. Case Document2 Filed 12/22/16 Page 1 of 20 PageID 126 Filing ii 48129551 E?Filed 10/2gg016 03:15:31 PM A IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT, IN AND OR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION NORWILLO, as surviving spouse and as Personal Representative of the Estate of FRANCIS NORWILLO, and MICHAEL DOUGHERTY, Plaintiff's, Case No.: 1.. v. Division: PURPLE SHOVEL, LLC, TACTICAL, LLC, RESOURCES, LLC, REGULUS GLOBAL LLC, and REGULUS GLOBAL ma, Defendants.. I COMPLAILJT Plaintiffs, ZIECHA NORWILLO, individually and as the Personal Representative: of the Estate of FRANCIS NORWILLO, deceased, and MICHAEL DOUGHERTY, sue Defendants PURPLE SHOVEL, TACTICAL, RESOURCES, REGULUS GLOBAL LLC, and REGULUS GLOBAL INC., and state; PARTIES AND VENUE I. This is an action for damages in excaas of Fi?aen Thousand Dollars exclusive afinterast, costs and attorneys? few. . 2. At all material times, Plaintiff ZIECHA NORWILLO (?Mm Norwillo?) was married to Francis Norwilla and they resided together in Fairviaw, Texas. 3. Pursuant to Florida?s Wrong?tl Death Act, Mr. Narwillo?s survivors and the bene?ciaries of the recovery in this action, in addition to his estate, is his spouse Mrs. Norwiilo. .- ,Case Document 2 Filed 12/22/16 Page 2 of 20 PageID 127 A 4. At all material times, Plaintiff MICHAEL DOUGHERTY (?Mn Dougherty") was a resident of Fort Walton, Okaloosa County, Florida. 5. At all material times, PURPLE SHOVEL, LLC (?Purple Shovel?) is a Florida for Pro?t Limited Liability Company, with its principal place of business at 4100 W. Kennedy Blvd, Suite 213 and doing business in the state of Florida for which it received revenue, and has a registered agent for service of process in Florida, to Wit: The Law Of?ce of Leighton J. Hyde, P.A., 4100 W. Kennedy #213, Tampa, Florida 33609. 6. Defendant, TACTICAL, LLC Tactical?) is a Florida for Pro?t Limited Liability Company with its principal place of business at 1715 North Westshore Blvd, Suite 320, Tampa, FL 33607 and doing business in the state of Florida for which it received revenue, and has a registered agent for service of process in Florida, to wit: Stephen Rumbley, 1715 North Westshore Blvd, Suite 320, Tampa, FL 33607. 7. Defendant, RESOURCES, LLC Resources") is a Florida for Pro?t Limited Liability Company with its principal place of business at HIS-North Westshore Blvd, Suite 320, Tampa, FL 33607 and doing business in the state of Florida for which it received revenue, and has a registered agent for service of process in Florida, to wit: Randall Bahlow at 1715 North Westshore Blvd, Suite 320, Tampa, FL 33607. 8. Defendant, REGULUS GLOBAL LLC (?Regulus Global is a Virginia for pro?t Limited Liability Corporation that is headquartered at 1528 Taylor Farm Rd., Suite 105, Virginia Beach, VA 23453 and doing business in the state ot' Florida for which it received revenue. Regulus Global LLC may be served through its registered agent, John M. Paris, Jr. at 22 Central Park Ave, Suite 1700, Virginia Beach, VA 23462. . Case Document 2 Filed 12/22/16 Page 3 of 20 PagelD 128 1?5 . - 9. Defendant, REGULUS GLOBAL INC., (?Regulus Global 1110.?) is a Virginia for pro?t corporation that is headquartered at 1528 Taylor Faun Rd, Suite 105, Virginia Beach, VA 23453 and doing business in the state of Florida for which it received revenue. Regulus Global Inc. may be served through its registered agent, William M. Somerindyke, Jr. at 1528 Taylor Farm Rd, Suite 105, Virginia Beach, VA 23453. 10. One or more of the Defendants are residents of or maintain of?ces and conduct business in Hillsborough County, Florida. 11. Venue is proper in this County because at least one Defendant resides in this County. See FLA. STAT. 47.021; see also id. at 47.051. 12. This Court has personal jurisdiction over Defendants because at least one Defendant resides in this County, and upon information and belief a substantial portion of the acts or omissions that form the basis of this suit took place in this County. See FLA. STAT. 48.193; see also id. at ?47.051. GENERAL ALLEGATIONS 13. On June 6, 2015, Mr. Norwillo was handling a rocket-propelled grenade at a weapons range in Bulgaria located near the village of Anevo when the grenade suddenly exploded without warning. 14. When the grenade exploded, Mr. Daugherty was standing next to Mr. Norwillo, using his phone to video record Mr. Norwillo. 15. Mr. Norwillo was killed by the explosion. 