies at the hands of
Defendants. Plaintiffs demand all damages recoverable under the Act including substantial
damages for funeral and medical expenses, conscious pain and suffering, as well as any
other damages recoverable under the Act.

Wherefore, Plaintiffs demand judgment against Defendants, jointly and severally, in an
amountthat exceeds $75,000 pursuantto MaIylandRule 2-305 plus interest and costs.

COUNT II Survival Action
(Against All Defendants)

The Plaintiffs repeats and realleges Paragraphs 1 58 of this Complaint with full force
and effect as if pleaded here in full.

As a direct and proximate result of one or more of the aforementioned acts or omissions of
the Defendants, the Plaintiff, Rhanda P. Gaines? decedent, Korryn Shadawn Gaines,
suffered serious injuries of a personal injury of a pecuniary nature, including, but not
limited to, great pain and suffering before his death and medical expenses, subjecting the
Defendant to liability pursuant under the Survival Act Statute. Defendants aforementioned
acts or omissions constituted negligence, gross negligence and/or a violation of decedent,
Korryn Shadawn Gaines constitutional rights under the Maryland Constitution.

Plaintiff, Rhanda P. Gaines, Personal Representative of the Estate of Korryn Shadawn
Gaines demands judgment against Defendants, jointly and severally, in an amount that exceeds
$75,000pursuantto Md Rule 2-305 in the form of compensatory and punitive damages (punitive
damages are only claimed Of?cer Ruby and only in his individual capacity), plus interest
and costs.

WHEREFORE, it is respectfully requested that judgment be entered in favor of the
Plaintiff, Rhanda P. Gaines, Personal Representative of the Estate of Korryn Shadawn
Gaines, deceased, against the Defendants, in an amount that exceeds $75,000 pursuant to
Maryland Rule 2-305(b) in order to fully and fairly compensate the estate for all losses

9

compensable under the terms of the Survival Statute.

COUNT Maryland Constitution
(Against All Defendants)

63. The Plaintiffs repeats and realleges Paragraphs 1 62 of this Complaint with full force
and effect as if pleaded here in full.

64. The acts of the Defendant police of?cers unlawfully searching Korryn Gaines? apartment
by illegally entering without a search warrant or reasonable belief that Korryn Gaines or
Kareem Courtney were inside; suppressing her freedom of Speech; and then seizing her by
killing her; and the conduct of Defendant Baltimore County in failing to properly train and
supervise the Defendant police of?cers as to the constitutional duties owed to Gaines,
violated Articles 10, 24 and 26 of the Maryland Declaration of Rights which guaranteed
Gaines a right to be free from unreasonable searches and seizures, without due process of
law before being deprived of her life and liberty, and a right not to be subjected to death by
excessive force.

65. Baltimore County is liable on the basis of respondent superior for any violations of the
Maryland Constitution by the Defendant police of?cers that deprived Korryn Gaines of her
rights under Articles 10, 24 and 26 of the Maryland Declaration of rights. Baltimore
County is also liable for its own violations of the Maryland Constitution because it failed
to supervise the Defendant police of?cers, and it failed to train, monitor and supervise its
police force in their actions and use of lethal force, as well as duties owed to citizens for
the prevention of State constitutional violations.

66. The Defendant Baltimore County?s failure to provide proper training and supervision
demonstrated deliberate indifference to the safety of Gaines and other civilians with whom
its police of?cers come into contact with, speci?cally those persons suffering from mental
anxiety disorders. The County?s wrongful conduct in failing to properly train and supervise
its of?cers directly and proximately caused the death of Korryn Gaines and to the injuries
and damages suffered by her survivors.

67. Wherefore, Plaintiffs demand judgment against Defendants, jointly and severally, in an
amount that exceeds $75,000 pursuant to Maryland Rule 2-305(b) in compensatory and punitive
damages (punitive damages are only claimed against Of?cer Ruby and only in his
individual capacity), plus interest and costs.

RELIEF SOUGHT

68. Plaintiff re-pleads and re-alleges paragraphs 1 - 69 with the same force and effect as if
set forth separately and at length herein.

