STATE OF INDIANA IN THE HAMILTON SUPERIOR COURT SS: COUNTY OF HAMILTON CAUSE NO.: 29D03 DESTINY CHANDA MARIE HOFFMAN, by next friend, JENNIFER HOFFMAN, and JENNIFER HOFFMAN, Plaintiffs, v.3 WESTFIELD WASHINGTON SCHOOL CORPORATION, Defendants. Summons To Interested Parties: Westfield Washington School Corporation 1143 181st Street Westfield, IN 46074 You are hereby notified that you have been sued by the person named as Petitioner and in the Court indicated above. The nature of the suit against you is stated in the Complaint which is attached to this Summons. It also states the relief sought or the demand made against you by the Plaintiffs. An answer or other responsive pleading is required, by your or your attorney, within twenty (20) days, commencing the day after you receive this summons, or judgment will be entered against you for what the Plaintiff has demanded. Dated: Clerk, HAMILTON SUPERIOR COURT Timothy R. Stoesz 13782?49 STOESZ STOESZ 211 E. Main St. P.O. Box 365 Westfield, IN 46074 (317) 867?1524 The following manner of service of Summons is hereby designated: Service on Individual at abOVe address: Personal Service by Attorney/Petitioner Registered or Certified Mail Service on Agent?Sheriff STATE OF INDIANA IN THE HAMILTON SUPERIOR COURT SS: COUNTY OF HAMILTON CAUSE NO.: 29D03 DESTINY CHANDA MARIE HOFFMAN, by next friend, JENNIFER HOFFMAN, and JENNIFER HOFFMAN, Plaintiffs, WESTFIELD WASHINGTON SCHOOL CORPORATION. v, Defendants. COMPLAINT FOR DAMAGES COMES NOW, Plaintiffs, Destiny Chanda Marie Hoffman, by next friend, Jennifer Hoffman, Jennifer Hoffman, individually, by counsel, Tim Stoesz, and for their Complaint for Damages would state as follows: 1. Plaintiff, Destiny Chanda Marie Hoffman, hereinafter ?Destiny?, was a student at Westfield Washington High School, a school operated by Defendant, Westfield Washington School Corporation, hereinafter 2. On April 23, 2014, Plaintiff Destiny was a student participant in a musical presented by and at Westfield Washington High School. 3. During a performance of the musical at Westfield High School, the stage on which Destiny was performing collapsed, causing her injuries for which she suffered damages. 4. After an investigation by law enforcement, it was determined that the stage had been improperly constructed by an employee of Defendant, WWSC, during and while acting as an employee of WWSC and within the scope of his duties as an employee of WWSC. 5. Defendant WWSC failed to properly supervise its employeets) who constructed the stage and failure to properly supervise was a proximate cause of the injuries suffered by Plaintiff, Destiny Chanda Marie Hoffman. 6. Plaintiffs seek damages against the Defendant, for the injuries suffered to Destiny as a result of negligent behavior and failure to provide a safe environment for the students of WWSC. 7. Destiny?s mother, Jennifer Hoffman, seeks damages for the loss of consortium, loss of income, and mental aguish as a result of the injuries incurred by Destiny which were the result of the negligent behavior of WWSC. Respectfully submitted, --. "x Timothy STOESZ STOESZ 211 East Main St. P.O. Box 365 Westfield, IN 46074 317-867-1524 tim@stoeszlaw.com STATE OF INDIANA IN THE HAMILTON SUPERIOR COURT SS: COUNTY OF HAMILTON CAUSE NO.: DESTINY CHANDA MARIE HOFFMAN, by next friend, JENNIFER HOFFMAN, and JENNIFER HOFFMAN, Plaintiffs, V. WESTFIELD WASHINGTON SCHOOL CORPORATION, Defendants. Agpearance l. Petitioning Party: Destiny Chanda Marie Hoffman Jennifer Hoffman 2. 3. Attorney Information: Tim Stoesz Attorney No.: 13782?49 211 E. Main St., P.O. Box 365, Westfield, Indiana 46074 (317) 867?1524 Fax: (317) 867-4007 tim@stoeszlaw.com 4. Case type requested is CT 5. Will accept fax service 6. There are no related cases. mw?crrv x/Zzoxl. Timothy R. sto??glz/ STATE OF INDIANA IN THE HAMILTON SUPERIOR COURT 1 3 SS: COUNTY OF HAMILTON CAUSE NO.: DESTINY CHANDA MARIE HOFFMAN, by next friend, JENNIFER HOFFMAN. and JENNIFER HOFFMAN, Plaintiffs, WESTFIELD WASHINGTON SCHOOL CORPORATION. v, Defendants. REQUEST FOR JURY TRIAL COMES NOW, Plaintiffs, Desinty Chanda Marie Hoffman and Jennifer Hoffman, by counsel, Tim Stoesz, and for their Praecipe For Trial would state as follows: 1. The Plaintiff filed a Complaint for Damages on October 6, 2016. 2. Plaintiffs seek a trial by jury. 3. Parties estimate this matter will take approximately 2 days of the Court's time. .e Tim StoesZ? Plaintiff's Aftorney ID 13782-49