16. Mr. Daugherty was severely injured by the explosion. l7. Defendants procured the rocket-propelled grenade that caused the explosion, among other weapons, for Mr. Norwillo and Mr. Dougherty to inspect. . Case Document 2 Filed 12/22/16 Page 4 of 20 PagelD 129 A - A 18. Defendants knew the grenade that exploded was manufactured along with several others over 30 years before in 1984 by a Bulgarian company rendering its shelf life expired from degraded and now defective components. 19. Defendants knew that the U.S. Government had rejected the use of these same grenades because the grenades were defective, unstable and dangerous. 20. Despite knowing the defective, unstable dangerous nature of the more than 30- year?old Bulgariammanufaotured grenades, Defendants knowingly and willfully procured the grenades and knowingly and willfully placed Mr. Norwille and Mr. Daugherty in grave danger. 21. After the incident, Defendants intentionally and knowingly misrepresented, hid, or tried to cover up the facts surrounding Mr. Norwillo?s death from his surviving spouse, Mrs. Norwillo. 22. All conditions precedent to the maintenance of this action have occurred, been waived, or have otherwise been ful?lled. causes or ACTION min; Wrongful Death of Francis Norwillo Against Purple Shovel, LLC 23. Plaintiff, Ziecha Norwillo, as personal representative of the Estate of Francis Norwillo, incorporates paragraphs 1-22 as if fully set forth herein. 24. On the date of the explosion, and in the weeks and months leading up to the explosion, Purple Shovel owed Mr. Norwillo a non~delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 25. Purple Shovel was negligent and branched this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Norwillo to inspect. ,Case Document 2 Filed 12/22/16 Page 5 of 20 PageID 130 . A 26. As a direct and proximate result of the Purple Shovel?s negligent acts or omissions, Francis Norwillo was killed. 27. Further, Purple Shovel?s acts or emissions were grossly negligent because Purple Shovel knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the consequences by procuring the defective and dangerous Bulgarian grenades for Norwillc and Daugherty to inspect. 28. As a direct and proximate result of Purple Shovel?s negligence, the Estate of Francis Norwillo incurred damages, including, but not limited to, ?meral expenses and loss of net accumulations due to his death. 29. As a direct and proximate result of Purple Shovel?s negligence, Mrs. Norwillc, as the surviving Spense, suffered damages including, but not limited to, lost support and services, loss of companionship and protection, and mental pain and su?ering as a result of Mr. Norwillo?s death. WHEREFORE, Mrs. Norwillo, as personal representative of Mr. Nerwillo?s Estate, demands judgment against Purple Shovel for damages, plus appropriate interest, costs, and such other relief as this Court deems just and preper. Count II Erengful Degth of Francis Norwillo Against Tactical, LLC 30. Plaintiff, Ziecha Norwillo, as personal representative of the Estate of Francis Norwillc, incorporates paragraphs l~22 as if ?Jlly set forth herein. 31. On the date of the explosion, and in the weeks and months leading up to the explosion, Tactical owed Mr. Norwillo a non-delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 5 ,Case Document 2 Filed 12/22/16 Page 6 of 20 PagelD 131 - 32. Tactical was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Norwillo to inspect. 33. As a direct and proximate result of the Tactical?s negligent acts or omissions, Francis Norwillo was killed. 34. Further, Tactical?s acts or emissions were grossly negligent because Tactical knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the consequences by procuring the defective and dangerous Bulgarian grenades for Norwillo and Dougherty to inspect. 35. As a direct and proximate result of Tactical?s negligence, the Estate of Francis Norwillo incurred damages, including, but not limited to, funeral expenses and loss of net accumulations due to his death. 