69. Plaintiff requests the following relief:

70. Compensatory and punitive1 damages in an amount that exceeds $75,000 pursuant to

 

1 Punitive damages are only being brought against Defendant Of?cer Ruby in his individual capacity and not against
Defendant Baltimore County Maryland.

10

Maryland Rule 

71. Pre and post-judgment interest.

72. The costs of litigation, including reasonable attorney?s fees, and expert witness fees, lost
wages and bene?ts the deceased would likely have earned if he had lived until
retirement, other contributions the deceased would likely have made to support, care,
and provide companionship and other services for his surviving family members.

73. Such other relief as may be just.

JURY DEMAND

76. Plaintiff demands a trial by jury.


. da Gor?c?lfin 

FICE OF

DAL GORDON, P.A.

20 South Charles Street, Suite 400

Baltimore, Maryland 21201

410.332.4121 0


Lead Counsel for Plainti?fs

 

    
     

A. Bell, Esq.

OFFICE OF JIMMY BELL, L.L.C.
. Box 2239

pper Marlboro, MD 20773

Tel: (301) 661-1165

Fax: (301) 560-5267

jimbellesq@aol.com

C0-C0unsel for Plaintiffs

11

 

 

 

Circuit Court for Baltimore County 
City or County

CIVIL - CASE INFORMATION REPORT

 

DIRECTIONS:

unless your case is exempted from the requirement by the Chief Judge of the Court oprpeaIs pursuant to Rule I 
A copy must be includedfor each defendant to be served.

Defendant: You must?ie an Information Report as required by Rule 
HIS INF ORMA TION REPORT CANNOT BE ACCEPTED AS AN ANSWER 0R RESPONSE.
FORM FILED BY: PLAINTIFF El DEFENDANT CASE NUMBER

CASE The Estate of Konyn Gaines et al. vs_ Baltimore County MD &Of?cer Ist Class Rub)
Plaintiff Defendant

JURY DEMAND: [Elves No Anticipated length oftrial: hours or 10 days
RELATED CASE Yes if yes, Case if known:

Special Requirements? Interpreter (Please attach Form 1)
Cl ADA accommodation (Please attach Form CC-DC-O49)

 

 

 

 

(Clerk to insert)

 

 

 

 

 

 

 

 

 

 

 

 

 

NATURE OF ACTION 
(CHECK ONE BOX)
TORTS LABOR A. roars 

DMotor Tort Workers' Comp. Actual Damages

Premises Liability Wrongful Discharge Under $7,500 Medical Bins

Assault Battery EEO $7,500 $50,000
DProduct Liability Other a? 550,000 - $100,000 Property Damages
DProfessional Malpractice CONTRACTS Over $100,000 
Wrongful Death Insurance wage LOSS

Business Commercial Judgment 

Libel Slander Other a 

False Arrest/Imprisonment REAL PROPERTY B. CONTRACTS C. NONMONETARY
El Nuisance DJudicial Sale

Toxic Torts Condemnation I: Under $10,000 Dneclaratory Judgment
DFraud DLandlord Tenant El $l0,000 - $20,000 Injunction
DMalicious Prosecution Other [3 Over $20,0000 Other

Lead Paint OTHER D. EQUITY

Asbestos DCivil Rights See Addendum
?3 Other Environmental

Survival Action DADA

Other
ALTERNATIVE DISPUTE RESOLUTION INFORMATION

Is this case appropriate for referral to an ADR process under Md. Rule 17-101? (Check all that a ly)
A. Mediation Yes No C. Settlement Conference No
B. Arbitration Yes No D. Neutral Evaluation Yes No

TRACK REQUEST

With the exception of Baltimore County and Baltimore City, please/ii! in the estimated LENGTH OF TRIAL.
HIS CASE WILL THEN BE RA CKED ACCORDINGLY.

1/2 day oftrial or less
1 day of trial time
2 days of trial time

 

3 days of trial time
More than 3 days oftrial time

 

 

 

 

 

   

I . I 
truss net tits-s. ante 'tr-atomtonnes" (eaten: "intensities

.. 

      

 

iitnt.tnar in t-tLOKL?EEItt-s?xti?i t.