36. As a direct and proximate result of Tactical?s negligence, Mrs. Norwillo, as the surviving spouse, suffered damages including, but not limited to, lost support and services, loss of companionship and protection, and mental pain and suffering as a resalt of Mr. Norwillo?s death. WHEREFORE, Mrs. Norwillo, as personal representative of Mr. Norwillo?s Estate, demands judgment against Tactical for damages, plus appropriate interest, costs, and such other relief as this Court deems just and preper. Count 111 Wrongful Death of Francis Norwillo Against Resources, LLC 37. Plaintiff, Ziecha Norwillo, as personal representative of the Estate of Francis Norwillo, incorporates paragraphs l-22 as if ?illy set forth herein. 6 Case Document 2 Filed 12/22/16 Page 7 of 20 PageID 132 - A 38. On the date of the explosion, and in the weeks and months leading up to the explosion, Resources owed Mr. Norwillo a non-delegable duty to exercise reasonable care in the procurement andhandling of the Bulgarian grenades. 39. Resources was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Norwillo to inspect. 40. As a direct and proximate result of the Resources? negligent acts er omissions, Francis Norwillo was killed. 41. Further, Resources? acts or emissions were grossly negligent because Resources knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the consequences by procuring the defective and dangerous Bulgarian grenades for Norwillo and Dougherty to inspect. 42. As a direct and proximate result of Resources? negligence, the Estate of Francis Norwillo incurred damages, including, but not limited to, funeral expenses and loss of net accumulations due to his death. 43. As a direct and proximate result of Resources? negligence, Mrs. Norwillo, as the surviving spouse, suffered damages including, but not limited to, lost support and services, loss of companionship and protection, and mental pain and suffering as a result of Mr. Norwillo?s death. WHEREFORE, Mrs. Norwillo, as personal representative of Mr. Norwillo?s Estate, demands judgment against Resources for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. ?Case Document 2 Filed 12/22/16 Page 8 of 20 PageID 133 A . - Count IV Wrongful Death of Francis orwillo Against Regulus Global LLC 44. Plaintiff, Ziecha Norwillo, as personal representative of the Estate of Francis Norwillo, incorporates paragraphs 1-22 as if fully set forth herein. 45. On the date of the explosion, and in the weeks and months leading up to the explosion, Regulus Global LLC owed Mr. Norwillo a non-delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 46. Regulus Global LLC was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Norwillo to inspect. 47. As a direct and proximate result of the Regulus Global negligent acts or omissions, Francis Norwillo was killed. 48. Further, Regulus Global acts or omissions were grossly negligent because Regulus Global LLC knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the consequences by procuring the defective and dangeroas Bulgarian grenades for Norwillo and Daugherty to inspect. 49. As a direct and proximate result of Regulus Global negligence, the Estate of Francis Norwillo incurred damages, including, but not limited to, funeral expenses and loss of net accumulations due to his death. 50. As a direct and proximate result of Regulus Global negligence, Mrs. Norwillo, as the surviving Spouse, suffered damages including, but not limited to, lost support and services, loss of companionship and protection, and mental pain and suffering as a result of Mr. Norwillo?s death. Case Document 2 Filed 12/22/16 Page 9 of 20 PagelD 134 WHEREFORE, Mrs. Norwillo, as personal representative of Mr. Norwillo?s Estate, demands judgment against Regulus Global LLC for damages, plus appropriate interest, costs, and such other relief as this Court deems just and prcper. Death of Francis Norwillo Against Regulus Global Inc. 51. Plaintiff, Ziecha Norwillo, as personal representative of the Estate of Francis Norwillo, incorporates paragraphs 1-22 as if fully set forth herein. 52. On the date of the explosion, and in the weeks and months leading up to the explosion, Regulus Global Inc. owed Mr. Norwillo a non~delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 53. Regulus Global Inc. was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Norwillo to inspect. 54. As a direct and proximate result of the Regulus Global Inc?s negligent acts or omissions, Francis Norwillo was killed. 55. Further, Regulus Global Inc.?s acts or emissions were grossly negligent because Regulus Global Inc?s knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the consequences by procuring the defective and dangerous Bulgarian grenades for Norwillo and Daugherty to inspect. 