   

  

For alljurisdt'ctions, if Business and Teclmoiogy track designation under Md. Rule 16?205 is requested, attach a duplicate
copy of complaint and check one OfIIte tracks below.

El

Expedited Standard
Trial within 7 months Trial within 18 months
ofFiling of Filing

EMERGENCY RELIEF REQUESTED

 

 

Signature Date

 

 
   
  

    

              

  
 

 
 

  
  

  ?gr: 
0R PURPOSES 0F POSSIBLE SPECIAL ASSIGNMENT T0 ANASTAR RESOURCE JUDGE under Md. Rule 16-202.

Please check the applicable box below andartoclt a duplicate copy ofyonr complaint.

Expedited - Trial within 7 months of Filing [3 Standard - Trial within 18 months ofFiling

 

IF YOU ARE FILING YOUR COMPLAINTIN BALTIMORE CITY, BA

LTIMORE COUNTY, 01? PRINCE GEORGES
COUNTY PLEASE FILL OUT THEAPPROPRIA TE BOX BELOW.

 

 

CIRCUIT COURT FOR BALTIMORE CITY (CHECK ONLY ONE)

 

Expedited Trial 60 to 120 days from notice. Non-jury matters.

Standard-Short Trial 210 days.

Standard Trial 360 days.

Lead Paint Fill in: Birth Date ofyoungest plaintil?im.
Asbestos Events and deadlines set by individual judge.

Protracted Cases Complex cases designated by the Administrative Judge.

 

CIRCUIT COURT FOR BALTIMORE COUNTY

 

.Expedited Attachment Before Judgment, Declaratory Judgment (Simple), Administrative Appeals, District
(Trial Date-90 days) Court Appeals and Jury Trial Prayers, Guardianship, injunction, Mandamus.

Standard Condemnation, Confessed Judgments (Vacated), Contract, Employment Related Cases, Fraud and
(Trial Date-240 days) Misrepresentation, International Tort, Motor 

ort, Other Personal Injury, Workers' Compensation
Cases.

[3 Extended Standard Asbestos, Professional Mal

practice, Serious Motor Text or Personal Injury Cases
(Trial Date-345 days)

(medical expenses and wage loss of $100,000, expert and out-of-state witnesses (parties), and trial
of?ve or more days), State Insolvency.

Complex Class Actions, Designated 'I?o

I xic Tort, Major Construction Contracts, Major Product Liabilities,
(Trial Date?450 days) Other Complex Cases.

 

 

CC-DCM-OOZ (Rev. 03/2016) Page 2 of 3

 

 

CIRCUIT COURT FOR PRINCE COUNTY

 

Liability is conceded.

Liability is seriously in dispute.

To assist the Court in determining the appropriate Trac
an admission and may not be used for any purpose other than Track Assignment.

Liability is not conceded, but is not seriously in dispute.

for this case, check one of the boxes below. This information is i



 

CIRCUIT COURT FOR PRINCE COUNTY ONLY

 

Section 1). Equity Cases Addendum

 

Accounting

Adverse Possession

Appointment ofa Trustee

 

Assumption of Jurisdiction

Authorized Sale

Breach ofCovcnant

 

Constructive Trust

Declaratory Judgment (Equity)

Declaratory Relief (Equity)

 

Detinue

Disciplinary Action

Ejectment

 

Equitable Relief

Establishment of Trust

Foreclosure Land Installment

 

Foreclosure Lien

Foreclosure Right of Redemption

[3 Foreclosure Statement Condo

 

Foreclosure of Deed Trust

Foreclosure Mortgage

Forfeiture of Prop. 1 Personal Item

 

Foreclosure of Currency or Vehicle

Fraudulent Conveyance

Injunctive Relief (Equity)

 

Mandamus (Equity)

Mechanic?s Lien

Notice of Lis Pendens

 

Part Sale in Lieu ofPart

Quiet Title

Receiverships

 

Removal of'l?rustce

Set Aside Dead

[3 Speci?c Performance

 

Speci?c Transaction

 

 

Structured Settlement

 

Trust

 

 

 

CC-DCM-DOZ (Rev. 03/2016)

Page 3 of3