56'. As a direct and proximate result of Regulus Global Inc?s negligence, the Estate of Francis Norwillo incurred damages, including, but not limited to, funeral expenses and loss of net accumulations due to his death. 'Case Document 2 Filed 12/22/16 Page 10 of 20 PageID 135 57. As a direct and proximate result of Regulus Global Inc.?s negligence, Mrs. Norwillo, as the surviving spouse, suffered damages including, but not limited to, lost support and services, loss of companionship and protection, and mental pain and suffering as a result of Mr. Norwillo?s death. WHEREFORE, Mrs. Norwillo, as personal representative of Mr. Norwillo?s Estate, demands judgment against Regulus Global Inc. for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Count VI Ziecha Norwillo?s Claims for Intentional ln?ietion of Emotional Distress Against Purple Shovel, LL52 58. Plaintiff, Zieeha Norwillo, incorporates paragraphs l~29 as if ?tlly set forth herein. 59. After Mr. Norwillo was killed, Purple Shovel misrepresented, hid, and covered up the facts surrounding his death ?om his surviving spouse, Ziecha Norwillo. 60. Purple Shovel continues to intentionally and recklessly misrepresent, hide, and cover up the facts surrounding Mr. Norwillo?s death. Purple Shovel knew that misrepresenting and covering up the facts surrounding Mr. Norwillo?s death has caused, and continues to cause, Ziecha Norwillo severe emotional distress. 62. Purple Shovel?s conduct is outrageous and goes beyond all bounds of decency. 63. As a direct and proximate result of Purple Shovel?s conduct, Ziecha Norwillo has suffered severe emotional distress. 10 Case Document 2 Filed 12/22/16 Page 11 of 20 PageID 136 . WHEREFORE, Mrs. Norwillo, individually, demands judgment against Purple Shovel for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Ziecha Norwiilo?s Claims for Intentional lnfliction of Emotional Distress Against Tactical, LLC 64. Plaintiff, Ziecha Norwillo, incorporates paragraphs 1-29 as if fully set forth herein. 65. After Mr. Norwillo was killed, Skybiidge Tactical misrepresented, hid, and covered up the facts surrounding his death from his surviving spouse, Ziecha Norwillo. 66. Tactical continues to intentionally and recklessly misrepresent, hide, and cover up the facts surrounding Mr. Norwillo?s death. 67. Tactical knew that misrepresenting and covering up the facts surrounding Mr. Norwillo?s death has caused, and continues to cause, Ziecha Norwillo severe emotional distress. 68. Tactical?s conduct is outrageous and goes beyond all bounds of decency. 69. As a direct and proximate result of Tactical?s conduct, Ziecha Norwillo has suffered severe emotional distress. WHEREFORE, Mrs. Norwillo, individually, demands judgment against Tactical for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. 11 .Case Document 2 Filed 12/22/16 Page 12 of 20 PageID 137 . A Ziecha Norwillo?s Claims for Intentional In?lction of Emotional Distress Against Resources, LLC 70. Plaintiff, Ziecha Norwillo, incorporates paragraphs 1-29 as if fully set forth herein. 71. After Mr. Norwillo was Itilled, Resources misrepresented, hid, and covered up the facts surrounding his death from his surviving Spouse, Ziecha Norwillo. 72. Resources continues to intentionally and recklessly misrepresent, hide, and cover up the facts surrounding Mr. Norwillo?s death. 73. Resources knew that misrepresenting and covering up the facts surrounding Mr. Norwillc?s death has caused, and continues to cause, Ziecha Norwillo severe emotional distress. 74. Resources? conduct is outrageous and goes beyond all bounds of decency. 75. As a direct and proximate result of Resonrces? conduct, Ziecha Norwillo has suffered severe emotional distress. WHEREFORE, Mrs. Norwillo, individually, demands judgment against Resources for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Count IX Ziecha Norwillo?s Claims for Intentional Infliction of Emotional Distress Against Regulus Global LLC 76. Plaintiff, Ziecha Norwillo, incorporates paragraphs 1?29 as if fully set forth herein. 12 Case Document 2 Filed 12/22/16 Page 13 of 20 PageID 138 f?x A 77. After Mr. Norwillo was killed, Regulus Global LLC misrepresented, hid, and covered up the facts surrounding his death from his surviving spouse, Ziecha Norwillo. 78. Regulus Global LLC continues to intentionally and recklessly misrepresent, hide, and cover up the facts surrounding Mr. Norwillo?s death. 79. Regulus Global LLC knew that misrepresenting and covering up the facts surrounding Mr. Norwillo?s death has caused, and continues to cause, Ziecha Norwillo severe emotional distress. 80. Regulus Global conduct is outrageous and goes beyond all bounds of decency. 81. As a direct and proximate result of Regulus Global LLC's conduct, Ziecha Norwillo has suifered severe emotional distress. WHEREFORE, Mrs. Norwillo, individually, demands judgment against Regulus Global LLC for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Ziecha Norwillo?s Claims for Intentional In?iction of Emotional Distress Against Regulus Global Inc. 82. Plaintiff, Ziecha Norwillo, incorporates paragraphs 1?29 as if ?illy set forth herein. 83. After Mr. Norwillo was killed, Regulus Global Inc. misrepresented, hid, and covered up the facts surrounding his death from his surviving spouse, Ziecha Norwillo. 84. Regulus Global Inc. continues to intentionally and recklessly misrepresent, hide, and cover up the facts surrounding Mr. Norwillo?s death. 13 _Case Document 2 Filed 12/22/16 Page 14 of 20 PageID 139 A 85. Regulus Global Inc. knew that misrepresenting and covering up the facts surrounding Mr. Norwillo?s death has caused, and continues to cause, Ziecha Norwillo severe emotional distress. 86. Regulus Global Inc. ?5 conduct is outrageous and goes beyond all bounds of decency. 87. As a direct and proximate result of Regulus Global Ino.?s conduct, Zieeha Norwillo has su??ered severe emotional distress. WHEREFORE, Mrs. Norwillo, individually, demands judgment against Regulus Global Inc. for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Count XI Michael Dougherty?s Claims for egligenee Gross Negligence . Against Purple Shovel. LLC . 88. Plaintiff, Michael Dougherty, incorporates paragraphs 1?22 as if fully set forth herein. 39. On the date of the explosion, and in the weeks and months leading up to the explosion, Purple Shovel owed Mr. Dougherty a non-delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 90. Purple Shovel was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Daugherty to inspect. 91. Further, Purple Shovel?s acts or omissions were grossly negligent because Purple Shovel knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the consequences by 14 {Case Document 2 Filed 12/22/16 Page 15 of 20 PagelD 140 A A procuring the defective and dangerous Bulgarian grenades for Norwillo and Daugherty to inspect. 92. As a direct and proximate result of the Purple Shovel?s negligent acts or omissions, Mr. Dougherty suffered severe and permanent injuries, resulting in pain and suffering, disability, dis?gurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, and loss of ability to earn money. The losses are permanent and continuing. WHEREFORE Mr. Daugherty demands judgment against Purple Shovel for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Count XII Michael Dougherty?s Claims for Negligence 3; Gross Negligence Against Tactical, LLC 93. Plaintiff, Michael Dougherty, incorporates paragraphs 1'22 as if ?illy set forth herein. 94. On the date of the explosion, and in the weeks and months leading up to the explosion, Tactical owed Mr. Dougherty a non-delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 95. Tactical was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Dougherty to inspect. 96. Further, Tactical?s acts or emissions were grossly negligent because Tactical knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the 15 ,Case Document 2 Filed 12/22/16 Page 16 of 20 PageID 141 PK A consequences by procuring the defective and dangerous Bulgarian grenades for Norwillo and Dougherty to inspect. 97. As a direct and proximate result of the Tactical?s negligent acts or omissions, Mr. Daugherty suffered severe and permanent injuries, resulting in pain and suffering, disability, dis?gurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, and loss of ability to earn money. The losses are permanent and continuing. WHEREFORE Mr. Dougherty demands judgment against Tactical for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. QM Michael Dougherty?s Claims for Negligence 8: Gross Negligence Against Resources, LLC 98. Plaintiff, Michael Dougherty, incorporates paragraphs 1~22 as if fully set forth herein. 99. On the date of the explosion, and in the weeks and months leading up to the explosion, Resources owed Mr. Dougherty a non~delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 100. Resources was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Daugherty to inspect. 101. Further, Resources" acts or omissions were grossly negligent because Resources knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the 16 . Case Document 2 Filed 12/22/16 Page 17 of 20 PageID 142 consequences by procuring the defective and dangerous Bulgarian grenades for Norwillo and Daugherty to inspect. 102. As a direct and proximate result of the Resources' negligent acts or omissions, Mr. Dougherty suffered severe and permanent injuries, resulting in pain and suffering, disability, dis?gurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, and loss of ability to earn money. The losses are permanent and continuing. WHEREFORE Mr. Daugherty demands judgment against Resources for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Count XIV Michael Dougherty?s Claims for Negligence Gross Negligence Against Regulus Global LLC 103. Plaintiff, Michael Daugherty, incorporates paragraphs 1-22 as if ?illy set forth herein. 104. On the date of the explosion, and in the weeks and months leading up to the explosion, Regulus Global LLC owed Mr. Daugherty a non?delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 105. Regulus Global LLC was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Daugherty to inspect. 106. Further, Regulus Global acts or emissions were grossly negligent because Regulus Global LLC knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the 17 .Case Document 2 Filed 12/22/16 Page 18 of 20 PagelD 143 consequences by procuring the defective and dangerous Bulgarian grenades for Norwillo and Dougherty to inspect. 107. As a direct and proximate result of the Regulus Global negligent acts or omissions, Mr. Dougherty suffered severe and pennanent injuries, resulting in pain and suffering, disability, dis?gurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, and loss of ability to earn money. The losses are permanent and continuing. WHEREFORE Mr. Dougherty demands judgment against Regulus Global LLC for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. Count Michael Dougherty?s Claims for Negligence Gross Negligence Against Regulus Global In c. 108. Plaintiff, Michael Dougherty, incorporates paragraphs 1-22 as if fully set forth herein. 109. On the date of the explosion, and in the weeks and months leading up to the explosion, Regulus Global Inc. owed Mr. Daugherty a non-delegable duty to exercise reasonable care in the procurement and handling of the Bulgarian grenades. 110. Regulus Global Inc. was negligent and breached this duty by procuring the defective and inherently dangerous Bulgarian grenades for Mr. Dougherty to inspect. 111. Further, Regulus Global Inc. ?5 acts or emissions were grossly negligent because Regulus Global Inc. knew that the Bulgarian grenades presented clear and present danger that amounted to a more than normal or usual peril, but still consciously disregarded the 18 _Case Document 2 Filed 12/22/16 Page 19 of 20 PageID 144 consequences by procuring the defective and dangerous Bulgarian grenades for Norwillo and Daugherty to inspect. 112. As a direct and proximate result of the Regulus Global Inn?s negligent acts or omissions, Mr. Daugherty suffered severe and permanent injuries, resulting in pain and suffering, disability, dis?gurement, mental anguish, loss of capacity for the enjoyment of life, expense of medical care and treatment, loss of earnings, endless of ability to earn money. The losses are permanent and continuing. WHEREFORE Mr. Daugherty demands judgment against Regulus Global Inc. for damages, plus appropriate interest, costs, and such other relief as this Court deems just and proper. JURY TRIAL DEMAND Plaintiffs hereby demand a trial by jury on all issues triable as a matter of right. Respectfully submitted, C. STEVE ER ESQ. Florida Bar 207594 DAVID D. DICKEY, ESQ. Florida Bar 949019 THE YERRID LAW FIRM 101 East Kennedy Blvd, Suite 3900 Tampa, FL 33602 Telephone: (813) 222-8222 Facsimile: (813) 222-3224 Service: MW ?and~ Kurt B. Arnold Pro-Hue Vice anticipated Texas Bar No.: 24036150 kamold?r?amolt1itkin.eom 19 Case Document 2 Filed 12/22/16 Page 20 of 20 PageID 145 A Caj. D. Boatright Pro-?Haw Vice anticipated Texas Bar No.: 24036237 ARNOLD ITKIN LLP 6009 Memorial Drive Houston, Texas 77007 Telephone: 713.222.3800 Facsimile: 713.222.3350 A PLA INTIFFS 20